--- title: "Thrivent White Rose Fund XVI Fund of Funds Reports $2.0 Billion Sold; the Adviser's Earlier ADV Shows Entirely Affiliated Ownership" url: https://altstreet.investments/news/thrivent-white-rose-fund-xvi-first-sale-2-billion-form-d-amendment-2026-10-13 kind: news-article updated: 2026-10-16 description: "Thrivent White Rose Fund XVI Fund of Funds' October 13, 2026 Form D/A reports $2.0 billion sold to 17 investors; the adviser's Form ADV reports the fund as entirely owned by the adviser and its related persons." publisher: AltStreet (https://altstreet.investments) license: Public factual pages may be read, quoted and cited with attribution and a link. Bulk redistribution is not permitted. --- # Thrivent White Rose Fund XVI Fund of Funds Reports $2.0 Billion Sold; the Adviser's Earlier ADV Shows Entirely Affiliated Ownership The fund's annual Form D amendment reports $2,001,500,000 sold to 17 investors since a first sale on October 31, 2025, with no sales commissions and $0 in the minimum-investment field. The adviser's most recent Form ADV reports the fund as 100% beneficially owned by the adviser and its related persons. By Michael E., Head of Research, AltStreet Research (https://altstreet.investments/authors/michael-e). Published October 16, 2026. Entity: Thrivent White Rose Fund XVI Fund of Funds, L.P. (CIK 2089007, https://altstreet.investments/edgar/2089007). Thrivent White Rose Fund XVI Fund of Funds, L.P. reported $2,001,500,000 sold to 17 investors in a Form D amendment filed with the Securities and Exchange Commission on October 13, 2026 (accession 0000905148-26-004446). The fund's original notice, filed October 10, 2025, reported that no sale had yet occurred; the amendment gives the first sale date as October 31, 2025, three weeks later. The adviser's most recent Form ADV, filed earlier in the year, reports the fund as 100% beneficially owned by the adviser and its related persons. It is the largest of four Thrivent White Rose funds that filed annual amendments the same day. With Thrivent White Rose Real Estate Fund VI ($1,250,931,250 from seven investors), Endurance Fund IV ($901,082,500 from 16) and Fund XVI Equity Direct ($781,387,500 from 19), the four notices report $4,934,901,250 across 59 investor positions. The notices do not say whether an investor, or a Thrivent vehicle, appears in more than one of them, so the four totals are not shown to be distinct capital. ## What the filings show The amendment is the annual update a continuing Regulation D offering files, and it reports the cumulative amount sold since the first sale rather than a single transaction; Form D's amount-sold figure includes amounts investors are obligated to pay under capital commitments as well as amounts paid. The total offering amount is listed as indefinite. The fund relies on Rule 506(b) and on the Section 3(c)(1) and 3(c)(7) exclusions of the Investment Company Act, reports no non-accredited investors, no sales commissions and no finders' fees, reports $0 in the form's minimum-investment field, and expects the offering to last more than a year. The sales-compensation item lists no recipients, so the notice carries no states of solicitation. The fund is a Delaware limited partnership organized in 2025 with its office at 901 Marquette Avenue in Minneapolis, classified as a pooled investment fund of the private equity type. Two related persons are listed: Thrivent White Rose GP XVI Fund of Funds, LLC, the general partner, and Thrivent Investment Capital Advisors, LLC, described as managing member of the general partner and investment manager of the fund. Both filings are signed by Jerome H. Borden, chief compliance officer of Thrivent Investment Capital Advisors. SEC adviser records list that firm under the business name Thrivent Private Investments (CRD 338378). The adviser's Form ADV annual updating amendment, filed March 30, 2026, describes the fund in Schedule D as a master fund with one feeder, Thrivent White Rose Feeder XVI Fund of Funds LLC, relying on both 3(c)(1) and 3(c)(7), with a gross asset value of $2,001,492,843. The schedule puts the minimum commitment routinely required of an outside investor at $100,000, a different question from Form D's minimum-investment field, where the fund reports $0; it counts about 16 beneficial owners against the Form D's 17 investors; and it reports the share beneficially owned by the adviser and its related persons at 100% and the share held by funds of funds at 0%. Those figures carry the amendment's reporting date, not its filing date. Gen II Fund Services, LLC of New York is the administrator, PricewaterhouseCoopers LLP of Minneapolis the auditor and UMB Bank, N.A. the custodian. The same schedule reports the three predecessor funds of funds the same way: Fund XV at $1,488,061,989 of gross assets with 17 beneficial owners, Fund XIV at $1,431,636,584 with 16 and Fund XIII at $864,562,699 with 16, each about 100% owned by the adviser and its related persons. Amount sold and gross asset value are different measures, one a cumulative sales figure that can include unfunded commitments and the other a point-in-time asset figure, so their closeness does not show that the commitments were funded or invested. ## Why it matters A two-billion-dollar fund with 17 investors, no placement fees and no stated minimum is the profile of capital raised from a small number of large accounts rather than marketed broadly, and Rule 506(b) does not allow general solicitation. The Form D asks for the number of investors, not who they are. The earlier ADV reports entirely adviser-related ownership, consistent with an affiliated capital structure; the filings do not identify the individual investors or reconcile the two counts. ## What the filings do not show The Form D does not identify the investors or say which of them invest through the feeder, and neither filing names the related persons who own the fund or describes the underlying funds the vehicle commits to. The Form D does not show how the $2,001,500,000 accumulated between October 31, 2025 and the amendment, or how much of it has been paid in, and it does not state a fund size or target, since the offering amount is indefinite. The Form ADV figures are as of the amendment's reporting date and may have moved since; the ADV's 16 beneficial owners and the Form D's 17 investors are different counts taken on different dates, and the filings do not reconcile them. ## Key facts - Form D/A filed 2026-10-13, accession 0000905148-26-004446, CIK 0002089007; original Form D 2025-10-10 (0000905148-25-003575) reported no sale yet. - Total amount sold $2,001,500,000 (a cumulative figure that can include unfunded commitments) from 17 investors; first sale 2025-10-31; total offering amount indefinite; sales-compensation item empty, so no states of solicitation listed. - Rule 506(b) with Investment Company Act 3(c)(1) and 3(c)(7); no non-accredited investors; sales commissions $0; finders' fees $0; $0 in the minimum-investment field; offering expected to last more than a year. - Related persons: Thrivent White Rose GP XVI Fund of Funds, LLC (general partner) and Thrivent Investment Capital Advisors, LLC (managing member of the GP and investment manager; Thrivent Private Investments, CRD 338378); signed by Jerome H. Borden, CCO. - Form ADV annual updating amendment filed 2026-03-30, Schedule D 7.B.(1), figures as of the amendment's reporting date: master fund with feeder Thrivent White Rose Feeder XVI Fund of Funds LLC; gross asset value $2,001,492,843; minimum commitment for outside investors $100,000; about 16 beneficial owners; 100% beneficially owned by the adviser and its related persons; 0% by funds of funds; administrator Gen II Fund Services, LLC; auditor PricewaterhouseCoopers LLP (Minneapolis); custodian UMB Bank, N.A. Predecessor funds of funds XV/XIV/XIII: $1,488,061,989 / $1,431,636,584 / $864,562,699, 17/16/16 beneficial owners, each about 100% adviser-related. - Four Thrivent White Rose funds filed annual D/As on 2026-10-13: $4,934,901,250 across 59 investor positions (Real Estate Fund VI, Endurance Fund IV, Fund XVI Equity Direct, Fund XVI Fund of Funds); the notices do not show whether investors or vehicles overlap. ## Sources - Thrivent White Rose Fund XVI Fund of Funds, L.P., Form D/A (October 13, 2026): https://www.sec.gov/Archives/edgar/data/2089007/000090514826004446/ - Thrivent White Rose Fund XVI Fund of Funds, L.P., Form D (October 10, 2025): https://www.sec.gov/Archives/edgar/data/2089007/000090514825003575/ - Thrivent Private Investments (Thrivent Investment Capital Advisors, LLC), Form ADV annual updating amendment, March 30, 2026: https://reports.adviserinfo.sec.gov/reports/ADV/338378/PDF/338378.pdf - Thrivent Private Investments, CRD 338378: https://adviserinfo.sec.gov/firm/summary/338378 - SEC Form D and instructions (amount sold includes mandatory capital commitments; Item 12 states of solicitation): https://www.sec.gov/files/formd.pdf - AltStreet: Thrivent White Rose Real Estate Fund VI Reports $1.25 Billion Sold to Seven Investors in Its First Year (October 15, 2026): https://altstreet.investments/news/thrivent-white-rose-real-estate-fund-vi-first-sale-1-25-billion-2026-10-13 ## SEC accession numbers - 0000905148-26-004446 --- Source page: https://altstreet.investments/news/thrivent-white-rose-fund-xvi-first-sale-2-billion-form-d-amendment-2026-10-13 Machine index: https://altstreet.investments/llms.txt AltStreet reads what platforms, funds and issuers file with the SEC and what they tell investors, and publishes the difference. Figures are as filed or as captured on the date stated; nothing here is investment advice.