INDEPENDENT VERDICT
Arlington Private Equity Fund VII, LLC has one of the clearest year-over-year fundraising expansions in this filing group. Its original September 16, 2025 Form D reported an indefinite Rule 506(b) offering with only $13.3 million sold to one investor on the day of first sale. The September 14, 2026 amendment reports $104.115 million sold to 85 investors — an increase of $90.815 million in reported subscriptions in roughly one year. Kenneth H. Polk remains the named executive officer and signer, the Birmingham address is unchanged, and the vehicle continues to rely on Section 3(c)(7). But one detail is easy to miss: despite the legal name "Arlington Private Equity Fund VII," the Form D does not check the SEC form's Private Equity Fund box. It classifies the issuer as an "Other Investment Fund." That distinction means researchers should not infer a conventional buyout mandate purely from the legal name; the actual portfolio mix and allocation policy have to be established from Arlington's offering and advisory documents.
THE MOST IMPORTANT STORY IS THAT ARLINGTON HAS THREE DIFFERENT "SIZE" NUMBERS — AND EACH MEASURES SOMETHING DIFFERENT
Fund VII's $104.115 million sold is only one layer of the Arlington platform. Arlington Partners LLC's March 2026 Form ADV reports approximately $2.31 billion of regulatory assets under management across 24 client accounts, while the public Arlington Family Offices website states that the broader organization oversees $16 billion of "Assets Under Stewardship" for 84 families and 870 "Souls Under Management." Arlington itself defines Assets Under Stewardship more broadly than discretionary investment AUM: it includes family financial assets for which Arlington provides asset management, advice, custody or administration. Those numbers therefore should not be placed in one column as if they were competing estimates of the same thing. $104.115 million is Fund VII securities sold; roughly $2.31 billion is regulatory AUM reported by Arlington Partners; $16 billion is a broader Arlington brand stewardship metric that includes assets subject to services beyond portfolio management. The differences are structural, not necessarily contradictions.
ARLINGTON VII IS ALSO THE LATEST LAYER OF A MUCH OLDER PRIVATE-FUND PROGRAM
The Fund VII filing is not a first-time private-market experiment. SEC records show Arlington Private Equity Fund III dating to 2013, followed by Funds IV, V, VI and VII, while Arlington Partners' current Form ADV also reports other private vehicles including Arlington Diversified Fund, Arlington Global Value Fund, Arlington IG Real Estate Fund and Arlington Income Fund. Fund VI alone reported $189.514 million sold in its February 2026 amendment against a $250 million stated offering. Arlington Income Fund reported $519.936 million sold in its February 2026 filing, while the IG Real Estate Fund has a separate multi-year Form D history. This diversification explains why the public Arlington brand cannot be analyzed through Fund VII alone: private equity, diversified strategies, global value, income and real estate vehicles coexist under the broader advisory platform. It also creates a concrete allocation question for Fund VII investors — which private opportunities are directed to Fund VII rather than Arlington's other pools or separately managed family accounts
THE WEBSITE-TO-SEC CONNECTION IS STRONG, BUT THE PUBLIC BRAND HAS EVOLVED BEYOND "ARLINGTON PARTNERS"
There is little identity ambiguity here. Arlington Partners LLC appears in SEC records under CIK 0001389848, CRD 109335 and SEC file 801-57250, with the same 2000 Morris Avenue, Suite 1300 Birmingham address used across the private funds. Arlington's public website now emphasizes the Arlington Family Offices name and describes a multidisciplinary family-office model rather than presenting itself simply as a private-equity manager. The website identifies Ken Polk as Founder and CEO and says the organization serves 84 families with 67 team members. Its disclosures further explain that Arlington Family Offices is a trade name under which Arlington Trust Company, LLC and affiliated entities provide trust, fiduciary, advisory, custody and related family-office services. This broader branding matters because a visitor seeing $16 billion on the website could easily assume that Arlington Private Equity Fund VII itself is part of a $16 billion investment fund complex. The SEC and website evidence support a common Arlington ecosystem, but the website's stewardship metric is not Fund VII NAV and should not be presented as such.
FINAL ASSESSMENT
Arlington Private Equity Fund VII is distinguishable by five facts that do not belong to a generic private fund: it grew from $13.3 million and one investor to $104.115 million and 85 investors in about a year; it carries "Private Equity" in its legal name but checks "Other Investment Fund" on Form D; Arlington Partners reports approximately $2.31 billion of regulatory AUM; the public Arlington Family Offices brand separately reports $16 billion of broader Assets Under Stewardship; and Fund VII sits inside a long-running collection of Arlington private vehicles spanning private equity, income, global value and real estate. The main diligence question is therefore not whether Arlington exists — that identity chain is unusually well documented — but how capital and opportunities are allocated across a family-office platform that manages or advises multiple funds and separately serves ultra-high-net-worth families. Fund VII's actual holdings, fee rate, valuation policy and co-investment practices matter more than the much larger stewardship number displayed by the public brand.
SEC SNAPSHOT
Issuer: Arlington Private Equity Fund VII, LLC CIK: 0002086131 SEC Form: Form D/A Accession No.: 0002086131-26-000001 File No.: 021-557647 Latest Filing Date: September 14, 2026 Original Filing Date: September 16, 2025 Year Organized: 2025 Jurisdiction: Delaware Principal Address: 2000 Morris Avenue, Suite 1300, Birmingham, AL 35203 Telephone: 205-488-4345 Industry: Pooled Investment Fund SEC Fund Classification: Other Investment Fund Legal Name Contains Private Equity: YES SEC Private Equity Fund Box Checked: NO Investment Company Registered: No Investment Company Act Exclusion: Section 3(c)(7) Offering Exemption: Rule 506(b) Security Type: Pooled Investment Fund Interests Offering Amount: Indefinite Amount Sold - September 16, 2025: $13,300,000 Investors - September 16, 2025: 1 Amount Sold - September 14, 2026: $104,115,000 Investors - September 14, 2026: 85 Increase in Amount Sold: $90,815,000 First Sale: September 16, 2025 Minimum Investment Reported: $1 Offering Duration Over One Year: Yes Sales Commissions: $0 Finder's Fees: $0 Named Executive Officer: Kenneth H. Polk Signer: Kenneth H. Polk Signer Title: Chief Executive Officer Management Fee: Annual management fee based on a specified percentage of AUM; exact percentage not disclosed in Form D
ARLINGTON ASSET-METRIC PENETRATION
Fund VII Form D Amount Sold: $104,115,000 Meaning: Securities sold in this specific exempt offering
Arlington Partners Regulatory AUM: Approximately $2.31 billion Meaning: Regulatory assets under management reported by investment adviser Client Accounts Reported: 24 CRD: 109335 SEC File No.: 801-57250
Arlington Family Offices Assets Under Stewardship: $16 billion Meaning: Broader organization-defined metric including assets for which Arlington provides management, advice, custody or administration Families Served: 84 Souls Under Management: 870 Team Members: 67
Interpretation: The $104.115M, approximately $2.31B and $16B figures measure different scopes and should not be combined or substituted for one another.
HISTORICAL FUND PENETRATION
Arlington Private Equity Fund III: Confirmed Arlington Private Equity Fund IV: Confirmed Arlington Private Equity Fund V: Confirmed in historical SEC records Arlington Private Equity Fund VI: Confirmed Arlington Private Equity Fund VII: Confirmed Fund VI February 2026 Amount Sold: $189,514,000 Fund VI Stated Offering Amount: $250,000,000 Arlington Diversified Fund: Confirmed Arlington Global Value Fund: Confirmed Arlington Income Fund: Confirmed Arlington Income Fund February 2026 Amount Sold: $519,935,750 Arlington IG Real Estate Fund: Confirmed
WEBSITE / ENTITY PENETRATION
Official Arlington website confirmed: YES Public-facing brand: Arlington Family Offices Arlington Partners LLC SEC adviser record confirmed: YES Arlington Partners LLC CIK: 0001389848 Arlington Partners LLC CRD: 109335 Arlington Partners LLC SEC File No.: 801-57250 SEC / adviser Birmingham address match: YES Fund VII / Arlington address match: YES Kenneth H. Polk SEC relationship confirmed: YES Ken Polk official website CEO relationship confirmed: YES Arlington Family Offices $16B stewardship claim confirmed on official website: YES Website defines Assets Under Stewardship more broadly than investment AUM: YES $16B equals Fund VII assets: NO $16B equals Arlington Partners regulatory AUM: NO Approximately $2.31B regulatory AUM equals Fund VII securities sold: NO Fund VII exact portfolio publicly disclosed in Form D: NO Fund VII exact management-fee percentage disclosed in Form D: NO Fund VII auditor independently confirmed from reviewed Form D: NO Fund VII administrator independently confirmed from reviewed Form D: NO
CORE INVESTOR QUESTIONS
Why is Arlington Private Equity Fund VII classified as an Other Investment Fund rather than a Private Equity Fund on Form D What asset classes does Fund VII actually hold What percentage is direct private equity, private funds, co-investments or secondary interests How are opportunities allocated among Fund VII, Fund VI and Arlington-managed family accounts Can Arlington family-office clients invest alongside Fund VII Can Fund VII purchase interests from or sell investments to other Arlington vehicles What is Fund VII's exact annual management-fee percentage Is carried interest or performance allocation charged How does Fund VII's portfolio differ from Arlington Diversified Fund and Arlington Income Fund How much of Fund VII's $104.115 million represents new outside capital versus affiliated or related-party subscriptions Why is the Form D minimum reported as only $1 What percentage of Fund VII is represented by the largest investors What independent valuation process applies to illiquid investments Who serves as auditor, administrator and custodian for Fund VII How have Funds III through VI performed on a realized net basis How much of Arlington's reported $16 billion Assets Under Stewardship is discretionary investment capital versus custody, advice or administrative assets
PRIMARY EVIDENCE REVIEWED
SEC Form D/A for Arlington Private Equity Fund VII, LLC filed September 14, 2026. SEC original Form D for Arlington Private Equity Fund VII, LLC filed September 16, 2025. SEC Form D records for Arlington Private Equity Fund VI. SEC historical Form D for Arlington Private Equity Fund III. SEC / Form ADV record for Arlington Partners LLC. Arlington Partners LLC 2026 adviser data reporting regulatory AUM and private-fund relationships. Arlington Partners LLC Form 13F filing confirming its Birmingham address and CIK. Arlington Family Offices official website. Arlington Family Offices official disclosures defining Assets Under Stewardship and affiliated family-office entities. SEC/Form ADV-linked records for Arlington Income Fund, Arlington IG Real Estate Fund, Arlington Global Value Fund and Arlington Diversified Fund.
IMPORTANT FORM D NOTICE
Arlington Private Equity Fund VII's $104.115 million amount sold, Arlington Partners' approximately $2.31 billion regulatory AUM and Arlington Family Offices' $16 billion Assets Under Stewardship are three different metrics covering different legal and economic scopes. FilingDossier does not present the $16 billion website figure as Fund VII assets or SEC-verified investment AUM. Form D, Form ADV, CIK and CRD records establish regulatory filings and identities; they do not constitute SEC approval, endorsement or verification of investment performance.