INDEPENDENT CONCLUSION
FilingDossier found no public evidence supporting a conclusion that EnCap Energy Capital Fund XIII, L.P. is a scam. The September 29, 2026 filing is a genuine Initial Form D, and the organization behind it has an unusually extensive public footprint: EnCap Investments traces its history to 1988, earlier EnCap Energy Capital funds appear across decades of SEC and institutional-investor records, and the same Houston address, senior executives and management chain can be independently verified. Separate Fund XIII-B and XIII-C vehicles were filed on the same day, while an iCapital-branded access vehicle referencing Fund XIII was filed five days earlier.
This is not, however, a case where a long manager history removes the need for due diligence. The main Fund XIII filing reported First Sale Yet to Occur, $0 sold and zero investors. EnCap Investments also has material regulatory history that investors should know about, including a 2018 SEC pay-to-play enforcement settlement involving the manager and a separate FTC antitrust matter involving Fund XI and an energy acquisition. Neither matter establishes fraud by Fund XIII, but both are relevant when assessing the manager beyond a simple Form D search.
IS ENCAP ENERGY CAPITAL FUND XIII A SCAM — INITIAL ASSESSMENT
EnCap Energy Capital Fund XIII, L.P. is a newly formed 2026 Delaware limited partnership, but the manager and investment franchise behind it are not new. The fund appears under CIK 0002151816 and filed an Initial Form D on September 29, 2026 from 9651 Katy Freeway, Suite 600, Houston, Texas. That address and telephone number match EnCap Investments' current official website, and the filing identifies EnCap Equity Fund XIII GP, L.P. as general partner together with senior EnCap executives Jason M. DeLorenzo and Douglas E. Swanson, Jr.
The broader EnCap record extends far beyond this filing. EnCap's official history says the firm was established in 1988 and has raised 25 institutional funds with more than $47 billion in capital commitments across its upstream, midstream and energy-transition strategies. SEC ownership and Form 13F records independently show a multi-layer control structure connecting EnCap Investments L.P., EnCap Investments GP, EnCap Partners and earlier Energy Capital funds. This history materially reduces concern that the Fund XIII identity was created recently without a genuine manager behind it, while still leaving Fund XIII itself as a new and largely unseasoned legal vehicle.
WHAT THE NEW FORM D ACTUALLY SHOWS
The Fund XIII filing classifies the issuer as a pooled investment fund and checks "Venture Capital Fund." It relies on Rule 506(b) and reports exclusions under both Sections 3(c)(1) and 3(c)(7) of the Investment Company Act. The offering is indefinite and is expected to last more than one year, while aggregate net asset value is not publicly disclosed.
At the filing date, the main vehicle reported First Sale Yet to Occur, $0 sold, zero investors, a $0 minimum-investment field, $0 estimated sales commissions and $0 estimated finder's fees. These figures do not mean the fund is fraudulent or commercially unsuccessful; an initial Form D can be filed before a first completed sale. They do mean that the September 29 filing itself did not establish a completed Fund XIII fundraising close, an existing Fund XIII investor base, a funded portfolio or a Fund XIII performance history.
THE "VENTURE CAPITAL FUND" LABEL NEEDS CONTEXT
One potentially confusing detail is the Form D classification. Fund XIII checks the box for "Venture Capital Fund," while EnCap's public investment strategy is centered on growth capital for energy businesses, particularly upstream oil and gas management teams. Investors unfamiliar with private-fund regulation could incorrectly interpret the SEC category as meaning Fund XIII is a conventional technology or startup venture-capital fund.
EnCap's own upstream materials provide a clearer economic description. The firm describes its Energy Capital funds as growth-capital vehicles focused on independent North American energy companies and management teams. Earlier EnCap Energy Capital funds have used similar institutional structures, and EnCap's website identifies Fund XII as a $5.25 billion growth-capital fund. The Form D classification is therefore a regulatory categorization and should not replace an examination of the fund's actual strategy in its private offering documents.
WHO CONTROLS FUND XIII
The Form D identifies EnCap Equity Fund XIII GP, L.P. as the general partner of the main Fund XIII vehicle. Jason DeLorenzo and Douglas Swanson are listed as executive officers, and both can be traced through years of EnCap public records. DeLorenzo's official EnCap biography states that he joined the firm in 1999 after working in energy finance, while Swanson appears repeatedly as a Managing Partner or authorized signatory in SEC records involving earlier EnCap funds and public securities holdings.
The historical control chain is more important than the presence of two recognizable names. SEC filings for earlier EnCap funds describe EnCap Partners GP, EnCap Partners, EnCap Investments Holdings, EnCap Investments GP and EnCap Investments L.P. as parts of the broader control structure above various fund-specific general partners. These filings demonstrate a recurring institutional architecture rather than a newly invented GP name, although Fund XIII's precise economic rights, fee arrangements and governance should still be determined from its own partnership documents rather than assumed from previous vintages.
ENCAP INVESTMENTS HAS AN ACTIVE REGULATORY FOOTPRINT — AS AN EXEMPT REPORTING ADVISER
EnCap Investments L.P. appears in investment-adviser records under CRD 160695 and SEC file number 802-74807 and reports as an Exempt Reporting Adviser. Historical SEC orders also expressly describe EnCap as an ERA. That status provides meaningful regulatory visibility, but it should not be described as SEC approval of EnCap or Fund XIII.
An Exempt Reporting Adviser is not the same as a fully SEC-registered investment adviser, and an adviser-reporting record does not mean that the Commission has verified private-fund performance, asset values or marketing claims. This distinction is especially relevant because EnCap's long operating history and large prior funds could make exaggerated statements such as "SEC-approved EnCap fund" sound plausible to an investor who does not understand the difference between reporting, registration and regulatory endorsement.
FUND XIII IS NOT ONE VEHICLE: XIII-B AND XIII-C WERE ALSO FILED
The September 29 filings reveal a broader structure than the main Fund XIII LP alone. EnCap Energy Capital Fund XIII-B, L.P., CIK 0002150948, and EnCap Energy Capital Fund XIII-C, L.P., CIK 0002150988, each filed their own Initial Form D on the same day. Both use the same Houston address, identify Jason DeLorenzo and Douglas Swanson and report their own Fund XIII-specific GP entities.
Both B and C also reported First Sale Yet to Occur, $0 sold and zero investors at filing. The matching names, date, address, executives and numbering strongly connect them to the Fund XIII fundraising structure, but FilingDossier does not assume that the three vehicles have identical tax treatment, economics or investor eligibility simply because their names are similar. Investors should identify whether their subscription is to the main LP, Fund XIII-B, Fund XIII-C or another related vehicle and verify that the legal name, CIK, partnership documents and receiving entity all correspond.
AN ICAPITAL ACCESS VEHICLE APPEARED BEFORE THE MAIN FUND FILING
A fourth SEC filing adds another layer. On September 24, 2026, iCapital Access Fund - EnCap Energy Capital Fund XIII, L.P. filed an Initial Form D under CIK 0002154855. Unlike the Houston-based EnCap vehicles, this access fund uses 60 East 42nd Street, 24th Floor, New York, identifies iCapital PE GP, LLC as its general partner and lists Max Schwartz as an authorized signatory of that GP.
The iCapital vehicle reported Rule 506(b), Section 3(c)(7), an indefinite offering, First Sale Yet to Occur, $0 sold and zero investors. Its regulatory identity is therefore clearly distinct from EnCap Energy Capital Fund XIII itself. The name strongly indicates an access structure connected economically to Fund XIII, but investors should not assume that participation through an iCapital access vehicle is legally identical to investing directly in the EnCap LP. Fees, eligibility, liquidity, administrative arrangements and investor rights may differ, and those differences require the actual subscription documents.
THE FUND XIII STRUCTURE HAS PRECEDENT IN EARLIER ENCAP VINTAGES
The existence of B, C and access structures is not inherently unusual within the EnCap franchise. Public records for earlier generations show EnCap Energy Capital Fund VIII-B, Fund XII-B, co-investment vehicles and other associated structures. Institutional portfolio disclosures also continue to show investments in several of these related EnCap vehicles years after their original fundraising periods.
That history is positive evidence that Fund XIII's multiple-vehicle structure is not appearing in isolation. At the same time, previous structures should not be used to guess how Fund XIII is organized. "B," "C," "access," "co-investment" and similar labels can reflect materially different legal, tax or distribution arrangements, so each entity should be treated as its own legal issuer until the fund documents establish the relationship.
FUND XII PROVIDES A USEFUL PREDECESSOR CHECK
EnCap's immediately preceding flagship upstream fund provides unusually useful context. EnCap announced in October 2024 that Fund XII closed with $5.25 billion of capital commitments, exceeded its original target and reached its hard cap. The firm also stated that approximately $1.2 billion of co-investment had been raised for Fund XII portfolio companies, bringing total capital associated with that fundraising cycle to roughly $6.4 billion.
The announcement said Fund XII already included 12 portfolio companies and that approximately 40% of commitments came from new institutional and large-family-office relationships. EnCap also stated that its existing portfolio had returned more than $22 billion in distributions to investors since the beginning of 2021. These figures are useful evidence of the manager's scale, but they are statements by EnCap and should not be presented as Fund XIII performance. Fund XII's fundraising success does not establish how much Fund XIII will raise, and historical distributions across the EnCap portfolio do not belong to the new Fund XIII vehicle.
PUBLIC INSTITUTIONAL INVESTORS PROVIDE INDEPENDENT EVIDENCE
EnCap's prior fund franchise is also visible outside the manager's own website. The District of Columbia Retirement Board disclosed a $100 million commitment to EnCap Energy Capital Fund XII that closed in September 2024. Public pension and investment reports from other institutions also identify holdings or commitments to earlier EnCap Energy Capital funds, providing independent evidence that major institutional investors have participated in the franchise over multiple vintages.
Public SEC filings provide another form of corroboration. Main Street Capital's June 2026 investment schedule identified LP interests in EnCap Energy Capital Funds VIII, IX, X and XII, while other registered investment-company filings continue to report positions in EnCap Energy Capital funds and related vehicles. These records do not prove that Fund XIII will perform well, but they substantially strengthen the evidence that EnCap's previous funds are genuine institutional investment vehicles rather than names that exist only in promotional materials.
THE 2018 SEC ENFORCEMENT ORDER IS A MATERIAL PART OF MANAGER DUE DILIGENCE
Unlike some established private-fund managers with no easily located adviser enforcement history, EnCap Investments has a past SEC order that deserves direct discussion. In July 2018, the SEC instituted settled administrative and cease-and-desist proceedings against EnCap Investments for violations of the Advisers Act pay-to-play rule. The Commission's order stated that covered associates made political contributions connected to officials in Texas, Wisconsin and Indiana whose offices could influence the selection of investment advisers for public pension entities, while EnCap continued providing compensated advisory services within the rule's two-year restricted period.
EnCap consented to the order without admitting or denying the findings except as to the SEC's jurisdiction and the subject matter of the proceeding. The order censured EnCap, required it to cease and desist from future violations and imposed a $500,000 civil penalty. The SEC specifically explained that the pay-to-play rule does not require proof of a quid pro quo or actual intent to influence an official, so the proceeding should not be rewritten as a finding that EnCap bribed pension officials or committed investment fraud.
For Fund XIII due diligence, the proper interpretation lies between ignoring the case and overstating it. It is a genuine regulatory violation involving the manager and public-pension relationships and therefore belongs in a serious manager review. It is not evidence that Fund XIII is fraudulent, and FilingDossier found no public SEC allegation that Fund XIII itself has engaged in fraud or misconduct.
THE FTC ALSO HAS A REGULATORY HISTORY INVOLVING AN EARLIER ENCAP FUND
EnCap's public record also includes a major competition-law matter involving EnCap Energy Capital Fund XI. The Federal Trade Commission challenged a proposed transaction involving Fund XI affiliates, Verdun Oil Company, XCL Resources and EP Energy. The FTC said the approximately $1.445 billion acquisition could reduce competition in the Uinta Basin crude-oil market and required divestiture of EP Energy's Utah assets as part of the resolution.
This was an antitrust matter, not a securities-fraud case. It should not be presented as evidence that EnCap misled investors or that Fund XIII is fraudulent. It is nevertheless useful evidence that the EnCap franchise operates through very large real-world energy transactions that can attract federal competition scrutiny. The FTC case page remained active in later years, and EnCap-related parties subsequently sought modification of aspects of the order as market conditions changed.
MAINSTREAM MEDIA PROVIDES ADDITIONAL OPERATING EVIDENCE
EnCap's energy portfolio is also visible in independent financial media rather than solely through its own announcements. Reuters reported in 2024 on EnCap-backed XCL Resources and a potential sale process, and later reported the sale of XCL's Uinta Basin assets to SM Energy for approximately $2 billion. Reuters also connected the company to the earlier FTC scrutiny surrounding the attempted combination with EP Energy.
These reports provide another layer of evidence that EnCap is an active energy investment manager with substantial operating portfolio companies and transaction activity. They do not independently validate Fund XIII's future returns or terms, but they make the underlying manager easier to verify than a fund whose claimed investments cannot be found outside its own website.
THE WEBSITE HAS NOT YET FULLY CAUGHT UP WITH THE NEW FUND XIII FILING
One interesting digital-footprint detail is that EnCap's current upstream page still describes Fund XII as the latest listed growth-capital fund and shows earlier flagship funds VIII through XII among its current investing vehicles. The September 29 Fund XIII SEC filings are newer than that public website content.
For a newly filed fund, this timing difference is not inherently suspicious. SEC filings can appear before a manager updates its marketing or strategy pages, particularly before a first close. It is nevertheless a useful due-diligence checkpoint: investors should be cautious if a third-party website claims Fund XIII has already closed at a particular amount or has a developed portfolio when EnCap's own public website has not yet published those details and the initial Form D still reports no first sale.
THE MAIN RISKS ARE NOT "$0 SOLD" — THEY ARE CLAIM ATTRIBUTION AND ENTITY CONFUSION
Fund XIII's $0 sold and zero-investor filing is easy to turn into a dramatic headline, but it is not the strongest risk finding in this investigation. The filing is new and explicitly states First Sale Yet to Occur, so the numbers can be consistent with an offering launched before its initial close. A more useful investor question is whether later marketing accurately distinguishes what belongs to Fund XIII from what belongs to EnCap's 38-year firm history and predecessor funds.
A promoter could, for example, cite EnCap's $47 billion-plus historical capital commitments, Fund XII's $5.25 billion close, $22 billion of historical distributions, public-pension investors or multi-billion-dollar portfolio transactions and then present those facts as though they were Fund XIII's own assets or returns. The underlying information could be genuine while the conclusion presented to an investor is misleading. The same risk applies to mixing the main Fund XIII LP with Fund XIII-B, Fund XIII-C or the iCapital access vehicle.
RULE 506(b) MAKES THE DISTRIBUTION CHANNEL RELEVANT
The principal Fund XIII vehicle, the B and C entities and the iCapital access filing all rely on Rule 506(b). Rule 506(b) generally does not permit general solicitation of the offering. That does not mean EnCap cannot maintain a public corporate website or discuss its strategy, portfolio companies and historical funds; the relevant question is whether the actual Fund XIII securities are being broadly offered to the public.
An unsolicited social-media account, messaging group or unknown investment website offering immediate retail access to "EnCap Fund XIII" therefore deserves independent verification. A sophisticated impersonator could copy the real Houston address, DeLorenzo and Swanson names, genuine CIK numbers, EnCap's historical fund sizes and even the 2018 SEC order to make the website look thoroughly researched. Accurate public data does not authenticate the person using it.
WHAT FORM D AND ENCAP'S HISTORY DO NOT PROVE
A genuine Form D proves that an exempt-offering notice exists; it does not mean the SEC approved Fund XIII. A CIK is an identifier, EnCap's ERA status is not regulatory endorsement, prior institutional commitments do not guarantee Fund XIII performance, and historical portfolio distributions are not Fund XIII returns. The filing does not publicly establish a final fund size, portfolio value, audited performance, complete fee economics, receiving bank account, custody arrangements or the authority of a particular salesperson.
The same caution applies to the past enforcement and antitrust records. A genuine SEC enforcement order against the manager should not be hidden, but it also should not be transformed into an allegation that Fund XIII is a scam. A genuine FTC competition case involving Fund XI should be understood as competition-law history rather than securities fraud. High-quality due diligence depends on preserving those distinctions instead of turning every negative record into the same type of risk.
POSITIVE EVIDENCE AND RISK INDICATORS
The positive evidence supporting the legitimacy of the underlying EnCap franchise is extensive. The Fund XIII filing is genuine, the GP and executives align with the manager's established history, the current address matches EnCap's website, three Fund XIII EnCap vehicles were filed together, an iCapital-branded access vehicle exists, previous EnCap funds have attracted public institutional capital, Fund XII closed at significant scale and EnCap-backed portfolio transactions are independently documented in public filings and major financial media.
The areas requiring greater scrutiny are more specific. Investors should investigate any claim that EnCap or Fund XIII is "SEC approved," any use of Fund XII or earlier performance as Fund XIII performance, any claim that Fund XIII has already raised a large amount when the initial filing reports $0 sold, any failure to distinguish the main LP from XIII-B, XIII-C or the iCapital access vehicle, any guaranteed-return language, any broad retail solicitation inconsistent with the private-offering structure and any payment instructions that cannot be independently tied to the authentic fund documents.
WHAT INVESTORS SHOULD VERIFY BEFORE INVESTING
An investor should begin by identifying the exact legal vehicle being offered and matching the legal name, CIK, GP, subscription documents and receiving entity. Fund XIII, Fund XIII-B, Fund XIII-C and the iCapital access fund are separate issuers, and a legitimate reason may exist for using a particular vehicle, but that reason should be clearly documented rather than assumed from a similar name.
Investors should also distinguish EnCap's manager-level history from Fund XIII-level facts, confirm the adviser and GP relationships, review actual fee and carried-interest provisions, identify relevant fund-level service providers and independently verify banking instructions. Claims about EnCap's past funds, pension investors, portfolio-company exits or historical distributions should be attributed to the correct vintage and source rather than presented as guaranteed or realized Fund XIII performance.
FINAL ASSESSMENT
FilingDossier found no public evidence supporting a conclusion that EnCap Energy Capital Fund XIII, L.P. is a scam. The underlying EnCap franchise is unusually well documented: EnCap has operated since 1988, multiple generations of Energy Capital funds appear in SEC and institutional records, the Fund XIII GP and executives fit the historical management structure, prior funds have raised billions of dollars and public pension and financial-statement records independently confirm institutional participation in earlier EnCap vehicles.
Fund XIII itself is much newer than that manager history. Its September 29 Initial Form D reported First Sale Yet to Occur, $0 sold and zero investors, while separate XIII-B and XIII-C issuers were filed the same day and an iCapital access vehicle appeared five days earlier. Investors therefore should not treat EnCap's historical scale as proof that the new Fund XIII has already raised or deployed comparable amounts.
EnCap's regulatory history also deserves a more nuanced conclusion than a simple "legit" label. The manager was censured by the SEC in 2018 and paid a $500,000 civil penalty in a pay-to-play rule proceeding, while an earlier EnCap fund was involved in an FTC antitrust matter concerning a large energy acquisition. Those are real regulatory events and should be part of serious manager due diligence, but neither establishes that Fund XIII itself is fraudulent.
The principal scam-related risk is therefore misuse or distortion of a genuine and complicated institutional structure. A real EnCap name can be impersonated, authentic historical fund sizes can be presented as Fund XIII fundraising, real institutional investors can be used to imply guarantees, and genuine SEC filings can be attached to unauthorized payment instructions. Confirming that EnCap Energy Capital Fund XIII exists is only the first step; investors should separately verify the exact vehicle, manager relationship, offering documents, performance attribution and receiving account before transferring capital.
At present, FilingDossier has identified no public evidence showing that EnCap Energy Capital Fund XIII, L.P. itself has been accused of fraud or linked to reported investor losses.
PRIMARY SOURCES
U.S. Securities and Exchange Commission EnCap Energy Capital Fund XIII, L.P. Initial Form D — September 29, 2026 CIK 0002151816 / Form D File No. 021-599143 https://www.sec.gov/edgar/browse/?CIK=2151816&owner=exclude
U.S. Securities and Exchange Commission EnCap Energy Capital Fund XIII-B, L.P. Initial Form D — September 29, 2026 CIK 0002150948 / Form D File No. 021-599144 https://www.sec.gov/edgar/browse/?CIK=2150948&owner=exclude
U.S. Securities and Exchange Commission EnCap Energy Capital Fund XIII-C, L.P. Initial Form D — September 29, 2026 CIK 0002150988 / Form D File No. 021-599145 https://www.sec.gov/edgar/browse/?CIK=2150988&owner=exclude
U.S. Securities and Exchange Commission iCapital Access Fund - EnCap Energy Capital Fund XIII, L.P. Initial Form D — September 24, 2026 CIK 0002154855 https://www.sec.gov/Archives/edgar/data/2154855/000215485526000001/0002154855-26-000001-index.htm
SEC Investment Adviser Public Disclosure EnCap Investments L.P. CRD 160695 / SEC File No. 802-74807 https://adviserinfo.sec.gov/firm/summary/160695
U.S. Securities and Exchange Commission In the Matter of EnCap Investments L.P. Investment Advisers Act Release No. 4959 — July 10, 2018 https://www.sec.gov/files/litigation/admin/2018/ia-4959.pdf
Federal Trade Commission EnCap / EP Energy — Matter No. 2110158 https://www.ftc.gov/legal-library/browse/cases-proceedings/2110158-encapep-energy-matter
EnCap Investments Our Story https://encapinvestments.com/about/our-story
EnCap Investments Upstream Investment Strategy and Fund History https://encapinvestments.com/about/upstream
EnCap Investments EnCap Investments Closes Fund XII at $5.25 Billion https://www.encapinvestments.com/news/encap-investments-closes-fund-xii-525-billion
District of Columbia Retirement Board Public Board Records — $100 million Fund XII commitment
INDEPENDENT CORROBORATION
Reuters EnCap Investments seeks sale of Utah oil producer XCL Resources — March 28, 2024
Reuters SM Energy to buy XCL's Uinta assets for approximately $2 billion — June 27, 2024