Apollo Debt Solutions IDF: Fund Rating and Research File

In brief

A debt fund the public can reach only through a policy

The fund relies on Section 3(c)(7) of the Investment Company Act and Rule 506(b), so its interests go only to qualified purchasers in a private offering. Apollo reports about 50 beneficial owners and none outside the United States. As an insurance-dedicated fund it is held through insurance company separate accounts, alongside the few other holders the Treasury rules allow, and a family reaches it through a policy whose insurer offers it.

Apollo files the fund as a private fund of the “debt investments” type. It is also the master fund for Apollo Debt Solutions IDF Series Feeder, LP, whose series file their own Form D; the feeder reported gross assets of USD 28.7 million and about 27 owners.

One point to raise with the insurer: in its Form ADV of 28 October 2026, Apollo reports that 0% of the fund's assets were valued in the last fiscal year by a person that is not related to Apollo. J.P. Morgan Hedge Fund Services is the administrator. The figure does not show how prices were set or checked, which is a question for the insurer.

The rating

Why Apollo Debt Solutions IDF has four stars

Apollo is a large, long-established manager: USD 718 billion of regulatory assets, registered with the SEC since 2007. The accounts are audited every year by Deloitte and sent to investors. Apollo reports that none of the assets were valued outside its own group last year. A 2025 action by the SEC against Apollo counts a little against the record.

The rating looks only at the areas below, which matter to a family holding the fund through a private placement policy. Past returns play no part: these funds do not report them in their SEC filings, and they say little about what a policy will earn.

Conduct and regulatory record

What regulators and courts have recorded against the manager, and for platform series against the platform, as the advisers report it to the SEC. Several proceedings on one set of facts count as one matter. Recent and serious matters count most, matters of other companies in the group count for less, matters of individuals are weighed by the person's role and their bearing on the business, and the size of the firm is taken into account.

Reported controls

What the adviser reports to the SEC for the fund: whether the accounts are audited every year by an accountant registered with the PCAOB and subject to its regular inspection, whether audited statements go to investors and what the audit opinion says, whether the administrator and custodian are outside the adviser's group, and what share of the assets was valued last year by a person not related to the adviser.

Depth and experience of the manager

The assets the manager runs, its investment staff and how long it has been registered with the SEC.

Fund scale and investor base

The fund's gross assets, the number of its owners and how long it has been offered.

Reporting and filings

Whether the fund and its adviser keep their SEC filings current and consistent with each other.

Fit for a life insurance policy

Whether the fund is insurance-dedicated, so that a policy can hold it, and the minimum it asks. Liquidity terms join this element as they are documented.

PPLI.comFund Rating

Investor experience. What policyholders, insurers and advisers tell us is shown separately and never changes the stars. A factual point they raise is checked against the filings, and if it holds, the data is corrected. We never publish names. Tell us about yours

The rating expresses the opinion of PPLI.com on the date shown. It is not a statement of fact about the fund or its manager, not a credit rating, not a forecast of returns and not investment advice. Read about the rating.

The fund at a glance

Identity, offering and service providers

Identity

Legal nameApollo Debt Solutions IDF, LP

OrganisedDelaware, 2022, limited partnership

SEC CIK0001957807 EDGAR

Private fund ID805-3613338412 ADV

AdviserApollo Capital Management, L.P., SEC 801-67592 IAPD

Offering, as filed on Form D

ExemptionsRule 506(b); Investment Company Act s. 3(c)(7)

First sale1 January 2023

Minimum investmentUSD 1 as filed (nominal)

Amount soldUSD 156.1 million to date

Investors in the offering80

Sales commissionsNone reported

Latest filingForm D/A, 17 February 2026 Source

Size and ownership, as filed on Form ADV

Gross asset valueUSD 152,895,218 (ADV filed 28 October 2026)

Beneficial ownersAbout 50

Owned by non-US persons0%

Service providers

AuditorDeloitte & Touche LLP, New York; registered with the PCAOB

CustodianJPMorgan Chase Bank, N.A., New York

AdministratorJ.P. Morgan Hedge Fund Services

Prime brokerNone reported

Valued by a person not related to the adviser0% of assets, last fiscal year

Figures are shown as filed, with their dates. Form D counts investors in the offering and Form ADV counts beneficial owners, so the two numbers need not match. Gross asset value counts total assets without deducting borrowings or other liabilities, so it is not a net asset value. The minimum on Form D is nominal; the amount a family actually needs is set by the insurer and the policy.

Inside a policy

What to check before this fund goes into a policy

Why the wrapper matters here

Interest from private loans is ordinary income for a US taxpayer, taxed at up to 37% plus the 3.8% net investment income tax, every year. Held through a policy that meets the tax rules, the same income compounds without a yearly tax bill. How the numbers work

Liquidity

The fund's redemption terms are not in its public filings. Read them in the offering documents and set them against the way the policy will need cash: loans, withdrawals and the insurer's own rules for moving between funds.

Who chooses the investments

The policyholder can choose this fund from the insurer's menu but cannot direct what the fund buys. That line comes from the investor control rules, and it is the reason the fund exists in a separate insurance-only form.

Diversification

A policy's separate account must meet the diversification test of section 817(h). Because the fund is reached only through insurance policies, the test can look through to its assets if the fund meets the conditions of the Treasury rules; whether a given account passes is a question for the insurer, not something these filings show.

Valuation

Apollo reports that none of the fund's assets were valued last year by a person outside its group. Ask the insurer how it checks the price at which the account buys, sells and reports this fund.

Fees

Management and performance fees are set in the offering documents and are not shown in these filings. They come on top of the policy's own charges.

This is research, not an offer of the fund or advice to buy it. Interests in the fund are available only through an insurance company, and only to investors who qualify.

The adviser's record

Regulatory and legal record of Apollo Capital Management

What the adviser itself discloses to the SEC, summarised, with a link to the filing. The full list for the firm is in the manager file.

202513 January 2025

SEC order on business communications kept off firm systems

Fund concerned: none named in the order. The matter concerns the adviser's own recordkeeping, not a specific fund, and none of the insurance-dedicated funds in this file is named.

The SEC found that from at least December 2019 Apollo Capital Management staff, managers among them, used messaging platforms that the firm had not approved for business, and that many of those messages were not preserved. The order found violations of the recordkeeping rule under Section 204 of the Advisers Act and a failure to supervise.

Apollo consented to the order, admitted the facts set out in it and acknowledged that its conduct broke the federal securities laws. The case was one of a series of similar SEC actions against advisers and broker-dealers over off-channel messaging.

US Securities and Exchange Commission · Settled, with admission · Civil penalty USD 8.5 million · Cease and desist · Form ADV, Item 11 disclosure

2018Filed 2018, closed 2019 and 2021

Shareholder class actions over the ADT Inc. listing, ended without liability

Fund concerned: ADT Inc. shares, a portfolio company of Apollo private equity funds. None of the insurance-dedicated funds in this file is named.

Buyers of ADT Inc. shares in its January 2018 listing sued ADT and a number of other defendants, among them Apollo Management, L.P. and several of its affiliates, under the Securities Act of 1933. Apollo reports two such cases. One was withdrawn by the plaintiff in October 2019. In the other, the court's judgment of January 2021 ended the claims against the Apollo entities with no admission, no finding of liability and no payment by them.

Private plaintiffs (US federal court) · Dismissed · No payment by Apollo reported · Form ADV, Item 11 disclosure

These are the matters Apollo Capital Management itself reports in Item 11 of its Form ADV, filed 28 October 2026. A reported matter is a fact about the adviser, not a finding by PPLI.com about this fund. None of them concerns the fund's investments.

Reader rating

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Apollo Debt Solutions IDF, LP