“Evergreen” describes behavior, not a legal form. Beneath it sit several distinct structures, each governed by a different regime and each offering a different liquidity promise. The differences are not cosmetic; they determine what a manager may and may not do when redemptions outpace the vehicle’s design.
Two regulatory details deserve emphasis. First, interval funds and tender-offer funds are not subject to the liquidity-risk-management rule that caps a mutual fund or ETF at 15 percent illiquid assets, which is precisely why they can hold predominantly private-market portfolios. Second, an interval fund must hold liquid assets equal to at least 100 percent of a repurchase offer amount from the time of notice to the repurchase date, and may suspend or postpone an offer only in limited emergency circumstances and only with the approval of a majority of the board, including a majority of the disinterested trustees.
Source: MFDF; ACA Group; Rule 23c-3.
The framework is still moving. In 2026, an application was filed for exemptive relief that would permit certain interval funds to conduct monthly repurchase offers of at least 2 percent of shares, within the existing rolling quarterly cap. The direction of travel is toward more frequent liquidity, but the periodic-cap architecture — the feature that defines the structure — is being preserved, not removed.
Source: Alston & Bird (June 2026), on an SEC exemptive-relief application filed March 2026, as amended May 2026.