Since the mid 1990s, in a generally strongly performing property market, there has been a significant growth in the number of unlisted real estate funds. These funds have provided fund managers with the opportunity to charge performance fees, without the manager being able to provide clear evidence of historic out-performance against market benchmarks. typically been described in terns of their differing styles core, core plus, value-added, opportunity with different return targets, different levels of leverage and different fee and incentive structures. These factors all suggest different risk levels. With the events of the period 2008-2011, investor confidence in the unlisted real estate fund investment structure has been significantly dented, with some investors demanding a new level of transparency. An area where this is particularly important is in the charging of performance fees by fund managers. Opportunity funds (as defined by INREV) have generally taken higher risks, including more leverage, relative to core funds (again defined by INREV). It is questionable both whether high risk strategies such as those employed by opportunity funds have delivered the necessary higher returns, and also whether fund performance fees adequately distinguish between risk taking and genuine outperformance. Taking acceptable/agreed risks with investors' capital should earn higher returns, but the returns from pure risk-taking should not be rewarded. Hence three questions arise. How has the performance of core funds and opportunity funds compared over periods of market strength and market weakness? To what extent can the relative performance be explained by leverage? Have the performance fees paid to managers been fairly earned?