City of London Investment Management Co Ltd

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City of London Investment Management Co Ltd
CRD #110986
SEC #801-46266
CIK #0001034546
AUM 6,842.6 M (2026-06-18)
Employees 74 (35% Investors, 0% Brokers)
Fees
Minimum
Phone011442077110771
Address77 Gracechurch Street
London, United Kingdom
Source [IAPD] [EDGAR] [Website] [LinkedIn]
Total AUM ($B)
10.08.06.04.02.00.01999200820172027
Fees and Compensation — Form ADV Part 2A (6/18/2026) [Brochure]
Item 5 – Fees and Compensation

Separate Accounts

The specific manner in which fees are calculated and charged by CLIM is established in each
separate account client’s investment management agreement. CLIM will generally bill its fees on
a monthly or quarterly basis in arrears based on the account value at the close of each month.
Ordinarily, management fees will be prorated for each contribution and withdrawal made during
the applicable month. Accounts initiated or terminated during a month will be charged a
prorated fee. Upon termination of any account, any prepaid, unearned fees will be refunded,
and any earned, unpaid fees will be due and payable. CLIM offers flat and tiered fee schedules to
clients in multiple types of accounts or multiple strategies. Fees for each strategy are generally
as set forth below. FEES ARE NEGOTIABLE.

Emerging Markets Equity Closed-End Fund Strategy (including Special Situations Closed-End Fund
Strategy and Emerging Markets Ex-China Equity Closed-End Fund Strategy)
1.00% (100 basis points) per annum on the total assets of the Account.

Frontier Markets Equity Closed-End Fund Strategy
1.25% (125 basis points) per annum on the total assets of the Account.

International Equity Closed-End Fund Strategy (including Global Equity, World Equity, World ex
US Equity and EAFE Equity Closed-End Fund Strategies)
0.65% per annum on the first US $50m of account assets; 0.60% per annum on the next US $50m
of account assets; 0.55% per annum on account assets above US $100m.

Listed Private Equity Closed-End Fund Strategy
0.90% (90 basis points) per annum on the total assets of the Account.

Opportunistic Value Closed-End Fund Strategy
0.80% (80 basis points) per annum on the total assets of the Account.

Tactical Income Closed-End Fund Strategy
0.85% (85 basis points) per annum on the total assets of the Account.

China “A” Share Equity Closed-End Fund Strategy
1.50% (150 basis points) per annum on the total assets of the Account.

Municipal Bond Closed-End Fund Strategy
0.45% (45 basis points) per annum on the total assets of the Account.

Set-up and operating costs for a separate account will depend on the specific custodian
appointed by the client and the client pays these costs. Clients will also incur brokerage and
transaction costs as discussed further under “Brokerage Practices.”

CLIM Funds

The investment management fee for a CLIM Fund is dependent on the following factors:
   • Investment strategy;
   • Benchmark; and
   • Type of investor/overall investor relationship.

The offering memorandum (“Offering Memorandum”) for each CLIM Fund sets forth the specific
fees to be charged to investors. Administration and custody fees are paid by CLIM, as the
investment manager, unless otherwise agreed. The CLIM Fund will bear all expenses incurred in
connection with the acquisition, ownership, transfer, or realization of investments (including, but
not limited to, transfer and withholding taxes, stamp duties, brokerage commissions, and other
settlement charges, and corporate actions, tax reclamation, transaction and holding fees and
charges), and any indemnification and related expenses as set forth in each CLIM Fund’s
Declaration of Trust and Offering Memorandum. In addition, for certain CLIM Funds, CLIM bears
the cost of professional fees and expenses, which include the services of the CLIM Fund’s
independent auditors, tax preparers, and legal counsel. Investors in a CLIM Fund may incur wire
transfer and electronic fund transfer fees, and other fees and taxes on brokerage accounts and
securities transactions.

CLIM has entered into certain “side letter” arrangements with respect to investments in a CLIM
Fund, including side letter arrangements in which CLIM agrees to charge a discounted
management fee that differs from the fee structure stated in the Offering Memorandum. CLIM
has entered into an intercompany agreement with its affiliate, KIM, in which CLIM does not
charge investment management fees for the portion of assets attributable to any KIM clients who
are investors in the CLIM Funds. FEES ARE NEGOTIABLE.

All Accounts

CLIM strategies typically invest in closed-end, open-end and exchange-traded funds (each, a
“Third Party Fund”) which also charge internal management fees, which are disclosed in a Third
Party Fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to
CLIM’s fee, and the Firm shall not receive any portion of these commissions, fees, and costs. To
the extent that CLIM invests client assets in a CLIM Fund, the Firm ensures that clients are not
double-charged.

CLIM has different fee schedules for products and services offered in jurisdictions outside of the
United States. CLIM will not generally be required to provide notice to, or obtain the consent of,
one client when waiving, reducing or varying fees or modifying other contractual terms with any
other client. However, some clients wish to negotiate most favored nation (“MFN”) clauses in
their side letters or investment management agreements with CLIM. These MFN clauses often
require CLIM to notify the client if we subsequently enter into a side letter or an investment
management agreement with another client that offers more favorable pricing or other
contractual terms than those currently offered to the MFN client. The applicability of an MFN
clause will depend on the degree of similarity between clients, including, but not limited to, the
type of client, account structure, tax status, scope of investment discretion, amount of assets
under management, fee structure and particular investment strategy.

Further descriptions of the factors that CLIM considers in selecting or recommending broker-
dealers for client transactions and determining the reasonableness of their compensation (e.g.,
commissions) are found in “Brokerage Practices.”
Account Minimums and Types of Clients — Form ADV Part 2A (6/18/2026) [Brochure]
Item 7 – Types of Clients

CLIM generally provides portfolio management services to institutional clients including:
investment companies, pooled investment vehicles, pension and profit sharing plans, charitable
organizations, state or municipal government entities, foreign funds such as UCITS, and other US
and international institutions.

The CLIM Funds generally are restricted to investors who are “accredited investors” and
“qualified purchasers”, as such terms are defined in the relevant CLIM Fund Offering
Memorandum, the Securities Act of 1933, as amended, and the Investment Company Act of 1940.

For separate accounts, CLIM generally requires a minimum investment amount for each of the
strategies it manages. Such minimum investment amounts will vary depending on the particular
investment strategy and type of account. CLIM in its sole discretion can waive the minimum
investment requirements.
Sector Form 13F Holdings Value ($B)
Abrdn Emerging Markets Equity Income Fund Inc 0.1
Mexico Fund Inc 0.1
Nvidia Corp 0.1
Apple Inc 0.1
Japan Smaller Capitalization Fund Inc 0.0
Kayne Anderson Energy Infrastructure Fund Inc 0.0
Alphabet Inc 0.0
Mexico Equity & Income Fund Inc 0.0
Microsoft Corp 0.0
BlackRock Municipal 2030 Target Term Trust 0.0
View All
Holdings by Sector ($B)
3.02.41.81.20.60.02011201620212027
Type Form D Funds Date Sold AUM
Other Global Equity Fund of CEFS [2022-09-27] 2.5 M 3.3 M
Filed 2026-01-06 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Other All World EX US Equity CEF Fund [2021-09-28] 275.3 M 298.2 M
Filed 2025-04-17 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Other CA All World EX US Equity CEF Fund [2020-09-25] 570.6 M 495.6 M
Filed 2025-09-09 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Other HA International Equity CEF Fund [2020-09-25] 197.4 M 178.3 M
Filed 2024-10-02 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Other Emerging Markets REIT Fund [2019-04-03] 11.3 M 11.9 M
Filed 2023-01-19 (D/A) · Exemption 506(b), 3(c), 3(c)(1) · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Other International REIT Fund [2019-04-03] 3.0 M 2.4 M
Filed 2023-01-19 (D/A) · Exemption 506(b), 3(c), 3(c)(1) · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Other EM Special Situations CEF Focused Fund [2018-09-28] 85.5 M 62.6 M
Filed 2026-02-10 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Other CA International Equity CEF Fund [2017-09-28] 707.8 M 523.1 M
Filed 2025-08-22 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Other Opportunistic Value Fund [2017-09-28] 70.3 M 60.6 M
Filed 2025-09-09 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Other The Bangladesh Fund [2017-09-28] 32.6 M 1.5 M
Filed 2022-10-13 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
View All
AUM Breakdown Accounts AUM ($B)
By Client Type
(a) Individuals (other than high net worth individuals) 0 0.0
(b) Individuals (high net worth individuals) 0 0.0
(c) Banking or thrift institutions 1 0.0
(d) Investment companies 1 0.5
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 18 3.7
(g) Pension and profit sharing plans 1 0.0
(h) Charitable organizations 4 1.6
(i) State or municipal government entities 4 0.6
(j) Other investment advisers 0 0.0
(k) Insurance companies 0 0.0
(l) Sovereign wealth funds and foreign official institutions 0 0.0
(m) Corporations or other businesses not listed above 2 0.4
(n) Other 0 0.0
Total 43 6.8
By Discretionary
Discretionary 43 6.8
Non-Discretionary 0 0.0
Total 43 6.8
By Non-United States Persons
Non-United States Persons 0.3
United States Persons 6.5
Total 43 6.8
Limited Partners2011 - 2026
Massachusetts Pension Reserves Investment Management
Orange County Employee Retirement System
Form D Directors Role # Filings # Firms 2011 - 2026
Bny Mellon Trust of Delaware Director 34 6
Walter Dewey Director 17 3
Joseph Zakrzewski Director 24 2
City of London Investment Management Company Limited Executive Officer, Promoter 24 2
Delaware Trustee Bny Mellon Trust of Delaware Director 19 2
Investment Manager City of London Investment Management Company Limited Promoter 18 2
Bny Mellon Trust of Delaware Director 2 1
Investment Manager City of Longdon Investment Management Company Limited Promoter 1 1
Investment Manager City of London Investment Mangement Co Promoter 1 1
EDGAR Form CIK 2011 - 2026
13F-HR [0001034546]
3 [0001034546]
4 [0001034546]
SC 13D [0001034546]
SC 13G [0001034546]
Form 13D/13G Filer Form 13D/13G Subject Filed
City of London Investment Management Co Ltd Morgan Stanley India Investment Fund Inc [2025-11-14]
City of London Investment Management Co Ltd BlackRock Energy & Resources Trust [2024-11-14]
City of London Investment Management Co Ltd MFS High Yield Municipal Trust [2024-11-14]
City of London Investment Management Co Ltd Neuberger Berman Next Generation Connectivity Fund Inc [2024-02-09]
City of London Investment Management Co Ltd Templeton Dragon Fund Inc [2024-01-04]
City of London Investment Management Co Ltd Templeton Dragon Fund Inc [2023-11-15]
City of London Investment Management Co Ltd Voya Emerging Markets High Dividend Equity Fund [2023-02-13]
City of London Investment Management Co Ltd Neuberger Berman Next Generation Connectivity Fund Inc [2023-02-13]
City of London Investment Management Co Ltd Voya Asia Pacific High Dividend Equity Income Fund [2022-12-09]
City of London Investment Management Co Ltd Neuberger Berman Next Generation Connectivity Fund Inc [2022-02-11]
View All
Firm Profile (Form ADV)
Discretionary AUM$3.3B
ServesInstitutional
Fund TypesHedge Fund
LEI549300OCYFAUVGQY5162
Form 3/4/5 Subject 2011 - 2026
China Fund Inc
City of London Investment Group PLC
City of London Investment Management Co Ltd
Asia Pacific Fund Inc
Korea Fund Inc
Latin American Discovery Fund Inc
Mexico Equity & Income Fund Inc
Templeton Dragon Fund Inc
Taiwan Fund Inc
Abrdn Emerging Markets Equity Income Fund Inc
View All
Insider Transaction (Form 3/4/5) Date Action Shares Price Value ($)
China Fund Inc CHN
Common Stock, par value $.01 per share
2019-02-14 Sell 124,185 $20.61 2,559,453
China Fund Inc CHN
Common Stock, par value $.01 per share
2019-02-14 Sell 125,738 $20.61 2,591,460
China Fund Inc CHN
Common Stock, par value $.01 per share
2019-02-14 Sell 101,789 $20.61 2,097,871
China Fund Inc CHN
Common Stock, par value $.01 per share
2019-02-14 Sell 81,392 $20.61 1,677,489
China Fund Inc CHN
Common Stock, par value $.01 per share
2019-02-14 Sell 47,454 $20.61 978,027
China Fund Inc CHN
Common Stock, par value $.01 per share
2019-02-14 Sell 166,544 $20.61 3,432,472
China Fund Inc CHN
Common Stock, par value $.01 per share
2019-02-14 Sell 17,137 $20.61 353,194
China Fund Inc CHN
Common Stock, par value $.01 per share
2019-02-14 Sell 70,034 $20.61 1,443,401
China Fund Inc CHN
Common Stock, par value $.01 per share
2019-02-14 Sell 938,677 $20.61 19,346,133
China Fund Inc CHN
Common Stock, par value $.01 per share
2019-02-14 Sell 4,737 $20.61 97,630
China Fund Inc CHN
Common Stock, par value $.01 per share
2019-02-14 Sell 18,994 $20.61 391,466
China Fund Inc CHN
Common Stock, par value $.01 per share
2019-02-14 Sell 68,421 $20.61 1,410,157
Asia Pacific Fund Inc APB
Common Stock, par value $.01 per share
2018-10-15 Sell 20,000 $12.50 250,000
Latin American Discovery Fund Inc LDF
Common Stock, par value $.01 per share
2018-09-19 Sell 25,000 $10.93 273,250
Mexico Equity & Income Fund Inc MXE
Common Stock, par value $.01 per share
2018-09-19 Sell 17,500 $12.21 213,675
Korea Fund Inc KF
Common Stock, par value $.01 per share
2018-09-19 Sell 900 $35.93 32,337
Templeton Dragon Fund Inc TDF
Common Stock, par value $.01 per share
2018-09-18 Sell 75,622 $19.39 1,466,311
Templeton Dragon Fund Inc TDF
Common Stock, par value $.01 per share
2018-09-18 Sell 15,124 $19.39 293,254
Templeton Dragon Fund Inc TDF
Common Stock, par value $.01 per share
2018-09-18 Sell 45,373 $19.39 879,782
Templeton Dragon Fund Inc TDF
Common Stock, par value $.01 per share
2018-09-17 Sell 77,125 $19.19 1,480,029
showing 20 of 200 most recent transactions
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