Open Door Investment Management Ltd

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Open Door Investment Management Ltd
CRD #159123
SEC #801-72755
CIK #
AUM 183.4 M (2026-03-27)
Employees 17 (59% Investors, 0% Brokers)
Fees
Minimum
Phone415-766-5888
Address100 Montgomery Street, Suite 1790
San Francisco, CA 94104
Source [IAPD] [Website] [LinkedIn]
Total AUM ($M)
60048036024012002010201520212027
Fees and Compensation — Form ADV Part 2A (3/20/2026) [Brochure]
ITEM 5 – FEES AND COMPENSATION

ODIM is compensated for its services by management fees, in part, on the basis of asset management
fees calculated as a percentage of a client’s assets under management. Negotiable management fees
ranging from 1.25% to 2% of assets managed are typically established for each client and strategy by
mutual agreement. Fees are typically calculated based on the net asset value of the account or fund
and are payable quarterly in arrears, unless otherwise agreed with the client. Performance fees are
discussed further below.

Performance-based fees may be charged only to clients that meet the definition of a “qualified client”
under Rule 205-3 of the Investment Advisers Act. Because ODIM may advise multiple funds and
accounts that pay different fee structures, a potential conflict of interest exists where the adviser may
have an incentive to favor accounts paying performance-based fees.

ODIM has adopted policies and procedures designed to mitigate these conflicts, including trade
allocation and compliance monitoring.

ODIM may receive performance-based fees/allocations. In such cases, ODIM generally assesses
performance-based fees/allocations based on realized and unrealized capital appreciation, if any, over
a threshold amount, such as a hurdle, benchmark or preferred return, and ODIM deducts or receives
a portion of any performance-based fees/allocations from client accounts, or collects or receives them
directly from clients on an annual basis. Any performance-based fee/allocation rates established are
individually negotiated with ODIM’s clients.

ODIM is also compensated by private fund investment managers for which it provides non-
discretionary portfolio selection advice. Such compensation is based on a percentage of the fund net
income received by such managers. Fund net income is calculated on the basis of management fees
received by the fund investment manager, minus expenses related to the management of the private
funds incurred by the investment manager.

Certain expenses are charged to more than one client, in which case ODIM determines the appropriate
allocation of expenses among each client depending on the nature of the expense. Certain expenses
are allocated between clients on a pro rata basis (as appropriate) while others are allocated more
specifically based on other factors, such as the relevant clients that have incurred the cost or received
the benefit arising from the expenses.

Private Funds

Under ODIM’s investment management agreement with each Private Fund, ODIM receives an annual
management fee based on the asset value of each Private Fund. ODIM, in its discretion, may waive
or reduce the management fee as to any or all of the investors in a Private Fund or agree with an
investor to waive or alter the management fee as to that investor.

Under ODIM’s investment management agreement with each Private Fund or a Private Fund’s charter
documents, as applicable, ODIM could potentially receive an annual performance-based fee or
allocation in arrears based on the net capital appreciation (i.e., capital appreciation less capital
depreciation) of each investor’s account in the Private Fund, however, such fees would only apply to
Private Funds established in the future, should ODIM decide to make such fees applicable to such

Private Funds. Any performance-based fee or allocation would be payable only if, and to the extent
that, the net capital appreciation of the investor’s account exceeded any net capital depreciation
accumulated in prior years (as adjusted for withdrawals of capital). ODIM, in its discretion, may waive
or reduce any performance-based fee or allocation as to any or all of the investors in a Private Fund
or agree with an investor to waive or alter the performance-based fee or allocation as to that investor.

The management fee is typically deducted by each Private Fund’s designated administrator according
to the fee terms of the investment management agreement or charter documents, as applicable. Any
performance-based fee or allocation, if applicable, would typically be deducted by each Private Fund’s
designated administrator on or about December 31 of each year in which a performance-based fee or
allocation is earned. If an investor withdraws all or a portion of its account in a Private Fund on a date
other than December 31, any performance-based fee or allocation, if applicable, would be based on
the amount withdrawn for the period from the prior January 1 to the date of withdrawal.

Each Private Fund bears all expenses of its organization and operation, expenses incurred in the
purchase and sale of investments, and accounting fees. Such expenses include, but are not limited to:
(i) brokerage and execution charges, commissions, custodial charges, and fees for quotation and other
data services, as discussed further below in Item 12; (ii) fees related to accounting, trading, portfolio
management and risk management systems; (iii) research subscription fees and expenses; (iv) broken
trade and broken deal fees; (v) expenses to register securities and transfer taxes; (vi) costs and
expenses incurred for the purpose of protecting and enhancing the value of the Private Fund’s
investments (including the costs of instituting and defending litigation); (vii) taxes, filing and
registration fees of the Private Fund; (viii) all costs, fees and expenses relating to investor
communications, relations, accounting and the preparation and mailing of financial, tax and
performance information to investors; (ix) fees, costs and expenses incurred in connection with
borrowings; (x) administration fees, costs and expenses; (xi) fees for attorneys, accountants,
consultants and other professionals or experts; and (xii) directors’ fees. Private Fund investors may
also indirectly bear a portion of any fees or expenses charged by investment funds (including mutual
...
Account Minimums and Types of Clients — Form ADV Part 2A (3/20/2026) [Brochure]
ITEM 7 – TYPES OF CLIENTS

Private Funds

ODIM serves as investment manager or sub-adviser to several Private Funds. The Private Funds
generally require investors to make a minimum initial investment and to maintain a minimum
investment in that Private Fund, although the amount of the minimums vary from fund to fund.
Investors that are U.S. persons generally must be “accredited investors” under Regulation D under the
Securities Act of 1933, as amended, who are qualified clients and therefore eligible to enter into a
performance fee arrangement under the Advisers Act, and for certain Private Funds, “qualified
purchasers” under Section 2(a)(51)(A) of the Investment Company Act of 1940, as amended. The
Private Funds require investors to make representations concerning their financial sophistication and
ability to bear the risk of loss of their entire investment in a Private Fund. If permissible under a Private
Fund’s charter documents, the minimum contribution and investor requirements may be waived by
ODIM in its sole discretion.

Managed Accounts

Through the use of Managed Accounts, ODIM makes its investment management services available
to high-net-worth individuals, corporate pension and profit-sharing plans, Taft-Hartley plans,
charitable institutions, foundations, endowments, municipalities, trust programs and other U.S. and
international institutions. ODIM generally requires Managed Account clients to initially provide and
to maintain a minimum of $20,000,000 in assets under management. Those clients generally must be
eligible to enter into a performance fee arrangement under the Advisers Act. The account minimum
may be waived by ODIM in its sole discretion.

Private Fund Managers

ODIM provides portfolio selection advisory services to investment managers of private funds
investing in Greater China securities. These fund managers have full discretion to accept or reject the
recommendations provided by ODIM. As described in Item 5, compensation for such arrangements
is based on a percentage of the fund net income received by such managers.
Type Form D Funds Date Sold AUM
HF Open Door China Healthcare Fund 2018-04-11 25.4 M
HF Open Door Greater China Fund 2018-04-11 6.1 M
HF Open Door SICAV PLC 2018-03-27
HF Open Door Greater China Master Fund Limited 2016-03-30 28.7 M
HF The China Absolute Fund Limited 2012-08-24 50.9 M
HF China Development Capital Partnership 2012-02-03 5.1 M
HF China Healthcare Partnership Master Fund LP 2012-02-03 3.7 M
HF Taiwan Opportunities Fund Limited 2012-02-03 31.1 M
HF The China 'A' Share Fund Limited 2012-02-03 154.7 M
AUM Breakdown Accounts AUM ($M)
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 0 0.0
(d) Investment companies 0 0.0
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 2 183.4
(g) Pension and profit sharing plans 0 0.0
(h) Charitable organizations 0 0.0
(i) State or municipal government entities 0 0.0
(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 0 0.0
(n) Other 0 0.0
Total 2 183.4
By Discretionary
Discretionary 2 183.4
Non-Discretionary 0 0.0
Total 2 183.4
By Non-United States Persons
Non-United States Persons 183.4
United States Persons 0.0
Total 2 183.4
Firm Profile (Form ADV)
Discretionary AUM$0.4B
ServesInstitutional
Fund TypesHedge Fund
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