Adviser’s Advisory Business
RAYS Capital Partners Limited, a company incorporated with limited liability in Hong Kong
(the “Adviser”), acts as the investment adviser to one or more private investment funds and
separately managed accounts. The Adviser was established in 2010. The Adviser is principally
owned by David Ching Chi RUAN and CHAN Chung Yuen, Lawrence, both Managing Partners.
The Adviser is licensed with the Securities and Futures Commission in Hong Kong to carry on
the activities of advising on securities (Type 4) and asset management (Type 9) under the
Securities and Futures Ordinance.
Types of Advisory Services offered by the Adviser
As an investment adviser, the Adviser provides portfolio management services, including
discretionary management and monitoring of investments, to investment funds and separately
managed accounts in accordance with the objectives, restrictions and guidelines as stated in each
Private Placing Memorandum (“PPM”) or the investment mandate(s). The investment activities
will primarily focus on investments in various kinds of assets and securities in various Asian
markets and any other markets that may fit within the objectives and strategies described in PPM
of respective investment fund or investment mandate of respective individual client.
As of December 31, 2023, the Adviser manages the following open-ended investment funds:
- Asian Opportunities Absolute Return Master Fund Limited (“AOFM”), and, one feeder
fund – Asian Opportunities Absolute Return Fund Limited (“AOF”)
- Asian Equity Special Opportunities Portfolio Master Fund Limited (“AESOPM”), and,
one feeder fund – Asian Equity Special Opportunities Portfolio Limited (“AESOP”)
- Asian Technology Absolute Return Fund (“ATF”)
- Asian Healthcare Discovery Master Fund (“AHDFM”), and one feeder fund – Asian
Healthcare Discovery Fund (“AHDF”)
- Greater China ESG Opportunities Absolute Return Fund (“GCESG”)
- Stable Income Fund (“SIF”)
- LM Growth Fund (“LMGF”)
(Note: Both AHDFM and AHDF ceased operations on March 22, 2024 and will be place in
voluntary
liquation before end of year 2024.)
All the investment funds above, collectively the “Funds”, are Cayman Islands exempted
companies.
Interests in the Funds are not registered securities under the U.S. Securities Act of 1933, as
amended (the “Securities Act”). In addition, the Funds are not registered as an investment
companies under the U.S. Investment Company Act of 1940, as amended (the “Investment
Company Act”). Accordingly, interests in the Funds are offered and sold exclusively to
investors satisfying the applicable eligibility and suitability requirements in private transactions
pursuant to available exemptions under the Securities Act, the Investment Company Act and any
applicable U.S. state securities laws.
The Adviser provides direct investment advisory services for Professional Investors, as defined
in the Securities and Futures Ordinance of Hong Kong. If and when the Adviser provides direct
investment advisory services for accredited investors and qualified clients that are US Persons on
a discretionary basis, the Adviser will develop customized investment strategies based on the
stated investment objectives, risk tolerance and financial circumstances of each client and such
client may impose reasonable restrictions on the management of their accounts, including by
restricting particular securities or types of investments.
Currently, the Funds generally may not impose restrictions on the management of their accounts,
other than restrictions stated in the PPMs of the Funds and other restrictions that are customary
in the ordinary course of business. Clients should be aware that performance of restricted
accounts may differ from performance of accounts without such impediments, possibly
producing lower overall results.
The Adviser does not participate, sponsor or act as a portfolio manager for any wrap fee
programs.
Assets Under Management
As of December 31, 2023, the Adviser had regulatory assets under management of
approximately US$ 472,376,000, all of which was managed on a discretionary basis.