Overview
Adviser’s Advisory Business
Tree Line Advisors (Hong Kong) Ltd., a company incorporated with limited liability in Hong
Kong (“Adviser”), acts as an investment adviser and provides investment advisory services for
the private investment companies in a master-feeder fund structure that are described below.
Adviser may also provide direct investment advisory services for accredited investors and
qualified clients on a discretionary basis. Adviser was established in 2006, along with its parent
company, Tree Line Investment Management Ltd. (“TLIM”), and its Singapore sister subsidiary,
Tree Line Advisors (Singapore) Pte Ltd. (“TLS”). TLIM, Adviser and TLS are members of the
Tree Line Group. Adviser is wholly owned by TLIM, which is principally owned by Zaheer
Abbas Sitabkhan, a director of Adviser (“Mr. Sitabkhan”). Mr. Sitabkhan is also the executive
director of each of the private investment companies for which the Adviser provides investment
advisory services. TLIM does not provide investment advice or investment management
services. TLS does not provide advice independently from Adviser.
Types of Advisory Services Adviser Offers
Adviser has been engaged to provide investment advisory services to the Tree Line Asia Master
Fund, a Cayman Islands exempted company (the “Master Fund”) and two feeder funds, the Tree
Line Asia Fund, a Cayman Islands open-ended investment company with limited liability and the
Tree Line Asia U.S. Feeder Fund, a Cayman Islands open-ended investment company with
limited liability (the “Feeder Funds,” and together with the Master Fund, the “Funds”), in its
capacity as investment adviser of the Funds.
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 investment
companies under the U.S. Investment Company Act of 1940, as amended (the “Investment
Company Act”). Accordingly, interests in the Funds that are offered and sold to U.S. persons are
sold to U.S. persons that satisfy 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.
Adviser provides investment advisory services to the Funds through the management of
investment portfolios in accordance with the investment objectives, risk tolerance and additional
guidelines as stated in each Fund’s Private Placing Memorandum (the “PPM”). Adviser expects
that its investment activities will focus on investments in various kinds of assets and securities in
various Asian markets and any other markets that may fit within the Funds’ objectives and
strategies described in their PPMs.
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.
Adviser does not participate, sponsor or act as a portfolio manager for any wrap fee programs.
Regulatory Assets Under Management
As of 31 December 2023, Adviser had regulatory assets under management of
US$1,114,660,645 of which all was managed on a discretionary basis and US$ 0 was managed
on a non-discretionary basis.