INDEPENDENT VERDICT
Bin Yuan Greater China Fund (US) LLC is not a new 2026 vehicle. Its SEC record traces the offering back to a March 4, 2013 first sale, and the September 14, 2026 amendment still reports an indefinite Rule 506(b) hedge-fund offering with $79,864,434 sold to nine investors and a $100,000 minimum. Bin Yuan Capital Limited is explicitly identified in the filing as Investment Manager, while Ping Zhou is named as a director of that manager. The same morning, a separate Cayman issuer, Bin Yuan Greater China Fund, filed its own amendment showing $49,404,032 sold to 22 investors. The critical analytical point is that these are distinct legal vehicles operating under the same Greater China strategy platform, and the public Form Ds do not by themselves prove that the $79.86 million and $49.40 million should be added to produce a consolidated fund size. The U.S. vehicle's capital has also remained unchanged from its initial 2024 Form D disclosure, while the Cayman vehicle added roughly $2.017 million in the 2026 amendment. That difference suggests the two wrappers are seeing different subscription activity rather than moving as a single filing unit.
THE MOST IMPORTANT STORY IS THE DIFFERENCE BETWEEN FUND-LEVEL FORM D CAPITAL AND THE MANAGER'S MUCH LARGER ADVISORY BUSINESS
Bin Yuan Capital Limited is independently registered with the SEC as an investment adviser under CRD 170109 and SEC file 801-79096, with registration effective January 22, 2014. Current adviser data reports roughly $888 million of regulatory AUM across six client accounts. That figure is far larger than either Greater China Form D amount because the adviser manages more than these two exempt-offering vehicles and may also serve institutional mandates or other pooled structures. Bin Yuan's official website describes the firm as a China-focused public-equity manager and states that it was licensed by the Hong Kong SFC for Type 9 asset management in December 2012, later adding Type 4 securities-advisory permission, and registered with the SEC in 2014. This creates three very different numbers that should not be collapsed: $79.86 million is securities sold through the U.S. fund's Regulation D offering; $49.40 million is securities sold through the Cayman issuer's separate U.S. offering; and approximately $888 million is manager-level regulatory AUM.
THE MANAGER'S HISTORY IS UNUSUALLY SPECIFIC AND EXPLAINS WHY THE STRATEGY HAS LASTED MORE THAN A DECADE
Bin Yuan's official team page identifies Ping Zhou as Founder and CIO and says he previously spent 17 years with GE, including responsibility at GE Asset Management for approximately $5 billion across emerging markets, China equity and China A-share portfolios. The same page identifies Cicy Wu as a founding and managing partner and portfolio manager, Frieda Luo as COO, and Lily Qian as partner and portfolio manager. The firm emphasizes long-term investment in publicly listed Chinese companies, with ESG analysis embedded into the investment process rather than marketing itself as a broad private-market or macro hedge fund. That continuity matters because the U.S. Greater China Fund's first sale predates Bin Yuan's SEC adviser registration by almost a year, while the official corporate history shows the Hong Kong management operation already licensed in 2012. The fund therefore belongs to a mature strategy lineage rather than being a 2026 product created solely to capitalize on renewed interest in China equities.
THE CAYMAN SISTER FUND SHOWS WHY LEGAL WRAPPER MATTERS
The Cayman vehicle is legally separate from Bin Yuan Greater China Fund (US) LLC. Its 2026 Form D/A reports $49,404,032 sold to 22 investors, a $100,000 minimum, Rule 506(b) and Section 3(c)(1), with a March 4, 2013 first sale — the same first-sale date as the U.S. vehicle. Ping Zhou and Bin Yuan Capital Limited again appear in the related-person chain, and Frieda Luo signs as COO of the Investment Manager. The matching strategy name, management team, first-sale date and investment-manager relationship strongly support a parallel or related access structure, but the Form D does not establish exactly how assets are held between them. Researchers should therefore resist the temptation to call one a feeder and the other a master without supporting organizational documents. The correct conclusion is narrower: they are two coordinated Greater China vehicles managed by the same firm, with different investor counts and different cumulative Form D sales.
PUBLIC MARKET RECORDS PROVIDE REAL PORTFOLIO EVIDENCE — BUT THEY ALSO SHOW WHY CURRENT HOLDINGS MUST BE VERIFIED CAREFULLY
Bin Yuan is visible in public-company ownership and investor-relations materials rather than existing only in fund filings. Public records have listed Bin Yuan Capital Limited among institutional holders of Hong Kong-listed companies such as Haichang Ocean Park and Vobile Group, and mainland listed-company investor-meeting records show Bin Yuan representatives including Cicy Wu, Lily Qian and Ping Zhou participating alongside other institutional investors. At the same time, a 2025 Hong Kong issuer announcement specifically clarified that Bin Yuan Capital Limited was not a shareholder of that company as of the announcement date despite being quoted as a shareholder in some public sources. That is a useful caution for portfolio research: public databases can lag, aggregate nominees or reflect historical positions. For FilingDossier, actual holdings should be attributed only when tied to a dated issuer filing, shareholder register or manager disclosure rather than copied from generic ownership databases.
FINAL ASSESSMENT
Bin Yuan Greater China Fund (US) LLC is distinguishable by at least five case-specific facts: its first sale dates to 2013; its Form D amount remains $79.864 million with only nine investors; a Cayman sister vehicle filed the same day with $49.404 million and 22 investors; the investment manager is a fully SEC-registered adviser with roughly $888 million of regulatory AUM and a Hong Kong SFC history going back to 2012; and Ping Zhou's pre-Bin Yuan background includes management responsibility for multi-billion-dollar emerging-market and China portfolios at GE Asset Management. The most important diligence issue is not whether Bin Yuan exists, but how the U.S. and Cayman Greater China vehicles relate economically, what their current NAVs are after years of gains, losses and redemptions, and which public-equity positions currently belong to each vehicle. The two Form D amounts should remain separate until fund documents establish whether any underlying capital overlaps.
SEC SNAPSHOT
Issuer: Bin Yuan Greater China Fund (US) LLC CIK: 0002036279 SEC Form: Form D/A Accession No.: 0002036279-26-000002 File No.: 021-524892 Filing Date: September 14, 2026 Jurisdiction: Delaware Entity Type: Limited Liability Company Principal Address: The Corporation Trust Company, 1209 Orange Street, Wilmington, DE 19801 Telephone: +852 2877 9330 Industry: Pooled Investment Fund Fund Classification: Hedge Fund Investment Company Registered: No Investment Company Act Exclusion: Section 3(c)(1) Offering Exemption: Rule 506(b) Security Types: Equity / Pooled Investment Fund Interests Offering Amount: Indefinite Amount Sold: $79,864,434 Investors: 9 Minimum Investment: $100,000 First Sale: March 4, 2013 Offering Duration Over One Year: Yes Sales Commissions: $0 Finder's Fees: $0 Related Person: Ping Zhou Investment Manager: Bin Yuan Capital Limited Signer: Frieda Luo Signer Role: COO of the Investment Manager
RELATED CAYMAN VEHICLE
Issuer: Bin Yuan Greater China Fund CIK: 0002036280 Jurisdiction: Cayman Islands Principal Address: Intertrust Corporate Services (Cayman) Ltd, One Nexus Way, Camana Bay, Grand Cayman, KY1-9005 Telephone: +852 2877 9330 Offering Exemption: Rule 506(b) Investment Company Act Exclusion: Section 3(c)(1) Offering Amount: Indefinite Amount Sold: $49,404,032 Investors: 22 Minimum Investment: $100,000 First Sale: March 4, 2013 Investment Manager: Bin Yuan Capital Limited 2024 Initial Form D Amount Sold: $47,387,032 2026 Incremental Increase: $2,017,000 2026 Cumulative Amount Sold: $49,404,032 U.S. Vehicle / Cayman Vehicle Form D Amounts Proven Additive: NO Confirmed Master / Feeder Relationship in Reviewed Form D: NO
ADVISER / REGULATORY PENETRATION
Investment Adviser: Bin Yuan Capital Limited CRD: 170109 SEC File No.: 801-79096 SEC Registration Status: Approved SEC Registration Effective Date: January 22, 2014 Latest Reported Regulatory AUM: Approximately $888 million Reported Client Accounts: 6 Discretionary AUM: Approximately $888 million Hong Kong SFC Licensed Corporation: YES SFC CE Number: BAM039 Type 9 Asset Management License: YES Type 4 Advising on Securities: Official website reports added in 2016 AMAC Asset Manager Recognition: Official website reports recognition in 2014 Official Website: binyuancapital.com
WEBSITE / ENTITY PENETRATION
Official Bin Yuan Capital website confirmed: YES Website legal name matches investment manager: YES SEC adviser record confirmed: YES CRD 170109 confirmed: YES SEC 801-79096 confirmed: YES Ping Zhou Founder / CIO role confirmed by official website: YES Ping Zhou relationship confirmed in Form D: YES Frieda Luo COO relationship confirmed by official website: YES Frieda Luo signed 2026 Form D: YES Cicy Wu investment-team role confirmed: YES Lily Qian investment-team role confirmed: YES Hong Kong SFC history confirmed: YES Greater China public-equity strategy confirmed: YES U.S. Fund current NAV disclosed in Form D: NO Cayman Fund current NAV disclosed in Form D: NO $888M adviser AUM equal to Greater China Fund assets: NO Dedicated public page showing current Greater China Fund holdings: NOT CONFIRMED
PUBLIC INVESTMENT EVIDENCE
Bin Yuan representatives documented in mainland listed-company investor meetings: YES Cicy Wu / Wu Chen appears in public investor records: YES Lily Qian appears in public investor records: YES Ping Zhou appears in public investor records: YES Bin Yuan Capital listed in public ownership databases for Hong Kong companies: YES Current holdings should be verified against issuer filings rather than database snapshots: YES 2025 Hong Kong issuer explicitly clarified Bin Yuan was not a shareholder despite earlier public-source references: YES
CORE INVESTOR QUESTIONS
How do Bin Yuan Greater China Fund (US) LLC and Bin Yuan Greater China Fund relate legally Do they invest pari passu in the same portfolio Is either vehicle a feeder into a separate master fund Why does the U.S. vehicle report $79.864 million sold while the Cayman vehicle reports $49.404 million What are the current NAVs of each vehicle How much capital has been redeemed since the March 2013 first sale Why has the U.S. Form D amount remained unchanged since the 2024 filing What drove the Cayman vehicle's $2.017 million increase in 2026 Which China A-share, H-share and ADR positions are currently held What percentage of the strategy is mainland China versus Hong Kong or offshore-listed China equities How concentrated is the portfolio in the top ten holdings What management and performance fees apply to each vehicle Are fee terms identical between U.S. and Cayman investors What is the role of Bin Yuan Capital (Cayman) Limited in the broader group How does Bin Yuan Asset Management (Shanghai) Ltd interact with Hong Kong research and trading What are the current auditor, administrator, custodian and prime-broker relationships How are ESG factors incorporated into security selection in practice How have the funds performed net of fees since 2013 relative to relevant China equity benchmarks
PRIMARY EVIDENCE REVIEWED
SEC Form D/A for Bin Yuan Greater China Fund (US) LLC filed September 14, 2026. SEC Form D/A for Bin Yuan Greater China Fund filed September 14, 2026. Historical 2024 and 2025 Form D filings for both Greater China vehicles. SEC Investment Adviser Public Disclosure record for Bin Yuan Capital Limited. Bin Yuan Capital official website. Bin Yuan Capital official About Us page. Bin Yuan Capital official investment-team biographies. Hong Kong SFC licensing records for Bin Yuan Capital Limited. Public mainland listed-company investor-relations records showing Bin Yuan participation. Hong Kong issuer announcement clarifying historical public-shareholder references. Current adviser data used to compare regulatory AUM with Form D offering amounts.
IMPORTANT FORM D NOTICE
The $79,864,434 reported by Bin Yuan Greater China Fund (US) LLC and the $49,404,032 reported by Bin Yuan Greater China Fund are separate issuer-level Regulation D sales figures. They should not automatically be added into a single strategy AUM number because the reviewed Form D filings do not establish whether the two vehicles overlap economically or feed a common master structure. Bin Yuan Capital Limited's approximately $888 million regulatory AUM is a broader adviser-level figure covering multiple accounts and should not be attributed solely to either Greater China fund. SEC registration, CIK and SFC licensing confirm regulatory identity and status; they do not constitute regulatory approval of investment performance.