HIDDEN LAKE ONSHORE FUND SEC FORM D REVIEW
Hidden Lake Onshore Fund LP's September 18, 2026 Form D amendment reports an indefinite hedge-fund offering with $22,921,993 sold to 18 investors. The Delaware limited partnership identifies February 1, 2020 as its first sale date, relies on Rule 506(b) and Investment Company Act Section 3(c)(1), and states that the offering is intended to continue for more than one year. The filing reports a $0 regulatory minimum investment, no commissions or finder fees and no direct payments from offering proceeds to the named related persons, although it expressly notes that the investment manager receives customary management fees. Hidden Lake Asset Management LP is identified as investment manager, Hidden Lake Fund GP LLC as general partner and Kevin Mok signed the filing as managing member of the general partner. This establishes a clear regulatory identity chain, but the $22.92 million figure should be treated as cumulative securities sold through this specific Form D offering rather than current net asset value, overall manager AUM or the size of the publicly traded portfolio.
That distinction becomes particularly important when the Form D is compared with Hidden Lake Asset Management's adviser-level disclosures. The firm is an SEC-registered investment adviser under CRD 298209 and SEC file number 801-115096, with registration effective since May 2019. Its March 27, 2026 Form ADV reported approximately $378.26 million of regulatory assets under management, all managed on a discretionary basis, across five pooled-investment accounts. Public adviser data also identifies roughly ten employees and no separately managed retail-client business, meaning Hidden Lake is fundamentally a pooled-vehicle manager rather than a conventional wealth manager. Kevin Ka Wah Mok appears in the ADV ownership structure as a managing member and control person of Hidden Lake Asset Management GP LLC, while Jonathan Andrew Rodriguez also appears within the ownership chain. John Morelli is identified in public adviser records in senior compliance and operational roles. The strong alignment among Form D, ADV, website and 13F addresses at 152 West 57th Street materially reduces entity-confusion risk.
Hidden Lake's quarterly 13F filings offer a rare window into how its strategy behaves in practice. The Q2 2026 filing reported approximately $332.21 million across 24 reportable positions. The visible portfolio was not simply a collection of long common-stock holdings: some of its largest disclosed exposures were options, including put exposure tied to semiconductor ETF SOXX and Nasdaq-100 ETF QQQ, call exposure on KraneShares China Internet ETF KWEB, and individual equity positions including AMD and other technology-related names. One Q2 position alone — an options exposure in an iShares vehicle — represented more than $70 million of reported 13F value, while KWEB call exposure exceeded $25 million. Earlier quarters show the structure shifting materially: Q1 2026 disclosed approximately $330.88 million, Q4 2025 approximately $395.39 million and Q3 2025 approximately $782.20 million. Those large quarter-to-quarter changes demonstrate why 13F gross market value should not be used as a substitute for hedge-fund NAV or AUM, particularly when options are significant.
The manager's stated strategy helps explain that portfolio construction. Hidden Lake describes a research-driven, fundamentally oriented investment process focused primarily on publicly traded global companies across technology, media, telecommunications, consumer and business services. Its long thesis can include market leaders with strengthening competitive advantages, companies trading below strategic or asset value and securities where corporate actions such as asset sales, mergers or share repurchases may close a valuation gap. Its short framework can target overhyped themes, businesses with weak reinvestment, unsustainable models or investor bases dominated by speculative enthusiasm. The public 13F evidence is broadly consistent with a flexible long-short approach rather than a traditional long-only fund: index puts can hedge broad market or factor exposure, sector puts can express negative thematic views and calls can create leveraged upside exposure without requiring equivalent cash equity positions.
Investors should nevertheless resist reconstructing Hidden Lake's actual portfolio directly from the 13F. Form 13F generally reports certain U.S.-listed long securities and listed options but does not reveal conventional short positions, many swaps, futures, cash, private securities, most non-U.S.-listed holdings or the complete economic effect of derivatives. A large put position therefore cannot automatically be interpreted as a simple bearish bet because it may hedge individual long positions, sector exposure or broader portfolio beta. Likewise, option market values reported through 13F can produce gross exposure figures that look very large relative to fund NAV without implying that the same amount of capital was invested. This explains how a manager with approximately $378 million of regulatory AUM can report quarterly 13F values that moved from roughly $154.6 million to $782.2 million and back below $400 million without those changes necessarily representing equivalent inflows or redemptions.
The parallel offshore vehicle adds another important structural layer. Hidden Lake Offshore Fund Ltd., a Cayman Islands exempted company under CIK 0001750427, filed its own September 18, 2026 Form D amendment reporting $2,402,491 sold to six investors under an indefinite Rule 506(b) offering. The offshore filing uses Investment Company Act Section 3(c)(1), identifies Hidden Lake Asset Management as the investment manager and uses Cayman-based directors and administration infrastructure. Historical Form ADV material places Hidden Lake Onshore Fund and the offshore vehicle within the same broader private-fund structure. Investors therefore need to understand whether assets are invested through a master fund, whether the vehicles trade substantially identical portfolios, how taxable and tax-exempt investors are separated and how expenses, gains, losses and liquidity are allocated. Form D alone cannot answer those questions.
KEY FINDINGS Hidden Lake Onshore Fund LP reported $22,921,993 sold to 18 investors in its September 18, 2026 Form D amendment. It is an indefinite Rule 506(b) hedge-fund offering operating under Section 3(c)(1), with its first sale dating to February 1, 2020. Hidden Lake Asset Management LP serves as investment manager and Hidden Lake Fund GP LLC serves as general partner. The manager is an SEC-registered adviser under CRD 298209 and SEC file number 801-115096. Its latest Form ADV reports approximately $378.26 million of discretionary RAUM across five pooled-investment accounts. Its Q2 2026 13F separately disclosed approximately $332.21 million across 24 reportable positions and showed extensive use of puts and calls. The related Hidden Lake Offshore Fund Ltd. reported $2.40 million sold to six investors in its own September 2026 Form D amendment.
FORM D HISTORY Original Form D: February 2020. 2020 initial amount sold: Early filing history began with approximately $250,000. February 2021 amendment: Additional reported fundraising activity. September 2021 amendment: Continued fundraising. September 2022 amendment: Approximately $10.5 million incremental activity reported by historical filing trackers. September 2023 amendment: Additional approximately $3.99 million historical activity. September 2024 amendment: No material incremental amount shown by historical trackers. September 2025 amendment: Continuing indefinite offering. September 18, 2026 amendment: $22,921,993 cumulative amount sold and 18 investors. Important interpretation: Historical incremental filing figures should not simply be added to the latest cumulative Form D amount; the current filing already provides the issuer's current reported total amount sold.
ADVISER REGISTRATION Manager: Hidden Lake Asset Management LP SEC File Number: 801-115096 SEC registration effective: May 1, 2019 Latest reviewed ADV date: March 27, 2026 Regulatory AUM: Approximately $378,263,704 Discretionary AUM: Approximately $378,263,704 Non-discretionary AUM: $0 Reported pooled-investment accounts: 5 Employees: Approximately 10 Primary business: Portfolio management for pooled investment vehicles Compensation structure disclosed through ADV: Asset-based and performance-based fees Headquarters: 152 West 57th Street, Suite 920, New York, NY 10019
Q2 2026 13F PENETRATION Manager 13F CIK: 0001750312 Report period: June 30, 2026 Filed: August 2026 Reportable positions: 24 Reported 13F market value: Approximately $332.21M Visible major exposures included SOXX puts, QQQ puts, KWEB calls, AMD and other equity / option positions. Q1 2026 13F value: Approximately $330.88M Q4 2025: Approximately $395.39M Q3 2025: Approximately $782.20M Q2 2025: Approximately $367.39M Q1 2025: Approximately $154.63M Interpretation: The enormous variability is consistent with a portfolio using derivatives and tactical positioning and should not be interpreted as direct quarter-to-quarter movement in manager AUM.
WHY 13F IS NOT FUND NAV Form D Amount Sold: Measures securities sold through the private offering. ADV RAUM: Measures regulatory assets managed by the adviser. 13F Market Value: Measures specified reportable long U.S. securities and option positions at quarter end. Fund NAV: Measures the net value of fund assets after liabilities and derivative economics. Gross Exposure: Can be substantially greater than NAV when derivatives or leverage are used. Net Exposure: Can be much lower than gross exposure when longs are offset by shorts, puts or other hedges. These measures answer different questions and should never be substituted for one another.
OFFSHORE VEHICLE PENETRATION Latest Form D/A: September 18, 2026 Offering: Indefinite Exemption: Rule 506(b) Investment Manager: Hidden Lake Asset Management LP Management Fees: Customary management fees disclosed Important question: Investors should determine whether Onshore and Offshore feed into a common master portfolio or otherwise share substantially equivalent investment exposure.
WEBSITE / ENTITY PENETRATION Fund: Hidden Lake Onshore Fund LP Manager: Hidden Lake Asset Management LP Website address: 152 West 57th Street, Suite 920, New York, NY 10019 SEC address match: Confirmed Website investor-relations email: [email protected] Website telephone: 212-237-1280 SEC fund telephone: 212-237-1290 Manager CRD: 298209 Manager SEC File Number: 801-115096 Fund CIK: 0001750426 Manager 13F CIK: 0001750312 Signatory: Kevin Mok Identity consistency: Strong, subject to the minor distinction between website and filing telephone lines
SERVICE-PROVIDER EVIDENCE Public private-fund reporting derived from Form ADV identifies institutional service providers including PwC in an audit role, Morgan Stanley and Jefferies in prime-broker relationships and JPMorgan Chase Bank and Morgan Stanley in custody-related roles. Morgan Stanley also appears in fund-administration data. Investors should verify the current provider lineup directly from the latest audited financial statements and offering documents because service-provider arrangements can change between ADV filing dates.
CORE INVESTOR QUESTIONS Investors should obtain the current Onshore Fund NAV and reconcile it with the $22.92M cumulative Form D sales figure; determine the precise master-feeder or parallel-fund relationship among the onshore, offshore and any other Hidden Lake vehicles; obtain monthly and annual net returns, volatility, Sharpe ratio and maximum drawdown; measure gross, net and beta-adjusted exposure through time; separate directional option positions from hedges; identify leverage and margin arrangements; review counterparty exposure to prime brokers; obtain the current management fee and performance allocation; determine high-water-mark and hurdle provisions; analyze portfolio concentration by issuer, theme and factor; verify redemption frequency, notice periods, gates and side-pocket provisions; and review whether any fund-level performance differs materially between onshore and offshore investors because of tax or structural effects.
CORE RISKS Hidden Lake's strategy appears materially more complex than a simple long-equity fund. Puts, calls, shorts and other derivatives can magnify gains but also introduce nonlinear losses, volatility, timing risk, liquidity risk and counterparty exposure. A portfolio that appears hedged on a quarter-end 13F may have very different exposures during the quarter. Technology, growth and thematic positions can become highly correlated during market stress. Short positions can experience theoretically unlimited loss, while purchased or written options can decay rapidly or create substantial sensitivity to volatility. The manager's public filings provide strong transparency around identity and broad exposure but do not disclose investor-level net returns, drawdowns or complete portfolio economics.
SEC SNAPSHOT SEC File No.: 021-360134 Latest Filing: Form D/A Principal Office: 152 West 57th Street, Suite 920, New York, NY 10019 SEC Phone: 212-237-1290 Federal Exemption: Rule 506(b) Investment Company Act Exclusion: Section 3(c)(1) Offering Amount: Indefinite Amount Sold: $22,921,993 Investors: 18 First Sale: February 1, 2020 Minimum Investment Reported: $0 Offering Duration: More than one year Sales Commissions: $0 Finder Fees: $0 Related-Person Proceeds: $0 estimated Management Fee: Customary management fees disclosed Aggregate NAV Range: Declined to disclose Investment Manager: Hidden Lake Asset Management LP General Partner: Hidden Lake Fund GP LLC Signatory: Kevin Mok
PRIMARY EVIDENCE REVIEWED SEC Form D/A for Hidden Lake Onshore Fund LP filed September 18, 2026. Historical SEC Form D amendments for Hidden Lake Onshore Fund LP. SEC IAPD / Form ADV for Hidden Lake Asset Management LP, CRD 298209. Hidden Lake Asset Management official website. Q2 2026 Form 13F and recent quarterly 13F history for Hidden Lake Asset Management LP. September 2026 Form D/A for Hidden Lake Offshore Fund Ltd. Form ADV private-fund structure and service-provider disclosures. Public SEC-derived portfolio databases used to cross-check option and equity positions.
IMPORTANT FORM D NOTICE Hidden Lake Onshore Fund's $22,921,993 Form D amount sold should not be compared directly with Hidden Lake Asset Management's approximately $378.26 million regulatory AUM or its approximately $332.21 million Q2 2026 13F portfolio value. The first number is cumulative securities sold through one private offering, the second is adviser-level regulatory AUM and the third is a quarter-end subset of reportable U.S. securities and options. None alone establishes current fund NAV, gross exposure, net exposure or investor performance. Form D and Form ADV establish regulatory disclosures but do not constitute SEC approval of Hidden Lake, its strategy or its returns.