INDEPENDENT VERDICT
Bin Yuan Greater China Fund has one of the strongest cross-verification trails in this research batch because the September 14, 2026 Form D amendments can be connected to a long-running master-feeder structure, a fully SEC-registered Hong Kong investment adviser, independently distributed European fund classes and identifiable Chinese public-equity positions. Two separate U.S. securities filings appeared within roughly nine minutes on September 14: Delaware-domiciled Bin Yuan Greater China Fund (US) LLC reported $79.864 million sold to nine investors, while Cayman-domiciled Bin Yuan Greater China Fund reported $49.404 million sold to 22 investors. Both use Rule 506(b), Section 3(c)(1), a $100,000 minimum, indefinite offering sizes and the same March 4, 2013 first-sale date. Those two reported amounts should not be added together and described as a $129.27 million fund. Bin Yuan's regulatory filings identify the vehicles as components of a master-feeder arrangement, while the investment adviser itself reported $888 million of regulatory AUM in March 2026, including $603 million managed for pooled investment vehicles. The Form D figures therefore describe U.S. exempt-offering subscriptions into particular entities, not total firm AUM or consolidated master-fund NAV.
The U.S. feeder is especially interesting because its legal presentation contains an unusual historical artifact. Bin Yuan Greater China Fund (US) LLC, CIK 0002036279 and SEC File No. 021-524892, is organized in Delaware and uses Corporation Trust Company at 1209 Orange Street as its legal address. Yet the Form D entity-type field describes it as "Other" and carries the description "Cayman Islands Exempted Company," despite the issuer name ending in LLC and jurisdiction being Delaware. The filing nevertheless gives a coherent economic record: first sale March 4, 2013, hedge-fund classification, Rule 506(b), Section 3(c)(1), $100,000 minimum, $79,864,434 sold, nine investors, no disclosed placement agent and zero reported commissions or finder fees. Ping Zhou appears as director of the investment manager and Bin Yuan Capital Limited is expressly identified as "Investment Manager to the Issuer." Frieda Luo signs the 2026 amendment as COO of the investment manager. The Delaware/Cayman entity-type mismatch should therefore be preserved as a regulatory data-quality issue rather than silently rewritten.
Nine minutes earlier, the Cayman vehicle filed its own amendment. Bin Yuan Greater China Fund, CIK 0002036280, reports Intertrust Corporate Services (Cayman) Limited at One Nexus Way, Camana Bay, Grand Cayman as its legal address and the same Hong Kong manager telephone number. It reports $49,404,032 sold to 22 investors, the same $100,000 minimum and the same March 4, 2013 first sale. Ping Zhou and Stefano Rodolphe Pizzo are listed as directors, while Bin Yuan Capital Limited is again the investment manager. The fund is categorized as a hedge fund and also relies on Rule 506(b) and Section 3(c)(1). These parallel filings are not merely two products sharing a brand: Bin Yuan's Form ADV documentation expressly identifies Bin Yuan Greater China Fund (US) LLC within a master-feeder arrangement and separately reports Bin Yuan Greater China Master Fund, Bin Yuan Greater China Fund and the U.S. LLC among the manager's private-fund structures. That regulatory evidence is strong enough to establish the architecture without guessing from the names.
THE FORM D NUMBERS ARE ONLY ONE SMALL WINDOW INTO A MUCH LARGER ADVISER
Bin Yuan Capital Limited is not an exempt-reporting adviser or a lightly documented offshore manager. IAPD lists the Hong Kong company under CRD 170109 / SEC file 801-79096 as an SEC-registered investment adviser, approved on January 22, 2014. Its March 11, 2026 Form ADV reports $888 million of discretionary regulatory assets under management across only six accounts. Of that, approximately $603 million is attributed to three pooled investment vehicles, $257 million to pension and profit-sharing plans, $16 million to state or municipal government entities and $12 million to other investment advisers. Approximately $872 million of the $888 million—about 98%—is attributed to non-U.S. persons. That profile is very different from a retail asset manager: a small number of large institutional mandates dominate the regulatory AUM base.
The same ADV also provides operational details that are particularly useful for diligence. Bin Yuan reports charging both asset-based and performance-based fees, says it manages portfolios on a discretionary basis, and discloses custody of approximately $21 million across eight clients. It states that qualified custodians send statements at least quarterly and that its pooled investment vehicles are audited annually by an independent public accountant, with audited financial statements distributed to investors. The adviser says neither it nor related persons act as the qualified custodian. Item 11 of the March 2026 filing shows no reported disciplinary disclosures for the adviser or supervised persons across the regulatory, criminal and civil categories covered by Form ADV. None of those facts verifies investment performance, but together they provide substantially more operational evidence than a Form D alone.
THE INVESTMENT BUSINESS CAN BE TRACED FROM PING ZHOU'S GE CAREER TO CURRENT CHINA EQUITY POSITIONS
Bin Yuan describes itself as a China-focused public-equity manager rather than a generic Greater China hedge fund. Founder and CIO Ping Zhou's biography says he spent 17 years with GE and ultimately managed approximately $5 billion at GE Asset Management across emerging-markets, China-equity and China-A-share portfolios. The firm says Zhou launched GE's China Equity Fund in 2002 and later established Bin Yuan with other former institutional investment professionals. Cicy Wu is listed as founding and managing partner and portfolio manager; Frieda Luo is COO; Lily Qian is partner and portfolio manager; and Tiffany Xue oversees trading risk and fund accounting. Bin Yuan's public materials emphasize fundamental research, direct company work, ESG integration and on-the-ground China access rather than quantitative trading or private-company investing.
That strategy leaves a visible footprint outside Bin Yuan's own website. Current public ownership datasets identify Hereford Funds – Bin Yuan Greater China Fund as holding approximately 9.91 million shares of Fangda Carbon Material as of March 31, 2026. Separate ownership data identifies Hereford Funds – Bin Yuan China Innovation Fund holding shares in Dalian Dalicap Technology, while Bin Yuan Capital has also appeared among significant holders of Xi'an Sinofuse Electric. These records do not reproduce the complete fund book and can change between reporting dates, but they independently support the central strategy claim: this is an actively managed portfolio of listed Chinese equities, not merely a fund carrying "Greater China" in its name.
Bin Yuan's 2026 research calendar provides a second strategy-level cross-check. Through the independently hosted Hereford fund platform, monthly Bin Yuan materials during 2026 covered aerospace, robotaxis, AI in healthcare, Insilico Medicine, gallium nitride and Innoscience, Montage Technology, MLCCs and power-inductor supply chains, Sunresin and "supernodes." That sequence is unusually useful because it demonstrates the actual research universe being discussed by the manager across semiconductors, advanced manufacturing, healthcare, autonomous mobility and industrial technology. The topics are also consistent with the individual Chinese public-equity holdings visible in external ownership databases. Investors can therefore verify not only that Bin Yuan exists, but that the investment research it publishes broadly corresponds to securities and sectors appearing in independently observable portfolios.
BIN YUAN IS ALSO DISTRIBUTED THROUGH REGULATED EUROPEAN FUND INFRASTRUCTURE
The private master-feeder complex is only part of the platform. Hereford Funds currently distributes Bin Yuan Greater China Fund through multiple Luxembourg share classes with distinct ISINs and published NAVs. For example, Class CB, ISIN LU1778255494, showed a NAV of 161.75 on September 17, 2026; multiple other USD, EUR and GBP classes are also published. Hereford simultaneously hosts current factsheets, monthly investment letters, PRIIPs KIDs, webinar material and a 2025 UN PRI assessment report. Bin Yuan China Innovation Fund is another separately distributed strategy on the same platform and is described as promoting environmental and social characteristics under SFDR Article 8.
There is an additional European institutional connection that is independent of the Hereford distribution arrangement. Spain's securities regulator CNMV lists Bin Yuan Capital Limited as an entity to which investment-management functions have been delegated and shows it as sub-manager of AZVALOR MANAGERS, FI, with the delegation registered on November 20, 2024. This matters because it provides regulator-level evidence that Bin Yuan is not solely managing proprietary Cayman vehicles; an external regulated European fund manager has formally delegated portfolio-management responsibility to it. That is a materially stronger institutional evidence point than an award, conference appearance or marketing testimonial.
THE REGULATORY FOOTPRINT SPANS THE U.S., HONG KONG AND MAINLAND CHINA
Bin Yuan's own regulatory history says the firm obtained Hong Kong SFC Type 9 asset-management authorization in December 2012 and Type 4 securities-advisory authorization in 2016, registered with the SEC as an investment adviser in 2014, and was recognized by the Asset Management Association of China in the same year. China's historical QFII register also records Bin Yuan Capital Limited among approved qualified foreign institutional investors, with Deutsche Bank shown as custodian and a December 14, 2020 approval date. These registrations fit the operating geography visible today: the manager's principal Hong Kong office is Room 1505, 15/F, 299QRC, 287–299 Queen's Road Central, Sheung Wan, while its Shanghai presence is shown at LJZ Riverside Center in Pudong.
The firm's current legal network extends beyond the primary Hong Kong adviser. The March 2026 ADV identifies Bin Yuan Asset Management (Shanghai) Ltd. and Bin Yuan Capital (Cayman) Limited as related entities; the Cayman affiliate carries separate SEC adviser file 801-79097. This provides a plausible regulatory/legal framework for a business that combines mainland research and market access, Hong Kong investment management, Cayman fund vehicles and U.S. private-offering access. It also helps explain why simply searching one company name produces different addresses and regulatory numbers across jurisdictions.
SEC FORM D SNAPSHOT — U.S. FEEDER
Legal Name: Bin Yuan Greater China Fund (US) LLC
CIK: 0002036279
SEC File No.: 021-524892
Latest Form D/A: September 14, 2026
Jurisdiction: Delaware
Legal Address: The Corporation Trust Company 1209 Orange Street Wilmington, Delaware 19801
Operating / Manager Contact: Hong Kong
First Sale: March 4, 2013
Industry: Pooled Investment Fund
Fund Classification: Hedge Fund
Federal Exemption: Rule 506(b)
Investment Company Act Exclusion: Section 3(c)(1)
Securities: Equity Pooled Investment Fund Interests
Offering: Indefinite
Amount Sold: $79,864,434
Investors: 9
Minimum: $100,000
Sales Commissions: $0
Finders' Fees: $0
Investment Manager: Bin Yuan Capital Limited
Manager Director: Ping Zhou
2026 Signer: Frieda Luo
Signer Capacity: COO of Investment Manager
Form D Entity-Type Anomaly: Issuer is Delaware and named LLC, but Form D "Other" description states Cayman Islands Exempted Company.
SEC FORM D SNAPSHOT — CAYMAN FUND
Legal Name: Bin Yuan Greater China Fund
CIK: 0002036280
Latest Form D/A: September 14, 2026
Jurisdiction: Cayman Islands
Legal Address: Intertrust Corporate Services (Cayman) Limited One Nexus Way Camana Bay Grand Cayman KY1-9005
First Sale: March 4, 2013
Fund Classification: Hedge Fund
Federal Exemption: Rule 506(b)
Investment Company Act Exclusion: Section 3(c)(1)
Offering: Indefinite
Amount Sold: $49,404,032
Investors: 22
Minimum: $100,000
Sales Commissions: $0
Finders' Fees: $0
Directors: Ping Zhou Stefano Rodolphe Pizzo
Investment Manager: Bin Yuan Capital Limited
2026 Signer: Frieda Luo
MASTER-FEEDER PENETRATION
Regulatory Private-Fund Complex: Bin Yuan Greater China Master Fund Bin Yuan Greater China Fund Bin Yuan Greater China Fund (US) LLC
U.S. Feeder Private Fund ID: 805-5386419992
U.S. Feeder Domicile: Delaware
Master-Feeder Status: Explicitly documented in Form ADV Schedule D
Regulatory Definition Applied: Feeder invests all or substantially all assets in a common master fund.
Research Significance: The Cayman and U.S. Form D totals should not automatically be added as unique underlying fund assets because feeder capital can ultimately represent interests in the same master portfolio.
ADVISER REGULATORY SNAPSHOT
Adviser: Bin Yuan Capital Limited
CRD: 170109
SEC File: 801-79096
SEC Status: Registered Investment Adviser
SEC Registration Effective: January 22, 2014
Latest Reviewed ADV: March 11, 2026
Regulatory AUM: $888,000,000
Accounts: 6
Discretionary RAUM: $888,000,000
RAUM Attributable to Non-U.S. Persons: $872,000,000
Pooled Vehicle RAUM: $603,000,000
Pension / Profit-Sharing Plan RAUM: $257,000,000
State / Municipal Entity RAUM: $16,000,000
Other Investment Adviser RAUM: $12,000,000
Fee Types: Asset-based Performance-based
Reported Regulatory Disclosures: None in current Form ADV Item 11
CUSTODY / AUDIT CONTROLS
Adviser Reports Custody: Yes
Amount Reported in Custody: Approximately $21 million
Clients: 8
Qualified Custodian Statements: Sent at least quarterly
Annual Independent Audits of Pooled Funds: Yes
Audited Statements Distributed to Investors: Yes
Adviser Acts as Qualified Custodian: No
Related Person Acts as Qualified Custodian: No
Research Significance: Provides regulator-filed evidence of current custody and private-fund audit procedures rather than relying solely on marketing statements.
ORGANIZATION AND TEAM
Founder / CIO: Ping Zhou, CFA
Prior Platform: GE Asset Management
Reported GE Career: 17 years
Reported Assets Under Responsibility at GE: Approximately $5 billion
Former Mandates Included: Emerging Markets China Equity China A Shares
Founding / Managing Partner: Cicy Wu, CFA
COO: Frieda Luo
Partner / Portfolio Manager: Lily Qian, CFA
Trading Risk & Fund Accounting Manager: Tiffany Xue
Primary Hong Kong Address: Room 1505 15/F, 299QRC 287–299 Queen's Road Central Sheung Wan, Hong Kong
Shanghai Presence: LJZ Riverside Center Pudong, Shanghai
STRATEGY EVIDENCE
Primary Asset Class: Chinese publicly listed equities
Geographic Universe: Mainland China Hong Kong Greater China opportunities
Investment Style: Fundamental Long-term Bottom-up research ESG integrated
2026 Research Topics Publicly Documented: Aerospace Robotaxis AI in healthcare Insilico Medicine GaN semiconductors Innoscience Montage Technology MLCCs Power-inductor supply chain Sunresin AI / computing supernodes
Research Significance: The public research stream is specific enough to compare with independently disclosed Chinese equity holdings.
INDEPENDENT HOLDINGS EVIDENCE
Fangda Carbon Material: Hereford Funds – Bin Yuan Greater China Fund Approximately 9,905,900 shares reported March 31, 2026 Approximately 0.26% ownership in the referenced dataset
Dalian Dalicap Technology: Hereford Funds – Bin Yuan China Innovation Fund 26,200 shares reported March 31, 2026
Xi'an Sinofuse Electric: Bin Yuan Capital appeared among institutional holders Approximately 1.87 million shares in a September 2025 ownership dataset
Important Qualification: Public ownership databases provide dated snapshots and do not represent the complete current portfolio.
EUROPEAN DISTRIBUTION / THIRD-PARTY VALIDATION
Platform: Hereford Funds
Strategy: Bin Yuan Greater China Fund
Example Share Class: Class CB
ISIN: LU1778255494
NAV at September 17, 2026: 161.75 USD
Public Documents Available: Factsheets Investment letters Webinar slides PRIIPs KIDs ESG material UN PRI assessment material
Separate Strategy: Bin Yuan China Innovation Fund
SFDR: Article 8 characteristics stated by fund platform
SPANISH REGULATORY CROSS-CHECK
Regulator: CNMV
Entity: Bin Yuan Capital Limited
Role: Entity to which investment-management function is delegated
Registration No.: 179
Registration Date: November 20, 2024
Sub-Managed Fund: AZVALOR MANAGERS, FI
Research Significance: Independent regulator-level evidence that a European regulated investment fund delegates investment management to Bin Yuan.
CROSS-BORDER REGULATORY FOOTPRINT
United States: SEC-registered investment adviser CRD 170109 SEC 801-79096
Hong Kong: SFC-regulated asset manager Type 9 asset management Type 4 advising on securities
Mainland China: AMAC-recognized asset-management presence stated by manager Shanghai affiliated entity Historical QFII approval
Historical QFII Entry: Bin Yuan Capital Limited Approval Date: December 14, 2020 Custodian: Deutsche Bank
Cayman: Greater China Master / feeder fund infrastructure Related adviser entity: Bin Yuan Capital (Cayman) Limited SEC File: 801-79097
FIGURES THAT MUST NOT BE COMBINED
$79.864M: Amount sold in U.S. feeder Form D
$49.404M: Amount sold in Cayman fund Form D
$603M: Adviser RAUM attributable to three pooled investment vehicles
$888M: Total Bin Yuan Capital regulatory AUM
Published Hereford NAVs: Share-class NAV measurements
These represent different legal entities, reporting regimes and measurement concepts.
Incorrect: "Bin Yuan Greater China Fund has $129.3M AUM because the two Form D amounts add to that number."
Incorrect: "Bin Yuan Greater China Fund has $888M AUM."
Better: The manager reports $888M regulatory AUM, while the two September 2026 Form D vehicles separately report $79.864M and $49.404M of securities sold within a regulator-documented master-feeder complex.
MATERIAL POINTS STILL REQUIRING FUND DOCUMENTS
Current Master Fund NAV: Not established by Form D
Current Consolidated Greater China Fund AUM: Not established by Form D
Exact Feeder Ownership of Master: Not publicly quantified in the reviewed filings
Gross Exposure: Not confirmed
Net Exposure: Not confirmed
Short Exposure: Not established despite Form D "hedge fund" classification
Leverage: Not confirmed
Derivatives: Not confirmed
Current Top-Ten Holdings: Should be verified from latest factsheet rather than inferred from dated ownership data
Management Fee by Share Class: Requires current offering document
Performance Fee: Manager uses performance-based compensation, but exact fund/share-class terms require current documents
Administrator: Corporate-services entities are visible, but administrator role should be confirmed from offering documents
Prime Broker: Not established in reviewed Form D
Current Auditor: ADV confirms annual independent audits but current fund-specific audit firm should be verified separately
INDEPENDENT ASSESSMENT
Bin Yuan Greater China Fund has an unusually complete institutional evidence chain. The manager has been SEC registered since 2014, reports $888 million of regulatory AUM, discloses institutional and pension clients, maintains Hong Kong and Shanghai operating infrastructure, and has a regulator-documented master-feeder arrangement. Separate Form D amendments verify the U.S. and Cayman vehicles; Hereford provides independently distributed daily-NAV fund classes and a long archive of investment materials; Spain's CNMV confirms a delegated portfolio-management mandate; and third-party ownership records show securities consistent with the manager's stated China public-equity strategy.
The most important analytical issue is measurement. The $79.864 million U.S. feeder Form D amount, the $49.404 million Cayman Form D amount, $603 million pooled-vehicle RAUM and $888 million adviser RAUM are not interchangeable. Because the U.S. LLC and Cayman fund participate in a master-feeder architecture, mechanically adding their Form D subscriptions risks double-counting capital that ultimately reaches the same master portfolio. The manager-level $888 million also includes institutional mandates outside the Greater China private-fund complex.
The second issue is that the Greater China strategy has far more observable substance than the Form D alone reveals. Ping Zhou's investment history, Bin Yuan's current sector research, European fund distribution, independently visible Chinese equity positions and third-party portfolio-management mandates all support the existence of a long-running institutional China-equity operation. At the same time, investors still need the latest master-fund financial statements and offering documents to establish current consolidated NAV, leverage, fees, liquidity and full portfolio concentration.
Finally, the U.S. feeder's Form D should be read literally rather than cleaned up for convenience: it is a Delaware issuer named "LLC," while its entity-type description says "Cayman Islands Exempted Company." That inconsistency does not outweigh the extensive independent evidence identifying the vehicle and manager, but it is precisely the kind of filing-level anomaly that a verification report should preserve instead of hiding.
Form D is a notice of an exempt securities offering and does not constitute SEC approval or endorsement of Bin Yuan Greater China Fund, Bin Yuan Capital Limited, Ping Zhou or any investment strategy. SEC registration, Hong Kong licensing, European delegation and master-feeder regulatory filings verify identities and regulatory relationships; they do not guarantee investment performance or eliminate China-equity market risk.