Splendid China Fund is best understood through its structure rather than by treating either feeder as a standalone portfolio. Bright Valley Capital Limited's Form ADV identifies Splendid China Master Fund as the Cayman master vehicle and lists Splendid China Offshore Feeder Fund and Splendid China US Feeder Fund as feeders into it. Cayman Islands Monetary Authority records independently show the master fund and both feeder vehicles entering the Cayman regulatory register in 2021. The U.S. securities filings tell the fundraising side of the same story: both feeders report a first sale on May 10, 2021, operate as indefinite Rule 506(b) hedge-fund offerings under Section 3(c)(1), require a $150,000 minimum investment and have continued filing amendments as subscriptions accumulate. The latest September 2026 disclosures show $491,042,798 sold to 59 investors in the offshore feeder and $82,200,000 sold to 11 investors in the U.S. feeder, producing approximately $573.24 million of combined cumulative Form D sales. That figure should not be labeled current AUM or master-fund NAV because subscriptions, redemptions, market performance, leverage and feeder-to-master accounting can all materially change the fund's actual net assets.
The manager itself is unusually transparent through regulatory records even though FilingDossier did not identify a clearly verified public corporate website. Bright Valley Capital Limited is based in Hong Kong at Unit 1129, 11/F, Admiralty Centre Tower 2, 18 Harcourt Road and files Form ADV under CRD 323827 and SEC exempt-reporting-adviser file 802-126919. The current fund filings identify Yusen Wang, Minyue Wang and Zehan Lai among the directors, while Albert Pang signs the Form D filings as Chief Compliance Officer. Hong Kong corporate and LEI records independently connect Bright Valley Capital to the same Admiralty address, and the same manager files quarterly Form 13F reports under CIK 0001965546. That combination of SEC Form D, Form ADV, 13F, CIMA registration and Hong Kong records provides a strong entity-verification chain even without relying on a marketing website.
The most distinctive 2026 evidence is the manager's dramatic change in publicly reportable U.S. securities exposure. Bright Valley's Q1 2026 Form 13F showed roughly $153.4 million across 13 reportable positions, including Intel common stock and calls, JOYY and other equity or option positions. By June 30, 2026, public 13F-derived data show the reportable book above $620 million across roughly 21 positions, more than four times the prior quarter. Intel became the largest visible position at roughly $219 million, while large SOXX and QQQ put positions, Intel calls, Atour Lifestyle, PDD Holdings, SanDisk and other semiconductor or China-linked securities were also visible. That profile suggests the fund cannot be reduced to a simple long-only China-equity product: the public book combines directional equities, options, sector hedges and global technology exposure. It also demonstrates why a large 13F value cannot automatically be treated as fund NAV—option notionals and gross long exposure can move sharply while the master fund's economic net exposure remains materially lower.
The name "Splendid China" should therefore be interpreted as a fund identity rather than proof that every position is a mainland Chinese security. Historical filings have shown Alibaba, JOYY, HUYA, PDD, New Oriental and Full Truck Alliance, but more recent quarters also include substantial Intel, semiconductor ETF and option exposure. The public holdings are consistent with a concentrated, opportunistic hedge-fund approach in which China-linked equities remain important but macro, semiconductor and global technology themes can dominate a quarter. Investors should obtain the private offering memorandum and current exposure report to determine the actual mandate, permitted geographic ranges, long/short limits, derivatives policy and whether the investment strategy has formally broadened since launch rather than inferring the mandate solely from the fund's name.
KEY FINDINGS AND STRUCTURE Splendid China Master Fund is the central Cayman master vehicle. Splendid China Offshore Feeder Fund, CIK 0001954871, reported $491,042,798 sold to 59 investors in its September 2026 amendment, while Splendid China US Feeder Fund, CIK 0001954502, reported $82,200,000 sold to 11 investors. Both offerings remain indefinite, both use Rule 506(b) and Section 3(c)(1), both report a May 10, 2021 first sale date and both list a $150,000 minimum investment. Combined cumulative sales are approximately $573.24 million, but the two Form D totals should not be added again to the master fund's assets because the master-feeder structure can otherwise create double counting. CIMA records confirm the Splendid China Master Fund and both feeders, while Bright Valley Capital's Form ADV explicitly links the three vehicles.
MANAGER, PORTFOLIO AND REGULATORY PENETRATION Bright Valley Capital Limited is a Hong Kong adviser reporting under CRD 323827 and SEC file 802-126919 as an exempt reporting adviser. Its business address, telephone number, directors and fund relationships align across Form ADV, Form D and Form 13F records. The manager's Q2 2026 13F reportable book exceeded $600 million after being approximately $153 million in Q1, with Intel becoming the dominant disclosed holding and additional visible exposure through SOXX puts, QQQ puts, Intel calls, Atour Lifestyle, PDD and other technology or China-linked securities. Historical quarters also show Alibaba, JOYY, HUYA, New Oriental and Full Truck Alliance. Because 13F excludes ordinary short positions, many derivatives, Hong Kong-listed and mainland-listed securities, cash and other instruments, it provides useful evidence of positioning but not a complete reconstruction of Splendid China's portfolio.
CORE DILIGENCE AND RISKS A prospective investor should obtain the current NAV of Splendid China Master Fund; reconcile the offshore and U.S. feeder ownership percentages; review subscriptions and redemptions since 2021; determine gross, net and beta-adjusted exposure; separate common-stock exposure from option notional and hedging; identify Hong Kong, mainland China, U.S. ADR and non-China allocations; obtain historical gross and net returns, volatility and maximum drawdown; review management fee, incentive fee, high-water-mark and liquidity terms; and confirm the auditor, administrator, custodian and prime brokers from current fund documents. Particular attention should be paid to China regulatory risk, ADR and VIE exposure, geopolitical restrictions, currency risk, concentrated technology positions and the possibility that derivatives cause reported 13F market value to change much faster than fund NAV.
SEC SNAPSHOT Master Fund: Splendid China Master Fund Manager: Bright Valley Capital Limited Manager CRD: 323827 Manager SEC File: 802-126919 Manager Status: Exempt Reporting Adviser Manager Address: Unit 1129, 11/F, Admiralty Centre Tower 2, 18 Harcourt Road, Admiralty, Hong Kong Manager 13F CIK: 0001965546
U.S. Feeder: SEC File No.: 021-473804 Latest Filing: Form D/A Latest Filing Date: September 11, 2026 Exemption: Rule 506(b) Aggregate NAV Range: Over $100,000,000 Sales Commissions: $0 Finder Fees: $0
Offshore Feeder: Latest Filing: Form D/A Latest Filing Date: September 11, 2026 Exemption: Rule 506(b) Aggregate NAV Range: Over $100,000,000 Sales Commissions: $0 Finder Fees: $0
Combined Feeder Form D Sales: $573,242,798
PRIMARY EVIDENCE REVIEWED September 2026 SEC Form D/A for Splendid China US Feeder Fund. September 2026 SEC Form D/A for Splendid China Offshore Feeder Fund. Bright Valley Capital Limited Form ADV, CRD 323827. Bright Valley Capital Form 13F filings through Q2 2026. Cayman Islands Monetary Authority fund-registration records for Splendid China Master Fund and both feeder funds. Hong Kong corporate and LEI records for Bright Valley Capital Limited. Public 13F-derived portfolio records used to cross-check current and historical U.S.-reportable positions.
IMPORTANT FORM D NOTICE The approximately $573.24 million figure is the sum of cumulative securities sold by the two feeder offerings and should not be described automatically as current Splendid China Master Fund NAV or current adviser AUM. Similarly, Bright Valley Capital's Q2 2026 13F value above $600 million represents reportable U.S. long securities and options, not the complete master-fund portfolio or its net exposure. Form D, Form ADV, Form 13F and Cayman registration establish regulatory disclosures and fund relationships; none constitutes SEC or CIMA approval of the strategy, investment performance or suitability.