RESEARCH

SRS Long Opportunities SEC Form D Review 2026: $579.5M Sold as SRS Expands an 11-Year Long-Only Hedge Fund

SRS Long Opportunities SEC Form D Review 2026: $579.5M Sold as SRS Expands an 11-Year Long-Only Hedge Fund

INDEPENDENT VERDICT

SRS Long Opportunities, Ltd is not a new 2026 launch. It is a Cayman Islands hedge-fund vehicle whose SEC offering dates back to October 1, 2015 and remains indefinite more than a decade later. The September 18, 2026 Form D/A reports $579,511,318 of pooled investment fund interests sold to 40 investors, with a $100,000 minimum investment, Rule 506(b) exemption and Section 3(c)(7) Investment Company Act exclusion. SRS Investment Management, LLC is identified as investment manager, while Sabrina Foster, Matt Auriemma and David Zales appear as directors or related persons. The filing reports no sales commissions, finder fees or Item 16 related-person payments and states that the fund charges a management fee described in its private offering documents. The strongest conclusion is therefore not that SRS suddenly raised $579.5 million in 2026, but that an existing open-ended fund has accumulated that amount of reported securities sales over a long-running offering whose investor count has continued expanding.

THE FORM D HISTORY SHOWS A SLOW BUILD FOLLOWED BY FASTER RECENT CAPITAL GROWTH

The amendment sequence gives an unusually clean view of the vehicle's evolution. In September 2022 SRS Long Opportunities reported $312,181,406 sold to 23 investors; 2023 increased that to $331,679,154 and 24 investors; 2024 rose much more sharply to $396,941,935 and 28 investors; 2025 jumped again to $553,483,489 and 31 investors; and the latest 2026 amendment reaches $579,511,318 with 40 investors. The increase from 2025 to 2026 is approximately $26.03 million, but the investor count increased by nine, while the two-year increase from 2024 to 2026 is approximately $182.57 million. Those changes are more informative than treating every annual amendment as a new fundraising round because the issuer remains the same vehicle, the first-sale date remains 2015 and the total offering remains indefinite. Form D "amount sold" also should not be substituted for current NAV: subscriptions, redemptions, performance, withdrawals and transfers can cause a hedge fund's present asset value to differ materially from cumulative securities sales reported over the life of an offering.

SRS LONG OPPORTUNITIES IS ONLY ONE PIECE OF A MUCH LARGER SRS PLATFORM

SRS Investment Management is an SEC-registered New York investment manager founded by Karthik Sarma in 2006 after his earlier career at Tiger Global and McKinsey. Current Form ADV-derived data identify SRS as managing multiple private funds, including SRS Partners Master Fund, SRS Long Opportunities Master Fund, SRS Special Opportunities Master II and SRS Active Extension Master, with regulatory assets under management reported at approximately $13.9 billion as of mid-2026. Separately, SRS's June 30, 2026 Form 13F disclosed approximately $10.81 billion of U.S.-listed long securities across 33 positions. These numbers describe different things and must remain separate: `$579.5M` is the cumulative Form D amount sold by this particular offshore fund, `$13.9B` is manager-level regulatory AUM across SRS accounts and private funds, and `$10.81B` is the value of reportable public long positions disclosed on one quarter-end 13F. None of the three should be substituted for another.

AVIS BUDGET MAKES SRS A VERY UNUSUAL "LONG OPPORTUNITIES" MANAGER

The most distinctive part of SRS's public investment record is its exceptionally concentrated relationship with Avis Budget Group. SRS has disclosed large Avis holdings for years through Schedule 13D filings, while Karthik Sarma has served on Avis's board since 2020 and SRS President Jagdeep Pahwa is currently Executive Chairman. Avis's own 2026 proxy states that Pahwa has led SRS's private-equity business since 2006 and that Sarma founded SRS and previously worked at Tiger Global; the proxy also preserves the long-running cooperation agreement between Avis and SRS. SRS's June 2026 public 13F still showed Avis as its largest listed position, with roughly 17.43 million shares valued at approximately $2.58 billion at quarter end, followed by substantially smaller public positions including Netflix, Roblox and Credo Technology. That concentration means investors in an SRS vehicle need to understand not only market-selection skill but position concentration, board involvement, liquidity and the extent to which different SRS funds or accounts share exposure to the same names.

GOVERNANCE EXPOSURE AROUND AVIS IS ALSO PART OF THE RISK RECORD

SRS's relationship with Avis has generated litigation as well as investment gains. A shareholder derivative lawsuit filed in federal court in New Jersey challenged aspects of how SRS accumulated its Avis stake and how cooperation agreements between SRS and Avis affected corporate governance. In December 2025 the district court granted motions to dismiss the amended complaint. The matter did not disappear entirely: in August 2026 the court addressed the plaintiff's request to file a second amended complaint and administratively terminated that motion pending supplemental briefing on whether the proposed claims would be futile for lack of subject-matter jurisdiction. Those proceedings are allegations and procedural rulings, not findings that SRS committed wrongdoing. They are nevertheless relevant because SRS's unusually large ownership position and board representation create governance issues that do not normally arise when a hedge fund holds small passive stakes across hundreds of companies.

FINAL ASSESSMENT

SRS Long Opportunities is a useful example of why Form D data should be interpreted as a capital-history record rather than a current fund-balance statement. The latest SEC amendment shows $579.51 million sold to 40 investors under an indefinite offering that began in 2015, up from $553.48 million and 31 investors in 2025 and $396.94 million and 28 investors in 2024. The fund is managed inside a much larger SRS platform whose public 13F holdings alone were worth about $10.81 billion at June 30, 2026, while manager-level regulatory AUM is higher still. The distinctive investment story is SRS's willingness to run unusually concentrated positions and become deeply involved in corporate governance, most visibly at Avis Budget. Investors should therefore request current NAV, gross and net exposure, concentration limits, redemption terms, side pockets, fund-level Avis exposure, performance attribution, leverage, liquidity terms, management fee, incentive allocation and audited financial statements before interpreting the `$579.5M` Form D number as either current assets or current investor equity. Form D is an exempt-offering notice and is not SEC approval of SRS Investment Management, SRS Long Opportunities, its portfolio positions or any expected return.

SEC SNAPSHOT

ISSUER: SRS Long Opportunities, Ltd | CIK: 0001654164 | FORM D/A FILED: September 18, 2026

ENTITY: Cayman Islands Corporation | ORGANIZED: More than five years ago | PRINCIPAL OFFICE: c/o Maples Corporate Services Limited, Ugland House, Grand Cayman, Cayman Islands

INDUSTRY: Pooled Investment Fund - Hedge Fund | EXEMPTION: Regulation D Rule 506(b) | INVESTMENT COMPANY ACT EXCLUSION: Section 3(c)(7)

SECURITY: Pooled Investment Fund Interests | FIRST SALE: October 1, 2015 | OFFERING DURATION: More than one year

TOTAL OFFERING: Indefinite | AMOUNT SOLD: $579,511,318 | INVESTORS: 40 | MINIMUM INVESTMENT: $100,000

INVESTMENT MANAGER: SRS Investment Management, LLC | ADDRESS: One Bryant Park, 39th Floor, New York, NY 10036

RELATED PERSONS: SRS Investment Management LLC — Investment Manager / Promoter | Sabrina Foster — Director | Matt Auriemma — Director | David Zales — Director

MANAGEMENT FEE: Fund charges a management fee described in private offering documents | SALES COMMISSIONS: $0 | FINDER FEES: $0 | ITEM 16 RELATED-PERSON PAYMENTS: $0

FORM D CAPITAL HISTORY: 2022 — $312.18M / 23 investors | 2023 — $331.68M / 24 investors | 2024 — $396.94M / 28 investors | 2025 — $553.48M / 31 investors | 2026 — $579.51M / 40 investors

IMPORTANT FORM D DISTINCTION: These annual numbers are amendments to one long-running indefinite offering. They should not be described as five separate annual fundraising rounds.

MANAGER REGISTRATION: SRS Investment Management LLC | CRD 157630 | SEC 801-74148

MANAGER-LEVEL RAUM: Approximately $13.9B according to current Form ADV-derived data. This is manager-level regulatory AUM, not SRS Long Opportunities NAV.

LATEST 13F: Reporting period June 30, 2026 | approximately $10.81B of reportable U.S.-listed long holdings | 33 positions. 13F value is not total firm AUM and does not disclose shorts, many derivatives, private investments or cash.

LARGEST PUBLIC 13F POSITION: Avis Budget Group | approximately 17.43M shares | quarter-end value approximately $2.58B.

OTHER LARGE PUBLIC 13F HOLDINGS INCLUDED: Netflix | Roblox | Credo Technology | Tapestry. These are manager-level disclosed positions and should not automatically be attributed specifically to SRS Long Opportunities.

AVIS GOVERNANCE CONNECTION: Karthik Sarma has served as an Avis director since 2020 | Jagdeep Pahwa is SRS President and serves as Avis Executive Chairman | SRS and Avis operate under a cooperation-agreement framework disclosed in Avis SEC filings.

LITIGATION CONTEXT: A shareholder derivative lawsuit challenged aspects of SRS's Avis ownership and governance relationship. The district court dismissed the amended complaint in December 2025. In August 2026, a motion seeking leave to file a second amended complaint was administratively terminated pending additional jurisdictional briefing. Allegations are not findings of wrongdoing.

CORE INDEPENDENT FINDING: SRS Long Opportunities has evolved from a small offshore hedge-fund offering launched in 2015 into a vehicle reporting nearly $580M of cumulative securities sold to 40 investors, while its manager now oversees a substantially larger and highly concentrated public-equity portfolio. The key diligence issue is not merely capital growth but how fund-level liquidity, concentration and governance exposure interact with SRS's unusually large positions in companies such as Avis Budget.

Form D is an exempt-offering notice and is not an SEC-issued certificate, approval or endorsement.

Important Form D notice: A Form D filing is a notice filing for an exempt securities offering. It does not mean that the U.S. Securities and Exchange Commission has approved, licensed, endorsed, or verified the issuer or the offering. Readers should verify information through official SEC sources and conduct their own due diligence.
Verification note: SEC.gov and the relevant regulator's official records remain authoritative. This site's research is independent editorial content.