INDEPENDENT VERDICT
Trigram Fund LP is a relatively small but increasingly well-documented hedge fund whose public record goes beyond Form D. The Delaware partnership was formed in 2024, began selling interests on January 8, 2025 and reported $14.758 million sold to 20 investors in its September 16, 2026 amendment, with a $100,000 minimum investment. The filing classifies the issuer as a hedge fund, relies on Rule 506(b) and Section 3(c)(1), and identifies Trigram Partners LLC as the general partner. Wengang Ji is named as CEO and CIO of the general partner, while Beini Feng appears as CFO. The unusual feature is not simply the fund's size, but the combination of a concentrated partnership structure, public ownership disclosures in Hong Kong-listed companies and Ji's own description of a fee model designed around no management fee and a performance allocation above an absolute hurdle. That makes Trigram more researchable than many small private funds whose investment style and portfolio activity remain almost completely invisible.
THE FUND HAS GROWN STEADILY RATHER THAN THROUGH ONE LARGE CLOSE
The filing chronology shows measured capital accumulation. Trigram reported $8.662 million sold in January 2025, remained at that level in April 2025, increased to $9.282 million by October 2025, reached $11.682 million in January 2026 and then rose to $14.758 million in the September 2026 amendment. The latest filing also reports 20 investors, up from a vehicle that began with a relatively small capital base. This trajectory is important because it shows a fund adding capital over time rather than announcing a large target and remaining far below it. The offering remains indefinite and is intended to last more than one year, so the $14.758 million figure represents cumulative securities sold rather than a fixed final fund size. The filing also reports zero sales commissions, zero finder's fees and zero estimated payments from offering proceeds to the related persons named in Item 3.
THE INVESTMENT STYLE IS MORE VISIBLE THAN THE FORM D ALONE SUGGESTS
Wengang Ji has publicly described Trigram Fund as his primary investment partnership and said the structure was formalized after years of separately managed accounts that were later contributed into the fund. In a 2026 interview, Ji stated that Trigram does not charge a management fee and instead earns 25% of profits above a 6% annually compounded absolute hurdle, explicitly drawing inspiration from the early Buffett Partnerships. He also described an approach built around a small number of high-conviction investments rather than index-like diversification. That investor-controlled description is materially more informative than the SEC classification "Hedge Fund," but it should still be separated from audited fund documents: an interview can explain philosophy and fee intent, while the partnership agreement governs the actual economic terms.
HONG KONG DISCLOSURES PROVIDE RARE PORTFOLIO-LEVEL EVIDENCE
Trigram's public footprint becomes more distinctive through Hong Kong substantial-shareholder filings. Hong Kong Exchanges and Clearing records show Trigram Fund LP making voluntary ownership disclosures in Wah Sun Handbags International Holdings Ltd., stock code 02683. One April 2025 filing reported an increase from 4.1 million shares to 5.0 million shares and expressly stated that the disclosure was filed by Trigram Partners LLC on behalf of Trigram Fund LP. A later voluntary disclosure in December 2025 again named Trigram Partners and linked directly to trigrampartners.com. These records do not reveal the entire portfolio, but they independently confirm that Trigram is not merely a shell fund with regulatory filings: the partnership has taken identifiable public-equity positions and has voluntarily disclosed ownership activity outside the United States.
ONE REGULATORY CHANGE DESERVES ATTENTION
There is one important filing change that should not be overlooked. Trigram's January 2026 amendment relied on Investment Company Act Section 3(c)(7), while the September 2026 amendment instead checks Section 3(c)(1). The latest Form D therefore differs from the earlier filing in the private-fund exclusion selected. Section 3(c)(1) and Section 3(c)(7) are not interchangeable: they impose different investor and structural conditions. The filing itself does not explain why the exclusion changed, so the public evidence does not establish whether this reflects a deliberate fund restructuring, a correction to prior reporting or another legal interpretation. For diligence purposes, investors should confirm the current partnership documents, investor-eligibility requirements and whether the September 2026 amendment was intended to supersede the earlier 3(c)(7) status.
FINAL ASSESSMENT
Trigram Fund has a richer evidence trail than its approximately $14.8 million size might suggest. SEC filings establish the fund, GP and executive relationships; the filing chronology shows capital rising from $8.662 million in early 2025 to $14.758 million by September 2026; Wengang Ji has publicly described a concentrated Buffett-inspired structure with no management fee and a hurdle-based performance allocation; and Hong Kong ownership filings independently demonstrate actual public-equity investing activity. The main unresolved questions concern audited net performance, the full portfolio beyond disclosed Hong Kong positions, current fund NAV, custody and administration, and the reason for the 2026 shift from a 3(c)(7) to a 3(c)(1) exclusion. The SEC filing verifies an exempt hedge-fund offering, but it does not establish performance quality, valuation accuracy or suitability for any investor.
SEC SNAPSHOT Trigram Fund LP | CIK 0002047665 | Form D/A | File No. 021-535522 | Accession 0002047665-26-000002 | Delaware LP | Formed 2024 | Hedge Fund | Rule 506(b) | Section 3(c)(1) | First Sale January 8, 2025 | Filed September 16, 2026 | $14,758,000 Sold | 20 Investors | $100,000 Minimum | GP: Trigram Partners LLC | CEO / CIO: Wengang Ji | CFO: Beini Feng
FUNDRAISING CHRONOLOGY January 2025 — $8,662,000 sold April 2025 — $8,662,000 sold October 2025 — $9,282,000 sold January 2026 — $11,682,000 sold September 2026 — $14,758,000 sold Latest investor count — 20 Latest minimum investment — $100,000
WEBSITE / ENTITY PENETRATION Official domain: https://www.trigrampartners.com/ Fund CIK: 0002047665 CEO / CIO: Wengang Ji CFO: Beini Feng Fund / GP East Stroudsburg address consistency: Confirmed Hong Kong ownership disclosure by Trigram Partners on behalf of Trigram Fund: Confirmed Public portfolio evidence: Partial Public fee-structure description: Yes Current SEC-registered adviser status: PUBLIC STRATEGY EVIDENCE Style: Concentrated value-oriented public equity Management fee described by Wengang Ji: 0% Performance allocation described by Wengang Ji: 25% above a 6% annually compounded absolute hurdle Historical inspiration: Buffett Partnership-style economics Portfolio disclosure evidence: Hong Kong-listed equity positions Full portfolio publicly disclosed: No
CORE INVESTOR QUESTIONS Why did the fund change from Section 3(c)(7) in January 2026 to Section 3(c)(1) in September 2026 Was the change a legal restructuring, filing correction or investor-base change What is current NAV compared with the $14.758 million cumulative securities sold What are audited annual and since-inception net returns How concentrated is the portfolio in its five largest positions Which administrator, custodian and auditor service the fund Are the no-management-fee and 25%-above-6%-hurdle terms identical for all LPs What high-water-mark provisions apply What percentage of assets is invested outside the United States What liquidity and redemption terms apply during periods of market stress
PRIMARY EVIDENCE REVIEWED SEC Form D/A — Trigram Fund LP — September 16, 2026 SEC Form D/A — Trigram Fund LP — January 12, 2026 Historical SEC Form D filings — Trigram Fund LP Hong Kong Exchanges and Clearing substantial-shareholder disclosures — Trigram Fund LP Public interview with Wengang Ji discussing Trigram Partners, fund launch and investment structure Trigram Partners public website reference appearing in HKEX disclosures
IMPORTANT FORM D NOTICE Form D is a notice filing for an exempt securities offering. It does not mean the SEC has approved Trigram Fund LP, verified its performance, reviewed its portfolio for investment merit or confirmed the accuracy of investor-facing return claims. The latest filing's Section 3(c)(1) designation should be read from the current filing rather than assumed from earlier 3(c)(7) amendments.