INDEPENDENT VERDICT
Twin Lions Partnership LP is a long-running concentrated public-equity hedge fund whose investment activity is considerably more transparent than the average private partnership visible through Form D. The September 11, 2026 amendment reports an indefinite Rule 506(b) offering with $132,195,711 sold to 58 investors since a July 1, 2018 first sale. Four investors are reported as non-accredited, which Rule 506(b) can permit subject to applicable sophistication and disclosure requirements. Twin Lions GP LLC is the general partner, Twin Lions Management LLC is the investment manager, and Timothy Abbott signed the filing as Managing Member of the General Partner. Unlike many private funds where investors can verify the manager but not the portfolio, Twin Lions also files institutional holdings reports: its Q2 2026 Form 13F disclosed approximately $127.5 million across only nine reportable U.S. equity positions. That overlap between the fund's stated concentrated strategy and its actual regulatory holdings is one of the strongest verification features of the vehicle.
A CONCENTRATED VALUE STRATEGY THAT CAN BE CHECKED AGAINST 13F FILINGS
Twin Lions Management states publicly that it treats common stocks as ownership interests in businesses and looks for companies with attractive returns on capital, capable and shareholder-aligned management teams, and market prices materially below its estimate of intrinsic value. The firm says portfolios typically contain roughly five to fifteen investments, usually held for several years with relatively low turnover, with most exposure historically concentrated in North American micro-, small- and mid-cap stocks. The Q2 2026 13F fits that description closely. Nine reported holdings totaled about $127.54 million, with Bank OZK, Credit Acceptance, Cal-Maine Foods, Booking Holdings, Seaboard, Malibu Boats, Bank7, Synchrony Financial and Patrick Industries making up the reportable portfolio. Bank OZK represented roughly one-fifth of reported 13F value, while Credit Acceptance represented almost another fifth, illustrating the degree of concentration the manager is willing to accept when it believes valuation and business quality are compelling.
The holdings history also shows that "low turnover" does not mean no portfolio changes. Between Q1 and Q2 2026, Twin Lions substantially reduced Credit Acceptance and Malibu Boats, exited Dollar General, materially increased Booking Holdings and modestly added to Seaboard while maintaining positions such as Bank OZK and Cal-Maine. Malibu Boats is particularly useful as an independent cross-check because Twin Lions previously crossed the 5% beneficial-ownership reporting threshold, and Malibu's own shareholder disclosures listed Twin Lions Management with roughly 1.05 million shares, or approximately 5.5%, in 2025. A later August 2026 Schedule 13G amendment reflected a reduced stake. These filings provide evidence that Twin Lions does not merely report passive fund-level statistics; in certain concentrated positions it becomes a sufficiently large shareholder to trigger separate ownership disclosures.
TIM ABBOTT AND THE MANAGER'S REGULATORY FOOTPRINT
Twin Lions Management says Timothy Abbott founded the firm in 2018 after working as an analyst at Hound Partners and, before that, at CPMG. The official website identifies Dixon McDonald as Partner, COO and CCO, with prior experience at Goldman Sachs and Ambra Health, and Trey Ashmore as an investment analyst who joined in March 2026 after technology M&A work at Moelis and energy M&A at Evercore. The firm now operates from 1 Landmark Square in Stamford, matching the current Form D and 13F address. Earlier SEC filings document the firm's migration from 57 West 57th Street in New York to New Canaan and ultimately to Stamford, giving the partnership an unusually continuous public regulatory trail since 2018.
Twin Lions Management appears in Form ADV records under CRD 325314 and SEC file 802-127697. Available regulatory records identify it as an Exempt Reporting Adviser rather than a conventional SEC-registered RIA, an important distinction when describing the firm. Recent regulatory-data sources report approximately $215.9 million in regulatory assets under management across three accounts/private funds, while the latest Twin Lions Partnership Form D reports $132.2 million sold and the Q2 2026 13F reports $127.5 million of securities. These numbers measure different things and should not be substituted for one another: regulatory AUM covers the manager's reportable advisory assets, Form D measures securities sold through this exempt offering, and Form 13F covers only specified reportable U.S.-listed securities at quarter-end.
FORM D HISTORY SHOWS A MAJOR STEP-UP IN CAPITAL SINCE 2023
Twin Lions began its current Form D offering in July 2018 and has amended it repeatedly. Earlier filings showed a much smaller partnership: approximately $12.9 million was reported sold in October 2023. By September 2024, total amount sold had jumped to approximately $94.3 million; September 2025 showed about $95.1 million; and the September 2026 amendment reached $132.2 million. The latest increase is therefore approximately $37.1 million versus the prior year's Form D figure. That progression is meaningful, but it should not be described as annual investment performance or pure net inflows because Form D amounts can be affected by subscriptions, redemptions and filing methodology. What it clearly demonstrates is that the partnership's capital base is materially larger than it was only several years earlier.
The latest filing also reports four non-accredited investors among 58 total investors. Rule 506(b) can allow up to 35 non-accredited investors who satisfy the applicable sophistication requirements, although additional information requirements may apply when non-accredited purchasers participate. The existence of four such investors is therefore not inherently evidence of a compliance problem. It does, however, distinguish Twin Lions from many Section 3(c)(7) institutional funds whose investor base is restricted to qualified purchasers. Twin Lions instead claims Section 3(c)(1), consistent with a private partnership whose beneficial-owner structure is governed differently.
FINAL ASSESSMENT
Twin Lions Partnership has an unusually strong public verification profile for a private hedge fund. The Form D history verifies an eight-year offering, $132.2 million reported sold and a named investment manager; Form ADV establishes the manager's regulatory identity; the official website publishes a specific concentrated-value philosophy and management team; and quarterly 13F filings expose a substantial portion of the public-equity portfolio to independent scrutiny. The Q2 2026 portfolio's nine reported stocks align closely with the firm's stated preference for a small number of high-conviction investments. That does not validate the investment results, however. Form 13F excludes cash, shorts, many derivatives, foreign securities and other non-reportable positions and therefore cannot be treated as a complete fund portfolio or used alone to calculate fund performance.
Investors should focus on strategy risk rather than basic identity risk. A nine-stock reported portfolio can produce substantial idiosyncratic volatility if one or two investment theses fail. Credit Acceptance introduces consumer-credit and regulatory sensitivity; Bank OZK and Bank7 introduce banking and credit-cycle exposure; Malibu Boats and Patrick Industries are cyclical; Cal-Maine has commodity and biological risks; Booking depends on travel economics; and Seaboard is a diversified but operationally complex business. Investors should obtain audited fund returns, gross and net exposures, cash and short positions, fee structure, drawdown history, redemption terms and concentration limits before judging whether Twin Lions' long-term value approach fits their risk tolerance.
KEY FINDINGS Twin Lions Partnership LP has operated its current offering since July 2018. The latest Form D/A was filed September 11, 2026. The offering is indefinite. $132,195,711 is reported sold. 58 investors are reported. Four non-accredited investors are reported. The fund relies on Rule 506(b). The fund relies on Investment Company Act Section 3(c)(1). Twin Lions GP LLC is the general partner. Twin Lions Management LLC is the investment manager. Timothy Abbott founded Twin Lions Management in 2018. Twin Lions publicly describes a concentrated value-oriented public-equity strategy. The manager says portfolios typically contain approximately 5-15 investments. The Q2 2026 13F contained nine reportable holdings. Q2 2026 reported 13F value was approximately $127.54 million. Largest disclosed positions included Bank OZK, Credit Acceptance, Cal-Maine Foods, Booking Holdings, Seaboard and Malibu Boats. Twin Lions previously exceeded the 5% reporting threshold in Malibu Boats. The partnership's Form D amount sold increased from approximately $12.9 million in 2023 to $132.2 million in 2026. Form D amount sold, regulatory AUM and Form 13F value are different measurements and should not be treated interchangeably.
FORM D CAPITAL HISTORY 2018 — Initial Form D; approximately $2.22 million reported 2019 — additional capital reported 2020 — additional capital reported 2021 — annual amendment 2022 — additional capital reported July 2023 — additional capital reported October 2023 — total amount sold approximately $12.86 million September 2024 — total amount sold approximately $94.33 million September 2025 — total amount sold approximately $95.11 million September 2026 — total amount sold $132,195,711 Increase versus September 2025 — approximately $37.09 million
Q2 2026 PUBLIC 13F SNAPSHOT Bank OZK — approximately $25.3 million Credit Acceptance — approximately $22.7 million Cal-Maine Foods — approximately $17.8 million Booking Holdings — approximately $14.4 million Seaboard — approximately $14.3 million Malibu Boats — approximately $13.8 million Bank7 — approximately $12.5 million Synchrony Financial — approximately $6.4 million Patrick Industries — approximately $0.3 million Total reported 13F value — approximately $127.54 million Reported positions — 9
13F LIMITATION Form 13F does not disclose a hedge fund's complete economic exposure. It generally omits cash, many short positions, many derivatives, non-U.S. securities and other assets outside the reporting regime. The $127.54 million Q2 2026 13F figure is therefore not the fund's verified NAV and should not be compared mechanically with the $132.20 million Form D amount sold or the manager's regulatory AUM.
WEBSITE / ENTITY PENETRATION Official manager: Twin Lions Management LLC Official domain: twinlionsmgmt.com Fund: Twin Lions Partnership LP CIK: 0001745898 Manager CIK: 0002055318 Manager CRD: 325314 Manager SEC file: 802-127697 General partner: Twin Lions GP LLC Founder: Timothy Abbott Timothy Abbott / manager relationship: Confirmed Stamford operating address: Confirmed across Form D, 13F and official website Fund / manager reporting relationship: Confirmed through SEC 13F filings Public investment philosophy: Confirmed Concentrated 5-15 position strategy: Confirmed Q2 2026 holdings: Confirmed through 13F Malibu Boats beneficial ownership history: Confirmed through Schedule 13G and issuer filings Current complete fund NAV: Not established by Form D Short positions: Not visible in Form 13F Cash balance: Not visible in Form 13F Non-reportable foreign holdings: Not fully visible Management fee rate: Not disclosed in Form D Performance fee: Not disclosed in Form D Auditor: Not established through Form D Administrator: Not established through Form D Prime broker: Not established through Form D
CORE INVESTOR QUESTIONS What is Twin Lions Partnership's current NAV How does fund NAV differ from the $132.2 million Form D amount sold What management fee applies What performance allocation applies Is there a high-water mark What is Timothy Abbott's personal GP commitment What is the fund's net equity exposure Can the fund short individual equities Can it use options or other derivatives How much cash is normally held What percentage may be invested in one company What is the largest historical position weight What is the largest historical drawdown What has audited net performance been since July 2018 How has the strategy performed versus its chosen benchmark How does the manager control liquidity risk in small- and micro-cap positions How long would it take to liquidate major positions under normal volume What redemption frequency applies What notice period applies Are investor-level or fund-level gates permitted Why are four non-accredited investors included and what disclosure process applies to them How are securities valued if market liquidity becomes impaired Who independently administers and audits the partnership
CORE RISKS Highly concentrated equity portfolio Small- and mid-cap liquidity risk Company-specific fundamental risk Bank and consumer-credit concentration Cyclical consumer exposure Value-trap risk Long holding periods Potential divergence from broad equity indices Key-person dependence on Timothy Abbott Private-fund illiquidity Limited Form D disclosure of fees and service providers 13F does not show complete portfolio risk Potential volatility from large ownership positions in smaller public companies
SEC SNAPSHOT Issuer: Twin Lions Partnership LP CIK: 0001745898 SEC File No.: 021-316380 Latest Form: D/A Filed: September 11, 2026 First sale: July 1, 2018 Jurisdiction: Delaware Principal address: 1 Landmark Square, Suite 730, Stamford, CT 06901 Phone: 212-203-4428 Industry: Pooled Investment Fund / Hedge Fund Security: Equity / Pooled Investment Fund Interests Exemption: Rule 506(b) Investment Company Act exclusion: Section 3(c)(1) Offering amount: Indefinite Amount sold: $132,195,711 Remaining: Indefinite Investors: 58 Non-accredited investors: 4 Minimum investment reported: $0 Offering longer than one year: Yes Sales commissions: $0 estimated Finder's fees: $0 estimated Related-person use of proceeds: $0 estimated General partner: Twin Lions GP LLC Investment manager: Twin Lions Management LLC Signer: Timothy Abbott Signer title: Managing Member of the General Partner Management fees: Customary management fees disclosed
PRIMARY EVIDENCE REVIEWED SEC EDGAR — Twin Lions Partnership LP Form D and amendment history SEC EDGAR — Twin Lions Partnership LP Form 13F notice filings SEC EDGAR — Twin Lions Management LLC Form 13F holdings SEC EDGAR — Malibu Boats Schedule 13G filings involving Twin Lions SEC IAPD / Form ADV — Twin Lions Management LLC Twin Lions Management — official website, investment philosophy and team materials Public regulatory-data records for Twin Lions Management assets and private funds
IMPORTANT FORM D NOTICE Form D is a notice of an exempt securities offering. Filing with the SEC does not mean the SEC has approved, endorsed, audited or verified Twin Lions Partnership, Twin Lions Management, Timothy Abbott, any reported stock holding, investment strategy, valuation or expected return. Form 13F also shows only certain reportable securities and is not a complete statement of fund assets, liabilities, short positions or performance. Investors should review audited financial statements, fund offering documents, fee terms, liquidity provisions and complete exposure reports before investing.