Private company
TIGER GLOBAL MANAGEMENT LLC
American company, incorporated in Delaware. Summary from the record
Last updated Oct 21, 2026.
Overview
- HeadquartersDE1
Corporate structure
TIGER GLOBAL MANAGEMENT LLC sits at the top of its group. 32 entities, 3 countries on record. Switch between the flow chart and the network, and select any entity to see its details.
Major holders of TIGER GLOBAL MANAGEMENT LLC
- Charles Payson Coleman Owns 75% or more of Tiger Global Management LLC, since 03/2001 (Form ADV)
- TIGER GLOBAL MANAGEMENT LLC DE
- 1Life Healthcare Inc Stake · San Francisco, California
- 8x8 Stake · San Jose, California, United States
- Apollo Global Management Stake · New York, New York, United States
- ATRenew Inc. Stake
- Blend Labs, Inc. Stake · Novato, California
- Carvana Stake · Tempe, Arizona, United States
- Cerebras Stake · San Francisco
- Despegar Stake · São Paulo
- Dingdong (Cayman) Ltd Stake · George Town, Cayman Islands
- DoubleVerify Holdings, Inc. Stake · New York, New York
- Embark Technology Stake · San Francisco, California, United States
- Just Eat Takeaway.com N.V. Stake · P7
- Katapult Holdings, Inc. Stake · New York, New York
- Logistics Innovation Technologies Corp. Stake · Atlanta, Georgia
- Missfresh Ltd Stake · Beijing, China
- Nu Holdings Ltd. Stake · Cayman Islands
- Oklo Stake · Wilmington, Delaware, United States
- Pagaya technologies Stake · New York City
- Perimeter Solutions, Inc. Stake · Clayton, Missouri
- Procore Stake · Carpinteria
- Qualtrics Stake · Provo, Utah, United States
- RingCentral Stake · Wilmington, Delaware, United States
- Starry Group Holdings, Inc. Stake · Boston, Massachusetts
- Sumo Logic Stake · Wilmington, Delaware, United States
- TaskUs, Inc. Stake · Wilmington, Delaware, United States
- and 6 more
Built from major holders from Schedules 13D and 13G; stakes of 5% or more it reported on Schedules 13D and 13G (31 companies); owners and owned firms from Form ADV, the registration investment advisers file with the SEC. Each entity in the chart links to its source.
Investment adviser
TIGER GLOBAL MANAGEMENT LLC is registered with the SEC as an investment adviser. This is what it reports on Form ADV, the registration every adviser files and keeps current.
- Assets it manages$78.0B2 33 accounts, all with discretion
- Employees149 49 in investment advice or research
- ClientsPooled investment vehicles (other than investment companies and: 45 ($78.0B)
- How it is paidA percentage of assets under its management; Performance-based fees
- What it doesPortfolio management for pooled investment vehicles (other than investment companies)
- Holds client assetsNo
- RegistrationSEC 801-73973, CRD 160318 IAPD record
Who owns it
Owners of 5% or more as the firm lists them (Schedule A), and the owners of those owners up the chain (Schedule B).
- Charles Payson Colemanowns 75% or more, since 03/2001
Disciplinary record
The firm answered yes to 1 of the disciplinary questions on Form ADV (Item 11). A yes can concern the firm itself or an affiliate.
- Any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority has found the firm or an advisory affiliate to have been involved in a violation of investment-related regulations or statutes.
Each event as the firm describes it on its Disclosure Reporting Pages:
FINANSINSPEKTIONEN - SWEDISH FINANCIAL SUPERVISORY AUTHORITY ("SFSA") · Apr 20, 2020 · fine $365 · final
Allegations: SFSA ALLEGED THAT ON JULY 19, 2018, THE ADVISER SUBMITTED A NET SHORT FILING WITH RESPECT TO A SWEDISH ISSUER TEN MINUTES AFTER THE APPLICABLE FILING DEADLINE.
Sanction: Civil and Administrative Penalt(ies) /Fine(s)
How it ended: Decision
Detail: N/A
Summary: THE ADVISER PROVIDED DOCUMENTATION TO SFSA DEMONSTRATING THAT THE JULY 19, 2018 FILING WAS SUBMITTED TEN MINUTES LATE BECAUSE THE ADVISER'S OUTSIDE FILING PROVIDER EXPERIENCED TECHNICAL DIFFICULTIES. SFSA ACKNOWLEDGED THE EXTENUATING CIRCUMSTANCES AND ASSESSED A REDUCED FEE EQUIVALENT TO APPROXIMATELY $365. NO ADDITIONAL CONDITIONS WERE IMPOSED ON THE ADVISER. No Information Filed
Resolved: Apr 20, 2020
In its own words: the client brochure
Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 3/27/2026.3 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.
Item 4: Advisory business Services
Tiger Global Management, LLC (the “Adviser”), a Delaware limited liability company, is an investment adviser with its principal place of business in New York, New York. The Adviser commenced operations as an investment adviser on March 1, 2001, and is registered with the U.S. Securities and Exchange Commission (the “SEC”) as an investment adviser. Charles P. Coleman III is the managing member of the Adviser. The Adviser provides investment advisory services on a discretionary basis to (i) open-ended long/short private investment funds (collectively, the “Tiger Global Investments”), (ii) open-ended long focused private investment funds (collectively, the “Long Opportunities Fund”), (iii) openended long focused public/private private investment funds (collectively, the “Crossover Fund”), (iv) closed-end private investment funds (the “Private Equity Funds”), and (v) certain other client accounts, including co-investment vehicles (collectively with Tiger Global Investments, the Long Opportunities Fund, the Crossover Fund and the Private Equity Funds, the “Funds”). The Funds are private investment vehicles intended for sophisticated investors and institutional investors. The Adviser provides advice to client accounts based on specific investment objectives and strategies (see Item 8 for a discussion of the Adviser’s strategies). The Adviser does not tailor advisory services to the individual needs of clients. Clients may not impose restrictions on investing in certain assets or certain types of assets. The Adviser does not participate in wrap fee programs. The Adviser bases its advice to clients on the investment objectives and restrictions (if any) set forth in the applicable offering memorandum, organizational documents, limited partnership agreement, investment management agreement, and/or subscription agreements, as the case may be (collectively, the “Governing Documents”). As of January 1, 2026, the Adviser had approximately $54.7 billion of net assets under management, all of which are managed on a discretionary basis.
Item 5: Fees and compensation Fees
Asset-Based Compensation The Adviser is generally paid an investment management fee equal to (i) 1.5% per annum of the net assets of Tiger Global Investments, (ii) 1.25% per annum of the net assets of the Long Opportunities Fund, and (iii) 1.5% per annum of the net assets of the Crossover Fund. Investment management fees are charged each quarter in advance based on the client’s net asset value (including net unrealized appreciation or depreciation of investments and cash, cash equivalents and accrued interest) on the first day of the quarter. If a new investor account is established during a quarter or an investor makes an addition to its account during a quarter the investment management fee will be charged as of the effective date of the subscription or the date of the additional contribution and will be prorated for the number of months remaining in the quarter. The Adviser is generally paid an investment management fee equal to 1.75% - 2% per annum of the capital commitments of each Private Equity Fund. Such fees are subject to reduction at the end of the Private Equity Fund’s investment period, or an earlier date in certain circumstances, based on criteria set forth in the relevant Private Equity Fund’s partnership agreement. Investment management fees are charged to the Private Equity Funds each quarter in advance on the first day of the quarter. Performance-Based Compensation An affiliate of the Adviser is paid performance-based compensation, which is compensation that is based on a share of the realized or unrealized net profits or capital appreciation of the assets of a client account. The Governing Documents of each Fund provide the definitive terms of such compensation. The performance-based compensation for Tiger Global Investments is 20% of net profits and is subject to loss carryforward provisions, which may reduce such percentage to 10% until certain loss recovery thresholds are met. The performance-based compensation for the Long Opportunities Fund is 20% of net profits in excess of a hurdle return and is subject to an underperformance carryforward provision and a clawback provision. The performance-based compensation for the Crossover Fund is 20% of net profits and, except with respect to certain private assets, is subject to loss carryforward provisions, which may reduce such percentage to 10% until certain loss recovery thresholds are met. The performance-based compensation for the Private Equity Funds is between 20% and 25% of each Private Equity Fund’s net profits. In certain cases, the performance-based compensation varies within those ranges based on the performance of the relevant Private Equity Fund. The performance-based compensation for the Private Equity Funds is subject to a clawback provision that is more fully described in each Fund’s Governing Documents. Co-investment vehicles may be offered on a no-fee basis or subject to asset-based and/or performance-based fees that are lower than the fees described above.
Fee and Expenses Generally The Adviser waives and modifies its investment management fees and performance-based compensation in its discretion (see also below regarding “side letters”). Additionally, for purposes of any management fee or other discount, the Adviser may, in its sole discretion, aggregate an investor’s investment with those of its affiliates, related investment entities or advisory relationships. The Adviser will also establish and/or manage for compensation, additional investment funds and/or accounts in the future. Investment management fees are deducted and paid to the Adviser or its affiliates from the assets of the relevant client accounts. Performance-based compensation is reallocated to affiliates of the Adviser from the assets of the relevant client accounts. An investor may obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of a billing period. The amount refunded will be determined on a pro rata basis calculated based on the number of months remaining in the quarter. The Adviser and its affiliates have entered, and anticipate in the future entering into, agreements, or “side letters,” with certain prospective or existing investors whereby such investors are, or will be, subject to terms and conditions that are more advantageous than those set forth in the Governing Documents. For example, such terms and conditions may provide for special rights to make future investments in a Fund, including at differing or preferential economic terms; accommodating legal, regulatory and/or compliance-related investment restrictions and other legal, regulatory, tax and/or compliance-related matters; and such other rights as may be negotiated by the Adviser and such investors. The modifications are solely at the discretion of the Adviser. Neither the Adviser nor its supervised persons accepts compensation for the sale of securities or other investment products, including asset-based sales charges or service fees. The Funds incur expenses in accordance with the Funds’ Governing Documents, such as expenses in connection with, among other things, brokerage services discussed in Item 12; fund administration, including, but not limited to, fees associated with a third-party administrator, investor capital activity and document processing (including electronic document platforms and investor portals), and anti-money laundering and know-your-customer diligence; legal, tax advisory, accounting, auditing and other professional expenses; fees and expenses of any independent committees (as further discussed in Item 11) and any professional advisors retained by such independent committees; Fund counterparty and vendor diligence; regulatory and compliance filings and reporting expenses and filing fees relating to the Funds (including, but not limited to, Section 13, Section 16, Form PF, Hart-Scott Rodino, Form D and Blue Sky filings, Form 144, Bureau of Economic Affairs, Treasury International Capital, Alternative Investment Fund Managers Directive, Cayman Islands Monetary Authority filings and other non-US securities and market participation filings); fees paid to proxy voting and class action advisory firms; organizational expenses; expenses related to the offering of fund interests (including negotiation of agreements with investors as well as unreimbursed costs and expenses incurred in connection with any proposed transfer); insurance expenses (including Fund-related insurance expenses and fees for directors’ and officers’ liability insurance for the Funds and the Adviser); real property or personal property taxes on investments; commissions, underwriting fees, brokerage fees and depository fees; stock distribution agent fees; reverse break-up, termination and similar fees;
interest on margin accounts; financing costs and interest and other amounts paid in connection with borrowings of the Funds; fees incurred in connection with the maintenance of bank or custodian accounts; registrar and transfer agent fees, bank service fees; all research and investment-related expenses, including, but not limited to, fees for research reports and subscriptions, surveys and survey-related expenses, statistical and/or market data, Bloomberg feeds and other data sets, analytical tools (including artificial intelligence tools), cloud storage and data processing; expenses and fees for order and research management software and related portfolio and position-monitoring tools and services; expenses related to the creation or operation of special purpose vehicles (“SPVs”) or holding companies (including amounts paid to persons or entities which are essential to the establishment or operation of such SPVs and holding companies); custodial fees; legal, accounting, tax, audit, administrative, overhead and employee, consultant and other personnel salary, fees and expenses of companies and non-US offices formed for the purpose of facilitating and/or holding investments or other assets by the Funds; finder’s, placement, management, incentive, consulting and other fees or commissions paid to or costs (including travel and expenses) incurred by or in connection with third parties unaffiliated with the Adviser (including without limitation, investment advisers, consulting firms and independent advisers and consultants) involved in performing services as a director, consultant or other outsourced support provider to portfolio companies (including, but not limited to, corporate strategy, recruiting and human resource services), sourcing, investigating, evaluating and monitoring investment opportunities related to the acquisition, disposition, holding, monitoring and/or management of Fund assets; and other expenses related to the purchase, sale, exchange or other disposition, or transmittal of Fund assets (whether or not the purchase, sale, exchange or other disposition is ultimately consummated). The Funds also bear fees associated with outsourced activities, including, but not limited to, the fees of any independent appraisers and valuation agents. The Adviser is entitled under the Governing Documents to be reimbursed for some or all expenses that it or its related persons incur on behalf of the relevant Fund. The Adviser uses its best efforts to ensure that expenses (including Broken Deal Expenses (as defined below)) are allocated appropriately among the Funds. In certain instances, expenses are shared among the Funds based on the Adviser’s determination that such sharing is a fair allocation of the expenses. Such sharing may occur, for example, in situations in which more than one Fund is invested in the same position or SPV, research is commissioned by a Fund and may benefit the other Funds, and expenses for services or products that benefit multiple Funds or are necessary for conducting the business of multiple Funds. When determining the fair allocation of an expense, the Adviser may take into account multiple factors, including, but not limited to, (i) overall Fund ownership and/or participation in a particular investment or research area, (ii) position size, (iii) Fund assets under management, (iv) the relative benefits derived by the Funds, and/or (v) other factors the Adviser reasonably deems relevant in such determination. Notwithstanding the foregoing, the Adviser periodically determines that an expense borne by one Fund that ultimately benefits one or more other Funds should not be shared among the relevant Funds. This may occur, for example, when research conducted for one Fund is general in nature, research expenses relating to a new position are incurred and have already been incurred by the relevant Fund, and the Adviser subsequently determines that investment in the same position is also appropriate for one or more other Funds, or the relevant research expense is de minimis. In such cases, the other Funds will not generally reimburse the Fund that incurred the relevant research expenses. Additionally, from time-to-time, certain research expenses will be shared with one or more unaffiliated third parties. Each investor participating in a co-investment, including persons affiliated with the Adviser or its affiliate (including the Adviser on such person’s behalf, investment professionals (including the Funds’ portfolio manager) and non-investment professionals), will generally bear its pro rata
portion of the investment-related expenses (including Broken Deal Expenses) attributable to such investment. Co-investment vehicles have been or may in the future be structured on a no fee basis or subject to a asset-based compensation and/or performance-based compensation, which would be borne by such vehicle. The Adviser and/or its employees will generally bear a portion of the total costs and expenses associated with the unconsummated purchase of securities, including but not limited to, legal and other advisory fees and expenses associated with such “broken deals” (collectively, “Broken Deal Expenses”) where such expenses are material and relate to a transaction with a private company that was terminated after the execution of a term sheet. The portion borne by the Adviser and/or its employees, if any, will be determined by the Adviser in accordance with its policies and procedures. Furthermore, except for Broken Deal Expenses, neither the Adviser nor its employees (except in their capacity as investors in the Funds) will bear any portion of Fund research or other expenses (i) incurred in connection with the Adviser’s review of potential investment opportunities that are not ultimately pursued by a Fund or (ii) that are general in nature and/or do not otherwise directly relate to an investment in which an employee co-investor participated. Client account assets may be invested in money market mutual funds, exchange-traded funds (“ETFs”) or other private funds and/or registered investment companies. In these cases, the client will bear its pro rata share of the investment management fee and other fees of the fund, which are in addition to the investment management fee paid to the Adviser. A more detailed description of the expenses paid by each Fund is included in the relevant Governing Documents of each Fund.
Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks
The Adviser utilizes a variety of methods and strategies to make investment decisions and recommendations. The Adviser’s investment goal is to produce superior long-term, risk-adjusted capital appreciation through its portfolio of long, short, and private investments in global markets. The Adviser utilizes a fundamentally-oriented investment approach to source investment ideas across sectors, geographies and stages. The Adviser bases its investment strategy on fundamental research and company analysis and attempts to identify investment opportunities by recognizing emerging trends in different sectors and geographies. When analyzing a potential investment idea, the Adviser’s investment team may focus on a number of factors which may include the quality of the company’s management, the company’s market position relative to its principal competitors, the company’s products and product cycles, the potential earnings growth of the company, the company’s assets and cash flow, and the valuation of the company. Notwithstanding the above, the Adviser has broad and flexible investment authority and anticipates being opportunistic in implementing a Fund’s investment strategy. Accordingly, the Adviser reserves the right to invest in any security, derivative, Digital Asset, real property, financial instrument, asset class, sector, country or region or other instrument. An investment with the Adviser involves substantial risks that should be considered carefully. Certain risk factors that may be considered applicable to an investment with the Adviser are outlined below. Additional risk factors are outlined in the Governing Documents for the applicable Fund. It should be noted, however, that there may be other risks applicable to such an investment that are not identified but that might still result in material losses to investors. Although the Adviser may attempt to manage these risks through careful research, ongoing monitoring of investments, and appropriate hedging techniques, there can be no assurance that the securities and other instruments purchased will increase in value or that the Adviser’s accounts will not incur significant losses. Prospective investors should also consult their own legal, investment, tax, and other advisers, and the Governing Documents, as to whether an investment with the Adviser is appropriate for them. Material Risks (Including Significant, or Unusual Risks) Relating to Investment Strategies. Short Selling Risk. The Adviser’s public equity investment program includes the execution of short sales. In a short sale transaction, the Adviser sells a security it does not own in anticipation that the market price of that security will decline. While short sales may be useful under certain circumstances in the pursuit of potential profit opportunities and/or the mitigation of certain forms of risk, they may result in an unlimited loss of capital within a relatively short period of time. There is also a risk that the securities borrowed by the Adviser in connection with a short sale would need to be returned to the securities lender on short notice. If such request for return of securities occurs at a time when other short sellers of the subject security are receiving similar requests, a “short squeeze” can occur, wherein the Adviser might be compelled, at the most disadvantageous time, to replace the borrowed securities previously sold short with purchases on the open market, possibly at prices significantly in excess of the proceeds received earlier. From time to time, regulatory or legislative action taken by regulators around the world may restrict the ability of the Adviser’s clients to engage in short selling. To the extent that such restrictions are imposed in the future, it could impact the Adviser’s ability to carry out its investment program. Additionally, borrowing costs associated with short selling will increase the Adviser’s trading expenses and may be significant depending on the availability of the borrowed security and/or length of time held by the Adviser.
Leverage. The Funds utilize leverage through a variety of techniques, including margin financing and subscription or other credit facilities, which generally involves the borrowing of funds from brokerage firms, banks and other institutions in order to be able to increase the amount of capital available for investments. The Adviser has the authority to cause a client to employ the maximum leverage permitted by applicable law and regulation and by persons extending credit or otherwise providing leverage to the client. Although the use of leverage may enhance overall investment returns, internal rates of return and/or increase the number of investments that can be made, it may also substantially increase financing costs (including due to increasing interest rates) and the risk of loss to a Fund. Additionally, any borrowing will be subject to interest, transaction and other costs, which will be borne by the Funds and may not be recovered by the return on Fund investments. Lack of Diversification. The portfolios of the Funds may not be diversified among a wide range of issuers, geographic areas, industries or types of securities and other assets, including Digital Assets. Accordingly, the Funds may be subject to more rapid change in value than would be the case if the Adviser were required to maintain a wider diversification among types of securities and other instruments. To the extent a Fund concentrates its investments in a particular security, company, other asset, sector, country, or region, its investments may become more susceptible to fluctuations in value resulting from adverse business or economic conditions affecting that particular security, company, other asset, sector, country, or region. As a consequence, the aggregate return of a Fund may be affected adversely by the unfavorable performance of one or a small number of securities, companies, other assets, sectors, countries or regions in which the Fund has invested. In certain cases, a Fund may acquire a majority of a portfolio company, which could further increase the volatility of the Fund’s portfolio. Due Diligence Risks; Third-Party Research and Diligence Providers. Before making certain investments, the Adviser intends to conduct due diligence that it deems reasonable and appropriate based on the facts and circumstances applicable to the relevant investment. When conducting due diligence, investment research and making assessments regarding investment opportunities on behalf of the Funds, the Adviser relies on both internal and external resources. With respect to external resources used in the investment research and diligence process, the Adviser relies on a number of third parties, including, but not limited to, consultants and consulting firms, professional advisers and third-party research firms (collectively, “Third-Party Research and Diligence Providers”). Additionally, certain investment opportunities must be evaluated on an expedited basis or with limited access to information, which will substantially limit the amount of due diligence and research conducted by the Adviser and/or its Third-Party Research and Diligence Providers. Accordingly, there can be no assurance that the research and due diligence conducted by the Adviser and/or the Third-Party Research and Diligence Providers will be sufficient to reveal or highlight all facts relevant or material to a particular investment opportunity and, as a result, there is a risk that instances of malfeasance or fraud may not be uncovered and may result in the total loss of an investment. Further, there can be no assurance that such an investigation will result in an investment being successful. As noted above, the Adviser relies on Third-Party Research and Diligence Providers as part of the overall investment and diligence process. Reliance on such providers presents the risk that any interruption in the business of, or the Adviser’s relationship with, such providers, may have an adverse effect on a Fund’s investment program and performance. Additionally, the costs and expenses of such providers, which are substantial, are generally borne by the Funds, rather than the Adviser.
Hedging. There can be no assurance that a particular hedge is appropriate, or that certain risk is measured properly. While the Adviser may enter into hedging transactions to seek to reduce risk, such transactions may result in poorer overall performance and increased (rather than reduced) risk for the Adviser’s investment portfolios than if the Adviser did not engage in any such hedging transactions. Further, one or more Funds may not employ hedging at all or only in select circumstances, and this may cause such Funds’ performance to have greater volatility. Issuer-Specific Changes. Changes in the financial condition of an issuer or counterparty, changes in specific economic or political conditions that affect a particular type of asset or issuer, and changes in general economic or political conditions can increase the risk of default by an issuer or counterparty, which can affect an asset’s value. The value of securities of smaller, less wellknown issuers can be more volatile than that of larger issuers. Smaller issuers can have more limited product lines, markets, or financial resources. Interest Rate Risks. Generally, the value of fixed-income securities changes inversely with changes in interest rates. As interest rates rise, the market value of fixed-income securities tends to decrease. Conversely, as interest rates fall, the market value of fixed-income securities tends to increase. This risk is greater for long-term securities than for short-term securities. Changes in interest rates also have a material impact on the broader economy and financial markets, including the non-fixed income securities held by the Funds. Additionally, the Funds engage in borrowing and other forms of leverage, which are subject to interest expense, the costs of which will increase or decrease in connection with interest rates, and therefore impact the Funds’ returns. Relative Value Risk. In the event that the perceived mispricings underlying the Adviser’s relative value trading positions were to fail to converge toward, or were to diverge further from, relationships expected by the Adviser, client accounts may incur a loss. Importance of the Adviser. The authority to make decisions and to exercise business discretion on behalf of the Funds is delegated to the Adviser. The success of the Funds is therefore expected to significantly depend on the expertise of certain of the Adviser’s key personnel. Therefore, the death, incapacity or withdrawal of such personnel could materially adversely affect the Funds, including possibly triggering a material number of investor withdrawals or redemptions in Tiger Global Investments, the Long Opportunities Fund and/or the Crossover Fund or limiting the Private Equity Funds’ and/or the Crossover Fund’s ability to call additional capital for future investments. Business and Regulatory Risks of Alternative Asset Managers. Legal, tax and regulatory changes could occur that may adversely affect alternative investments, which are the focus of the Adviser’s strategies. The legal, tax and regulatory environment for alternative investments continues to evolve, and changes in such regulation may adversely affect the value of such investments in the Adviser’s strategies. In addition, the securities and futures markets are subject to comprehensive statutes, regulations and margin requirements. The SEC, other regulators and self-regulatory organizations and exchanges are authorized to take extraordinary actions in the event of market emergencies, and retain the right to suspend or limit trading in securities, which could expose client accounts to losses. The effect of any future regulatory change on the Funds could be substantial and adverse including, for example, increased compliance costs, the prohibition of certain types of trading and/or the inhibition of a Fund’s ability to pursue certain of its investment strategies as described herein.
Item 7: Types of clients
The Adviser’s clients consist of the Funds. The initial and additional subscription or capital commitment minimums are disclosed in the Governing Documents of the investment vehicles.
Item 6: Performance-based fees and side-by-side management Conflicts of interest
As noted in Item 5, the Adviser charges performance-based compensation. The Adviser and its investment personnel provide investment management services to multiple portfolios for multiple clients. The Adviser and/or its affiliates are entitled to be paid performancebased compensation by Tiger Global Investments, the Long Opportunities Fund, the Crossover Fund and the Private Equity Funds. Several of the Adviser’s investment personnel are compensated on a basis that includes a performance-based component. Certain client accounts have higher asset-based fees or more favorable performance-based compensation arrangements than other accounts. When the Adviser and its investment personnel manage more than one client account, and particularly in situations where the compensation arrangements differ among client accounts, a potential exists for one client account to be favored over another client account. To mitigate the risk of favoring certain clients over others, the Adviser has implemented policies and procedures intended to address conflicts of interest relating to the management of multiple accounts and the allocation of investment opportunities. In certain circumstances, the Funds have overlapping investment objectives and investment strategies. Accordingly, the Funds and other clients (as well as proprietary accounts of the Adviser, its affiliates or employees of the Adviser (including the Adviser on such person’s behalf, investment professionals (including the Funds’ portfolio manager) and non-investment professionals)) co-invest in many of the same securities and issuers. While it is anticipated that there will be significant overlap among certain Fund portfolios (in particular the long portfolio of Tiger Global Investments and the portfolios of the Long Opportunities Fund and the Crossover Fund), each Fund will invest pursuant to its focus, mandate, objective, liquidity, concentration, risk tolerance and other applicable parameters. There is no requirement that the Funds with similar investment strategies hold investments pro rata or otherwise hold or invest in securities on a "sideby-side" basis. The portfolio manager has broad authority to make investment decisions based on several factors such as risk/return opportunity, absolute performance potential and portfolio construction preferences. Allocations among the Funds generally will be based on whether the security or the issuer is publicly- traded. If the issuer has publicly-traded securities, Tiger Global Investments, the Long Opportunities Fund and the Crossover Fund generally will be given priority over the Private Equity Funds. If the issuer does not have any publicly- traded securities, the Private Equity Funds generally will be given priority with Tiger Global Investments next in line for such securities, followed by the Long Opportunities Fund, and the Crossover Fund having last priority. If securities are offered as part of an initial public offering, Tiger Global Investments will be given priority with the Long Opportunities Fund next in line for such securities, followed by the Crossover Fund, and the Private Equity Funds given last priority. Allocations among the Private Equity Funds generally will be based on the Private Equity Funds’ vintage, capital, strategies and restrictions. In general, allocations of new investments are made to the most recently launched Private Equity Fund. Allocations of Digital Assets will generally be based on the allocation methodology applicable to securities, with the determination of whether a Digital Asset is “publicly-traded” based on whether such Digital Asset is actively traded on an institutional exchange, as determined in the sole discretion of the Adviser. For purposes of this brochure, “Digital Assets” means cryptocurrencies,
decentralized application tokens, protocol tokens and other cryptofinance coins, tokens and digital assets and instruments that are based on blockchain, distributed ledger or similar technologies. With respect to follow-on investments (i.e., investments in the securities of a company already held by one or more Funds), the Fund(s) that made the prior investment(s) (including but not limited to co-investment vehicles) will have priority over other Funds and, to the extent that multiple Funds have an existing investment in such issuer, such Funds will generally have the right to participate in the follow-on investment on a pro rata basis based on existing holdings of such issuer. Any remaining opportunity will be subject to the allocation waterfall set forth above with respect to non-publicly traded equity securities (i.e., remaining private security opportunities will be offered to the most recent Private Equity Fund vintage first). The Adviser may allocate follow-on investments among the Funds in a manner different than as specified in this paragraph. In certain circumstances, more than one Fund will invest in the same issuer and/or the same security or other asset at the same time or at different times. In these situations, conflicts will arise because investment decisions made with respect to one Fund’s investment may have an adverse impact on the value of another Fund’s investment. In addition, in certain circumstances liquidity may only be offered to a particular level of an issuer’s capital structure, in which event only the Fund holding such security may have the ability to liquidate its position. The Adviser can take other actions that could be adverse to one or more Funds including, but not limited to, (i) participation in subsequent investments in a portfolio company at better terms than those offered to the other Fund, (ii) participation in subsequent investments in the portfolio company that dilute the other Fund's investment in the portfolio company, and (iii) secondary sales of investments in the portfolio company that can adversely impact the value and liquidity of the other Fund's investment in the portfolio company. On the other hand, subsequent investments by a Fund in a portfolio company in which another Fund has previously invested may increase the value of the other Fund’s investment or otherwise benefit the other Fund (e.g., by providing necessary capital to the portfolio company). Furthermore, rights held by a Fund may be exercised by the Adviser for the benefit of another Fund or client in accordance with the policies and procedures of the Adviser (e.g., follow-on rights, rights of first refusal). Finally, in certain circumstances, an investment by a Fund may restrict another Fund’s opportunity to participate in a particular investment opportunity due to legal and/or regulatory restrictions. This could result in the other Fund not participating in an investment that it otherwise would have, which may have an adverse impact on that Fund. The decision to sell a portfolio holding will be made in accordance with the investment mandates of each Fund. If more than one Fund is selling a publicly-traded security or exchange-traded Digital Asset, fully executed orders will be allocated on a pro rata, average price basis unless otherwise determined by the portfolio managers. In instances where the Funds invest in the same private security or Digital Asset and the investment in the private security or Digital Asset is partially realized, the disposition generally will be allocated at the same price pro rata based upon the ownership percentage of each participating Fund. Portfolio holdings sold at different times will likely be sold at different valuations and, as a result, each Fund may realize different returns as compared to the same investment held by another Fund. These variations in timing may be detrimental to a Fund. Additionally, from time to time one Fund may elect to distribute securities in kind to its investors where another Fund elects to sell the same securities in the open market. This could negatively impact the timing and price at which either the investors, the applicable Fund, or both, are able to sell their portfolio holdings, particularly where the distribution in kind is a material portion of the trading volume of the portfolio holdings.
As mentioned above, in addition to Tiger Global Investments, the Long Opportunities Fund, the Crossover Fund, and the Private Equity Funds investing in many of the same assets and/or issuers, the Adviser offers the right to participate, directly or indirectly, in investment opportunities available to such Funds, in whole or in part, to investors (including current or prospective investors), individuals, groups, partnerships, corporations and/or persons affiliated with the Adviser or its affiliates (including the Adviser on such person’s behalf, investment professionals (including the Funds’ portfolio manager) and non-investment professionals). Allocations of such opportunities are made in the sole discretion of the Adviser. The eligibility parameters and offering terms applicable to any such co-investment opportunity (e.g., fees and/or performance based compensation) will be established in the sole discretion of the Adviser. Co-investment opportunities are generally offered to a limited number of potential co-investors. The Adviser considers a wide range of factors when offering co-investment opportunities including, but not limited to, (i) whether a potential co-investor expressed interest in being presented with coinvestment opportunities in connection with an investment (or prospective investment) in a Fund; (ii) whether the potential co-investor has the financial resources to provide the requisite capital in a timely manner; (iii) whether a potential co-investor has a history of participating in opportunities and/or the sophistication and experience to promptly diligence and respond to the co-investment opportunity; (iv) the size of the potential co-investor’s commitment (or potential commitment) to one or more Funds and the overall strategic benefit to the Adviser and/or Funds alongside which such co-investment may be made; (v) the legal or regulatory constraints to which the proposed investment is expected to give rise; (vi) any tax efficiencies or adverse tax consequences related to the proposed co-investment; and (vii) other facts or circumstances that the Adviser deems appropriate or relevant in its sole discretion. These factors will lead the Adviser to favor some coinvestors over others with respect to the frequency with which such co-investors are offered coinvestment opportunities. A Fund may make investments with the expectation of offering a portion of such investment as a co-investment opportunity as described above. However, if the Adviser is not successful in offering a co-investment opportunity to one or more potential co-investors, in whole or in part, the applicable Fund may consequently hold a greater concentration and have more exposure in the related investment opportunity. Greater concentration and exposure to an investment opportunity could adversely affect the applicable Fund by amplifying potential losses if the investment underperforms. As set forth in its policies and procedures, the Adviser may deviate from the allocation guidelines set forth above based on a variety of factors, including but not limited to: (i) contribution and withdrawal activity of one or more Funds and the timing and size thereof; (ii) gross and net exposure considerations of one or more Funds; (iii) the amount of capital available or anticipated to be available for investment; (iv) liquidity considerations of one or more Funds; (v) to avoid a de minimis allocation to a particular account; (vi) tax considerations; (vii) regulatory, legal or contractual obligations or considerations; and (viii) the current portfolio composition of a particular client account.
Item 10: Other financial industry activities and affiliations Conflicts of interest
The Adviser and its management persons are not registered as broker-dealers and do not have any application pending to register with the SEC as a broker-dealer or registered representative of a broker-dealer. Neither the Adviser nor any of our management persons are registered as, and none of us have any application to register as, futures commission merchants, commodity pool operators, commodity trading advisors or associated persons of the foregoing entities. The Adviser and Tiger Global Performance, LLC, an affiliate of the Adviser, currently rely on exemptions from registration as commodity pool operators pursuant to U.S. Commodity Futures Trading Commission Regulation 4.13(a)(3). Tiger Global Performance, LLC; Tiger Global Management LLC, and Tiger Global PIP Management, LLC serve as the general partners of certain Funds. The Adviser does not recommend or select other investment advisers for our clients.
Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest
Client Transactions and Personal Trading The Adviser has adopted a Code of Ethics (the “Code”) pursuant to Rule 204A-1 under the Advisers Act that establishes the standard of business conduct that all related persons of the Adviser must follow. The Code comprises the following general principles which all related persons have agreed to uphold: to put the interests of the Adviser’s clients before their own interests, to conduct the Adviser’s business in a manner consistent with the Code, to avoid taking any inappropriate advantage of one’s position at the Adviser, to maintain confidentiality of all information concerning the Adviser’s business, and to provide full, fair, and accurate disclosure required by auditors, regulators, or other government entities. The Code also provides guidelines for related persons regarding (i) preclearing and reporting of securities transactions, (ii) engaging in activities outside of the Adviser’s business, (iii) documenting close personal or family relationships, and (iv) giving and receiving business-related gifts and providing and receiving entertainment. All of the Adviser’s personnel are also required to comply with applicable securities laws, and to report any violation or suspected violation of the Code to the Chief Compliance Officer. The Adviser or its related persons, in the course of their investment management and other activities, will come into possession of confidential or material nonpublic information about issuers, including issuers in which the Adviser, the Funds or their related persons have invested or seek to invest on behalf of clients. The Adviser’s related persons are prohibited from improperly disclosing or using such information for their own benefit or for the benefit of any other person, regardless of whether such other person is a client. The Adviser maintains and enforces written policies and procedures that are designed (i) to prohibit the communication of such information to persons who do not have a legitimate need to know such information and (ii) to ensure that the Adviser satisfies its obligations to clients and remains in compliance with applicable law. In certain circumstances, the Adviser or its related persons will possess certain confidential or material, nonpublic information that, if disclosed, might be material to a decision to buy, sell or hold a security, but the Adviser’s related persons will be prohibited from communicating such information to the client or using such information for the client’s benefit. In such circumstances, the Adviser will have no responsibility or liability to the client for not disclosing such information to the client (or the fact that the Adviser possesses such information), or not using such information for the client’s benefit, as a result of following the Adviser’s policies and procedures designed to provide reasonable assurances that it is complying with applicable law or regulation. Employees, principals, partners and members of the Adviser are permitted to invest in the Funds (including co-investment vehicles), and will have access to information that is not available to other investors and/or will have access to information on a timelier basis than other investors. This may raise potential conflicts between and among the Adviser, its personnel, such Fund, and the Fund’s underlying investors. Additionally, the Adviser and such persons will have an incentive to favor accounts in which they have a more proprietary interest, including in the allocation of investments, time and attention. The Adviser takes reasonable steps to manage these conflicts and to prevent the misuse of material information about the Funds and its investments. The Adviser or its related persons, as principal, may buy securities or other assets from or sell securities or other assets to its clients (see below regarding warehousing investment opportunities). This practice could create a conflict of interest because the Adviser or related person would have an incentive to buy securities or other assets from or sell securities or other assets to clients based on its own financial interests, rather than solely the interests of a client. The Adviser generally does not itself trade securities or other assets on a principal basis with
clients. To the extent that the Adviser and/or its related persons engage in principal transactions, any such transactions will comply with Section 206(3) of the Advisers Act. Additionally, certain clients have established “independent committees” and/or limited partner advisory committees, to consider and, on behalf of the underlying investors, approve or disapprove, to the extent required by applicable law (including Section 206(3) of the Advisers Act), principal transactions and certain other related-party transactions. As a general matter, the Adviser’s personnel are not permitted to engage in securities transactions for their personal securities accounts other than (i) in connection with the disposition of certain securities held prior to employment with the Adviser (upon pre-approval by the Adviser’s Compliance Team) and/or received in connection with an in-kind distribution by the Funds or other vehicles, and (ii) to invest in (A) open-end investment companies (mutual funds), (B) government securities, and (C) currency and certain limited Digital Assets. Upon pre-approval by the Adviser’s Compliance Team, the Adviser’s personnel are permitted to make investments in certain other securities such as ETFs, ETNs, pooled investment vehicles and private companies. The Adviser may make an exception to this general policy under certain circumstances. Further to the foregoing, there are expected to be instances where a Fund makes an investment into a private company or other asset in which an employee of the Adviser has previously made a personal investment. This presents a conflict of interest where the Fund’s investment results in an increase in the value of the employee’s personal investment. Additionally, employees of the Adviser may be permitted to invest in the securities of companies in which the Funds declined to invest or in which the Funds were otherwise unable to invest. In such instances, the Adviser’s employees may benefit from the research and diligence done on behalf of the Funds and for which the Funds ultimately bore the expense. In order to seek to minimize the foregoing conflicts, the Adviser’s personal trading policies and procedures require pre-approval of private securities transactions. As described in Item 6 above, the Adviser offers the right to participate, directly or indirectly, in investment opportunities of the Funds, in whole or in part, to investors (including current or prospective investors), individuals, groups, partnerships, corporations and/or persons affiliated with the Adviser or its affiliates (including the Adviser on such person’s behalf, investment professionals (including the Funds’ portfolio manager) and non-investment professionals). In addition to the co-investments described in Item 6, the Adviser permits certain of its and its affiliates’ investment professionals, including the portfolio manager of the Funds’, to make coinvestments in securities together with the Private Equity Funds and the Crossover Fund in accordance with policies that (i) set aside a certain portion of each investment for co-investment rights by such investment professionals and (ii) contain requirements regarding participation in follow-on investments. As a result of the offering of investment opportunities and the Adviser’s personal trading and co-investment policies described herein, there have been and will in the future occur situations in which the Adviser and/or the Adviser’s personnel invest in securities of an issuer or other assets in which a Fund has an existing investment or makes a future investment, and certain conflicts may arise for the Adviser and its personnel in these scenarios. Furthermore, as a result of setting aside a portion of investments made by the Private Equity Funds and the Crossover Fund for co-investment opportunities, there may be instances where such Funds do not receive their preferred allocation because of the portion of the investment that has been reserved for co-investment opportunities. Each investor participating in a coinvestment, including persons affiliated with the Adviser or its affiliate (or the Adviser on such person’s behalf), will generally bear its pro rata portion of the investment-related expenses (including Broken Deal Expenses) attributable to such investment. The Adviser and/or its employees will generally bear a portion of the total costs and expenses associated with the
unconsummated purchase of securities, including but not limited to, Broken Deal Expenses where such expenses are material and relate to a transaction with a private company that was terminated after the execution of a term sheet. The portion borne by the Adviser and/or its employees, if any, will be determined by the Adviser in accordance with its policies and procedures. The Adviser regularly selects service providers (“Service Providers”) for, or on behalf of, the Funds. The Adviser, the Funds and/or their employees are expected to directly or indirectly receive benefits from selecting certain Service Providers over others. For example, in certain cases, the Funds, the Adviser and/or their affiliates and/or their employees will be invested in the securities of these Service Providers (including, for example, custodians and/or exchanges of Digital Assets held by the Funds). In addition, certain Service Providers and/or their employees may be invested in one or more Funds. Fees earned by a Service Provider from the Funds may improve the financial situation of such Service Provider, which can indirectly benefit the Funds, the Adviser, and its employees. Additionally, the costs of the Funds’ Service Providers, including Third-Party Research and Diligence Providers (as described in Item 8) are borne by the Funds rather than the Adviser, and such costs are substantial. The Adviser periodically evaluates its Service Provider relationships, including Third-Party Research and Diligence Providers, in an effort to mitigate the potential conflict created by such relationships. From time to time, the Adviser directly and/or indirectly lends capital to one or more Funds by, among other methods, (i) warehousing investment opportunities, (ii) directly lending in connection with transaction funding, (iii) paying expenses on behalf of a Fund, and (iv) delaying the collection of management fees. In the case of warehousing investment opportunities, lending for transaction funding and bearing expenses on behalf of a Fund, to the extent the Adviser borrows funds in connection with such lending activity, the Adviser will pass through the relevant interest charges to the Fund. The Adviser will provide a copy of the Code to a client or prospective client upon request.
Item 12: Brokerage practices Conflicts of interest
The Adviser considers a number of factors in selecting a broker-dealer to execute transactions (or series of transactions) and determining the reasonableness of the broker-dealer’s compensation. Such factors may include, but are not limited to, the ability of the broker to provide liquidity, financial stability of the broker, the actual executed price of the security and the broker’s commission rates, research (including economic forecasts, investment strategy advice, fundamental and technical advice on individual securities, valuation advice, market analysis and access to industry analysts and management teams), responsiveness to the Adviser, custodial and other services provided by such brokers and/or dealers that are expected to enhance the Adviser’s general portfolio management capabilities, the size and type of the transaction, the difficulty of execution and the ability to handle difficult trades, the operational facilities of the brokers and/or dealers involved (including back office efficiency), ability to maintain confidentiality; and the ability to handle a block order for securities and distribution capabilities. In selecting a broker- dealer to execute transactions (or series of transactions) and determining the reasonableness of the broker-dealer’s compensation, the Adviser need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. It is not the Adviser’s practice to negotiate “execution only” commission rates, thus a client may be deemed to be paying for research, brokerage or other services provided by a broker-dealer which are included in the commission rate. The Adviser evaluates the appropriateness of brokerage commissions on an ongoing basis. The Adviser receives research or other products or services other than execution from a brokerdealer and/or a third-party in connection with client securities transactions. This is known as a “soft dollar” relationship. The use of commissions arising from a Fund’s investment transactions for services other than research and brokerage will be limited to services that would otherwise be a Fund expense. Research services within Section 28(e) of the Exchange Act may include, but are not limited to, research reports (including market research); certain financial newsletters and trade journals; software providing analysis of securities portfolios; corporate governance research and rating services; attendance at certain seminars and conferences; discussions with research analysts; meetings with management teams; consultants’ advice on portfolio strategy; data services (including services providing market data, company financial data and economic data); advice from broker-dealers on order execution; and certain proxy services. Brokerage services within Section 28(e) of the Exchange Act may include, but are not limited to, services related to the execution, clearing and settlement of securities transactions and functions incidental thereto (i.e., connectivity services between an adviser and a broker-dealer and other relevant parties such as custodians); trading software operated by a broker- dealer to route orders; software that provides trade analytics and trading strategies; software used to transmit orders; clearance and settlement in connection with a trade; electronic communication of allocation instructions; routing settlement instructions; post-trade matching of trade information; and services required by the SEC or a self-regulatory organization such as comparison services, electronic confirms or trade affirmations. As required by Section 28(e) of the Exchange Act, the Adviser reviews and evaluates its soft dollar practices in order to determine, in good faith, whether, with respect to any research or other products or services received from a broker-dealer, that the commissions used to obtain those products and services were reasonable in relation to the value of the brokerage, research or other products or services provided by the broker-dealer. This determination will be viewed in terms of either the specific transaction or the Adviser’s overall responsibilities to the accounts or portfolios over which the Adviser exercises investment discretion.
From time to time, research and brokerage services obtained by the use of commissions arising from a client’s portfolio transactions will be used by the Adviser in its other investment activities, including, for the benefit of other client accounts, which may be expected to pay less in brokerage commissions and/or generate fewer soft dollars. Accordingly, a client will not necessarily, in any particular instance, be the sole direct or indirect beneficiary of the research or brokerage services provided. The Adviser does not seek to allocate soft dollar benefits to client accounts proportionately to the soft dollar credits the accounts generate. As a result of client brokerage commissions, the Adviser and/or its related persons acquire research and brokerage related services. Such services may include, among other things, the provision of information on economic trends or conditions, political developments, industries, groups of securities, individual countries, and individual companies, as well as post-trade brokerage services or communication services related to the execution, clearing, and settlement of transactions. The Adviser has entered into “client commission arrangements” pursuant to which the Adviser may execute transactions through a broker-dealer and request that the broker-dealer allocate a portion of the commissions or commission credits to another firm that provides research and other products to the Adviser. The clients primarily pay for research services directly, rather than through commissions arising from the clients’ investment transactions. In some instances, the Adviser obtains a product or service that is used, in part, by the Adviser for Section 28(e) eligible purposes and, in part, for other purposes. In such instances, the Adviser will make a good faith effort to determine the relative proportion of the product or service used to assist the Adviser in carrying out its investment decision-making responsibilities and the relative proportion used for administrative or other purposes outside Section 28(e). Such determination will be made based on an evaluation of the research and non-research uses of the product. The proportion of the product or service attributable to assisting the Adviser in carrying out its investment decision-making responsibilities will be paid through brokerage commissions generated by client transactions and the proportion attributable to administrative or other purposes outside Section 28(e) will be paid for by the Adviser from its own resources. The determination of the appropriate allocation of “mixed use” products and services creates a potential conflict of interest between the Adviser and clients. From time to time the Adviser may participate and has in the past participated in capital introduction programs arranged by broker- dealers, including firms that serve as prime brokers to one or more Funds or recommend these Funds as an investment to clients. The Adviser may place and has in the past placed client portfolio transactions with firms which (i) make or have made such recommendations or provided capital introduction opportunities or (ii) refer or have referred investors to the Funds, if the Adviser determines that it is otherwise consistent with seeking best execution. In no event will the Adviser select a broker-dealer as a means of remuneration for recommending the Adviser or any other product managed by the Adviser (or an affiliate) or affording the Adviser with the opportunity to participate in capital introduction programs. The Adviser will also use brokers affiliated with certain investors in the Funds, if the Adviser determines that it is otherwise consistent with seeking best execution. The Adviser, when consistent with market conditions, purchases or sells the same security for clients contemporaneously and using the same executing broker. Such bunched or aggregated orders may enable the Adviser to obtain for clients a more favorable execution and reduced brokerage costs. When an aggregated order is filled completely, the Adviser allocates the securities purchased or proceeds of sale pro rata (based on order size) among the participating
accounts. Order sizes may be expressed by the Adviser’s portfolio manager in several manners, including, but not limited to, as a percentage of Fund NAV, gross dollars, and/or “pro rata” (i.e., an equivalent percentage of the participating Funds’ NAVs). The Adviser’s Compliance Team periodically reviews aggregated allocations. Adjustments or changes may be made under certain circumstances, such as to avoid holding odd lots or excessively small numbers of positions. If the order at a particular broker is filled at several different prices, through multiple trades, generally all such participating accounts will receive the average price and pay the average commission, subject to odd lots, rounding, and market practice. If an aggregated order is only partially filled, the Adviser’s procedures provide that the securities or proceeds are to be allocated in a manner deemed fair and equitable to clients. Depending on the investment strategy pursued and the type of security, this may not result in a pro rata allocation to all participating clients. To the extent permitted by applicable law and the applicable Governing Documents, the Adviser may effect “cross transactions” between the Adviser’s and/or its client accounts in which one client will purchase securities held by another client. In certain circumstances, cross transactions may be approved by one or more independent committees and/or limited partner advisory committees on behalf of underlying investors (as further discussed in Item 11). The Adviser will direct clients to enter into such transactions only when the transactions are consistent with the best interests of both clients and at a price that the Adviser believes constitutes best execution for both clients. The Adviser does not receive any commission or commission equivalent in connection with these transactions. If it appears that a trade error has occurred, the Adviser will review the relevant facts and circumstances to determine an appropriate course of action. To the extent that a trade error occurs, the Adviser’s procedure is to ensure that clients are treated fairly. The Adviser has discretion to resolve a particular error in an appropriate manner that is consistent with the above stated policy. Notwithstanding the foregoing, any financial gains or losses resulting from trade errors are generally borne by the client and underlying investors (as more fully described in the Governing Documents). The Adviser does not currently participate in directed brokerage.
Item 14: Client referrals and other compensation Conflicts of interest
The Adviser compensates third-party solicitors or other promoters for referrals of private fund investors. The Adviser’s arrangements with third-party solicitors or other promoters may vary. Any compensation paid pursuant to these arrangements creates an incentive for the third-party solicitor or other promoter to recommend the Adviser’s private funds, resulting in a material conflict of interest. In addition, as stated in Item 12, the Adviser may enter and has in the past entered into capital introduction agreements with certain financial institutions under which the financial institution does not receive compensation for this service. The Adviser does not currently select or recommend broker-dealers based on whether the Adviser or its related persons receive client referrals.
Item 9: Disciplinary information
This Item is not applicable.
Item 13: Review of accounts
For Tiger Global Investments, the Long Opportunities Fund and the Crossover Fund, the portfolio manager is responsible for reviewing trading data on a continuous basis to determine whether securities positions or positions in other assets should be maintained in view of current market conditions. Similarly, for each of the Private Equity Funds, the portfolio manager is responsible for monitoring the portfolio on a continuous basis. Such matters reviewed include specific securities and other assets held, adherence to applicable investment guidelines, and the performance of each client account. The Adviser uses independent third parties to conduct financial audits of the accounts of its clients. The Chief Compliance Officer reviews certain other aspects of regulatory compliance. The timing of such reviews is dependent upon the purpose of the review and other factors. The Adviser provides investors with written reports on a periodic basis that include, among other things, the net asset value or balance of the investor’s account. Such written reports are provided pursuant to the terms of the Governing Documents.
Item 15: Custody
Client assets are generally held in custody by an unaffiliated qualified custodian. Please also refer to Item 8 regarding Digital Assets. Fund investors do not receive account statements from the custodian; rather, the Funds are subject to an annual audit, and audited financial statements are distributed to each Fund investor. The Adviser and affiliates of the Adviser are deemed to have custody of the assets of pooled investment vehicles and intends to comply with Rule 206(4)-2 under the Investment Advisers Act by meeting the conditions of the pooled vehicle annual audit provision.
Item 16: Investment discretion
The Adviser provides investment advisory services on a discretionary basis to clients. Prior to assuming full discretion in managing a client’s assets, the Adviser enters into an investment management agreement or other agreement that sets forth the scope of the Adviser’s discretion. Any limitations on the Adviser’s discretionary authority are described in the relevant Governing Documents.
Item 17: Voting client securities
The Advisers Act generally requires investment advisers to vote all proxies within their authority. When the Adviser has discretion to vote the proxies of its clients, it will seek to vote those proxies in the best interest of its clients and in accordance with the Adviser’s policies and procedures. The Adviser will generally vote proxies for clients with the same or substantially similar investment strategies and objectives in the same way. The Adviser has retained an independent third-party proxy voting service (the “Proxy Voting Service”) to assist it in voting proxies with respect to client securities. The Adviser monitors the Proxy Voting Service to ensure that proxies are being voted properly and that appropriate records are being retained. The Adviser will periodically review the proxy voting policies, procedures and methodologies, research, conflicts of interest, and overall competency and capabilities of the Proxy Voting Service. The Adviser does not vote proxies where the cost of doing so, in the opinion of the Adviser, would exceed the expected benefits to the client. The Adviser will generally vote proxies in accordance with the recommendations of the Proxy Voting Service; however, where the Proxy Voting Service’s recommendations on material matters are not in alignment with the relevant issuer’s management and the Adviser believes that the particular vote is material to the relevant client’s position, the Adviser will consult with the portfolio manager and/or relevant analyst to determine whether it is in a client’s best interest to deviate from the recommendation of the Proxy Voting Service. Upon request, the Adviser will provide a client with a copy of its proxy voting policies and procedures and information about how the client’s proxies were voted.
Item 18: Financial information
This Item is not applicable.
Appendix: Item 2. Material Changes The Adviser filed an annual update of the brochure on March 31, 2025. The Adviser has made routine updates and clarifying changes to the brochure, none of which are material changes since the Adviser last filed an annual update to the brochure. Investors and prospective investors, however, should review the entirety of this brochure carefully.
Filings
23 filings to the SEC since October 2021: 23 other. The latest 20:
- Aug 31, 2026N-PX EDGAR
- Aug 14, 202613F-HR EDGAR
- May 15, 202613F-HR EDGAR
- Feb 17, 202613F-HR EDGAR
- Nov 14, 202513F-HR EDGAR
- Aug 29, 2025N-PX EDGAR
- Aug 14, 202513F-HR EDGAR
- May 15, 202513F-HR EDGAR
- Feb 14, 202513F-HR EDGAR
- Nov 14, 202413F-HR EDGAR
- Aug 30, 2024N-PX EDGAR
- Aug 14, 202413F-HR EDGAR
- May 15, 202413F-HR EDGAR
- Feb 14, 202413F-HR EDGAR
- Nov 14, 202313F-HR EDGAR
- Aug 14, 202313F-HR EDGAR
- May 15, 202313F-HR EDGAR
- Feb 14, 202313F-HR EDGAR
- Nov 14, 202213F-HR EDGAR
- Aug 15, 202213F-HR EDGAR
The 23 filings since October 2021 can be filtered by form type and year here when JavaScript is on.
Every filing from the last five years, summarized. The full record is on SEC EDGAR.
Stakes it holds
TIGER GLOBAL MANAGEMENT LLC has told the SEC it owns more than 5% of 31 companies, latest first (Schedules 13D and 13G).
- CerebrasSCHEDULE 13G May 22, 20264
- WealthfrontSCHEDULE 13G Feb 17, 20265
- ZKH Group LtdSCHEDULE 13G/A Feb 14, 2024 to Nov 14, 20256
- ATRenew Inc.SCHEDULE 13G/A Dec 2, 2022 to Aug 14, 20257
- OkloSC 13G/A Feb 14, 2024 to Aug 14, 20248
- Pagaya technologiesSC 13G/A Jul 5, 2022 to Aug 4, 20239
- Weave Communications, Inc.SC 13G/A Nov 17, 2021 to Jun 12, 202310
- 1Life Healthcare IncSC 13G/A Feb 14, 2022 to Feb 14, 202311
- 8x8SC 13G/A Feb 14, 202312
- Blend Labs, Inc.SC 13G/A Feb 14, 2022 to Feb 14, 202313
- CarvanaSC 13G/A Feb 14, 2022 to Feb 14, 202314
- Dingdong (Cayman) LtdSC 13G/A Feb 14, 202315
- DoubleVerify Holdings, Inc.SC 13G/A Feb 14, 2022 to Feb 14, 202316
- Embark TechnologySC 13G/A Nov 22, 2021 to Feb 14, 202317
- Just Eat Takeaway.com N.V.SC 13G/A Feb 14, 2022 to Feb 14, 202318
- Katapult Holdings, Inc.SC 13G/A Feb 14, 202319
- Logistics Innovation Technologies Corp.SC 13G/A Feb 14, 202320
- Missfresh LtdSC 13G/A Feb 14, 2022 to Feb 14, 202321
- Nu Holdings Ltd.SC 13G/A Feb 14, 2022 to Feb 14, 202322
- Perimeter Solutions, Inc.SC 13G/A Nov 19, 2021 to Feb 14, 202323
- ProcoreSC 13G/A Feb 14, 2022 to Feb 14, 202324
- QualtricsSC 13G/A Nov 15, 2021 to Feb 14, 202325
- RingCentralSC 13G/A Oct 14, 2021 to Feb 14, 202326
- TCV Acquisition Corp.SC 13G/A Feb 14, 202327
- TaskUs, Inc.SC 13G/A Nov 1, 2021 to Feb 14, 202328
- VTEXSC 13G/A Mar 30, 2022 to Dec 23, 202229
- Starry Group Holdings, Inc.SC 13G/A Apr 6, 2022 to Dec 8, 202230
- Apollo Global ManagementSC 13G/A Feb 14, 202231
- DespegarSC 13G/A Feb 14, 202232
- Sumo LogicSC 13G/A Feb 14, 202233
All 31 companies
- Yatsen Holding LtdSC 13G/A Feb 14, 202234
Sources
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