- S&P 500 7,659.44 −1.09%
- Dow Jones 52,002.41 −0.34%
- Nasdaq 26,713.03 +0.08%
- VIX 19.99 +21.45%
- 10-year Treasury 5.09% −0.01
- Dollar index 121.40 −0.14%
- WTI crude $101.91 +1.04%
CRCM L.P.: investment adviser
CRCM L.P. is an investment adviser registered with the SEC (file 801-74362, CRD 160976). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.
- Assets managed
- $746.7M
- Discretionary
- 100%
- Accounts
- 19
- Employees
- 13
- In advisory roles
- 4
- Disclosures
- 0
SEC adviser record · Full Form ADV (PDF)
The firm reports that it or a related person has custody of client cash and securities.
Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.
Clients and fees
Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.
| Client type | Clients | Assets | Share |
|---|---|---|---|
| High net worth individuals | 6 | $12.2M | 1.6% |
| Private funds and other pooled vehicles | 13 | $734.6M | 98.4% |
How it is paid
- A percentage of assets under your management
- Other: Incentive allocations
Services
- Portfolio management for pooled investment vehicles (other than investment companies)
Who owns it
Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.
Direct owners (Schedule A)
| Owner | Type | Role | Stake | Since | Control | Public company |
|---|---|---|---|---|---|---|
| Ajd I Trust | Company (U.S.) | Limited partner | C 25% to 50% | Aug 2019 | Yes | |
| LLD I Trust | Company (U.S.) | Limited partner | C 25% to 50% | Aug 2019 | Yes | |
| MZD I Trust | Company (U.S.) | Limited partner | C 25% to 50% | Aug 2019 | Yes |
Indirect owners (Schedule B)
| Owner | Owns a stake in | Type | Stake | Control | Public company |
|---|---|---|---|---|---|
| Ajd I Trust | Ajd I Trust | Company (U.S.) | F General partner, trustee or managing member | Yes | |
| Gregory Stephen Harrison | Ajd I Trust | Person | F General partner, trustee or managing member | ||
| Gregory Stephen Harrison | LLD I Trust | Person | F General partner, trustee or managing member | ||
| Gregory Stephen Harrison | MZD I Trust | Person | F General partner, trustee or managing member | ||
| LLD I Trust | LLD I Trust | Company (U.S.) | F General partner, trustee or managing member | Yes | |
| MZD I Trust | MZD I Trust | Company (U.S.) | F General partner, trustee or managing member | Yes | |
| Chun R Ding | CRCM LLC | Person | E 75% or more | Yes |
Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.
Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.
Disciplinary history
The firm answered No to every disciplinary question on Form ADV (Item 11).
The brochure
Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.
CRCM, LP Part 2A Brochure - 3-2025, filed Mar 31, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18
Item 4. Advisory business
CRCM is a limited partnership organized under the laws of the State of Delaware and has been providing investment advisory services since November 21, 2007. The general partner of CRCM is CRCM LLC, a Delaware limited liability company that is owned by Chun R. Ding. For estate planning purposes, in 2019 Mr. Ding conveyed limited partnership interests in CRCM LP to family trusts while he maintained control of the firm through CRCM LLC. CRCM provides discretionary investment advisory services to (i) privately offered funds (the “Funds”) and (ii) persons or entities on a managed account basis (each such arrangement, a “Managed Account,” and the person(s) or entity(ies) funding a Managed Account, a “Managed Account Client”).
Read the rest of Item 4 (642 more words)
For the purposes of this brochure, a “Client” will refer to a Fund (and not the investors in a Fund) and/or a Managed Account Client. As used herein, any reference to “or” shall mean “and/or” and any reference to “including” shall mean “including but not limited to.” Funds CRCM serves as investment adviser to each Fund and also serves as the general partner of the Fintech Fund, the Institutional Onshore Feeder, the Opportunity Funds (with the exception of Opportunity Fund IV), the SPAC Fund, and a number of SPVs, each as defined below. Each Fund is either exempt from registration as an investment company pursuant to Section 3(c)(1) or Section 3(c)(7) of the Investment Company Act of 1940, as amended (“1940 Act”). Three of the open-end Funds are organized in a master-feeder structure, consisting of a U.S. feeder fund, an offshore feeder fund and a master fund (the “Institutional Onshore Feeder,” the “Institutional Offshore Feeder” and the “Institutional Master Fund,” respectively, and, collectively, the “Institutional Funds”). Each of the Institutional Onshore Feeder and the Institutional Offshore Feeder is expected to invest substantially all of its assets in the Institutional Master Fund. Each Institutional Fund seeks to achieve long-term capital appreciation through investments in debt and equity securities of companies listed anywhere in the world, as well as treasury securities, commodities, and digital assets. The Institutional Funds will adopt a global focus to investing and its investments will be allocated to prominent markets in North America and Asia, although investments may be made anywhere in the world and, at times, the focus may shift fully away from prominent markets to other markets and toward real assets such as commodities and digital assets. CRCM serves as investment adviser and general partner to an open-end fund (the “Fintech Fund”). The Fintech Fund seeks to achieve long-term capital appreciation primarily through investments in digital assets, instruments to secure rights to future digital asset issuances, and private companies that issue digital assets, or have a business related to blockchain or the fintech sector. CRCM serves as investment adviser and general partner to a closed-end fund that invests in the securities of special purpose acquisition companies (“SPAC”) (the “SPAC Fund”). The SPAC Fund seeks to achieve growth of principal primarily through investments in the publicly traded shares and warrants of SPACs and SPAC- related companies.
CRCM also serves as investment adviser to four closed-end funds that invest in nonpublicly traded companies with operations in China and the United States (“Opportunity Fund II”, “Opportunity Fund III”, “Opportunity Fund IV”, together the “Opportunity Funds” and “Frontier Technology Fund I”). Affiliates of CRCM, CRCM Opportunity GP IV LLC (“Opportunity GP IV”) and CRCM Global Media Fund I GP, LLC (“Frontier Technology Fund I GP”) serve as the general partner of Opportunity Fund IV and Frontier Technology Fund I, respectively. The Opportunity Funds and Frontier Technology Fund I target private investments. CRCM also serves as investment adviser to other vehicles including co-investment and other closed-end special purpose or special investment vehicles (the “SPVs”) including three that invests in a single publicly traded company and one that invests in a non-publicly traded company along with the Opportunity Funds. CRCM serve as the managing member of these SPVs. For further details regarding CRCM’s management of the Funds, please see Item 8 below. Managed Accounts CRCM works with each of its Managed Account Clients to develop investment guidelines based upon the Managed Account Client’s specific investment objectives. Managed Account advisory services are governed by a written agreement (“Managed Account Agreement”) between CRCM and the Managed Account Client. Managed Account Clients may amend their investment guidelines as their needs change or impose restrictions on investing in certain securities or types of securities. Managed Accounts may grant CRCM investment discretion or may be nondiscretionary. As of December 31, 2025, CRCM managed approximately $746,742,881 on a discretionary basis.
Item 5. Fees and compensation
Institutional Funds CRCM is entitled to receive a management fee from the Institutional Master Fund of approximately 1.5% (on an annualized basis) of the Institutional Master Fund’s net assets. In addition, CRCM and the affiliates hold a class of shares of the Institutional Master Fund that is entitled to receive an annual incentive allocation from the Institutional Master Fund. This incentive allocation is equal to 20% of the net profits, if any, of each Institutional Master Fund shareholder for the applicable year, subject to a “high water mark” provision. Opportunity Funds CRCM is entitled to receive a management fee of up to 2% of the aggregate capital commitments of the Opportunity Fund II limited partners. This management fee declines over the term of the Opportunity Fund II.
Read the rest of Item 5 (916 more words)
In addition, CRCM is entitled to receive carried interest distributions from the Opportunity Fund II equal to 20% of the distributions received by an Opportunity Fund II limited partner after that limited partner has received distributions equal to its aggregate capital contribution.
CRCM is entitled to receive a management fee of up to 2% of the aggregate capital commitments of the Opportunity Fund III limited partners. This management fee declines over the term of the Opportunity Fund III. In addition, CRCM is entitled to receive carried interest distributions from the Opportunity Fund III equal to 20% of the distributions received by an Opportunity Fund III limited partner after that limited partner has received distributions equal to its aggregate capital contribution. The Opportunity GP IV is entitled to receive a management fee of up to 2% of the aggregate capital commitments of the Opportunity Fund IV limited partners. This management fee declines over the term of the Opportunity Fund IV. The Opportunity GP IV assigned the Management Fee to CRCM pursuant to an Investment Management Agreement entered into by the Opportunity Fund IV, the Opportunity GP IV and CRCM. In addition, the Opportunity GP IV is entitled to receive carried interest distributions from the Opportunity Fund IV equal to 20% of the distributions received by an Opportunity Fund IV limited partner after that limited partner has received distributions equal to its aggregate capital contribution. The foregoing fees and allocations may be negotiable in certain circumstances and may be reduced or waived, including with respect to investors that are employees of CRCM or CRCM’s affiliates. Frontier Technology Fund I CRCM is entitled to receive a management fee of up to 2% of the aggregate capital commitments of the Frontier Technology Fund I limited partners. This management fee declines over the term of the Frontier Technology Fund I. The Frontier Technology Fund I GP is entitled to receive carried interest distributions from the Frontier Technology Fund I equal to 20% of the distributions received by Frontier Technology Fund I limited partner after that limited partner has received distributions equal to its aggregate capital contribution. Fintech Fund CRCM is entitled to receive a management fee from the Fintech Fund of 2.0% for Class A Interests, 1.5% for Class B Interests (except a lower fee is charged for Bitcoin and Ethereum positions) and 0.25% for Class C Interests (all on an annualized basis) of the Fintech Fund’s net assets. In addition, CRCM is entitled to receive an incentive allocation equal to 20% of the distributions received by Fintech Fund limited partners after the limited partner has received distributions equal to its aggregate capital contribution for Class A and Class B (with a higher incentive allocation percentage applicable to Class B after a Limited Partner has received 5 times its aggregate Capital Contributions with respect to Class B Interests). No incentive allocation is charged to Class C Interests. SPAC Fund CRCM (or an affiliate) is entitled to receive a management fee from the SPAC Fund of 2.0% (on an annualized basis) of the SPAC Fund’s net assets. In addition, the CRCM is entitled to receive an incentive allocation equal to 20% of the distributions received by SPAC Fund limited
partners after the limited partners have received distributions equal to their aggregate capital contributions. SPVs With respect to the SPVs, the specific compensation terms are set forth in the relevant operating agreements. Generally, CRCM or its affiliates may receive a combination of management fees and an incentive allocation on distributions following a return of an investor’s aggregate capital contributions to the particular SPV. Managed Account Fees CRCM may be paid a management fee and/or performance fee or allocation with respect to a Managed Account in accordance with the terms of the applicable Managed Account Agreement. Other Expenses Each Client bears its ongoing expenses, including expenses associated with transactions (e.g., brokerage commissions and custody expenses), investment (including any direct or indirect costs of investing in potential investments or maximizing return on existing investments), consulting, research (including due diligence-related expenses) and statistical services, administrative, legal (including blue-sky compliance), compliance and accounting expenses associated with formation and maintenance of investment vehicles, tax preparation, insurance, audit expenses, any extraordinary expenses (e.g. litigation expenses) and any expenses for services that the Client requires CRCM to obtain. Clients also pay the fees and expenses of their prime brokers, futures commission merchants and administrators. Please see Item 12 for a discussion of CRCM’s brokerage practices. The specific manner in which fees are charged by CRCM is established in a Client’s written agreement with CRCM. CRCM typically deducts fees from the Funds, but bills Managed Account Clients for its fees. Management fees are generally paid quarterly in advance. Upon redemption or termination of the advisory relationship or upon investment other than at the beginning of the normal investment cycle, CRCM or its affiliate will refund fees and/or charge that Client only for the actual period of time that CRCM provided advisory services. Performance fees or allocations, if applicable, are paid at the end of the financial year to which the fee or allocation pertains or upon a withdrawal or redemption from or termination of a Fund or Managed Account. In closed-end funds and special purpose vehicles, carried interest is typically charged on distributions after a return of invested capital. Neither CRCM nor any of its supervised persons accepts compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds.
Item 6. Performance-based fees and side-by-side management
CRCM’s Clients are generally charged both a management fee and a performance fee, incentive allocation or carried interest, as described above in Item 5. The performance-based fees or allocations are structured to comply with Section 205 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and are charged or allocated in accordance with each Client’s governing documents. CRCM advises a variety of investment funds and separately managed accounts pursuing private and public market investment strategies and, as a result, faces conflicts of interest in allocating purchase and sale opportunities among its clients, including due to different management fees and incentive allocations charged across funds and accounts.
Read the rest of Item 6 (433 more words)
It is CRCM’s general policy to allocate purchase or sale opportunities on a pro rata basis to all applicable Clients that have similar investment guidelines risk, and liquidity profiles and strategies (subject to having capital available to invest, as determined by CRCM), measured by reference to the Clients’ relative amounts of investment capital as of the time of investment, provided that, in respect of private company follow-on investments, Clients with an established position will receive priority, and Clients with no existing holdings will generally not be permitted to participate unless Clients with established positions have received full allocations. However, CRCM recognizes that a pro rata allocation of purchase or sale opportunities will not always be feasible or in the best interests of Clients, and CRCM will adjust allocations from pro rata when it is determined to be fair and equitable, based on certain investment or Client characteristics. Factors for non-pro rata allocations may include, for example, relative size, target allocation of capital to an asset class or strategy, cash availability, liquidity requirements, investment term, or other reasons as determined by CRCM. Accordingly, CRCM has adopted procedures that permit CRCM to allocate purchase or sale opportunities on a non-pro rata basis under certain circumstances. When allocating on a non-pro rata basis, CRCM faces conflicts of interest in determining such allocations, including the size of any allocation, the timing of entry or exit, and whether any Client should receive priority. An exception to CRCM’s general policy of the pro rata allocation of purchase or sale opportunities will be documented and reviewed by CRCM’s Chief Compliance Officer (“CCO”). CRCM will make allocation decisions in its sole discretion and is not obligated to identify or pursue every investment opportunity for each Client. As a result, investment returns may differ significantly across Client accounts. From time to time, CRCM may form SPVs to pursue investments when existing funds and accounts are fully allocated. CRCM may have economic or other incentives to form SPVs or to provide SPV investors with opportunities not otherwise available to existing fund investors, and faces conflicts of interest in determining whether existing Clients are fully allocated prior to forming an SPV. A performance fee or allocation may also create an incentive for CRCM to make investments that are riskier or more speculative than would be the case in the absence of a financial
incentive based on the performance of a Client. CRCM monitors the investments made for Clients on an ongoing basis, and endeavors to ensure that investments made for the Clients are appropriate without regard to the potential for performance-based fees or allocations.
Item 7. Types of clients
CRCM currently provides investment advice to the Funds, as discussed in Item 4 above, and to one or more Managed Account Clients. CRCM may also advise different types of clients in the future. Each investor in the Funds must generally be an “accredited investor” as defined in Regulation D promulgated under the Securities Act of 1933, as amended, and a “qualified purchaser” under the 1940 Act. Additional restrictions may apply, and are set forth in the offering or organizational documents for each Fund. The minimum investment in the Fintech Fund, Institutional Onshore Feeder and the Institutional Offshore Feeder, subject to waiver, is $1,000,000. The minimum capital commitment to the Opportunity Funds and Frontier Technology Fund I, absent a waiver, is $1,000,000.
Read the rest of Item 7 (156 more words)
Fintech Fund investors of Class A and Class B may not withdraw any portion of their interest referable to a capital contribution made less than three years prior to the date the withdrawal is to be effective, and thereafter may withdraw capital on the last business date of each calendar year, excluding private investments. Absent a waiver, Institutional Fund and Fintech Fund investors may not effect a partial redemption of their interest or shares in the applicable Fund if, after such redemption, their investment in the applicable Fund would be less than the required minimum investment. Because the Opportunity Funds, Frontier Technology Fund I, SPAC Fund, and the SPVs are closed-end funds, investors may generally not redeem their investment in such Funds. The conditions for starting and maintaining a Managed Account will vary with the circumstances of each Managed Account and be negotiated and set forth on an individual basis in the relevant Managed Account Agreement.
Item 8. Methods of analysis, investment strategies and risk of loss
The methods of analysis and significant investment strategies used by CRCM with regard to the Funds are set forth below. The methods of analysis and significant investment strategies used by CRCM with regard to Managed Account Clients vary depending on the needs of each Managed Account Client, but are expected to be comparable to those described below for the Funds. Investments in the Funds and Managed Accounts are not guaranteed; the instruments in which the Funds and Managed Accounts invest may lose value. An investment in a Fund or Managed Account involves a risk of loss that an investor should be prepared to bear. Significant Strategies and Methods of Analysis. Institutional Funds. CRCM seeks to employ a value-oriented investment selection process to identify potential investments for the Institutional Funds. Each Institutional Fund may invest in
Read the rest of Item 8 (3,122 more words)
a variety of potential instruments and securities including but not limited to stocks and equityrelated securities, listed securities, futures, options, forex and interest rates, indexed securities, commodities and derivatives, forward, future and repurchase agreements, convertible securities, currency and equity swaps, bonds and other debt securities, currencies, other private funds, and digital assets. The Institutional Funds will generally not invest in the shares of private companies. The Institutional Funds’ strategy will be broad and flexible and remain focused on longterm capital appreciation. Consistent with its broad and flexible mandate, the Institutional Funds will have no concentration limits. CRCM expects to utilize long and short positions to construct the Institutional Funds’ portfolios and may use short positions to manage risk. CRCM expects to periodically adjust the investment strategies in order to adapt to changing market conditions. Fintech Fund. The Fintech Fund will seek to invest digital assets, instruments to secure rights to future digital assets issuances and private companies that issue digital assets, or have business related to blockchain or fintech sectors. Class C solely invests in digital assets. Opportunity Funds. The Opportunity Funds will seek to invest primarily in non-publicly traded early stage companies with operations in China and the United States which are positioned as emerging leaders in the sectors related to artificial intelligence, virtual or augmented reality, autonomous devices or distribution platforms, and climate technology; and may also opportunistically invest in companies of all types, stages and locations with the goal of producing compelling returns for the Funds’ investors. In addition, the Funds may invest opportunistically in digital assets. Given the nature of certain early stage venture capital investments, diligence may be limited when compared to other CRCM Investments Frontier Technology Fund I. The Frontier Technology Fund I will seek to invest primarily in non-publicly traded early-stage companies with operations in China and the United States which are positioned as emerging leaders in the sectors related to media, virtual reality, augmented reality, and artificial intelligence. SPAC Fund. The SPAC Fund will seek to invest primarily in listed securities and options of the publicly traded SPACs and SPAC-related companies. SPVs. The SPVs will seek to invest and co-invest primarily in non-publicly traded earlystage companies. There can be no assurance that the Funds or Managed Accounts will achieve their investment objectives or avoid substantial losses. Material Risks. The material risks of investing in the Funds or Managed Accounts including the following:
Market Risk. Prices of the securities held by a Client will fluctuate sometimes rapidly and unexpectedly. These fluctuations may cause the price of a security to decline for short- or long-term periods and cause the security to be worth less than it was worth when purchased by that Client.
Business Risks; Economic Conditions. Investments are subject to risk from changes in the economic climate, including, for example, interest rates, inflation rates, industry conditions, competition, technological developments, political and diplomatic events and trends, tax laws, the competency of management, and innumerable other factors, in a similar way to other industrial or commercial companies. None of these conditions are within the control of CRCM. For these and other reasons, there can be no guarantee that companies in which the Clients invest will develop as anticipated or that the consistent, absolute returns sought will actually be achieved.
Foreign Securities. Investments in equity or debt securities of non-U.S. issuers may involve certain special risks due to economic, political and legal developments, including favorable or unfavorable changes in currency exchange rates, exchange control regulations (including currency blockage), expropriation of assets or nationalization, imposition of withholding taxes on dividend or interest payments, and possible difficulty in obtaining and enforcing judgments against non-U.S. entities. Furthermore, issuers of non-U.S. securities are subject to different, often less comprehensive accounting reporting and disclosure requirements than domestic issuers. The securities of some foreign governments and companies and foreign securities markets are less liquid and at times more volatile than comparable U.S. securities and securities markets.
Specific Risks Relating to China. It is expected that a material portion of the assets of the Opportunity Funds, the Frontier Technology Fund I and the SPVs will be comprised of investments in companies and other entities with significant assets, investments, production facilities, trading or other business interests in China or which derive a significant part of their revenue from China. As a result, an investment in such Funds or a Managed Account with a similar strategy will involve certain considerations in addition to the risks normally associated with making investments in foreign securities. In particular:
The value of the Client’s assets may be adversely affected by political, economic, social instability or diplomatic developments in China, and by changes in Chinese law or regulations.
Foreign investment in the securities of Chinese companies is restricted or controlled to varying degrees. These restrictions or controls are subject to change, and may at times limit or preclude foreign investment in certain Chinese companies and increase the costs and expenses of the Client.
There are differences between China’s legal, accounting and auditing framework, reporting practices and disclosure requirements and those generally accepted internationally.
Illiquid Securities. Substantially all of the investments of the Opportunity Funds, Frontier Technology Fund I, the SPVs and a portion of the investments held by other Clients will be highly illiquid investments with the exception of some digital assets
held in Opportunity Fund III and Opportunity Fund IV. The market prices, if any, for illiquid assets tend to be volatile, may be difficult to obtain, and may fluctuate due to a variety of factors that are inherently difficult to predict. A Client may not be able to sell assets when it desires to do so or to realize what it perceives to be their fair value in the event of a sale. The sale of illiquid assets and restricted securities often requires more time and results in higher brokerage charges or dealer discounts and other selling expenses than does the sale of securities eligible for trading on national securities exchanges or in the over-the-counter markets. A Client may be required to hold illiquid securities for several years before any disposition can be effected.
Regulatory Risks Relating to Digital Assets. A significant portion of the Fintech Fund’s assets are invested in digital assets. Additionally, the Institutional Funds, Opportunity Fund III and Opportunity Fund IV are invested in digital assets. The effect of any future regulatory change on the Fintech Fund, other Funds holding digital assets, or the digital assets is impossible to predict, but such change could be substantial and adverse to the subject Funds and their investments in digital assets. Countries may in the future take regulatory actions that prohibit or severely restrict the right to acquire, own, hold, sell, use or trade digital assets or to exchange digital assets for fiat currency. By extension, similar actions by other countries, may result in the termination and liquidation of the subject Funds at a time that is disadvantageous to its investors.
Leverage. The Institutional Funds and certain other Clients may seek to enhance returns through the use of leverage, which can be described as exposure to changes in price at a ratio greater than 1:1 in reference to the amount invested. Leverage magnifies both the favorable and unfavorable effects of price movements in the investments made by a Client, all of which may subject that Client to substantial risk of loss.
Currency Risk. Although each Client will generally compute and distribute its income in U.S. dollars, a large portion of the investments held by such Client will be currencies other than the U.S. dollar, and in particular in Renminbi, which is the currency of China. As a result, changes in currency exchange rates will affect the value of the Client’s assets. Currency exchange rates may fluctuate significantly over short periods of time due to factors beyond the control of CRCM. Although CRCM may seek to mitigate the risk of currency exchange fluctuation through the use of currency hedges, there can be no assurance that such hedging techniques will be effective.
Portfolio Concentration. The Fintech Fund, Opportunity Funds, Frontier Technology Fund I, the SPVs and certain other Clients may own a relatively concentrated portfolio of investments. The limited number of investments and the extent to which a Client’s portfolio investments are concentrated may cause the performance of that Client to be more volatile than the performance of a more diversified investment product.
Custody Risk. CRCM expects to hold the Fintech Fund, Opportunity Funds, Institutional Funds and certain other Clients’ commodities (e.g. gold bullion) and digital assets through a combination of custodial solutions that include third party custodial solutions of all or a portion of such investments, and may self-custody digital
assets at times when custodial solutions are not available. There is a risk that any selected custodial solution may involve risks of loss from hacking, compromised access credentials, loss, damage, theft or restrictions of access due to natural events or human actions. Furthermore, the third-party custodians may not carry adequate insurance coverage of the digital assets held by the Funds and as a result any loss of the digital assets by such custodian may not be recoverable resulting in a loss by the Funds. The third-party custodians may also not be required to indemnify the Funds for losses except in limited circumstances, and as a result, losses due to misappropriation of digital assets or commodities may not be recoverable. The Funds’ ownership of digital assets is evidenced using blockchain technology, and such assets are generally not held at a custodian bank. At times, CRCM may have access to and/or have possession of some of the private keys and passwords for the Funds’ digital assets.
Dependence on Key Personnel. Each Client’s success depends, to a significant extent, upon the efforts and abilities of the principal of CRCM and its affiliates, Chun R. Ding. The loss of the services of Mr. Ding may have a material adverse effect on the operations of CRCM and its affiliates.
Diverse Interests. In certain circumstances, the various types of Fund investors and Managed Account Clients, may have conflicting investment, tax and other interests with respect to their interests. The conflicting interests of particular investors and clients may relate to or arise from, among other things, the nature of investments made by a Fund or Managed Account, the structuring of the acquisition, ownership and disposition of investments, the timing of disposition of investments, the transfer or disposition by an investor of its investment, and the manner in which one or more investments are reported for tax purposes. Fund Investors include taxable and taxexempt entities and may include persons or entities organized in various jurisdictions. As a result, conflicts of interest may arise in connection with decisions made by the General Partner and/or CRCM that may be more beneficial for one type of investor than for another type of investor, including investors affiliated with the General Partner. As a consequence, conflicts of interest arise in connection with CRCM’s decisions regarding these matters, which will be adverse to some investors and/or clients, or may be more beneficial to certain other investors and/or clients (including CRCM or CRCM’s affiliates) over others.
CRCM believes that the Clients may be subject to additional material risks and special considerations, as explained below:
Recent Market Conditions. Events in the financial sector in recent years have resulted, and may continue to result, in an unusually high degree of volatility in the financial markets, both domestic and foreign, and in the net asset values of many investment funds, including the Funds. These events have also decreased liquidity in some markets and may continue to do so. Because the situation is unprecedented and widespread, it may be unusually difficult to identify both risks and opportunities using past models of the interplay of market forces, or to predict the duration of these market events.
Market Disruption and Geopolitical Risks. The Funds and Managed Accounts are subject to the risk that geopolitical and other events (e.g., wars and terrorism) will disrupt securities markets and adversely affect global economies and markets, thereby decreasing the value of a Fund or Managed Account’s investments. Sudden or significant changes in the supply or prices of commodities or other economic inputs may have material and unexpected effects on both global securities markets and individual countries, regions, sectors, companies, or industries, which could significantly reduce the value of a Fund or Managed Account’s investments. Terrorism in the United States and around the world has increased geopolitical risk. Securities markets may be susceptible to market manipulation or other fraudulent trading practices, which could disrupt their orderly functioning or reduce the prices of securities traded on them. Recently, the global financial markets have been undergoing pervasive and fundamental disruptions as a result of a global pandemic and resultant supply shocks and inflationary pressures which have led in varying degrees to extensive and unprecedented governmental intervention. Such intervention has in certain cases been implemented on an “emergency” basis, suddenly and substantially eliminating the ability of market participants to continue to implement certain strategies or manage the risk of their outstanding positions. In addition, as one would expect given the complexities of the financial markets and the limited time frame within which governments have felt compelled to take action, these interventions have typically been unclear in scope and application, resulting in confusion and uncertainty which in itself has been materially detrimental to the efficient functioning of the markets as well as previously successful investment strategies. It is impossible to predict what additional interim or permanent governmental restrictions may be imposed on the markets and/or the effects of such restrictions on a Fund or Managed Account’s investment strategy.
Banking Conditions. Actual events involving limited liquidity, defaults, nonperformance or other adverse developments that affect financial institutions, transactional counterparties or other companies in the financial services industry or the financial services industry generally, or concerns or rumors about any events of these kinds or other similar risks amplified by digital communications, have in the past and may in the future lead to market-wide liquidity problems which could adversely affect CRCM’s Clients. For example, the recent banking turmoil spread uncertainty over liquidity concerns broadly across the global financial system and jolted financial markets.
Pandemic/Covid 19. Certain impacts from COVID-19 outbreak may have a significant negative impact on the Funds’ operations and performance. These circumstances may continue for an extended period of time, and may have an adverse impact on economic and market conditions. The ultimate economic fallout from the pandemic, and the longterm impact on economies, markets, industries and individual companies, are not yet known but the pandemic has contributed to, and may contribute to disruptions in global supply chains, disruptions in the availability of financing, and/or volatility in financial markets, which may disrupt historical pricing relationships or trends. The extent of
impact to the financial performance and the operations of the Funds will depend on future developments, which are highly uncertain and cannot be predicted. In addition, future epidemics and pandemics could result in a general decline in the global economy, and negatively affect the performance of individual countries, industries, or sectors in significant and unforeseen ways. Deteriorating economic fundamentals may in turn increase the risk to investments, negatively impact market value, increase market volatility, and reduce liquidity.
Equity Securities. Investment in equity securities involves certain risks, including issuer, industry, market and general economic related risks. CRCM may attempt to reduce these risks; however, adverse developments or perceived adverse developments in one or more of these areas could cause a substantial decline in the value of equity securities owned by a Fund or Managed Account.
Debt and Other Income Securities. Debt and other income securities are subject to interest rate, market and credit risk. Interest rate risk relates to changes in a security’s value as a result of changes in interest rates generally. Even though such instruments are investments that may promise a stable stream of income, the prices of such securities are inversely affected by changes in interest rates and, therefore, are subject to the risk of market price fluctuations. Market risk relates to the changes in the risk or perceived risk of an issuer, country or region. Credit risk relates to the ability of the issuer to make payments of principal and interest. The values of income securities may be affected by changes in the credit rating or financial condition of the issuing entities.
Derivatives. The use of derivative instruments involves risks different from, or possibly greater than, the risks associated with investing directly in securities and other traditional investments. Derivatives are subject to a number of risks, such as interest rate risk, market risk, and credit risk. They also involve the risk of mispricing or improper valuation and the risk that changes in the value of the derivative may not correlate perfectly with the underlying asset, rate, or index. With an investment in a derivative instrument, an investor could lose more than the principal amount invested. Also, suitable derivative transactions may not be available in all circumstances.
Futures Contracts. The low margin deposits normally required in futures contract trading (typically between 2% and 25% of the value of the contract purchased or sold) permit an extremely high degree of economic leverage. Accordingly, a relatively small price movement in a futures contract may result in immediate and substantial losses. In entering into futures contracts and options on futures contracts, there is a credit risk that a counterparty will not be able to meet its obligations to the Fund.
Digital Assets. The price of digital assets can be affected by many factors, including, but not limited to, global supply and demand, the expected future prices, inflation expectations, interest rates, currency exchange rates, fiat currency withdrawal and deposit policies at exchanges for digital assets, regulatory measures that restrict the use of digital assets or financial events. Pricing also might be influenced by efforts at market manipulation by certain participants. Drastic or even gradual changes in price
of digital assets and their derivatives could materially affect the Fund’s digital assets. The market for digital asset is smaller and less liquid than other assets, with extremely volatile pricing.
Commodities. The prices of commodities have been, and are likely to continue to be, volatile and subject to wide fluctuations in response to many factors, including, but not limited to, changes of the supply and demand for each commodity, market uncertainly, geopolitical conditions, the foreign supply of precious, base and industrial metals, overall economic conditions, inflations and variety of other factors that are beyond the controls of the Funds.
Investors and prospective investors should review the offering memorandum of the Fund in which they are invested (or are seeking to invest) for additional information about the risks associated with an investment in such Fund.
Item 9. Disciplinary information
This item is not applicable to CRCM.
Item 10. Other financial industry activities and affiliations
Except as described below, neither CRCM nor any of its management persons is registered, or has an application pending to register, as a broker-dealer, registered representative of a brokerdealer, futures commission merchant (“FCM”), commodity pool operator (“CPO”) or commodity trading advisor (“CTA”). In addition, except as described below, neither CRCM nor any of its management persons is an associated person of an FCM, a CPO or CTA. As described earlier, certain affiliates of CRCM provide services to or are involved in the management of the Funds:
Opportunity GP IV serves as the general partner of the Opportunity Fund IV and, in such capacity, is entitled to receive both management fees and carried interest from the Opportunity Fund IV.
Read the rest of Item 10 (82 more words)
Frontier Technology Fund I GP serves as the general partner of the Frontier Technology Fund I and, in such capacity, is entitled to receive carried interest from the Frontier Technology Fund I.
CRCM does not recommend or select other investment advisers for its Clients. Certain affiliates of CRCM are principals of CRBN GP, LLC, which are exempt commodity pool operators and commodity trading advisors to an open-end fund that invests in California Carbon Allowances, including options and futures on California Carbon Allowances.
Item 11. Code of ethics, participation in client transactions and personal trading
Trading CRCM has adopted a Code of Ethics (“Code”) pursuant to Rule 204A-1 under the Advisers Act. All “access persons” (including employees, managers and officers) of CRCM must comply with the Code. The Code states that CRCM personnel must always place the interests of CRCM’s Clients first. The Code sets forth standards of conduct expected of CRCM’s personnel, which reflect the fiduciary obligations of CRCM and its personnel to its Clients, and requires CRCM’s personnel to comply with applicable federal securities laws. The Code also requires any employee of CRCM to report potential violations of the Code promptly to the CCO.
Read the rest of Item 11 (289 more words)
CRCM provides each employee with a copy of the Code and any amendments, and employees are required to provide a written acknowledgement that they have received the Code, as amended from time to time. Under the Code, access persons must, in certain limited circumstances, obtain prior approval from the CCO and CRCM’s Chief Investment Officer before buying or selling any security, option or futures contract. In addition, access persons must submit an annual report of brokerage accounts and holdings along with an annual acknowledgement and certification stating that the individual will comply with the Code. The Code further requires personnel to submit quarterly transaction reports (or brokerage statements) that detail the individual’s securities transactions for the quarter, and for the CCO to review those reports. Finally, the Code also contains restrictions on the use of insider information and non-public information regarding a CRCM Client. CRCM keeps records of reports and other information that access persons are required to provide under the Code. The CCO reports on issues that arise under the Code to CRCM’s senior management at least annually. Clients and prospective clients can obtain a copy of the Code upon request by contacting CRCM by telephone ((415) 578-5700) or by email (kkoo@crcm.com). CRCM may, from time to time, facilitate the purchase and sale of securities between two Clients. CRCM will seek to effect such transactions between Clients only if it determines that doing so would be in the best interest of each Client involved. CRCM will consider all relevant factors in making this determination, including without limitation the availability of the underlying securities in the marketplace, execution costs and the potential effect on the Clients of executing purchase and sale transactions in the underlying securities in the marketplace.
Item 12. Brokerage practices
CRCM is responsible for determining what securities will be purchased and sold for each Client and selecting the broker-dealer to execute the transactions on behalf of Clients. It is CRCM’s policy to seek best execution on behalf of its Clients – that is, CRCM seeks to achieve the best overall qualitative execution for a Client in a particular circumstance. In selecting broker-dealers, CRCM seeks those broker-dealers who can provide best execution of transactions under the circumstances. The principal factors that CRCM considers when selecting a broker-dealer include: (1) a broker’s ability to execute the types of transactions occurring in Client accounts; (2) the net prices for such transactions; and (3) trading ideas
Read the rest of Item 12 (580 more words)
generated by brokers. “Best execution” is not synonymous with lowest brokerage commission. Consequently, in a particular transaction a Client may pay a brokerage commission in excess of that which another broker might have charged for executing the same transaction. Execution prices may vary across the Funds due to the use of different broker-dealers. CRCM may generate “soft dollars” with regard to trades made on behalf of Clients. “Soft dollars” refers to CRCM’s receipt of research or other products or services other than execution from brokers. Products and services CRCM obtained through soft dollar arrangements in the past year include (i) market data, from vendors such as Bloomberg, NYSE, Nasdaq etc or (ii) proprietary research from brokers or third-party consultants, which may be written, oral or electronic. Research products may also include, among other things, permitted computer databases and quotation software, in each case, to access research or which provide research directly, other software, databases and certain other technical and telecommunication services utilized in the investment management process. Research services (which may be in written or oral form or electronic) may include, among other things, research concerning market, economic and financial data, statistical information, data on pricing and availability of securities, financial publications (to the extent appropriate), electronic market quotations and news, performance measurement and pricing services, permitted risk management analysis and performance studies, analyses concerning specific securities, companies or sectors, and market, economic and financial studies and forecasts. CRCM uses soft dollar benefits to service all of its Clients’ accounts and not only those that generate the benefits. Because the brokerage and research benefit all accounts, soft dollar benefits are not proportionally allocated to any Clients that may generate different amounts of the soft dollar benefits. When CRCM uses Client brokerage commissions (or markups or markdowns) to obtain research or other products or services, CRCM receives a benefit because it does not have to produce or pay for the research, products or services. As a result, CRCM may have an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services, rather than on its Clients’ interest in receiving the most favorable execution. CRCM has a formal approval process for the addition of any new soft dollar service. Information relating to the soft dollar service is reviewed and signed by the CCO. The CCO also reviews the soft dollar budget on a regular basis. Within the past year, CRCM used soft dollar benefits to acquire (i) market data, from vendors such as Bloomberg, (ii) proprietary research from brokers and/or third party vendors, and (iii) specialized financial publications. CRCM does not consider, in selecting or recommending broker-dealers, any client referrals it may receive from a broker-dealer or third party. CRCM does not recommend, request or require that a Client directs the execution of transactions through a specified broker-dealer, nor does it have any arrangement in which it directs transactions for any Client to a specific broker-dealer based on any other consideration than best execution and the Client’s best interests. From time to time, CRCM’s Clients may seek to buy and sell the same investments and, in such cases, CRCM may aggregate purchases and sales of investments. CRCM will generally seek
to aggregate purchases and sales when CRCM believes that aggregation will result in the execution of transactions in a more timely and efficient manner, such as a reduction in overall execution costs and impact on the market price of the underlying securities.
Item 13. Review of accounts
CRCM’s Chief Investment Officer reviews the daily profit and loss reports for every position in the Institutional Master Fund and the SPAC Fund. On a weekly basis, CRCM’s Chief Investment Officer reviews the status of the positions in the Fintech Fund, Opportunity Funds and Frontier Technology Fund I. Risk management is initially performed by each respective CRCM portfolio manager and is supervised by the Chief Investment Officer. Decisions to change positions are made by the Chief Investment Officer after consultation with the respective CRCM portfolio manager. In addition, the respective CRCM portfolio manager, the Chief Investment Officer and Head of Trading monitor news flow and trading activity for every significant position in Clients’ portfolios during each trading day.
Read the rest of Item 13 (140 more words)
At least once a week, the Chief Investment Officer, and one or more of CRCM management committee members, review profit and loss for every significant position and gross/net exposures of Client portfolios. CRCM analyzes monthly trading reports that detail total commission costs. In the case of the Funds, an administrator may independently price the portfolio, or the Funds may use cost or broker quotes to value certain investments and, in particular, generally uses the cost or based upon the last round of financing for its venture capital investments as of each valuation date. In general, each Fund investor receives an annual audited financial report. Investors may also receive other periodic reports as described in the applicable Fund’s offering or organizational documents. Managed Account Clients will receive the reports and disclosures required under the terms of the relevant Managed Account Agreement.
Item 14. Client referrals and other compensation
CRCM does not receive an economic benefit from any person who is not a client for providing investment advice or other advisory services. CRCM may, from time to time, enter into arrangements with third parties for marketing and solicitation activities in respect of CRCM and the Funds. Solicitation arrangements may create conflicts of interests for CRCM and/or the third parties because the third parties receive compensation for introductions regardless of the merit of the Funds and/or Managed Accounts. CRCM seeks to address these conflicts by only paying these third parties out of its own management fee and performance fee or allocation.
Read the rest of Item 14 (45 more words)
CRCM also seeks to address these conflicts by fully disclosing the referral arrangement to all introduced Fund investors and/or Managed Account Clients, in advance of the investments, to enable such Fund investors and/or Managed Account Clients to make informed decisions in connection with their investments.
Item 15. Custody
CRCM is deemed to have custody of the assets of each Fund. To comply with the requirements of the Advisers Act, each Fund is audited each year by an independent public accountant and these audited financial statements are provided to Fund investors within 120 days of fiscal year end. CRCM generally does not have custody over the assets of Managed Account Clients. Managed Account Clients will receive account statements from the qualified custodian for their accounts and should carefully review those statements. CRCM generally does not provide statements to Managed Account Clients, except if specifically requested or in certain limited circumstances.
Read the rest of Item 15 (66 more words)
Managed Account Clients who receive account statements from CRCM should compare those statements with the account statements received from the qualified custodian. Custody of digital assets in the Fintech Fund, Institutional Funds, Opportunity Fund III and Opportunity Fund IV presents particularized issues not present with other funds managed by CRCM. Investors should carefully review the particular Fund’s offering materials for a detailed discussion of these issues.
Item 16. Investment discretion
CRCM has discretionary authority over the investment activities of the Funds and may have discretionary authority over certain Managed Accounts. In the case of Funds, this discretionary authority is generally granted to CRCM pursuant to the organizational documents of each Fund and/or pursuant to CRCM’s investment advisory agreement with such Fund. In the case of Managed Accounts, CRCM is granted discretionary authority in the Managed Account Agreements. In all cases, CRCM is obligated to exercise its investment discretion in a manner consistent with the stated investment objectives, policies, guidelines, and restrictions/limitations for a particular Client account.
Item 17. Voting client securities
CRCM has the authority to vote all proxies on behalf of the Funds it advises and may be delegated the authority to vote proxies held in a Managed Account. CRCM has adopted a policy governing the voting of proxies that is designed to ensure that CRCM votes Fund securities in the best interest of its Funds. CRCM generally will vote proxies only when the Funds hold a material position in the securities, so as to promote the long-term economic value of the underlying securities. Each proxy proposal will be considered on its own merits, and CRCM will make an independent determination whether to support or oppose management’s position.
Read the rest of Item 17 (208 more words)
If there is any actual or apparent conflict of interest between the interests of CRCM and its Clients, CRCM will endeavor to resolve such conflict in a manner that is consistent with the best interest of the Clients and in a manner not affected by such actual or apparent conflict of interest. If a Managed Account Client has not delegated the power to vote proxies to CRCM, that Managed Account Client may direct CRCM to vote in a particular manner at any time upon written notice to CRCM. In those circumstances, CRCM will comply with the Managed Account Client’s specific directions to vote proxies, whether or not such directions specify voting proxies in a
manner that is different from these policies and procedures. In instances where CRCM does not have authority to vote Managed Account Client proxies, it is the responsibility of the Managed Account Client to instruct the relevant custodian bank or banks or prime broker to mail proxy material directly to such Managed Account Client. Fund investors and Managed Account Clients may obtain a copy of these proxy voting policies, obtain information about how CRCM has voted its Clients’ proxies or discuss any particular solicitation by contacting CRCM by telephone ((415) 578-5700) or by email (kkoo@crcm.com).
Item 18. Financial information
CRCM does not require or solicit prepayment of any advisory fees from the Funds or Managed Accounts. As a result, CRCM is not required to provide a balance sheet for its most recent fiscal year. CRCM is unaware of any financial condition that is reasonably likely to impair its ability to meet its commitments to its Clients. CRCM has not been the subject of a bankruptcy petition during the past 10 years.
Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.