Form D · Hedge Fund

Gabelli Associates LTD

Tortola, D8 · CIK 0001345391

Offering snapshot reported Nov 28, 2025 · SEC filing

Reported sold: $456M
Investors reported: 174
Minimum accepted: $1M
First sale: Jan 1, 2005

Fundraising history

Reported sold

Dates are filing dates, not cash receipt dates. Decreases are reported revisions, not evidence of withdrawals. Separate offering histories are not added together.

What changed?

Latest filing versus its linked predecessor, where available.

Reported sold$452,579,412 → $455,579,412

Filing history

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Filed	Filing type	Reported sold	Change vs linked filing	Investors	Source
Nov 28, 2025	Amendment	$455,579,412	$3,000,000vs Nov 29, 2024	174	SEC filing
Nov 29, 2024	Amendment	$452,579,412	$0vs Dec 1, 2023	174	SEC filing
Dec 1, 2023	Amendment	$452,579,412	$3,367,000vs Dec 2, 2022	174	SEC filing
Dec 2, 2022	Amendment	$449,212,412	$24,350,000vs Dec 16, 2021	172	SEC filing
Dec 16, 2021	Amendment	$424,862,412	$219,857,399vs Dec 16, 2020	168	SEC filing
Dec 16, 2020	Amendment	$205,005,013	$12,500,000vs Dec 27, 2019	76	SEC filing
Dec 27, 2019	Amendment	$192,505,013	$15,700,000vs Dec 28, 2018	76	SEC filing
Dec 28, 2018	Amendment	$176,805,013	$17,795,000vs Dec 28, 2017	74	SEC filing
Dec 28, 2017	Amendment	$159,010,013	$19,075,000vs Dec 28, 2016	70	SEC filing
Dec 28, 2016	Amendment	$139,935,013	$29,900,000vs Jan 15, 2016	70	SEC filing
Jan 15, 2016	Amendment	$110,035,013	$13,393,000vs Jan 15, 2015	68	SEC filing
Jan 15, 2015	Amendment	$96,642,013	$10,248,195vs Jan 15, 2014	66	SEC filing
Jan 15, 2014	Amendment	$86,393,818	-$115,236,274vs Mar 16, 2009	64	SEC filing
Jan 14, 2013	Amendment	$74,820,818	-$126,809,274vs Mar 16, 2009	59	SEC filing
Jan 13, 2012	Amendment	$67,323,740	-$134,306,352vs Mar 16, 2009	55	SEC filing
Jan 21, 2011	Amendment	$51,893,348	-$149,736,744vs Mar 16, 2009	46	SEC filing
Jan 20, 2010	Amendment	$205,403,655	$3,773,563vs Mar 16, 2009	109	SEC filing
Mar 16, 2009	Amendment	$201,630,092	No comparison	Not reported	SEC filing
Nov 21, 2005	Paper	Not reported	No comparison	Not reported	SEC filing

Offering details

Securities: Equity, Pooled investment fund
Exemptions: 06b, 3C, 3C.1
Duration over one year: Yes
Business combination: No

Sales commissions: $0 (estimated)
Finders' fees: $0 (estimated)
Form D file number: 021-86792

If applicable, employees of the recipient listed in item 12. are paid an amount equal to a percentage of the management fee paid to the Investment Manager (or its affiliate) attributable to certain assets under management.

Sales compensation recipients

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Recipient	CRD	Associated broker-dealer
TimeCapital Securities Corporation	000006845
G.research, LLC	000007353
Arete Wealth Management, LLC	000044856

Source: Form D, filed Nov 28, 2025. Minimum accepted may differ from a standard advertised minimum.

Fund connections

The linked fund shows its most recently reported ADV details.

Matched by reported Form D file number

GABELLI ASSOCIATES LIMITED

Investment adviser: GABELLI & COMPANY INVESTMENT ADVISERS, INC.

Gross asset value: $331M
Beneficial owners: 57
ADV minimum commitment: $1M

Reported in Form ADV on Jul 7, 2026. Fund assets and beneficial owners measure different things from Form D sales and investors.

Service providers

Fund administrator BNP PARIBAS BANK & TRUST CAYMAN LIMITED GRAND CAYMAN, Cayman Islands Investor statements: Yes (provided to all investors) Related to adviser: No

Auditor PRICEWATERHOUSECOOPERS GRAND CAYMAN, Cayman Islands

Custodian JEFFERIES LLC NEW YORK, New York, United States Related to adviser: No

Custodian STATE STREET BANK AND TRUST COMPANY BOSTON, Massachusetts, United States Related to adviser: No

Custodian UBS SECURITIES LLC NEW YORK, New York, United States Related to adviser: No

Marketer ARETE WEALTH MANAGEMENT, LLC CHICAGO, Illinois, United States Related to adviser: No

Marketer DELPHOS MMJ L.P. NEW YORK, New York, United States Related to adviser: No

Marketer NICOLO DUBINI MILANO, Italy Related to adviser: No

Marketer OCP CAPITAL, LLC WELLINGTON, Florida, United States Related to adviser: No

Marketer PAULLIER & CIA INTL. CORP. PANAMA, Panama Related to adviser: No

Marketer VICTOR PAULLIER & CIA MONTEVIDEO, Uruguay Related to adviser: No

Prime broker JEFFERIES LLC NEW YORK, New York, United States

Prime broker UBS SECURITIES LLC NEW YORK, New York, United States

Provider details

Annual audit: Yes
Prime brokers: Yes
Custodians: Yes
Administrator other than the adviser: Yes
External marketing: Yes

PRICEWATERHOUSECOOPERS
PCAOB 1266

JEFFERIES LLC
SEC 8-15074

STATE STREET BANK AND TRUST COMPANY
LEI 571474TGEMMWANRLN572

UBS SECURITIES LLC
SEC 8-22651

ARETE WEALTH MANAGEMENT, LLC
CRD 44856 · SEC 8-50854

DELPHOS MMJ L.P.
CRD 137389 · SEC 8-67083

OCP CAPITAL, LLC
CRD 143381 · SEC 8-67556

JEFFERIES LLC
CRD 2347 · SEC 8-15074

UBS SECURITIES LLC
CRD 7654 · SEC 8-22651

Filing source

Form ADV 2118089 · Jul 7, 2026 · Schedule D 7.B.(1), fund 805-2242459172

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

People & organizations

Current and past Form D appearances. These existing records do not establish a person's current role or uniquely identify them across issuers.

People and organizations reported in Form D filings
Name	Reported role
John Birch	Director
Vincent D. Enright	Director
Michael Gabelli	Director
Gabelli & Company Investment Advisers, Inc.	Executive
Gabelli Securities, Inc.	Executive, Promoter
Patrick J Guarino	Director
Douglas R. Jamieson	Director
Raffaele Rocco	Director
Anthonie C. Van Ekris	Director

Issuer details

Industry: Pooled Investment Fund (See others in industry)

Address:

Harney Westwood & Riegels Lp Craigmuir Chambers, Road Town
Tortola, D8, VG1110