Form D · Hedge Fund

Marco Polo Pure China Fund

Hong Kong, K3 · CIK 0001551779

Offering snapshot reported Jun 21, 2012 · SEC filing

Reported sold: $46M
Investors reported: 325
Minimum accepted: $50K
First sale: Sep 23, 2004

What changed?

Latest filing versus its linked predecessor, where available.

No comparable changes in the displayed metrics.

Filing history

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Filed	Filing type	Reported sold	Change vs linked filing	Investors	Source
Jun 21, 2012	Initial	$46,000,000	No comparison	325	SEC filing

Offering details

Securities: Pooled investment fund
Exemptions: 3C, 3C.7
Duration over one year: Yes
Business combination: No

Sales commissions: $0
Finders' fees: $0
Form D file number: 021-180071

Total Amount Sold is the total amount of money raised from US investors.

A Sales Charge of up to 5% of the subscription amount may be allowed or paid, at the discretion of the Manager, to dealers in securities or other intermediaries through whom applications for Participating Shares are received.

Sales compensation recipients

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Recipient	CRD	Associated broker-dealer
Pappas Financial	None	The Enterprise Securities Company · CRD 26598
Molewski Financial Partners	109437	M Holdings Securities, Inc · CRD 43285
San Diego Private Bank	None

Source: Form D, filed Jun 21, 2012. 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

MARCO POLO PURE CHINA FUND

Investment adviser: MARCO POLO PURE ASSET MANAGEMENT LIMITED

Gross asset value: $6.98M
Beneficial owners: 59
ADV minimum commitment: $250K

Reported in Form ADV on Mar 30, 2026. Fund assets and beneficial owners measure different things from Form D sales and investors.

Service providers

Fund administrator CITIC SECURITIES FUND SERVICES (ASIA) LTD HONG KONG, Hong Kong Investor statements: Yes (provided to all investors) Related to adviser: No

Auditor PRICEWATERHOUSECOOPERS GEORGE TOWN, Cayman Islands

Custodian CHINA MERCHANTS SECURITIES (HK) CO. LTD HONG KONG, Hong Kong Related to adviser: No

Custodian SHENWAN HONGYUAN SECURITIES (H.K.) LIMITED HONG KONG, Hong Kong Related to adviser: No

Marketer AICO ALTERNATIVE INVESTMENTS COMPANY AG ZURICH, Switzerland Related to adviser: No

Marketer FEDERAL FUN INVESTMENT ADVISORS LIMITED TAIPEI, Taiwan, Republic of China Related to adviser: No

Marketer FINANCIAL PARTNERS HOLDINGS LIMITED HONG KONG, Hong Kong Related to adviser: No

Marketer PAPPAS FINANCIAL FARMINGTON HILLS, Michigan, United States Related to adviser: No

Marketer PRESIDENT SECURITIES (HONG KONG) LIMITED HONG KONG, Hong Kong Related to adviser: No

Marketer SAN DIEGO PRIVATE BANK LA JOLLA, California, United States Related to adviser: No

Marketer SUPREME FINANCIAL SERVICES LIMITED TAIPEI, Taiwan, Republic of China Related to adviser: No

Provider details

Annual audit: Yes
Prime brokers: No
Custodians: Yes
Administrator other than the adviser: Yes
External marketing: Yes

PRICEWATERHOUSECOOPERS
PCAOB 1266

Filing source

Form ADV 2066710 · Mar 30, 2026 · Schedule D 7.B.(1), fund 805-5245673180

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
Aaron Scott Boesky	Director, Executive
Chris Wing Mui Tang	Director, Executive

Issuer details

Industry: Pooled Investment Fund (See others in industry)

Address:

Suite 1203, The Centrium 60 Wyndham Street, Central
Hong Kong, K3, HKG