# Brilliance Asset Management Limited

> Brilliance Asset Management Limited is an SEC-registered investment advisory firm in Hong Kong, Hong Kong, registered since 2016, reporting $500 million to $1 billion in regulatory assets under management in its Form ADV filing dated September 24, 2026.

- CRD: 282553
- Filed as: BRILLIANCE ASSET MANAGEMENT LIMITED
- Also doing business as: BRILLIANCE CAPITAL
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Hong Kong, Hong Kong
- Filing period: October 2026
- Form ADV filing dated: September 24, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/282553
- AdvisorCensus page: https://advisorcensus.com/firm/brilliance-asset-management-limited-hong-kong-282553

## Quick answers

**How is Brilliance Asset Management Limited compensated?**
On its Form ADV (Item 5.E, October 2026), Brilliance Asset Management Limited reports these compensation arrangements: a percentage of assets under its management; performance-based fees. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is Brilliance Asset Management Limited located?**
Brilliance Asset Management Limited's principal office is in Hong Kong, Hong Kong, according to its Form ADV.

**Is Brilliance Asset Management Limited registered with the SEC or a state?**
Brilliance Asset Management Limited is an SEC-registered investment advisory firm, registered since 2016. Status as filed: Approved. CRD 282553.

**How much does Brilliance Asset Management Limited manage?**
Brilliance Asset Management Limited reports $851,248,326 in regulatory assets under management in its Form ADV filing dated September 24, 2026 (100% discretionary).

**How have Brilliance Asset Management Limited's assets and staff changed since 2021?**
In the Form ADV data for Brilliance Asset Management Limited: Regulatory assets under management: $4,818,777,995 in the October 2021 data and $851,248,326 in the October 2026 data, down 82%. Total employees: 45 in October 2021 and 17 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Brilliance Asset Management Limited serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (4).

**Does Brilliance Asset Management Limited report any disciplinary disclosures?**
Reports 2 disclosure items on Form ADV Item 11: yes answers to 11.D(2) (another regulator's finding of a violation) and 11.D(4) (another regulator's order in the past ten years). Each question covers the firm and its advisory affiliates, and one event can produce several yes answers. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/282553

**What changed in Brilliance Asset Management Limited's recent Form ADV filings?**
In the December 2025 filing data: Employees performing advisory functions went from 4 to 5. Regulatory assets under management went from $846,311,659 to $936,527,922 (+11%).

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Performance-based fees

### Regulatory assets under management (Item 5.F)
- Total: $851,248,326
- Discretionary: $851,248,326
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 4 | $851,248,326 |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)

### Firm details
- Registered since: 2016 (10 years)
- Employees: 17 total, 5 performing advisory functions
- Wrap fee program participation: No
- Disclosures (Item 11): Reports 2 disclosure items on Form ADV Item 11.

### Item 11 questions answered yes
- 11.D(2): Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?
- 11.D(4): In the past ten years, has another federal regulator, a state regulator, or a foreign financial regulator entered an order against the firm or an advisory affiliate in connection with investment-related activity?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. The detail of each yes answer is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/282553

### Websites listed on Form ADV (Item 1.I)
- [brilliancecap.com](https://brilliancecap.com)

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $4,818,777,995 | 45 | September 28, 2021 |
| October 2022 | $2,677,473,689 | 24 | September 27, 2022 |
| October 2023 | $1,195,840,750 | 20 | September 26, 2023 |
| October 2024 | $686,606,566 | 14 | September 26, 2024 |
| October 2025 | $846,311,659 | 14 | January 26, 2025 |
| October 2026 | $851,248,326 | 17 | September 24, 2026 |

Regulatory assets under management: $4,818,777,995 in the October 2021 data and $851,248,326 in the October 2026 data, down 82%.
Total employees: 45 in October 2021 and 17 in October 2026.

## Changes in the filing (last 12 months)

### December 2025
- Employees performing advisory functions went from 4 to 5.
- Regulatory assets under management went from $846,311,659 to $936,527,922 (+11%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Brilliance Asset Management Limited (CRD 282553): Form ADV filing data as of October 2026.