# Rays Capital Partners Limited

> Rays Capital Partners Limited is an SEC-registered investment advisory firm in Central, Hong Kong, registered since 2017, reporting $500 million to $1 billion in regulatory assets under management in its Form ADV filing dated September 14, 2026.

- CRD: 171821
- Filed as: RAYS CAPITAL PARTNERS LIMITED
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Central, Hong Kong
- Filing period: October 2026
- Form ADV filing dated: September 14, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/171821
- AdvisorCensus page: https://advisorcensus.com/firm/rays-capital-partners-limited-central-171821

## Quick answers

**How is Rays Capital Partners Limited compensated?**
On its Form ADV (Item 5.E, October 2026), Rays Capital Partners Limited reports these compensation arrangements: a percentage of assets under its management; fixed fees (other than subscription fees); performance-based fees.

**How much does Rays Capital Partners Limited charge?**
Its Form ADV Part 2A brochure dated March 26, 2026 states: Asset-based fee: up to 2% of assets a year (the maximum the brochure states). Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is Rays Capital Partners Limited located?**
Rays Capital Partners Limited's principal office is in Central, Hong Kong, according to its Form ADV.

**Is Rays Capital Partners Limited registered with the SEC or a state?**
Rays Capital Partners Limited is an SEC-registered investment advisory firm, registered since 2017. Status as filed: Approved. CRD 171821.

**How much does Rays Capital Partners Limited manage?**
Rays Capital Partners Limited reports $547,185,000 in regulatory assets under management in its Form ADV filing dated September 14, 2026 (100% discretionary).

**How have Rays Capital Partners Limited's assets and staff changed since 2021?**
In the Form ADV data for Rays Capital Partners Limited: Regulatory assets under management: $849,530,000 in the October 2021 data and $547,185,000 in the October 2026 data, down 36%. Total employees: 26 in October 2021 and 23 in October 2026. Assets under management move with markets as well as with clients coming and going.

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

**Which custodians does Rays Capital Partners Limited use?**
Rays Capital Partners Limited's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Citibank N.A., Hong Kong Branch, Interactive Brokers LLC and UOB KAY Hian (Hong Kong) Limited as custodians holding 10% or more of its separately managed account assets.

**Does Rays Capital Partners Limited report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/171821

**What changed in Rays Capital Partners Limited's recent Form ADV filings?**
In the April 2026 filing data: Regulatory assets under management went from $362,758,000 to $547,185,000 (+51%).

## From the Form ADV filing

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

### Fees and minimums (Form ADV Part 2A brochure dated March 26, 2026)

- Asset-based fee: up to 2% of assets a year (the maximum the brochure states)

> Currently, the Adviser, among the Funds it manages, receives management fees up to two percent (2.0%) per annum of the net asset value of the relevant Funds.

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- Citibank N.A., Hong Kong Branch
- Interactive Brokers LLC
- UOB KAY Hian (Hong Kong) Limited

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

### Regulatory assets under management (Item 5.F)
- Total: $547,185,000
- Discretionary: $547,185,000
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| High net worth individuals | Fewer than 5 | $16,234,000 |
| Pooled investment vehicles (other than investment companies and business development companies) | 5 | $514,588,000 |
| Corporations or other businesses not listed above | Fewer than 5 | $16,363,000 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses
- Portfolio management for pooled investment vehicles (other than investment companies)
- Portfolio management for businesses (other than small businesses) or institutional clients
- Publication of periodicals or newsletters

### Firm details
- Registered since: 2017 (9 years)
- Employees: 23 total, 14 performing advisory functions
- Wrap fee program participation: No
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Websites listed on Form ADV (Item 1.I)
- rayscapital.com

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $849,530,000 | 26 | March 22, 2021 |
| October 2022 | $1,114,580,000 | 33 | August 19, 2022 |
| October 2023 | $682,049,000 | 32 | July 3, 2023 |
| October 2024 | $472,376,000 | 28 | March 25, 2024 |
| October 2025 | $362,758,000 | 22 | May 6, 2025 |
| October 2026 | $547,185,000 | 23 | September 14, 2026 |

Regulatory assets under management: $849,530,000 in the October 2021 data and $547,185,000 in the October 2026 data, down 36%.
Total employees: 26 in October 2021 and 23 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Regulatory assets under management went from $362,758,000 to $547,185,000 (+51%).

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Rays Capital Partners Limited (CRD 171821): Form ADV filing data as of October 2026.