Private fund adviser · Hong Kong, Hong Kong
Willing Capital Management Limited
SEC-registered investment adviser · CRD 310353 · SEC 801-119495
At a glance
Willing Capital Management Limited is an SEC-registered investment adviser based in Hong Kong, Hong Kong, with $806 million in regulatory assets under management as of its Form ADV filed March 24, 2026. Its largest client group by assets is pooled investment vehicles. By Form ADV it is a private fund adviser, ranked 2,531st of 4,686 private fund advisers and 6,060th of 17,210 SEC-registered advisers by assets.
Main office +85239791800As filed on Form ADV
- Regulatory AUM
- $806M
- Rank among private fund advisers
- #2,531 of 4,686
- Rank among all SEC RIAs
- #6,060 of 17,210
- Clients
- 6
- Accounts
- 6
- Discretionary
- 100% of AUM
- Employees
- 13
- Advisory staff
- 7
- Offices
- 1
Owners and executives on its Form ADV
- Xiao LinChief Investment Officer, Shareholder, Director
- Yanmin MaChief Operating Officer
- Xinyue LiuShareholder
Custody and brokerage
Custodian
Willing Capital Management Limited’s Form ADV lists no custodian for separately managed accounts. Firms report one only when they manage $10 million or more in those accounts.
Who it serves
| Client type | Clients | Regulatory AUM | Share |
|---|---|---|---|
| Pooled investment vehicles | 6 | $806M | 100% |
Private funds
Willing Capital Management Limited reports 1 private funds with $624M in gross assets: hedge funds (Form ADV Item 7.B).
Disciplinary disclosures
Willing Capital Management Limited reports no disciplinary disclosures in Item 11 of Form ADV. Read the details on the SEC’s adviser search ↗
Services
- Portfolio management for pooled investment vehicles
How it’s paid
- A percentage of assets under management
- Performance-based fees
Form ADV and brochures on the SEC’s adviser search ↗
AtlasMembers
The full record on Willing Capital Management Limited
Ten years of SEC filings, its owners and contacts, and how it stacks up against its peers. Atlas members see all of it.
- Assets, accounts, clients and staff, 4 years of filings
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- Growth over one, three and five years
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- Rank against 2,219 peers of its type and size
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- Owners and executives, with titles and stakes
- 3 namedLocked
- Main office, fax and compliance officer
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- Filing changes this year, with alerts
- 1Locked
Free while Atlas launches: create a free account and confirm your email. Every figure comes from SEC filings.
Background
Questions
How much does Willing Capital Management Limited manage?
Willing Capital Management Limited reports $806 million in regulatory assets under management across 6 accounts, 100% of it on a discretionary basis, on its Form ADV filed March 24, 2026.
What kind of firm is Willing Capital Management Limited?
Willing Capital Management Limited is a private fund adviser by its Form ADV answers. Private funds are at least half of its business by assets.
Who are Willing Capital Management Limited’s clients?
By assets, its largest client types are pooled investment vehicles ($806 million, 6 clients).
Does Willing Capital Management Limited manage private funds?
Yes. It reports 1 private funds with $624 million in gross assets, including hedge funds.
Does Willing Capital Management Limited have any disciplinary history?
Willing Capital Management Limited reports no disciplinary disclosures in Item 11 of its Form ADV. Check the SEC’s adviser search for the latest record.
Where these numbers come from
Every figure is Willing Capital Management Limited’s own answer on its latest Form ADV, from the SEC’s registered-adviser list as of October 1, 2026: regulatory assets and accounts (Item 5.F), clients by type (5.D), employees (5.A and 5.B), compensation (5.E) and services (5.G). Custodians come from Schedule D 5.K(3) of its latest filing (2026-03-24), which lists those holding 10% or more of separately managed account assets and the amount at each. “Hybrid” means some employees are also registered representatives of a broker-dealer (Item 5.B(2)); affiliated broker-dealers are the related persons it lists in Item 7.A and Schedule D. Firm type comes from its own answers: broker-dealer firms are registered broker-dealers themselves (Item 6.A); private fund advisers manage mostly private funds (Item 7.B, 5.D); wealth managers manage at least half their assets for individuals (5.D). Ranks compare it by regulatory assets with every SEC-registered adviser and with firms of its type. Figures are as of the firm’s last annual update, so they can lag recent deals and market moves. Regulatory AUM counts assets the firm continuously supervises and can differ from what a firm markets.
Not an endorsement or a recommendation. Before hiring any adviser, read its Form ADV Part 2A brochure and check its record on the SEC’s adviser search. How to check a financial advisor →