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SEC EDGAR · Form D
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Hedge  · May 15, 2026  · 06b

Satori Fund Ltd.

Offering
$31.0M
Analysis

The four-GP structure—with two principals (Daniel and Jennifer Niles) plus Kevin Lincoln and Niles Investment Management as entity co-signatories—indicates a formalized partnership where management company liability is separated from individual operator names, a setup common when building institutional credibility or preparing for delegation of operational duties across multiple strategies.

The complete absence of prior EDGAR filings from any variation of Niles Investment Management signals this is a debut institutional vehicle; the hedge fund choice (rather than a fund of funds or multi-strategy platform) combined with the 06b exemption reflects a manager launching into regulated AUM territory for the first time, likely migrating from private advisory or family office relationships.

A May 2026 filing for a $31M hedge fund target arrives during a period of LP rebalancing into alternatives after equity volatility, and the tight pre-existing-relationships-only exemption choice suggests the managers are funding this raise through a specific cohort of known LPs rather than pursuing broad market access—typical for emerging managers validating product-market fit before larger infrastructure investment.

Verify whether Daniel and Jennifer Niles hold current Series 7 or Series 65 registrations and whether Kevin Lincoln is bound by non-compete or key-person clauses from prior roles, as these individuals' regulatory history and availability will directly affect fund continuity if either principal becomes unavailable during the fund's life.

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Niles Investment Management, LLC · Daniel Niles · Jennifer Niles · Kevin Lincoln
SEC EDGAR →
0002017639-26-000001