Firm profile

Vulpes Investment Management Private Limited

SINGAPORE, SingaporeCRD 161048Registration Status: ApprovedEffective since December 16, 2025SEC # 801-134470Latest ADV March 30, 2026

Vulpes Investment Management Private Limited is an SEC registered investment adviser with a primary office location in Singapore, Singapore. Its latest Form ADV filing, dated March 30, 2026, reports $97M in regulatory assets under management, 8 employees, 1 office, and 4 accounts.

Assets Under Management
$97M
Employees
8
Offices
1 office
Total Clients
<5

Associated firm names

1 name listed
  • VULPES INVESTMENT MANAGEMENT PRIVATE LIMITED

Leadership

3 roles identified
CEOChee Seng N. Ng
CCOChee Seng N. Ng
CIOWilson N. Er

Advisory services offered

1 types reported
Portfolio management for pooled investment vehicles

Fee models offered

2 types reported
Asset based fees
Performance-based fees

Offices & Contact

Primary office

SINGAPORE, Singapore

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Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

Singapore

SINGAPOREPrimary office

1 office records listed · 1 total offices reported. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$97Mas of March 30, 2026
Discretionary100.0%
$97M
100% of total RAUM100.0%
Non-discretionary0.0%
$0
0% of total RAUM0.0%
All regulatory assets under management are discretionary.

Client Coverage Demographics

Top client segmentPooled Investment Vehicles represent 100.0% of total clients.
Top client categories% of clientsClients
1
Pooled Investment Vehicles
100.0%
4

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$97M
Total Accounts4
10Y AUM Change$-61M (-38.7%)

Private Funds

Private funds reported by Vulpes Investment Management Private Limited

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Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees8
Clients per Employee1:1
10Y Employee Change0 (0.0%)

Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.


Ownership

Reported direct and indirect ownership ranges

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
VULPES INVESTMENT MANAGEMENT LIMITEDDirect owner · Schedule AInterest in VULPES INVESTMENT MANAGEMENT PRIVATE LIMITED
75%+
LOMAX HOLDINGS LIMITEDIndirect owner · Schedule BInterest in VULPES INVESTMENT MANAGEMENT LIMITED
75%+
KAREN DANIELLE FRASERIndirect owner · Schedule BInterest in LOMAX HOLDINGS LIMITED
75%+

Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Vulpes Investment Management Private Limited.

Reported ownership and control details

Form ADV · Filing date 2026-03-30 · Schedules A and B

8 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1STEPHEN CHARLES DIGGLEFOUNDER AND DIRECTORIndividualVULPES INVESTMENT MANAGEMENT PRIVATE LIMITEDLess than 5%Code NAYesFOUNDER AND DIRECTOR03/2002Schedule APDF page 20
2VULPES INVESTMENT MANAGEMENT LIMITED100% CORPORATE SHAREHOLDERForeign entityVULPES INVESTMENT MANAGEMENT PRIVATE LIMITED75% or moreCode EYes100% CORPORATE SHAREHOLDER04/2011Schedule APDF page 20
3WILLIAM OVERLOCK CRISPINDIRECTOR, CHIEF LEGAL OFFICERIndividualVULPES INVESTMENT MANAGEMENT PRIVATE LIMITEDLess than 5%Code NAYesDIRECTOR, CHIEF LEGAL OFFICER09/2022Schedule APDF page 20
4WILSON NMN ERCHIEF INVESTMENT OFFICERIndividualVULPES INVESTMENT MANAGEMENT PRIVATE LIMITEDLess than 5%Code NAYesCHIEF INVESTMENT OFFICER08/2025Schedule APDF page 20
5CHEE SENG NMN NGCHIEF COMPLIANCE OFFICER, CHIEF EXECUTIVE OFFICERIndividualVULPES INVESTMENT MANAGEMENT PRIVATE LIMITEDLess than 5%Code NAYesCHIEF COMPLIANCE OFFICER, CHIEF EXECUTIVE OFFICER01/2021Schedule APDF page 20
6NICHOLAS ROBERT THIBEAULTDIRECTORIndividualVULPES INVESTMENT MANAGEMENT PRIVATE LIMITEDLess than 5%Code NAYesDIRECTOR11/2024Schedule APDF page 20
7LOMAX HOLDINGS LIMITED100% CORPORATE SHAREHOLDERForeign entityVULPES INVESTMENT MANAGEMENT LIMITED75% or moreCode EYes100% CORPORATE SHAREHOLDER02/2012Schedule BPDF page 21
8KAREN DANIELLE FRASER100% SHAREHOLDERIndividualLOMAX HOLDINGS LIMITED75% or moreCode EYes100% SHAREHOLDER02/2012Schedule BPDF page 21

Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.

Compliance & Disclosures

Filing dated 3/30/2026 6:48:50 AM

Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.

RIA or supervised-person involvementThe RIA reported that none of the events below involve the firm or its supervised persons.RIA responseNo
AFelonies2 No

In the past ten years, have you or any advisory affiliate:

  • A1Been convicted of or pleaded guilty or no contest to a felony?No
  • A2Been charged with a felony?No
BMisdemeanors2 No

In the past ten years, have you or any advisory affiliate:

  • B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
  • B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions5 No

Has the SEC or CFTC ever:

  • C1Found you or an advisory affiliate made a false statement or omission?No
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?No
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?No
DOther regulatory actions5 No

Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:

  • D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
  • D2Found you or an advisory affiliate violated investment-related regulations or statutes?No
  • D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions4 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?No
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?No
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
  • GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No

(1) Court actions

Has a domestic or foreign court:

  • H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
  • H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
  • H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No

(2) Pending civil proceedings

  • H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No

* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.