Firm profile

Dalton Investments, Inc..

EL SEGUNDO, CACRD 308609Registration Status: ApprovedEffective since July 30, 2021SEC # 801-121986Latest ADV March 30, 2026

Dalton Investments, Inc. is an SEC registered investment adviser organized as a corporation with a primary office location in El Segundo, CA. Its latest Form ADV filing, dated March 30, 2026, reports $5.7B in regulatory assets under management, 46 employees, 7 offices, and 40 accounts.

Assets Under Management
$5.7B
Employees
46
Offices
7 offices
Total Clients
40

Associated firm names

7 names listed
  • DALTON ADVISORY KK (JAPAN AFFILIATE)
  • DALTON KOREA CO., LTD. (KOREA AFFILIATE)
  • DALTON INVESTMENTS, INC.
  • DALTON INVESTMENTS LLC

Leadership

6 roles identified
CEOFrank G. Combs
CEOSarah B. Alfandari
CCOChristopher A. Ha

Advisory services offered

3 types reported
Portfolio management for businesses
Portfolio management for individuals and small businesses
Portfolio management for pooled investment vehicles

Fee models offered

2 types reported
Asset based fees
Performance-based fees

Offices & Contact

Primary office

EL SEGUNDO, California, United States

Loading map…

Primary office regionOther reported regions

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

California

EL SEGUNDOPrimary office · REDONDO BEACH

Australia

CROWS NEST, NSW

Hong Kong

HONG KONG

India

MUMBAI, MAHARASHTRA

Japan

TOKYO

Korea, South

SEOCHO-GU, SEOUL

7 office records listed · 7 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$5.7Bas of March 30, 2026
Discretionary100.0%
$5.7B
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 67.5% of total clients.
Top client categories% of clientsClients
1
Pooled Investment Vehicles
67.5%
27
2
Pension Plans
15.0%
6
3
HNWI
5.0%
2
4
Charitable
5.0%
2
5
Insurance Cos.
2.5%
1

Assets under management Growth by Quarter

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

Total AUM$5.7B
Total Accounts40
10Y AUM Change+$3.9B (+219.1%)

Private Funds

Private funds reported by Dalton Investments, Inc..

Loading private fund disclosures…

Employee Growth by Quarter

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

Total Employees46
Clients per Employee1:1
10Y Employee Change+5 (+12.2%)

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%
ROSENWALD CAPITAL MANAGEMENT, INC.Direct owner · Schedule AInterest in DALTON INVESTMENTS, INC.
50% to < 75%
WALKING ROCK NEVADA, INC.Direct owner · Schedule AInterest in DALTON INVESTMENTS, INC.
10% to < 25%
IRADNAFLA LLCDirect owner · Schedule AInterest in DALTON INVESTMENTS, INC.
5% to < 10%
ROSENWALD FAMILY TRUSTIndirect owner · Schedule BInterest in ROSENWALD CAPITAL MANAGEMENT, INC.
75%+
FRANK GIFFORD COMBSIndirect owner · Schedule BInterest in WALKING ROCK NEVADA, INC.
75%+
SARAH BARBARA ALFANDARIIndirect owner · Schedule BInterest in IRADNAFLA LLC
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 Dalton Investments, Inc...

Reported ownership and control details

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

16 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1SARAH BARBARA ALFANDARICHIEF EXECUTIVE OFFICER AND PRESIDENT, AND DIRECTOR OF THE BOARD OF DIRECTORS, DALTON INVESTMENTS, INC.IndividualDALTON INVESTMENTS, INC.Less than 5%Code NAYesCHIEF EXECUTIVE OFFICER AND PRESIDENT, AND DIRECTOR OF THE BOARD OF DIRECTORS, DALTON INVESTMENTS, INC.09/2020Schedule APDF page 93
2FRANK GIFFORD COMBSPORTFOLIO MANAGER, AND DIRECTOR OF THE BOARD OF DIRECTORS, DALTON INVESTMENTS, INC.IndividualDALTON INVESTMENTS, INC.Less than 5%Code NAYesPORTFOLIO MANAGER, AND DIRECTOR OF THE BOARD OF DIRECTORS, DALTON INVESTMENTS, INC.12/2019Schedule APDF page 93
3IAIN NA DOUGLASCHIEF MARKETING OFFICER, DALTON INVESTMENTS, INC.IndividualDALTON INVESTMENTS, INC.Less than 5%Code NAYesCHIEF MARKETING OFFICER, DALTON INVESTMENTS, INC.03/2021Schedule APDF page 93
4CHRISTOPHER ALFRED HASECRETARY, CHIEF COMPLIANCE OFFICER AND COUNSEL, DALTON INVESTMENTS, INC.IndividualDALTON INVESTMENTS, INC.Less than 5%Code NAYesSECRETARY, CHIEF COMPLIANCE OFFICER AND COUNSEL, DALTON INVESTMENTS, INC.01/2021Schedule APDF page 93
5JANET NA HUNPADONGRATTREASURER, CHIEF OPERATING OFFICER AND CHIEF FINANCIAL OFFICER, DALTON INVESTMENTS, INC.IndividualDALTON INVESTMENTS, INC.Less than 5%Code NAYesTREASURER, CHIEF OPERATING OFFICER AND CHIEF FINANCIAL OFFICER, DALTON INVESTMENTS, INC.01/2022Schedule APDF page 93
6JAMES BENNO ROSENWALDCHAIRMAN OF THE BOARD OF DIRECTORS, AND CHIEF INVESTMENT OFFICER, DALTON INVESTMENTS, INC.IndividualDALTON INVESTMENTS, INC.Less than 5%Code NAYesCHAIRMAN OF THE BOARD OF DIRECTORS, AND CHIEF INVESTMENT OFFICER, DALTON INVESTMENTS, INC.09/2020Schedule APDF page 94
7JOCELYN MAY ROSENWALDDIRECTOR OF THE BOARD OF DIRECTORS, DALTON INVESTMENTS, INC.IndividualDALTON INVESTMENTS, INC.Less than 5%Code NAYesDIRECTOR OF THE BOARD OF DIRECTORS, DALTON INVESTMENTS, INC.09/2020Schedule APDF page 94
8ROSENWALD CAPITAL MANAGEMENT, INC.MAJORITY OWNER OF DALTON INVESTMENTS, INC.Domestic entityDALTON INVESTMENTS, INC.50% to less than 75%Code DYesMAJORITY OWNER OF DALTON INVESTMENTS, INC.07/2024Schedule APDF page 94
9CRAIG ALAN MERCERCHIEF RESEARCH OFFICER AND CHIEF SUSTAINABILITY OFFICERIndividualDALTON INVESTMENTS, INC.Less than 5%Code NAYesCHIEF RESEARCH OFFICER AND CHIEF SUSTAINABILITY OFFICER08/2024Schedule APDF page 94
10WALKING ROCK NEVADA, INC.OWNER OF DALTON INVESTMENTS, INC.Domestic entityDALTON INVESTMENTS, INC.10% to less than 25%Code BNoOWNER OF DALTON INVESTMENTS, INC.07/2024Schedule APDF page 94
11IRADNAFLA LLCOWNER OF DALTON INVESTMENTS, INC.Domestic entityDALTON INVESTMENTS, INC.5% to less than 10%Code ANoOWNER OF DALTON INVESTMENTS, INC.07/2024Schedule APDF page 94
12ROSENWALD FAMILY TRUSTOWNERDomestic entityROSENWALD CAPITAL MANAGEMENT, INC.75% or moreCode EYesOWNER12/1997Schedule BPDF page 94
13JAMES BENNO ROSENWALDTRUSTEEIndividualROSENWALD FAMILY TRUSTPercentage not specifiedCode FYesTRUSTEE12/1997Schedule BPDF page 94
14LAURA PARKER ROSENWALDTRUSTEEIndividualROSENWALD FAMILY TRUSTPercentage not specifiedCode FYesTRUSTEE12/1997Schedule BPDF page 94
15FRANK GIFFORD COMBSCHIEF EXECUTIVE OFFICERIndividualWALKING ROCK NEVADA, INC.75% or moreCode EYesCHIEF EXECUTIVE OFFICER10/2002Schedule BPDF page 94
16SARAH BARBARA ALFANDARIMEMBERIndividualIRADNAFLA LLC75% or moreCode EYesMEMBER05/2020Schedule BPDF page 94

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 12:05:35 PM

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 actions1 Yes4 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?Yes
  • 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
Additional DRP filings 2 source blocks

Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.

regulatory · block 1DALTON INVESTMENTS LLCPDF pages 95–97
Advisory affiliate name — filed text
DALTON INVESTMENTS LLC
Regulator name — filed text
SECURITIES AND FUTURES COMMISSION OF KOREA
Monetary/Fine Amount — filed text
$ 6,700.00
How was matter resolved — filed text
Order

Action status / disposition — filed text

SEE ABOVE.
Other filed details

Description of allegations — filed text

IN SEPTEMBER 2018, THE KOREAN SECURITIES AND FUTURES COMMISSION ("SFC") DETERMINED TO IMPOSE ON DALTON INVESTMENTS LLC ("DALTON") AN "ADMINISTRATIVE FINE" OF 7,500,000 KRW (APPROXIMATELY $6,700 USD), WHICH DALTON PAID IN DUE COURSE. THE SFC ALLEGED THAT DALTON, ON BEHALF OF ONE OF THE FUNDS UNDER DALTON'S MANAGEMENT, PLACED AN ORDER IN JULY 2017 TO ENGAGE IN A SHORT SALE IN KOREA WITHOUT BORROWING THE SECURITIES TO BE SOLD, VIOLATING THE SHORT SALE RESTRICTION PROVISIONS IN THE FINANCIAL INVESTMENT SERVICES AND CAPITAL MARKETS ACT OF KOREA. THIS MATTER ARISES OUT OF THE FOLLOWING: DALTON, ON BEHALF OF ONE OF ITS FUNDS, REQUESTED ITS PRIME BROKER TO LOCATE AND MAKE AVAILABLE SHARES OF A SECURITY WITH AN INTENT TO SELL THE SHARES SHORT. AFTER DALTON'S PRIME BROKER APPROVED THE REQUEST, DALTON PLACED A SHORT SALE TRADE. THEREAFTER, THE EXECUTING BROKER IN KOREA NOTIFIED DALTON THAT THE TRADE WAS FAILING BECAUSE THE SHARES HAD NOT BEEN PLACED IN DALTONFUND'S INVESTOR REGISTRATION CODE ("IRC") ACCOUNT BUT RATHER WERE IN THE PRIME BROKER'S SWAP IRC ACCOUNT. TO RESOLVE THIS PROBLEM, THE TRADE WAS SETTLED ON TIME AFTER THE EXECUTING BROKER DELIVERED THE SHARES FROM ITSINVENTORY. UPON LEARNING OF THIS ISSUE, DALTON IMMEDIATELY PURCHASED THE SHARES IN THE OPEN MARKET AND RETURNED THE SHARES TO THE EXECUTING BROKER.

Sanction detail — filed text

SEE ABOVE.
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
109538
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DALTON INVESTMENTS LLC
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:

SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SECURITIES AND FUTURES COMMISSION OF KOREA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/25/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
DALTON INVESTMENTS LLC
6.
Principal Product Type:
Other
Other Product Types: 
PRIVATE FUND
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN SEPTEMBER 2018, THE KOREAN SECURITIES AND FUTURES COMMISSION ("SFC") DETERMINED TO IMPOSE ON DALTON INVESTMENTS LLC
("DALTON") AN "ADMINISTRATIVE FINE" OF 7,500,000 KRW (APPROXIMATELY $6,700 USD), WHICH DALTON PAID IN DUE COURSE. THE SFC ALLEGED
THAT DALTON, ON BEHALF OF ONE OF THE FUNDS UNDER DALTON'S MANAGEMENT, PLACED AN ORDER IN JULY 2017 TO ENGAGE IN A SHORT SALE IN
KOREA WITHOUT BORROWING THE SECURITIES TO BE SOLD, VIOLATING THE SHORT SALE RESTRICTION PROVISIONS IN THE FINANCIAL INVESTMENT
SERVICES AND CAPITAL MARKETS ACT OF KOREA. THIS MATTER ARISES OUT OF THE FOLLOWING: DALTON, ON BEHALF OF ONE OF ITS FUNDS,
REQUESTED ITS PRIME BROKER TO LOCATE AND MAKE AVAILABLE SHARES OF A SECURITY WITH AN INTENT TO SELL THE SHARES SHORT. AFTER
DALTON'S PRIME BROKER APPROVED THE REQUEST, DALTON PLACED A SHORT SALE TRADE. THEREAFTER, THE EXECUTING BROKER IN KOREA NOTIFIED
DALTON THAT THE TRADE WAS FAILING BECAUSE THE SHARES HAD NOT BEEN PLACED IN DALTONFUND'S INVESTOR REGISTRATION CODE ("IRC")
ACCOUNT BUT RATHER WERE IN THE PRIME BROKER'S SWAP IRC ACCOUNT. TO RESOLVE THIS PROBLEM, THE TRADE WAS SETTLED ON TIME AFTER THE
EXECUTING BROKER DELIVERED THE SHARES FROM ITSINVENTORY. UPON LEARNING OF THIS ISSUE, DALTON IMMEDIATELY PURCHASED THE SHARES
IN THE OPEN MARKET AND RETURNED THE SHARES TO THE EXECUTING BROKER.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
09/04/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 6,700.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
SEE ABOVE.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
SEE ABOVE.
regulatory · block 2DALTON INVESTMENTS LLCPDF pages 97–98
Advisory affiliate name — filed text
DALTON INVESTMENTS LLC
Regulator name — filed text
FINANCIAL SUPERVISORY AUTHORITY OF NORWAY
Monetary/Fine Amount — filed text
$ 12,000.00
How was matter resolved — filed text
Order

Action status / disposition — filed text

SEE ABOVE.
Other filed details

Description of allegations — filed text

IN MARCH 2016, THE FINANCIAL SUPERVISORY AUTHORITY OF NORWAY ("FINANSTILSYNET") SENT A LETTER TO DALTON INVESTMENTS LLC ("DALTON"),NOTIFYING IT OF THE FINANSTILSYNET'S DECISION TO IMPOSE A CHARGE OF 100,000 NOK (APPROXIMATELY $12,000 USD) FOR VIOLATING THE NOTIFICATION REQUIREMENT UNDER NORWEGIAN LAW. NORWEGIAN LAW REQUIRES THAT A NOTIFICATION BEGIVEN TO THE FINANSTILSYNET IF A PERSON'S PROPORTION OF SHARES OF A PORTFOLIO COMPANY FALLS BELOW 10%. ON JULY 7, 2015, A SALE BY DALTON, ON BEHALF OF ITS CLIENTS/FUNDS, RESULTED IN ITS OWNERSHIP OF A PORTFOLIO COMPANY DECREASING FROM 10.14% TO 9.998% ON AN AGGREGATED BASIS. DALTON FILED THE REPORT ON JULY 10, 2015, WHICH THEFINANSTILSYNET DID NOT DEEM AS "IMMEDIATE" UNDER NORWEGIAN LAW. DALTON PAID THE PENALTY IN DUE COURSE.

Sanction detail — filed text

SEE ABOVE.
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
109538
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DALTON INVESTMENTS LLC
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINANCIAL SUPERVISORY AUTHORITY OF NORWAY

2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/28/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
15/6983
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
DALTON INVESTMENTS LLC
6.
Principal Product Type:
Other
Other Product Types: 
FUNDS AND SEPARATELY MANAGED ACCOUNTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN MARCH 2016, THE FINANCIAL SUPERVISORY AUTHORITY OF NORWAY ("FINANSTILSYNET") SENT A LETTER TO DALTON INVESTMENTS LLC
("DALTON"),NOTIFYING IT OF THE FINANSTILSYNET'S DECISION TO IMPOSE A CHARGE OF 100,000 NOK (APPROXIMATELY $12,000 USD) FOR
VIOLATING THE NOTIFICATION REQUIREMENT UNDER NORWEGIAN LAW. NORWEGIAN LAW REQUIRES THAT A NOTIFICATION BEGIVEN TO THE
FINANSTILSYNET IF A PERSON'S PROPORTION OF SHARES OF A PORTFOLIO COMPANY FALLS BELOW 10%. ON JULY 7, 2015, A SALE BY DALTON, ON
BEHALF OF ITS CLIENTS/FUNDS, RESULTED IN ITS OWNERSHIP OF A PORTFOLIO COMPANY DECREASING FROM 10.14% TO 9.998% ON AN
AGGREGATED BASIS. DALTON FILED THE REPORT ON JULY 10, 2015, WHICH THEFINANSTILSYNET DID NOT DEEM AS "IMMEDIATE" UNDER NORWEGIAN
LAW. DALTON PAID THE PENALTY IN DUE COURSE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
04/14/2016
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 12,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
SEE ABOVE.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
SEE ABOVE.

* 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.