Orion Commodities Offshore Fund Ltd. is a hedge fund based in Grand Cayman, Cayman Islands. According to its most recent Form D, filed Apr 22, 2026, the fund has sold $499,850,349 of interests to 93 investors since its first sale in Apr 2017. The minimum investment it accepts from an outside investor is $10,000,000. It relies on the Section 3(c)(7) exclusion, so investors generally must be qualified purchasers. The offering uses Rule 506(b), which does not permit general solicitation. Related persons named in the filing include John Fallon; Brian Burkholder; Daniel Walsh.
Performance
No verified returns have been reported for this fund. Hedge fund returns are not part of SEC filings; managers report them to HedgeMountain directly.
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- Total raised
- $499,850,349Cumulative sales reported on Form D
- Investors
- 93
- First sale
- Apr 1, 2017
- Minimum investment
- $10,000,000
- Who can invest
- Qualified purchasersSection 3(c)(7): generally $5M+ in investments
- Offering exemption
- Rule 506(b)No general advertising
- Key people and entities
- John Fallon; Brian Burkholder; Daniel Walsh
- Latest Form D
- Apr 22, 2026
From SEC filings, not verified. This page republishes the fund's Form D as filed. It is not an offer, solicitation or recommendation, and HedgeMountain has not reviewed the fund. “Raised” is cumulative sales, not current assets or performance. Private funds are speculative, illiquid and generally limited to accredited investors or qualified purchasers. Full disclosures
Size compared with every hedge fund
Raised more than 75% of the 2,343 hedge funds based in Cayman Islands, and more than 81% of all 10,157 that report sales.