Point Olema Amends Form D/A, Confirms 3(c)(7) Exemption

TL;DR

**Point Olema's D/A filing confirms its private fund status, targeting only wealthy investors.**

AI Summary

Point Olema Diversifying Assets - Private Investments Portfolio, L.P. filed an amended Form D/A on March 23, 2026, updating its notice of exempt offering of securities. This filing specifically indicates the fund operates under Section 3(c)(7) of the Investment Company Act, meaning it caters to 'qualified purchasers' and is exempt from certain regulations. For investors, this matters because it confirms the fund's strategy of targeting sophisticated investors and its operational framework as a private investment vehicle, which typically implies higher risk and less transparency than publicly traded funds.

Why It Matters

This filing confirms Point Olema's status as a private fund for 'qualified purchasers,' meaning it's not subject to the same public scrutiny as a mutual fund, which impacts transparency and accessibility for average investors.

Risk Assessment

Risk Level: medium — Private investment funds, especially those under 3(c)(7), inherently carry medium risk due to less regulatory oversight and limited liquidity compared to public offerings.

Analyst Insight

Investors should understand that funds operating under Section 3(c)(7) are not available to the general public and require a 'qualified purchaser' status, implying a higher net worth and financial sophistication.

Key Numbers

• 2026-03-23 — Filing Date (the date the D/A amendment was filed and accepted by the SEC)
• 021-364192 — File No. (the SEC file number associated with this offering)
• 26783101 — Film No. (the film number for the filing)
• 3(c)(7) — Investment Company Act Section (the specific exemption under which the fund operates, indicating it serves 'qualified purchasers')

Key Players & Entities

• Point Olema Diversifying Assets - Private Investments Portfolio, L.P. (company) — the filer of the D/A form
• 0001807890 (company) — the CIK (Central Index Key) for the filer
• Delaware (company) — the state of incorporation for Point Olema
• 38 KEYES AVENUE, SUITE 130 SAN FRANCISCO CA 94129 (company) — the mailing and business address of the filer

Forward-Looking Statements

• Point Olema will continue to target 'qualified purchasers' for its private investment offerings. (Point Olema Diversifying Assets - Private Investments Portfolio, L.P.) — high confidence, target: 2027-03-23
• The fund will maintain its exemption under Section 3(c)(7) for the foreseeable future. (Point Olema Diversifying Assets - Private Investments Portfolio, L.P.) — high confidence, target: 2027-03-23

FAQ

Key Financial Figures

• $1 — enues   No Aggregate Net Asset Value   $1 - $1,000,000 $1 - $5,000,000   $1,000,
• $1,000,000 — No Aggregate Net Asset Value   $1 - $1,000,000 $1 - $5,000,000   $1,000,001 - $5,000,
• $5,000,000 — Net Asset Value   $1 - $1,000,000 $1 - $5,000,000   $1,000,001 - $5,000,000   $5,000,001
• $1,000,001 — e   $1 - $1,000,000 $1 - $5,000,000   $1,000,001 - $5,000,000   $5,000,001 - $25,000,000
• $5,000,001 — $5,000,000   $1,000,001 - $5,000,000   $5,000,001 - $25,000,000 $5,000,001 - $25,000,000
• $25,000,000 — $1,000,001 - $5,000,000   $5,000,001 - $25,000,000 $5,000,001 - $25,000,000   $25,000,001
• $25,000,001 — $25,000,000 $5,000,001 - $25,000,000   $25,000,001 - $50,000,000 $25,000,001 - $100,000,0
• $50,000,000 — 5,000,001 - $25,000,000   $25,000,001 - $50,000,000 $25,000,001 - $100,000,000   $50,000,0
• $100,000,000 — 25,000,001 - $50,000,000 $25,000,001 - $100,000,000   $50,000,001 - $100,000,000   Over $1
• $50,000,001 — 0,000,000 $25,000,001 - $100,000,000   $50,000,001 - $100,000,000   Over $100,000,000   O

Filing Documents

• primary_doc.html (D/A)
• primary_doc.xml (D/A) — 5KB
• 0001807890-26-000003.txt ( ) — 6KB

From the Filing

Form D FORM D Notice of Exempt Offering of Securities UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. OMB APPROVAL OMB Number: 3235-0076 Estimated Average burden hours per response: 4.0 1. Issuer's Identity CIK (Filer ID Number) Previous Name(s) None Entity Type Corporation Limited Partnership   Limited Liability Company   General Partnership   Business Trust Other   Name of Issuer   Point Olema Diversifying Assets - Private Investments Portfolio, L.P. Jurisdiction of Incorporation/Organization DELAWARE   Year of Incorporation/Organization Over Five Years Ago Within Last Five Years (Specify Year)   Yet to Be Formed           2. Principal Place of Business and Contact Information Name of Issuer   Point Olema Diversifying Assets - Private Investments Portfolio, L.P. Street Address 1 Street Address 2   38 KEYES AVENUE, SUITE 130     SAN FRANCISCO   CALIFORNIA     94129   415-851-0411   3. Related Persons Last Name First Name Middle Name O'Connor John Street Address 1 Street Address 2   38 Keyes Avenue     Suite 130   San Francisco   CALIFORNIA   94129   Relationship: Executive Officer Director Promoter Clarification of Response (if Necessary) Member and Manager of the Ultimate General Partner 4. Industry Group   Agriculture Banking & Financial Services     Commercial Banking     Insurance   Investing     Investment Banking     Pooled Investment Fund Hedge Fund Other Investment Fund Private Equity Fund Venture Capital Fund *Is the issuer registered as an investment company under the Investment Company Act of 1940? Yes  No   Other Banking & Financial Services   Business Services Energy     Coal Mining     Electric Utilities     Energy Conservation     Environmental Services     Oil & Gas     Other Energy Health Care     Biotechnology     Health Insurance     Hospitals & Physicians     Pharmaceuticals     Other Health Care                         Manufacturing Real Estate   Commercial   Construction   REITS & Finance   Residential Other Real Estate   Retailing Restaurants Technology   Computers   Telecommunications   Other Technology Travel   Airlines & Airports   Lodging & Conventions   Tourism & Travel Services   Other Travel Other        5. Issuer Size Revenue Range Aggregate Net Asset Value Range No Revenues   No Aggregate Net Asset Value   $1 - $1,000,000 $1 - $5,000,000   $1,000,001 - $5,000,000   $5,000,001 - $25,000,000 $5,000,001 - $25,000,000   $25,000,001 - $50,000,000 $25,000,001 - $100,000,000   $50,000,001 - $100,000,000   Over $100,000,000   Over $100,000,000   Decline to Disclose   Decline to Disclose   Not Applicable   Not Applicable   6. Federal Exemption(s) and Exclusion(s) Claimed (select all that apply) Rule 504(b)(1) (not (i), (ii) or (iii)) Rule 506(b)         Rule 504 (b)(1)(i) Rule 506(c) Rule 504 (b)(1)(ii) Securities Act Section 4(a)(5) Rule 504 (b)(1)(iii) Investment Company Act Section 3(c) Section 3(c)(1) Section 3(c)(9) Section 3(c)(2) Section 3(c)(10) Section 3(c)(3) Section 3(c)(11) Section 3(c)(4) Section 3(c)(12) Section 3(c)(5) Section 3(c)(13) Section 3(c)(6) Section 3(c)(14) Section 3(c)(7)     7. Type of Filing   New Notice Date of First Sale   2020-04-24   First Sale Yet to Occur   Amendment     8. Duration of Offering Does the Issuer intend this offering to last more than one year?   Yes   No     9. Type(s) of Securities Offered (select all that apply) Pooled Investment Fund Interests Equity Tenant-in-Common Securities Debt Mineral Property Securities Option, Warrant or Other Right to Acquire Another Security Security to be Acquired Upon Exercise of Option, Warrant or Other Right to Acquire Security Other (describe)       10. Business Combination Transaction Is this offering being made in connection with a business combination transaction, such as a merger, acquisition or exchange offer?   Yes   No Clarification of Response (if Necessary)       11. Minimum Investment Minimum investment accepted from any outside investor $   0 USD 12. Sales Compensation Recipient   Recipient CRD Number None     (Associated) Broker or Dealer None (Associated) Broker or Dealer CRD Number  None     Street Address 1 Street Address 2             13. Offering and Sales Amounts   Total Offering Amount $   USD Indefinite Total Amount Sold $ 48482000 USD Total Remaining to be Sold $   USD Indefinite Clarification of Response (if Necessary)      14. Investors Select if securities in the offering have been or may be sold to persons who do not qualify as accredited investors, Number of such non-accredited investors who already have invested in the offering       Regardless of whether securities in the offering have been or may be sold to persons who do not qualify as accredited investors, enter the total number of investors who already have invested in the offerin

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View this D/A filing on SEC EDGAR