Filing Details

 

 

(CUSIP Number)

 

 

 

April 27, 2017

If the filing person has previously filed a statement on Schedule 13G to report the acquisition which is the subject of this Schedule 13D, and is filing this schedule because of Rule 13d-1(e), (f) or (g), check the following box ☐.

*The remainder of this cover page shall be filled out for a reporting person's initial filing on this form with respect to the subject class of securities, and for any subsequent amendment containing information, which would alter disclosures provided in a prior cover page.

The information required on the remainder of this cover page shall not be deemed to be "filed" for the purpose of Section 18 of the Securities Exchange Act of 1934 or otherwise subject to the liabilities of that section of the Act but shall be subject to all other provisions of the Act.

 

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1	NAMES OF REPORTING PERSONS
	S.S. OR I.R.S. IDENTIFICATION NOS. OF ABOVE PERSONS
	City of London Investment Management Company Limited (CLIM), a company incorporated under the laws of England and Wales.
2	CHECK THE APPROPRIATE BOX IF A MEMBER OF A GROUP			(a)	☐
				(b)	☐
3	SEC USE ONLY
4	SOURCE OF FUNDS*
	WC
5	CHECK BOX IF DISCLOSURE OF LEGAL PROCEEDINGS IS REQUIRED PURSUANT TO ITEM 2(d) OR 2(e)				☐
6	CITIZENSHIP OR PLACE OF ORGANIZATION
	England and Wales
NUMBER OF SHARES BENEFICIALLY OWNED BY EACH REPORTING PERSON WITH:		7	SOLE VOTING POWER
			0
		8	SHARED VOTING POWER
			3,812,930
		9	SOLE DISPOSITIVE POWER
			0
		10	SHARED DISPOSITIVE POWER
			3,812,930
11	AGGREGATE AMOUNT BENEFICIALLY OWNED BY EACH REPORTING PERSON
	3,812,930
12	CHECK BOX IF THE AGGREGATE AMOUNT IN ROW (11) EXCLUDES CERTAIN SHARES				☐
13	PERCENT OF CLASS REPRESENTED BY AMOUNT IN ROW (11)
	24.3%
14	TYPE OF REPORTING PERSON*
	IA

 

After reasonable inquiry and to the best of my knowledge and belief, I certify that the information set forth in this statement is true, complete, and correct.

 

Exhibit A

April 27, 2017

Mr. Joe O. Rogers, Chairman

The China Fund, Inc.

2477 Foxwood Drive

Chapel Hill, NC  27514

Dear Mr. Rogers,

City of London Investment Management Company Limited ("City of London") is, on behalf of our clients, a long-term investor in The China Fund, Inc. ("the Fund").  We are writing in response to the Board's announcement on March 31, 2017, that "its Board of Directors has selected Open Door Investment Management, Ltd ("Open Door") to become its Investment Manager, subject to stockholder approval." 

City of London will not support Open Door as Investment Manager of the Fund.  We would presume that every other stockholder must also be dismayed by the Board's decision.  The principals of Open Door are the same two individuals who were the most senior members of the investment team whose actions were at the core of the SEC Administrative Proceeding during their previous tenure as the Investment Manager of The China Fund, Inc. (https://www.sec.gov/litigation/admin/2014/ic-31066.pdf). The Board's decision in this instance reinforces our long-held view that stockholders should have no confidence in this Board.

We intend to submit a 14a-8 proposal to terminate the investment management contract prior to the deadline of September 21, 2017. This action would be separate from our intent to also vote against the approval of Open Door as Investment Advisor, and also separate from our intent to vote against all incumbent Directors up for re-election at the Fund's Annual General Meetings going forward.

Sincerely yours,

Jeremy Bannister

Director, Corporate Governance