ABS Long/Short Strategies Fund Tender: 6.8% of Offers Used

The offer of October 28, 2026

The fund is a Delaware statutory trust registered under the Investment Company Act of 1940, run by ABS Investment Management LLC of Stamford, Connecticut. It began operations on January 4, 2016. Its only outstanding class is Founders' Shares, which are not traded anywhere; liquidity comes only from offers like this one, which the board is not obliged to make. The annual report puts it plainly: “Shareholders do not have the right to require the Fund to redeem any or all of their shares.”

Three details matter to a holder. The price is set 34 days after the deadline: a holder who tenders by November 27 does not know the December 31 NAV (our arithmetic). The right to withdraw comes back after 40 business days from October 28 if the fund has not accepted the tender, which falls in late December 2026 (our arithmetic). The tender is a taxable sale in the fund's words, either a “sale or exchange” or, in some cases, a dividend under Code section 302(b); our wash-sale explainer and Form 8949 guide cover the reporting.

Twenty-seven offers, 6.8% of the amount used

The fund has made a tender offer almost every quarter. Each result below is from the final Schedule TO-I/A. “Offered” is the dollar amount the final amendment gives for the offer. The first two offers of 2020 were for up to 40% of net asset value; every one since July 2020 has been 25%.

Summed, the 27 offers asked for $1,521,585,773 and received $103,247,461, or 6.8% (our arithmetic). Three readings, none a forecast.

The big ones are few and recent. February 2020 (three holders, $25.7 million, 13.9% of the fund's $185.1 million NAV when the offer was filed), February 2025 (two holders, $22.5 million, 8.8% of $253.9 million) and November 2025 (five holders, $15.5 million, 6.4% of $244.3 million) are our arithmetic on the NAV in each Schedule TO-I. Two of them were two- or three-holder events, which fits a concentrated shareholder list, but the filings do not name who tendered.

Nobody has been cut back. The most any offer reached was 35.4% of the amount, so the pro rata clause has never applied. The offer documents say that if more is tendered than the fund is buying, the fund will purchase only a pro rata portion of each holder's shares. With one holder at 35.68% of the shares, the arithmetic of a full tender by that holder alone is above the cap (see below).

The record ties to the audited accounts. The three results valued between June 30, 2025 and December 31, 2025 sum to $18,571,354 (our arithmetic), against $18,571,356 of “Payments for shares repurchased” in the annual report for the year to April 30, 2026; the four for the year to April 30, 2025 sum to $26,465,491 against $26,465,490. The SEC tender filings capture the whole outflow.

The shareholder who owns 35.68%

The Schedule TO-I lists Operating Engineers Local 324 Pension Fund of Troy, Michigan with 893,352 shares, 35.68% of the 2,503,828 outstanding on September 1, 2026, and says it “may be deemed to control the Fund.” Holders above 25% may determine the outcome of any matter put to a shareholder vote. The August 28, 2026 prospectus gives 35.70% on July 31, 2026.

Its share count has risen in steps each spring, +77.4% since January 2020 against +46.1% for all shares (our arithmetic). The filings do not explain the steps; the annual report says holders are automatically enrolled in a dividend reinvestment plan, and in both of the last two fiscal years reinvested distributions equal total distributions to the dollar. The jump from 30.12% to 33.13% between the offers filed April 30 and July 31, 2025 came as the fund's shares fell from 2,600,555 to 2,364,139, after the February 2025 tender of $22.5 million.

Worked example (our arithmetic): 893,352 shares at $105.8088 are $94,524,503, which is 1.43 times the $66,231,726 that 25% of the September 1 NAV allows. If this holder alone tendered everything, the offer would be oversubscribed and every tendering holder would be cut back pro rata. The filings give no sign that it will; they say only that no executive officer, Trustee or other affiliate of the fund plans to tender, which is a statement about the fund's insiders and does not mention this holder.

Everything else a holder can read about the shareholder base is thin. The prospectus sells Founders' Shares only to accredited investors at a stated minimum initial subscription of $100,000,000 that the board may reduce or waive. Institutional Shares have a $25,000 minimum but none are outstanding, and A Shares have not started. A small investor therefore cannot simply buy in; the filings do not say how the existing holders came to own their shares.

When the cash arrives

A holder who tenders everything and is accepted receives the initial payment of “not less than 95%” of unaudited NAV. The fund holds the remainder as a contingent payment until “the next annual audit,” which it generally pays within two business days of completion. A partial tender is paid in full.

Two things follow. The first payment is fast and predictable: 56 to 63 days in the last six offers, so an offer expiring November 27, 2026 would pay about January 22 to January 29, 2027, inside the 65-day limit of January 31, 2027 (our arithmetic). The last 5% waits months. Every December 31 valuation in the amendments reports an audit “by the end of June” of the following year, and the May 2026 offer's amendment says: “The Fund expects that the audit will be completed by the end of June 2027.” The fiscal year ends April 30, so the audit that settles a December 31, 2026 tender is, on the same pattern, the one finishing at the end of June 2027, six months after the valuation (our arithmetic; the October 28 filing does not give the date).

Worked example (our arithmetic): a $1,000,000 tender of a whole position is accepted in full. The initial payment is at least $950,000, in late January 2027; up to $50,000 follows after the audit, around July 2027, adjusted for any change the audit makes to the NAV.

The reports are slow too. Final amendments came 84 to 237 days after expiry, so the SEC record of an offer appears three to eight months after it ends. The September 30, 2026 offer expired August 28, 2026 and has no final amendment at October 30, 2026; the October 28 filing is where we learn nobody tendered: “There were no Founders’ Shares tendered pursuant to the September 30, 2026 offer.”

What the fund owns, and how fast it can sell

The fund is a fund of hedge funds. At April 30, 2026 it held 24 “Portfolio Funds” with a fair value of $253,066,359, 98.2% of shareholders' capital of $257,810,580, plus $4,922,394 of cash. The annual report calls them private placements restricted as to resale, all pledged as collateral for a $20,000,000 line of credit with Bank of America whose maturity is December 11, 2026.

The five largest positions are Seligman Tech Spectrum Fund ($18.2 million, 7.05% of shareholders' capital), Seligman Healthcare Spectrum Fund ($16.5 million, 6.40%), Medina Value Partners I ($15.3 million, 5.95%), Forest Avenue Offshore Fund ($15.2 million, 5.91%) and 140 Summer Partners Offshore ($13.9 million, 5.40%). Together the five are 31.3% of the portfolio value (our arithmetic). Lancaster European LS Equity ($13.3 million) is an affiliated investment, one where the fund owns more than 5% of the underlying fund's capital.

Footnotes to the schedule say 11 of the 24 funds, 43.3% of the value (our arithmetic), can institute a gate on redemptions, at the fund level (10% to 50% of the investment) or the investor level (25% to 50% a quarter).

Why this matters for a 25% offer. The Schedule TO-I says the adviser expects to minimize portfolio changes by selling assets pro rata “to the extent possible given applicable Portfolio Fund liquidity restrictions and withdrawal notification requirements.” With a December 31 valuation, a quarterly fund with 60 days' notice needed its notice by about November 1, 2026 and a 90-day monthly fund by about October 2, both before the November 27 deadline (our arithmetic). The fund had only $4.9 million of cash on April 30, 2026, 1.9% of capital, against a $66.2 million cap. History says the cap is rarely approached, which is how the structure has worked; it is not a guarantee.

What it costs

The annual report shows a gross expense ratio of 1.28% of average shareholders' capital and a net ratio of 1.16% after waivers. That excludes the fees of the 24 funds underneath. The August 28, 2026 prospectus fee table for Founders' Shares counts them:

On $1,000,000 that is about $70,400 a year (our arithmetic). Reported returns are already net of these costs. The annual report's performance table shows the fund up 25.09% in the year to April 30, 2026 and 6.57% annualized since inception, against 5.73% for the HFRI Fund of Funds: Strategic index, which the report does not call the fund's benchmark. Past returns do not describe what a December 31 tender will be paid.

One inconsistency in the fund's own documents: the performance page of the annual report says total annual operating expenses including acquired funds were 6.16% “as of April 30, 2025,” while the prospectus table says 7.16%. We use the later prospectus figure.

Where the money comes from

The statement of changes in shareholders' capital explains why the fund does not shrink. In the year to April 30, 2026 it sold $350,000 of shares, reinvested $32,060,003 of distributions and repurchased $18,571,356; a year earlier the figures were $175,000, $25,210,710 and $26,465,490. Reinvested distributions were 14.5% of opening capital of $221,584,102 in 2026 (our arithmetic). Net capital transactions were +$13,838,647 in 2026 and −$1,079,780 in 2025.

So new money is almost entirely the fund's own distributions coming back. Reinvestment is the default for every holder, which keeps the fund's size steady while redemptions stay small, and it is also why a single large holder's share can creep up.

What a reader can do with this

This is analysis of public documents, not investment, legal or tax advice. If you hold Founders' Shares, the filings frame five questions:

• Dates. Tenders are due by 11:59 p.m. Eastern on November 27, 2026 and can be withdrawn until then. The price is the December 31, 2026 NAV, so you carry the fund's market risk for another 34 days after the deadline.
• Size against the offer. The cap is about $66.2 million. Your tender is only cut back if total tenders exceed it, which has never happened, but a very large holder is a reason to ask the administrator, UMB Fund Services, at (877) 499-9990 how the offer stands before you decide.
• How you will be paid. A full tender gets at least 95% by about the end of January 2027 and the rest after an audit expected around June 2027; a partial tender gets 100% in the first payment.
• The all-in cost. The 1.28% in the annual report is not the 7.16% in the prospectus. Compare any alternative on the same measure.
• Tax. The fund calls the sale taxable and says the treatment depends on the Code section 302(b) tests. Ask a tax adviser before tendering; our tender explainer lists how the forms work.

For how other tender funds compare, see Aspiriant's two funds, whose offers are capped at about 5% of net assets, and Blackstone's multi-strategy hedge fund. The other deadlines this quarter are in our Q4 2026 tender deadline list.

FAQ

Compiled from SEC EDGAR on October 30, 2026: the fund's Schedule TO-I and TO-I/A filings from October 2019 to October 28, 2026, the N-CSR for the year ended April 30, 2026 (filed July 8, 2026) and the post-effective amendment to the registration statement of August 28, 2026. Percentages and totals marked “our arithmetic” are ours. “Offered” in the results table is the amount stated in each final amendment. This is analysis of public documents, not investment, legal or tax advice.