Pillar Value Fund Ltd

Pillar Value Fund Ltd is a Bermuda entity that first filed a Form D on June 5, 2014 and most recently amended it on May 8, 2023, describing itself as a hedge fund. The offering claims Rule 506(b), Section 3(c), Section 3(c)(7) and covers equity and pooled investment fund interests. Pillar Value Fund Ltd reported $89,050,000 sold from 15 investors in an offering of indefinite size as of the Form D filed May 8, 2023. The offering relies on Rule 506(b), which permits sales to accredited investors and to no more than 35 non-accredited investors who meet a sophistication standard, and prohibits general solicitation. Because the fund also relies on Section 3(c)(7), each investor must be a qualified purchaser, generally an individual with at least $5 million in investments. The filing reports no non-accredited investors. The minimum investment accepted from an outside investor is $100,000. The Form D names FTI Capital Advisors, LLC (CRD 123434), associated with None; Agecroft Partners, LLC (CRD 139227), associated with None; TigerRisk Capital Markets & Advisory (CRD 172729), associated with None as recipients of sales compensation soliciting in AL, AZ, CA, CO, CT, DC, DE, FL, GA, IL, MA, MD, MI, MN, NC, NJ, NY, PA, PR, SC, TX, UT, VA, WA. The issuer's address of record is 11 Church Street, Hamilton, Bermuda HM11.