Thomas Perugini
About Thomas Perugini
Thomas Perugini serves as Treasurer and Principal Financial Officer (PFO) of The China Fund, Inc. (CHN) and is identified as born in 1969; he has served as an officer of the Fund since 2024 and also signed the Fund’s N-CSR as Chief Financial Officer for SOX certifications on July 1, 2025 . CHN is a closed-end fund now in liquidation; typical operating-company metrics (revenue/EBITDA) do not apply, but as context the Fund reported total net assets of $179,712,807.30 as of September 26, 2025 and an NAV per share of $18.70 used for liquidation planning . Under the approved Plan of Liquidation, the Treasurer has specific responsibilities for declaring dividends to eliminate corporate-level tax and for cash management through liquidation and distributions—functions central to execution risk and investor outcomes .
Past Roles
| Organization | Role | Years | Strategic Impact |
|---|---|---|---|
| Foreside Fund Officer Services, LLC | Senior Principal Consultant / Principal Financial Officer | 2023–present | External provider of treasury/PFO services to CHN; Perugini is CHN’s Treasurer/PFO since 2024 |
| State Street Corporation | VP, Fund Administration Product | 2019–2023 | Fund administration product leadership (as disclosed in officer biography) |
External Roles
| Organization | Role | Years | Notes |
|---|---|---|---|
| Foreside Fund Officer Services, LLC | Senior Principal Consultant / Principal Financial Officer | 2023–present | Employer of record; provides Perugini to CHN as Treasurer/PFO |
Fixed Compensation
| Element | CHN-Paid Amount | Notes |
|---|---|---|
| Base salary | $0 | “The Fund does not compensate the officers of the Fund.” |
| Target bonus % | Not applicable | No officer cash incentive plan disclosed by the Fund |
| Actual bonus paid | $0 | No officer compensation paid by CHN |
| Perquisites/benefits | Not disclosed at CHN level | Officers are compensated by service provider (Foreside), not the Fund |
Performance Compensation
| Incentive Type | Metric(s) | Weighting | Target | Actual | Payout | Vesting |
|---|---|---|---|---|---|---|
| None disclosed for CHN officers | — | — | — | — | — | — |
The Fund does not grant equity/option awards or cash bonuses to officers; officers are not compensated by the Fund .
Equity Ownership & Alignment
| Item | Detail |
|---|---|
| Beneficial ownership – Directors and executive officers as a group | Less than 1% of outstanding shares as of September 26, 2025 |
| Individual ownership (Perugini) | Not individually disclosed in 2025 proxy materials reviewed |
| Options (exercisable/unexercisable) | None disclosed for officers |
| Shares pledged/hedged | Not disclosed for officers |
Top 5% beneficial owners as of September 26, 2025:
| Holder | Shares | % of Class |
|---|---|---|
| City of London Investment Management Co. Ltd. | 2,788,999 | 28.89% |
| Lazard Asset Management | 819,965 | 8.49% |
| Allspring Global Investments, LLC | 748,320 | 7.75% |
| CSS, LLC | 531,194 | 5.50% |
| Bill & Melinda Gates Foundation Trust | 520,704 | 5.39% |
Employment Terms
| Term | Disclosure |
|---|---|
| Officer start date / tenure | Officer since 2024 (Treasurer & PFO) |
| Employer | Foreside Fund Officer Services, LLC (external service provider) |
| Contract term/auto-renewal | Not disclosed in 2025 proxy materials reviewed |
| Severance / Change-in-control | Not disclosed for officers; Fund does not compensate officers |
| Vesting/accelerated vesting | No officer equity awards disclosed |
| Clawback provisions | Not disclosed for officers |
| Non-compete / Non-solicit / Garden leave | Not disclosed for officers |
Performance & Track Record (role-relevant events)
| Date | Event | Perugini’s Role/Implication |
|---|---|---|
| July 1, 2025 | Form N-CSR certifications signed by Perugini as Chief Financial Officer and by the Treasurer/PFO; SOX 302/906 compliance affirmed | |
| October 6, 2025 | Board circulates Special Meeting proxy for liquidation; Plan assigns Treasurer authority to declare dividends to eliminate corporate-level tax and manage liquidating distributions | |
| October 21, 2025 | Stockholders approve liquidation and dissolution; books to close Oct 29; distributions to commence as practicable | |
| October 31, 2025 | Form 25 filed—removal from NYSE listing/registration in connection with liquidation |
Additional context: During six months ended April 30, 2025, the Fund repurchased 131,439 shares at an average price of $12.27 as part of discount management; these activities frame prior capital allocation context before liquidation .
Board Governance (for reference)
- Governance, Nominating and Compensation Committee and other committees consist entirely of independent directors; officer compensation is not paid by the Fund, so no officer pay programs are overseen at CHN level .
- Section 16(a) compliance: to the Fund’s knowledge, all officers’ and directors’ filings were timely in fiscal 2024 except an initial Form 3 for a different officer (Byrkit); no delinquency noted for Perugini .
Compensation Structure Analysis
- No CHN-paid officer cash or equity compensation; officers are compensated by Foreside. This implies no Fund-level base/bonus/equity alignment or vesting overhang for Perugini; consequently, no CHN-driven insider selling pressure or equity pledging risk from officer grants .
- With no CHN equity awards, there are no change-in-control acceleration terms, repricings, or PSU/RSU targets to evaluate; Treasurer responsibilities are operational (dividends, cash management) under the Liquidation Plan rather than incentivized by Fund equity .
- Directors and officers as a group own <1% of shares; ownership influence and “skin-in-the-game” at the officer level appear limited based on disclosures reviewed .
Risk Indicators & Red Flags
- Hedging/pledging: No officer pledging disclosed; no officer equity awards disclosed .
- Legal/SEC matters: None disclosed for Perugini in reviewed 2025 proxy materials .
- Section 16 compliance: No delinquency noted for Perugini; separate delinquency noted only for Mr. Byrkit’s initial Form 3 (administrative error) .
- Structural risk: Approved liquidation and NYSE delisting elevate execution risk; the Treasurer’s dividend/distribution determinations are central to timing, tax, and cash outcome for investors .
Investment Implications
- Alignment/overhang: With no CHN-paid officer equity or options, there is no vesting calendar or incentive-related selling pressure tied to Perugini; officer alignment is via professional obligations and reputational capital rather than Fund equity ownership .
- Retention/transition: As an external officer (Foreside) since 2024, retention risk is tied to service provider continuity; CHN’s liquidation and deregistration will wind down the need for Fund officers post-distribution, shifting the analytical focus to execution timing and accuracy rather than long-term retention .
- Execution focus: Monitor Treasurer-led dividend determinations and liquidating distribution schedules under the Plan; accurate reserve setting and tax spillback management are key levers affecting proceeds and timing to shareholders .
- Governance/compliance signal: Timely SOX certifications and no noted Perugini Section 16 issues indicate sound reporting controls during the transition period—a positive for execution reliability .