Fundamental based analysis relies on the study of external factors to predict the price movement of a given investment. Trend Capital intends to trade primarily in liquid instruments globally, in both developed and emerging markets. There can be no assurance that the Funds will be able to maintain the ability to borrow financial instruments sold short. The Funds will usually enter into swaps on a net basis (i.e., the two payment streams are netted out in a cash settlement on the payment date or dates specified in the agreement). Governments from time to time intervene, directly and by regulation, in certain markets, particularly those dealing in precious metals. Trend Capital has adopted a Code of Ethics, which is a part of Trend Capitals compliance manual and has been designed to comply with the requirements of Advisers Act Rule 204A-1. Live market coverage co-anchored from Hong Kong and New York. As noted above, one of the managed accounts will close at the end of March 2020. To the extent unhedged, the value of the Funds assets will fluctuate with U.S. dollar exchange rates as well as with price changes of their investments in the various local markets and currencies. Prices of currency contracts traded by the Funds are affected generally by relative interest rates, which in turn are influenced by a wide variety of complex and difficult to predict factors such as money supply and demand, balance of payments, inflation levels, fiscal policy and political and economic events. If you are an SEC-registered adviser, briefly describe your code of ethics adopted pursuant to SEC rule 204A-1 or similar state rules. The minimum initial investment amount for the Enhanced Return SPs is $100,000,000and the minimum additional investment amount is $100,000, in each case subject to waiver, reduction or change at the discretion of Trend Capital, the respective general partner or the Board of Directors, as applicable. Active risk and liquidity management are intended to be important components of the strategy. Flexible Investment Approach. Research and Other Soft Dollar Benefits. Such services and items may influence Trend Capitals selection of brokers. Delray Beach, Florida, United States . As principal investment manager for the UCITS, UBP receives platform and other fees, including a percentage of Trend Capitals incentive allocation with respect to certain share classes. Swap transactions dependent upon credit events are priced incorporating many variables including the pricing and volatility of the common stock and potential loss upon default, among other factors. If more than 50% of your revenue from advisory clients results from commissions and other compensation for the sale of investment products you recommend to your clients, including asset-based distribution fees from the sale of mutual funds, disclose that commissions provide your primary or, if applicable, your exclusive compensation.Not applicable. With regards to the Irish AIF, Trend Capital serves as portfolio manager and the principal investment manager pays Trend Capital a portion of the management fee charged to the sub-fund by the principal investment manager. The incentive allocation, if any, will be determined as of each fiscal year end and, with respect to capital withdrawn/redeemed other than as of a fiscal year end, as of the time of such withdrawal/redemption with respect to the withdrawn/redeemed amount. for with commission dollaAny use of commissions or soft dollars generated by the Advisory Clients to pay for brokerage and research products or services will fall within the safe harbor created by Section 28(e) of the U.S. Securities Exchange Act of 1934, as amended. The Funds and the Managed Accounts have broad and flexible investment authority. Special risks may apply to instruments that are invested in by the Funds in the future that cannot be determined at this time or until such instruments are developed or invested in by the Funds. Investors should carefully review the audited financial statements of the Funds upon receipt. 2. illiquidity compared to the U.S. capital markets. An inability to establish or maintain such relationships is likely to limit the Funds trading activities or their ability to engage in certain transactions, could result in losses and might prevent the Funds from trading at optimal rates and terms. Accordingly, in addition to bearing their proportionate share of the Funds expenses (e.g., Management Fees and operating expenses), shareholders may also indirectly bear similar expenses of an ETF, which can have an adverse effect on the return on capital of the Funds. A forward currency contract, which involves an obligation to purchase or sell a specific currency at a future date at a price set at the time of the contract, reduces the Funds exposure with respect to their investment to changes in the value of the currency it will deliver and increases its exposure to changes in the value of the currency it will receive for the duration of the contract. While the Funds intend to invest in a diversified portfolio, they are not subject to formal diversification guidelines or formal policies limiting the leverage used by the Funds. The applicable fee share is disclosed in the Prospectus and related Prospectus Supplement. If you permit a client to direct brokerage, describe your practice. However, there is no guarantee that any such borrowing arrangements or other arrangements for obtaining leverage will be available, or, if available, will be available on terms and conditions acceptable to the Funds. The prices and trading volumes for certain commodities can be volatile. Industry Group Agriculture Banking & Financial Services Business Services Energy Coal Mining Electric Utilities Trend Capital presently provides investment advisory services to the Funds and the Managed Accounts, which provide Trend Capital with varying levels of compensation due to varying compensation structures. Describe the factors that you consider in selecting or recommending brokerdealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). Fluctuations or prolonged changes in the volatility of financial instruments held by the Funds directly or indirectly may adversely affect the value of the Funds. These actions could adversely affect the Funds operations and profitability. Explain the pro If you consider, in selecting or recommending broker-dealers, whether you or a related person receives client referrals from a broker-dealer or third party, disclose this practice and discuss the conflicts of interest it creates. Trend Capital will generally follow the guidelines set forth below in aggregating client orders for investments: In general, trades will be allocated pro-rata to Advisory Client accounts, based on each Advisory Client accounts net assets under management; No Advisory Client will be favored over any other Advisory Client; When trades are aggregated, if all such orders are not filled at the same price, Trend Capital will generally average the prices paid and each participating Advisory Client will generally be allocated investments on an average price basis for that investment position on a given business day and transaction costs will be shared pro rata based on each Advisory Clients participation in the transaction, provided, however, that in instances in which exchange rules do not permit allocation based on average price, trades shall be filled 38 and allocated as follows: Instances in which exchange rules do not permit allocation based on average price, by using splits and rounding, all trades are allocated to each Advisory Client based on ownership percentages. Describe the types of products and services you or any of your related persons acquired with client brokerage commissions (or markups or markdowns) within your last fiscal year. If you have been the subject of a bankruptcy petition at any time during the past ten years, disclose this fact, the date the petition was first brought and the current status. As described in Item 12.A.1 above, brokers may provide other services that are beneficial to Trend Capital, but not necessarily beneficial to the Advisory Clients, including capital introduction. There can be no assurance that the Funds will be able to secure or maintain adequate financing. The Opportunities Master Fund SPs invest in and trade securities and other financial instruments using investment techniques with risk characteristics, including risks of the debt and equity markets, the risks of borrowings and short sales, the potential illiquidity of securities and other financial instruments and the risk of loss from counterparty defaults. Describe generally how you address conflicts that arise. Managed Accounts:As described in Item 4.A above, Trend Capital also provides advisory servicesto Managed Accounts, the fees for which are separately negotiated with theadvisory client. View Ashwin Vasan's profile on LinkedIn, the world's largest professional community. The Firm has adopted and implemented a compliance program to monitor its Funds and managed accounts and mitigate any potential conflicts of interest. Unlisted Financial Instruments. Sep 3, 2017 | Fund Employees. Trend Capital Management LP - Boca Raton - Ashwin Vasan in General Discussions Trend Capital Management LP is a discretionary global macro hedge fund manager. If you require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, include a balance sheet for your most recent fiscal year. For purposes of this Item, economic benefits include any sales awards or other prizes. The instruments and borrowings utilized by the Funds to leverage investments may be collateralized by the Funds portfolio. Concentration of Investments. Ashwin Kumar Vasan, Trend Capital Management LP: Profile and Biography - Bloomberg Markets Live Now Bloomberg TV+ Bloomberg Balance of Power Bloomberg: Balance of Power focuses on the. While the Funds intend to invest a substantial portion of the portfolio in liquid securities, there can be no assurance that any of these securities will not become illiquid at some point in time. Trend Capital takes a balanced approach to investing the Trend Macro Funds or Enhanced Returns assets. Explain whether (and, if so, how) you tailor your advisory services to the individual needs of clients. Trend Capital can provide further details or a copy of the Firms Allocation Policy upon request. T. The Funds may incur risks associated with the sale and purchase of put options. For Trend Macro Fund and the ERISA Fund, the management fee is computed at the annual rate of 2.0% of each capital account or share class established in connection with Class A Interests/Shares. The respective general partner may, in its sole discretion, waive, reduce or calculate differently the management fee with respect to certain investors. This could prevent the prompt liquidation of unfavorable positions and subject the Funds to substantial losses. Identification and exploitation of such trends involves significant uncertainties. The production and marketing of commodities may be affected by actions and changes in governments. Forward Trading. Portfolio No one trade idea, Liquidity. Derivative Financial Instruments and Instruments Generally. Phone (703) 729-1500. Stock Index Options. Also, please let us know if you would like detailed information about how any proxies were actually voted by calling the Chief Compliance Officer, Brian Barry, at 561-617-5086. Prospective investors are provided with an offering memorandum prior to their investment and are encouraged to carefully review the offering memorandum, along with all other relevant offering documents and to be sure that the proposed investment is consistent with their investment goals and tolerance for risk. An affiliate entity of Trend Capital also serves as a general partner to the Master Funds and each feeder fund that is structured as a limited partnership and the Class M Shareholder with respect to the Opportunities Master. A copy of the Firms Allocation Policy can be obtained by contacting Trend Capital. Combined with stop losses, such hedges are intended to protect the portfolio in the event trades move meaningfully against the direction the Trend Capital anticipated when making the investment. Ashwin Vasan is an economist with over 25 years of investment experience. Corporate debt securities, mortgagebacked securities, bank loans, mezzanine investments and certain other investments that may be purchased and sold are traded in private, unregistered transactions and subject to restrictions on resale. The Funds expect to borrow or utilize other forms of leverage (on a secured or unsecured basis) for any purpose, including to increase investment capacity, cover operating expenses, or for clearance of transactions. Successful use of stock index futures contracts by the Funds also is subject to Trend Capitals ability to correctly predict movements in the direction of the market. In addition, new and additional regulations and laws may apply to swaps and other derivatives that have not heretofore been applied. When deemed appropriate for a large or strategic investor, Trend Capital has established, and may again in the future establish, a Managed Account that will tailor its investment objectives to those of the specific investor (including restrictions on investing in certain types of securities) and/or be subject to different terms and/or fees than those of the Funds. If you do not have authority to vote client securities, disclose this fact. The inability of key marketplace intermediaries to function could have an adverse impact upon liquidity as well as the ability of the Funds to trade positions. Risk Disclosure. Margin requirements for transactions that are not bona fide hedging are significantly higher than for bona fide hedging transactions. 3. The management fee for Class C and Class D Interests/Shares is at the annual rate of 1.5%, provided the aggregate subscription amount (less any withdrawals/redemptions other than withdrawals/redemptions of aggregate net profits, which, for this purpose, any amounts withdrawn or redeemed will be first applied against aggregate net profits, if any) meets or exceeds a threshold amount set forth in the applicable offering documents. If you recommend or select other investment advisers for your clients and you receive compensation directly or indirectly from those advisers that creates a material conflict of interest, or if you have other business relationships with those advisers that create a material conflict of interest, describe these practices and discuss the material conflicts of interest these practices create and how you address them. If you do, describe the frequency and nature of the review and the titles of the supervised persons who conduct the review. If you charge advisory fees in addition to commissions or markups, disclose whether you reduce your advisory fees to offset the commissions or markups.Not applicable. Illiquidity. The minimum and additional subscription amounts are reduced for each investor introduced to one of the Trend Macro Funds by Merrill Lynch. Each Funds offering documents contain a detailed description of the applicable Funds fee schedule.Management Fee. A self-regulatory organization (SRO) proceeding in which your firm or a management person. Trend Capital is permitted to use leverage in pursuing its investment objective and this leverage may be significant. Further, Trend Capital charges the Funds fees based on a percentage of assets under management via the management fee and performance via the incentive allocation. It typically will not concentrate the portfolio in individual positions or groups of correlated positions to the extent that losses from such areas of concentration would be so extreme that the portfolio could not possibly generate returns from other positions mitigating or exceeding such losses.
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