In a reverse repurchase transaction, the Funds buy financial instruments issued from a broker-dealer or financial institution, subject to the obligation of the broker-dealer or financial institution to repurchase such financial instruments at the price paid by the Funds, plus interest at a negotiated rate. Forgot your password? Fluctuations or prolonged changes in the volatility of such instruments, therefore, can adversely affect the value of investments held by the Funds. These transactions are not subject to exchange rules. Investors should carefully review the audited financial statements of the Funds upon receipt. The seller (writer) of a put option which is covered (i.e., the writer has a short position in the underlying financial instrument) assumes the risk of an increase in the market price of the underlying financial instrument above the sales price (in establishing the short position) of the underlying financial instrument plus the premium received and gives up the opportunity for gain on the underlying financial instrument if the market price falls below the exercise price of the option. Describe the methods of analysis and investment strategies you use in formulating investment advice or managing assets. 33ITEM 12 BROKERAGE PRACTICES .. 35ITEM 13 REVIEW OF ACCOUNTS .. 39ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION 40ITEM 15 CUSTODY 41ITEM 16 INVESTMENT DISCRETION .. 42ITEM 17 VOTING CLIENT SECURITIES . Except to the extent that values are independently affected by currency exchange rate fluctuations, when interest rates decline, the value of fixedincome securities generally can be expected to rise. Currency transactions made on a spot basis are for cash at the spot rate prevailing in the currency market for buying or selling currency. Companies whose securities are not publicly traded may not be subject to public disclosure and other investor protection requirements applicable to publicly traded securities. If you recommend primarily a particular type of security, explain the material risks involved. Generally, there is no public or over-the-counter trading market for these financial instruments and the Funds might only be able to liquidate these positions at highly disadvantageous prices, if at all. Describe the factors that you consider in selecting or recommending brokerdealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). The Funds may trade on exchanges or markets located outside the U.S. Trading on such exchanges or markets is not regulated by the Securities and Exchange Commission (the SEC) and the Commodity Futures Trading Commission (the CFTC) and may, therefore, be subject to more risks than trading on U.S. exchanges, such as the risks of exchange controls, expropriation, burdensome taxation, moratoria and political or diplomatic events. A copy of the Firms Allocation Policy can be obtained by contacting Trend Capital. The Funds may incur risks associated with the sale and purchase of call options. Investment StrategyTrend Capital seeks to identify and capitalize on fundamental trends in interest rates, currencies and credit and equity indices in both developed and emerging markets. In addition, the Funds assets are also subject to the risk of the failure of any of the exchanges on which its positions trade or of its clearinghouses or counterparties. In addition to its quantitative modeling, Trend Capital incorporates qualitative factors into its assessment of each trend. 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. 4. was the subject of any order, judgment, or decree permanently or temporarily enjoining, or otherwise limiting, your firm or a management person from engaging in any investment-related activity, or from violating any investment-related statute, rule, or order Not applicable. Ashwin Kumar Vasan - Trend Capital Management LP. There are 191 active home listings and 9 new homes for sale in Ashburn, VA. Homes in Ashburn, VA were selling for a median price of $685,000 in November 2022. As noted above, an incentive fee is also received from the Managed Accounts and is payable annually, in arrears, subject to a loss carryforward provision. Market disruption events could also affect the principal prime brokers that carry and clear the Funds trades and positions. Ashwin Vasan (born November 15, 1980) is an American physician and epidemiologist serving as the 44th commissioner of the New York City Department of Health and Mental Hygiene. 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. The Funds, however, will generally value their assets in U.S. dollars. While the Firm has taken steps to mitigate the adverse consequences that could arise from the occurrence of a market disruption event, the inability to predict the timing, location, source and severity of such event or events make it 20 difficult to provide assurances that the Funds would not suffer adverse consequences should a market disruption event occur. Trend Capital acts as the investment manager of the Funds. Risks in investments in non-U.S. securities, futures, commodities and other financial instruments may also include reduced and less reliable information about issuers and markets, less stringent accounting standards, illiquidity of securities and markets, higher brokerage commissions and custody fees. Trading in Currencies. The UCITS is not open to U.S. investors. If you provide investment advice only with respect to limited types of investments, explain the type of investment advice you offer and disclose that your advice is limited to those types of investments. Ashwin Vasan Related Companies. Describe whether you deduct fees from clients assets or bill clients for fees incurred. Disclose whether the fees are negotiable.The Funds offer interests or shares, as applicable, only to certain qualified investors and admission in the Funds is not open to the general public. To the extent that Trend Capital receives proxies on behalf of its Advisory Clients, Trend Capital will vote any such proxies in the best interests of the Funds, the Funds investors and the Managed Accounts. After the end of March 2020, Managed Account relationshipswill include an Irish UCITS and an Irish Alternative Investment Fund (AIF). Trend Capital Management LP, 092120 DECH, 2019-0064-KSJM Document Cited in Precedent Map Related Vincent PETER EARLY, Plaintiff, v. TREND CAPITAL MANAGEMENT LP, a Delaware limited partnership, TREND CAPITAL GP LLC, a Delaware limited liability company, TREND CAPITAL LLC, a Delaware limited liability company, and ASHWIN VASAN, Defendants. In addition, certain Funds or managed accounts may have different trade error policies for legal or regulatory reasons (e.g. 29 Aug 2019 by Joel St.Germain. It is critical that investors refer to the relevant offering documents for a complete understanding of that Advisory Clients investment objectives and strategies. The Enhanced Return sizing due to additional leverage and resulting liquidity is expected to differ from Trend Macro Fund from time-to-time, depending on the portfolio assets. 2022 Trend Capital Management LP, All Rights Reserved. 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. The incentive allocation ranges from 15% to 20% of net profits per annum, depending on the Fund andthe Class of Interests/Shares or SP in which an investor subscribes. Investment Program of Trend Capital. The Funds may invest in exchange traded funds 24 (ETFs), which are shares of publicly-traded unit investment trusts, open-end funds, or depository receipts that seek to track the performance and dividend yield of specific indexes or companies in related industries. This requires different skills and techniques than predicting changes in the price of individual stocks. If your primary strategy involves frequent trading of securities, explain how frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Volatility. ITEM 2 MATERIAL CHANGES . Trend Capitals principal owner is Ashwin Vasan. The seller of an uncovered put option assumes the risk of a decline in the market price of the underlying financial instrument 27 below the exercise price of the option. The seller of an uncovered call option assumes the risk of a Theoretically unlimited increase in the market price of the underlying financial instrument above the exercise price of the option. Qualifications of the independent public accountant and any accompanying independent public accountants report must conform to Article 2 of SEC Regulation S-X. Trend Capitals trading program relies on a fundamental-based approach in identifying potential investments. As such, there is a potential conflict of interest related to managing accounts that provide Trend Capital with higher performance-based compensation alongside accounts that provide lower performance-based compensation. Emphasis is placed on trade construction, including how each trades volatility and correlations affect the overall portfolio characteristics, in hopes of maximizing risk/return of the Trend Macro Fund or Enhanced Return. Stock Index Options. Ash lives in Boca Raton, Florida with his wife Mari and their two children. The use of repurchase and reverse repurchase agreements by the Funds involves certain risks. The purpose of these visits is to ascertain the views of domestic policymakers, both private and public, assess the state of domestic businesses and business conditions, understand domestic politics and understand local investor sentiment as well as supply/demand conditions, so that these qualitative factors may be incorporated into Trend Capitals portfolio decisions. Explain how a client may obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period. In addition, many nonU.S. Sep 3, 2017 | Fund Employees. Securities futures contracts include both futures contracts on single stocks and futures contracts on narrow-based securities indices. 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. If the Funds engage in an offsetting transaction, it will incur a gain or loss to the extent that there has been movement in forward currency contract prices. Additional risks associated with derivatives trading include: Tracking. In the manner described above, credit default swaps can be used to hedge a portion of the default risk on a single corporate bond or a portfolio of bonds. If you permit a client to direct brokerage, describe your practice. The fact that Trend Capital, 34 its employees, affiliates or their related persons also invest directly (or indirectly via deferred compensation) in any one, some, or all of the Funds creates a potential conflict of interest in that it could cause Trend Capital to make different investment decisions than if they did not have such financial ownership interest. Trend Capital applies rigorous fundamental macroeconomic analysis and a disciplined portfolio construction framework to generate absolute returns with low correlation to the markets. 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