Turnover. Trend Capital Management LP has been registered with the CFTC as a commodity pool operator under the Commodity Exchange Act and has been a member of the National Futures Association since January 2, 2013; Trend Capital GP LLC has also been registered with the CFTC as a commodity pool operator under the Commodity Exchange Act and has been a member of the National Futures Association since January 2, 2013; and Trend Capital Advisers LP has been registered with the CFTC as a commodity pool operator under the Commodity Exchange Act and has been a member of the National Futures Association since October 16, 2017. The value of fixed-income securities in which the Funds may invest will change in response to fluctuations in interest rates. Unlisted Financial Instrument Swaps and other derivatives instruments are subject to legal, tax and market uncertainties that present risks in entering into these derivatives. Phone (703) 729-1500. If forward prices go down during the period between the date the Funds enter into a forward currency contract for the sale of a currency and the date they enter into an offsetting contract for the purchase of the currency, the Funds will realize a gain to the extent that the price of the currency they have agreed to sell exceeds the price of the currency they have agreed to buy. Trend Capital has discretionary authority to manage the investments of the Funds and the Managed Accounts. Trend Capital is headquartered in Boca Raton, Florida and maintains a branch office in Greenwich, Connecticut. ashwin vasan Founder and cio at Trend Capital Management LP . 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. ETFs are also subject to certain additional risks, including, without limitation, the risk that their prices may not correlate perfectly with changes in the prices of the underlying securities they are designed to track and the risk of trading in an ETF halting due to market conditions or other reasons, based on the policies of the exchange upon which the ETF trades. In addition, brokers may provide other services that are beneficial to Trend Capital, but not necessarily beneficial to the Funds, including, without limitation, capital introduction, marketing assistance, consulting with respect to technology, operations or equipment and other services or items. Items 9.A, 9.B and 9.C list specific legal and disciplinary events presumed to be material for this Item. If your clients either may or must pay your fees in advance, disclose this fact. 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. Trend Capital Management LP is a Delaware limited partnership that was formed in May 2011 to manage entities that capitalize on fundamental trends in currencies, interest rates, and credit and equity indices in both developed and emerging markets. Mr. Vasan began his career at Citibank in 1989 as an International Economist. Trend Capital Opportunities GP LLC is the general partner of the Opportunities Onshore and Class M Shareholder of the Opportunities Master. The Funds may hold cash or cash equivalent instruments at any point in time. 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. 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. Ashwin Kumar Vasan - Trend Capital Management LP. If you do not have authority to vote client securities, disclose this fact. Trend Capitals trading program relies on a fundamental-based approach in identifying potential investments. The price of stock index futures contracts may not correlate perfectly with the movement in the underlying stock index because of certain market distortions. The investment strategy for any future SP will be described in detail in the applicable PPM Supplement. Investment Program of Trend Capital. Trend Capital also compensates Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S) for its clients introduced to the Trend Macro Funds. 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If you recommend primarily a particular type of security, explain the material risks involved. Ashwin Vasan is an economist with over 25 years of investment experience. Non-U.S. Investments. Found 2 colleagues at Trend Capital Management LP. The adverse effects of prepayments may impact the Funds portfolio in two ways. For documentation purposes, Trend Capital will always provide the date of the last annual update of the Brochure. This requires different skills and techniques than predicting changes in the price of individual stocks. On average, homes in Ashburn, VA sell after 20 days on the market compared to 275 days last year. ITEM 2 MATERIAL CHANGES . Trend Capitalis paid a 1.25% annualized management fee for the Enhanced Return SP, subject to an initial minimum subscription amount.The respective general partner (or other Trend Capital affiliate) may, in its sole discretion, waive, reduce or calculate differently the incentive allocation with respect to certain investors. As further described in Item 8.A below, the Trend Macro Fund, ERISA Master, Enhanced Return and associated Managed Accounts, subject to applicable legal, regulatory or investment restrictions, invest to capitalize on fundamental trends in currencies, interest rates and credit and equity indices in both developed and emerging markets. The same individuals serve as directors for the ERISA Offshore, Opportunities Offshore, and Opportunities Master. Ashwin has 1 job listed on their profile. IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE 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. Disclose that you may have an incentive to select or recommend a brokerdealer based on your interest in receiving the research or other products or services, rather than on your clients interest in receiving most favorable execution. Describe how clients may obtain information from you about how you voted their securities. Ashwin Vasan has an ownership stake in Trend Capital Management LP of more than 75%. Explain whether (and, if so, how) you tailor your advisory services to the individual needs of clients. 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 applicable fee share is disclosed in the Prospectus and related Prospectus Supplement. Commodity-Related Instruments. This could prevent the prompt liquidation of unfavorable positions and subject the Funds to substantial losses. Additionally, such events may have a substantial effect on economies and securities markets, and could adversely affect individual issuers or related groups of issuers, securities markets, interest rates, credit ratings, inflation, investor sentiment, and other factors affecting the value of the Funds investments. In addition, credit default swaps can be used to implement Trend Capitals view that a particular credit, or group of credits, will experience credit improvement. If you receive research or other products or services other than execution from a broker-dealer or a third party in connection with client securities transactions (soft dollar benefits), disclose your practices and discuss the conflicts of interest they create. Derivative Financial Instruments and Instruments Generally. [1] [2] Vasan is also a public health professor and was most recently the president and CEO of Fountain House, a national mental health nonprofit. In addition, many nonU.S. Explain the procedures you used during your last fiscal year to direct client transactions to a particular broker-dealer in return for soft dollar benefits you received. It is possible that as a result of war, terrorist act, natural disaster, outbreaks of infectious disease, epidemic, pandemic or other serious public health concern, or geopolitical or other extraordinary or unforeseen circumstance or event, one or more of these markets may cease operating for a limited or indeterminate period of time. 2022 Trend Capital Management LP, All Rights Reserved. For example, in a directed brokerage account, the client may pay higher brokerage commissions because you may not be able to aggregate orders to reduce transaction costs, or the client may receive less favorable prices. Exchange Traded Funds. In addition, the Funds will have 15 the authority to borrow money for cash management purposes and to meet withdrawals that would otherwise result in the premature liquidation of their investments. Ashwin Vasan is an economist with over 25 years of investment experience. Indicate whether you periodically review client accounts or financial plans. 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. Trend Capital seeks to identify those trends that it believes are not priced in by the market and uses technical analysis and other factors to identify the entry and exit points it believes are most appropriate. Thus, the leverage offered by trading in derivatives will magnify the gains and losses experienced by the Funds and could cause the Funds net asset value to be subject to wider fluctuations than would be the case if the Funds did not use the leverage feature of derivatives. 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. Leverage; Borrowing for Operations. 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. As noted above, one of the managed accounts will close at the end of March 2020. The Funds expect to use and may use a high degree of, leverage as part of the Funds investment program. Ashwin Vasan, Ramesh Parameswar, Brian Goldenberg, Bryan Getz and Brian Barry are each registered as principals and associated persons of Trend Capital Management LP, Trend Capital GP LLC and Trend Capital Advisers LP and Amy Bordonaro Collins is registered as an associated person of Trend Capital Management LP, Trend Capital GP LLC and Trend Capital Advisers LP. In markets in which liquid options are available, Trend Capital often implements option hedges against trades in the Trend Macro Funds or Enhanced Returns portfolio. The limitation of potential (and actual) loss in any period of time is pivotal to the investment framework of the Trend Macro Fund or Enhanced Return. In addition, daily limits on price fluctuations and speculative position limits on exchanges on which the Funds may conduct their transactions in derivatives may prevent profitable 25 liquidation of positions, subjecting the Funds to the potential of greater losses. Therefore, the Funds will not receive any benefit of CFTC regulation for these trading activities. There is also less regulation, generally, of the markets in non-U.S. countries than there is in the United States. All personnel of Trend Capital are required to certify their compliance with the Code of Ethics. Companies whose securities are not publicly traded may not be subject to public disclosure and other investor protection requirements applicable to publicly traded securities. The Funds may enter into spot and forward currency contracts and options on currencies to trade currencies or to shift exposure to foreign currency fluctuations from one currency to another with respect to the Funds. Ashwin Vasan Email Founder and Chief Information Officer @ Trend Capital Management Preparing Ashwin profile View Ashwin's Email . The level of interest rates generally and the rates at which the Funds can borrow particularly, will affect the operating results of the Funds. Identify the related person and if the relationship or arrangement creates a material conflict of interest with clients, describe the nature of the conflict and how you address it. This Foreign Limited Liability company is located at 1800 N. MILITARY TRAIL, SUITE 475, BOCA RATON, FL, 33431, US and has been running for seven years. Investors should carefully review the audited financial statements of the Funds upon receipt. Reset here, 1999 - 2023 citywire.com. Trend Capital LLC is a Connecticut Foreign Limited-Liability Company filed on May 13, 2011. Commodity exchanges and trading facilities limit fluctuations in certain commodity futures contract prices during a single day by regulations referred to as daily price fluctuation limits or daily limits. Trend Capital acts as the investment manager for each of the Funds and investment adviser or designated portfolio manager to three (3) Managed Accounts, one of which is also structured as a private investment fund for clients of an unaffiliated alternative asset management firm. . The minimum and additional subscription amounts are reduced for each investor introduced to one of the Trend Macro Funds by Merrill Lynch. The receipt of an incentive allocation creates an incentive for Trend Capital to make investments that are riskier or more speculative than it otherwise would. Price movements of commodity futures contracts are influenced by, among other things, changing supply and demand relationships, governmental agricultural and trade programs and policies and national and international political and economic events. Market disruption events could also affect the principal prime brokers that carry and clear the Funds trades and positions. 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. Citywire ranks and rates all portfolio managers running mutual funds without charge. 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. Ashwin is Chief Investment Officer and has served as Chief Investment Officer since 05/01/2011. The buyer of a call option assumes the risk of losing its entire premium investment in the call option. Provide your fee schedule. Before joining Tudor, he was a Portfolio Manager at Oppenheimer Funds with oversight of the international fixed income business. Trend Capital endeavors to limit the impact of extreme events in financial 12 markets through the use of dollar loss limits and risk controls, including a limited reliance on stop losses and judicious use of portfolio and position hedges. 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. No advisory board has been established for Funds other than Trend Macro Fund. 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. 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. The Funds and the Managed Accounts have broad and flexible investment authority. Secondly, from the point of view of speculators, the deposit requirements in the futures market are less onerous than margin requirements in the securities market. Further, the Chief Compliance Officer periodically reviews Trend Capitals investments to ensure consistency with applicable law and regulations. In addition, it is possible that Trend Capital may select investments that are concentrated in a limited number or type of financial instruments or assets. Commodity futures trading is highly speculative. Each such related person transaction is separately identified and made strictly in accordance with Trend Capitals Code of Ethics. The investment manager may also invest up to 10% of the applicable master funds net asset value (determined as of the date of the last purchase) in single-name corporate CDS and other credit securities. Where the Funds and/or Managed Accounts are managed pari passu (subject to legal, regulatory and investment guideline restrictions or expanded exposure limits), Trend Capital addresses the potential conflict by making any allocation decisions based upon the best interests of all Advisory Clients on a fair and equitable basis consistent with Trend Capitals fiduciary obligations to the extent possible, under existing laws and regulations in accordance with the Firms Allocation Policy. 2. was found to have been involved in a violation of the SROs rules and was: (i) barred or suspended from membership or from association with other members, or was expelled from membership; (ii) otherwise significantly limited from investment-related activities; or (iii) fined more than $2,500. Trading instructions may have to be modified and the Funds positions may need to be liquidated to avoid exceeding these limits. The Opportunities Offshore and Opportunities Onshore will each create a separate SP for each investment opportunity it offers to investors, each of which will invest all of its investable assets in a corresponding SP of the Opportunities Master Fund. The information contained in this Item 8 is a summary only and is qualified in its entirety by the relevant Advisory Clients offering documents. If the seller becomes insolvent and subject to liquidation or reorganization under applicable bankruptcy or other laws, the Funds ability to dispose of the underlying financial instruments may be restricted. Sovereign Debt may include securities that Trend Capital believes are likely to be included in restructurings of the external debt obligations of the issuer in question. rend Macro Funds assets in a way that it will be flat or positive carry in aggregate, including the cost of its hedging program. 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. Trend Capital is of the view that its long-term business interests are best served by adherence to the principle that investors interests come first. The lack of evaluation and oversight of over-the-counter markets exposes the Funds to the risk that a counterparty will not settle a transaction in accordance with its terms and conditions because of a dispute over the terms of the contract (whether or not bona fide) or because of a credit or liquidity problem, thus causing the Funds to suffer a loss. Relatively small futures positions have the potential to significantly erode or erase the Funds gains in other investments. All futures positions held by all accounts owned or controlled by Trend Capital and its principals will be aggregated with the Funds positions for purposes of determining compliance with these limits. Please see terms and conditions for restrictions on use of Citywire's Fund Manager database. Such risks may include, but are not limited to: (i) increased risk of nationalization or expropriation of assets or confiscatory taxation; (ii) greater social, economic and political uncertainty including war; (iii) higher dependence on exports and the corresponding importance of international trade; (iv) greater volatility, less liquidity and smaller capitalization of securities markets; (v) greater volatility in currency exchange rates; (vi) greater risk of inflation; (vii) greater controls on foreign investment and limitations on repatriation of invested capital and on the ability to exchange local currencies for U.S. dollars; (viii) increased likelihood of governmental involvement in and control over the economies; (ix) governmental decisions to cease support of economic reform programs or to impose centrally planned economies; (x) differences in auditing and financial reporting standards which may result in the unavailability of material information about issuers; (xi) less extensive regulation of the securities markets; (xii) less established tax laws and procedures; (xiii) longer settlement periods for securities transactions and less reliable clearance and custody arrangements; (xiv) less developed corporate laws regarding fiduciary duties of officers and directors and the protection of investors; and (xv) certain considerations regarding the maintenance of Fund securities and cash with non-U.S. brokers and securities depositories. 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. If you do not aggregate orders when you have the opportunity to do so, explain your practice and describe the costs to clients of not aggregating. Disclose whether you use soft dollar benefits to service all of your clients accounts or only those that paid for the benefits. 3. Trend Capital presently provides investment advisory services to the Funds via master-feeder structures and three (3) Managed Accounts. Trend Capital Management, LLC (TCM) is a Registered Investment Advisor in the states of Kansas and Missouri. The Funds global macro investing consists primarily of trading in global interest rates, currencies, credit and equity indices and their related derivatives, in order to exploit fundamental, economic, financial and political trends that may exist in and between developed and emerging markets throughout the world. Trend Capital provides investment advisory services to the Funds, which are private investment vehicles. Commodity Interest Trading may be Volatile. There can be no assurance that Trend Capital will be successful in applying its approach and there is material risk that an investor may suffer significant impairment or total loss of its capital. Trend Capital will always select brokers on the basis of seeking best execution and may consider capital introduction services as one among many relevant factors. Daily Price Fluctuation Limits. At times, certain market makers have refused to quote prices for forward contracts, or have quoted prices with an unusually wide spread between the price at which they are prepared to buy and sell. In the event that the theses underlying the Funds positions fail to be borne out in developments expected by Trend Capital, the Funds may incur losses, which could be substantial. Similarly, floating rate issuers and borrowers tend to prepay their obligations when spreads narrow. Sovereign Debt. Describe the methods of analysis and investment strategies you use in formulating investment advice or managing assets. Limited diversity could expose the Funds to losses disproportionate to market movements in general if there are disproportionately greater adverse price movements in those financial instruments or assets. 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. Prior to Shumway, Mr. Vasan was a Partner and Portfolio Manager at Tudor Investment Corporation from 1999 to 2009. Such services and items may influence Trend Capitals selection of brokers. 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. Securities Futures Contracts. Each Fund or SP, as applicable, will bear all of its (and the pro-rata share of its corresponding master funds or master fund SPs, as applicable) legal and other organizational expenses incurred in the formation of that Fund (its master fund or master fund SP and, each SP shall also pay 20% of the organizational expenses incurred in formation of the Opportunities Funds umbrella structure) and its ongoing capital-raising activities, including all expenses relating to the offer and sale of interests/shares. Refer to Item 12 for further information. 100 W Putnam Ave Greenwich, CT 06830. Such intervention often is intended directly to influence prices and may, together with other factors, cause all of such markets to move rapidly in the same direction because of, among other things, interest rate fluctuations. Explain that when you use client brokerage commissions (or markups or markdowns) to obtain research or other products or services, you receive a benefit because you do not have to produce or pay for the research, products or services. Trend Capital may have other investment strategies or methods of analysis, or engage in other activities, than those described herein. If you or any of your supervised persons accepts performance-based fees that is, fees based on a share of capital gains on or capital appreciation of the assets of a client (such as a client that is a hedge fund or other pooled investment vehicle) disclose this fact.
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