Thus, the Funds face the risk that their counterparties may not perform their obligations. Advertisements. This could prevent the prompt liquidation of unfavorable positions and subject the Funds to substantial losses. Operational Leverage. Margin requirements vary not only by the type of commodity contract, but also depending upon whether the transaction is for bona fide hedging as defined in Section 1.3(z) of the CFTC Regulations. Trend Capital may invest in zero coupon bonds and deferred interest bonds, which are debt obligations issued at a significant discount from face value. Increases in interest rates may cause the value of the Funds investments to decline. 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Disclose the date as of which you calculated the amounts. Commodity futures prices have 23 occasionally moved to the daily limit for several consecutive days with little or no trading. 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. For each significant investment strategy or method of analysis you use, explain the material risks involved. Provide your fee schedule. 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. Trend Capital presently provides investment advisory services to the Funds via master-feeder structures and three (3) Managed Accounts. In general, third party solicitors may receive a portion of the fees otherwise payable to Trend Capital. This requires different skills and techniques than predicting changes in the price of individual stocks. Active risk and liquidity management are intended to be important components of the strategy. The Funds receive or pay, as the case may be, only the net amount of the two payments. Trend Capital acts as the investment manager of the Funds. Managed Account payment terms are specifically negotiated, with payment generally in arrears. 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. Please contact Trend Capital for further information. 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. Ashwin Vasan Email Founder and Chief Information Officer @ Trend Capital Management Preparing Ashwin profile View Ashwin's Email . The value of fixed-income securities in which the Funds may invest will change in response to fluctuations in interest rates. Notwithstanding the foregoing, in Trend Macro Offshore, ERISA Offshore or Opportunities Offshore, the minimum initial investment may never be less than the then-current minimum as prescribed by the Mutual Funds Law (as amended) of the Cayman Islands (currently $100,000USD). The Funds also could experience losses if derivatives are poorly correlated with its other investments. Fundamental analysis produces positive results only to the extent that Trend Capital correctly predicts how external factors (such as government regulation, new technologies and political and economic events) will influence the market price of a given investment. 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. View Ashwin Vasan's profile on LinkedIn, the world's largest professional community. There can be no assurance that the investment program will be successful in a given set of market conditions, or that it is the most successful system available. Lenders providing financing to the Funds can apply essentially discretionary margin, haircut, and financing and collateral valuation policies. 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. There is currently limited case law or litigation characterizing swaps and certain other derivatives, interpreting their provisions or characterizing their tax treatment. Describe the types of advisory services you offer. Each such related person transaction is separately identified and made strictly in accordance with Trend Capitals Code of Ethics. If you or any of your supervised persons accepts compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds, disclose this fact and respond to Items 5.E.1, 5.E.2, 5.E.3 and 5.E.4. Dun & Bradstreet Data last . If forward prices go up, the Funds will suffer a loss to the extent the price of the currency they have agreed to buy exceeds the price of the currency they have agreed to sell. If you do, describe the frequency and nature of the review and the titles of the supervised persons who conduct the review. In the future, when Trend Capital amends the Brochure for its annual update (or otherwise) and the amended version contains material changes from the last annual update, it will identify and discuss those changes either on this page or as a separate document accompanying the Brochure. Incentive AllocationIn addition, the applicable Funds general partner (or other Trend Capital affiliate) may receive an incentive allocation if net profits allocated to the respective master funds capital account exceed net losses allocated to that account, subject to a loss carryforward provision. 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. Trend Capital applies rigorous fundamental macroeconomic analysis and a disciplined portfolio construction framework to generate absolute returns with low correlation to the markets. Trend Capital may retain an independent third party to vote proxies in certain situations (including situations where a material conflict of interest is identified). Trend Capital takes a balanced approach to investing the Trend Macro Funds or Enhanced Returns assets. Describe how you are compensated for your advisory services. Disclose whether you use soft dollar benefits to service all of your clients accounts or only those that paid for the benefits. Swap Transactions. Trend Capital may utilize such leverage, position size, duration and other portfolio management techniques as it believes are appropriate for the Funds. Changes in liquidity may result in significant, rapid and unpredictable changes in the prices for derivatives. 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. 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. In addition, significant disparities may exist between bid and asked prices for derivatives that are not traded on an exchange. Each SP of the Opportunities Funds pursues its own investment opportunities, as described further in Item 8.A. 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. If someone who is not a client provides an economic benefit to you for providing investment advice or other advisory services to your clients, generally describe the arrangement, explain the conflicts of interest and describe how you address the conflicts of interest. Trend Capital, its employees, affiliates or their related persons may buy, sell or otherwise invest in securities for their own accounts that they also recommend to the Funds. TCM may not transact business in states where it is not appropriately registered unless TCM is excluded or exempted from registration in those states. In addition, many nonU.S. Emerging and Developing Markets. Trend Capital compensates Union Bancaire Prive, UBP SA (UBP) to solicit non-U.S. investors in designated jurisdictions for the Trend Macro Offshore. 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. Securities futures contracts are subject to the same risks as other securities, as well as to the greater volatility and risks of futures trading. 2. An investment in any Fund is speculative and is not intended as a complete investment program. 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. If your clients also receive account statements from you, your explanation must include a statement urging clients to compare the account statements they receive from the qualified custodian with those they receive from you. Markets never sleep, and neither does Bloomberg. The companies were formed over a two year period with the most recent being incorporated four years ago in May of 2018. 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. Live market coverage co-anchored from Hong Kong and New York. Purchasing financial instruments to cover the exercise of an uncovered call option can cause the price of the financial instruments to increase, thereby exacerbating the loss. The effect of the use of leverage by the Funds in a market that moves adversely to its investments could result in substantial losses to the Funds, which would be greater than if the Funds were not leveraged. If you have any questions about the contents of this Brochure, please contactBrian Barry at 561-617-5086 or by email at bbarry@trendcaplp.com. All personnel of Trend Capital are required to certify their compliance with the Code of Ethics. An administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority in which your firm or a management person, 1. was found to have caused an investment-related business to lose its authorization to do business; or, 2. was found to have been involved in a violation of an investmentrelated statute or regulation and was the subject of an order by the agency or authority. Portfolio No one trade idea, 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. Margin requirements for transactions that are not bona fide hedging are significantly higher than for bona fide hedging transactions. As of December 31, 2019, Trend Capital and its affiliates have $1,690,535,398 of regulatory assets under management and $1,348,292,058 of net assets under management, which are managed on a discretionary basis. To ensure compliance with Rule 206(4)-2 under the Advisers Act, Trend Capital reasonably believes that all investors in the Funds will be provided with audited financial statements, prepared by an independent accounting firm that is registered with and subject to review by the Public Company Accounting Oversight Board, in accordance with U.S. Generally Accepted Accounting Principles, within 120 days, of the end of the Funds fiscal years. Prior to Shumway, Mr. Vasan was a Partner and Portfolio Manager at Tudor Investment Corporation from 1999 to 2009. Blue Sky Digital Outdoor Advertising Fund Fund Data, Sarasin Ie Global Equity Opportunities (Usd) Fund Data, Themelios Ventures Ii-A, L.P. Fund Data. Since many fixed rate obligations will be discount instruments when interest rates and/or spreads are high and will be premium instruments when interest rates and/or spreads are low, such debt instruments and asset-backed instruments may be adversely affected by changes in prepayments in any interest rate environment. 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. If you do not have authority to vote client securities, disclose this fact. Trend Capital has established an Advisory Board for Trend Macro Fund (the Advisory Board), the members of which serve as members of the Board of Directors of the Trend Macro Offshore. 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. 3. Sep 3, 2017 | Fund Employees. It should be noted that the fact that a Funds general partner (or other Trend Capital affiliate)receives performance-based compensation creates a potential conflict of interest in that it may create an incentive for Trend Capital to effectuate larger and riskier transactions than would be the case in the absence of such form of compensation. 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. Such concentration of risk may increase the losses suffered by the Funds or reduce their ability to hedge their exposure and to dispose of depreciating assets. In general, Trend Capital may receive a monthly management fee in advance based on the net asset value of the Trend Macro Fund, ERISA Master or applicable SP of the Opportunitiesfeeder funds, payable as of the first day of each month (adjusted for contributions made during the month). Source. Live from New York and Hong Kong, bringing you the essential stories from the close of the U.S. markets to the open of trading across Asia. Research and Other Soft Dollar Benefits. The applicable fee share is disclosed in the Prospectus and related Prospectus Supplement. Advisory Clients may be deemed to be paying for research and other services with soft or commission dollars. In fact, the Funds portfolio, at times, may be highly concentrated. 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. Ashwin Vasan Software Engineer at Amazon Web Services (AWS) Seattle, Washington, United States500+ connections Join to connect University of Colorado Boulder Activity I had a conversation with. Currency and Exchange Rate Risks. 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. Describe generally how you address conflicts that arise. r-dealer might charge or apply.If Trend Capital concludes that the commissions charged by a broker or the 36 spreads applied by a dealer are reasonable in relation to the quality of services rendered by such broker or dealer (including, without limitation, the value of the brokerage and research products or services provided by such broker or dealer), the Advisory Clients may pay commissions to or be subject to spreads applied by such broker-dealer in an amount greater than the amount another broker-dealer might charge or apply. Managed account trade error policies are the subject of negotiated agreements and may vary. It is critical that investors refer to the relevant offering documents for a complete understanding of that Advisory Clients investment objectives and strategies. The use of leverage should allow the Funds to make additional investments, thereby increasing their exposure to assets, such that their total assets may be greater than their capital; however, leverage may also magnify the volatility of changes in the value of the Funds portfolio. 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. 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. These actions could adversely affect the Funds operations and profitability. The value of fixed-income securities in which the Funds may invest will change in response to fluctuations in interest rates. For purposes of this Brochure, each such account is referred to as a Managed Account and together with the Funds, the Advisory Clients. 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. If you permit a client to direct brokerage, describe your practice. The Registered Agent on file for this company is R Scott Beach and is located at Day Pitnet Llp One East Putnam Ave, Greenwich, CT . Interests/Shares are sold only to qualified investors who are accredited investors under Rule 501 of Regulation D of the Securities Act of 1933, as amended, and qualified purchasers as such term is defined in Section 2(a)(51)of the Investment Company Act of 1940, as amended. Investors in designated jurisdictions for the trend Macro Funds or Enhanced returns.. 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