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. 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. Short selling involves selling financial instruments which are not owned by the short seller and borrowing them for delivery to the purchaser, with an obligation to replace the borrowed financial instruments at a later date. The instruments and borrowings utilized by the Funds to leverage investments may be collateralized by the Funds portfolio. 1. broker-dealer, municipal securities dealer, or government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or hedge fund, and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading advisor, 11. sponsor or syndicator of limited partnerships. The original discount approximates the total amount of interest the bonds will accrue and compound over the period until maturity or the first interest accrual date at a rate of interest reflecting the market rate of the security at the time of issuance. Clients or prospective clients may arrange a time to review Trend Capitals Code of Ethics at its offices in Boca Raton, Florida by contacting the Chief Compliance Officer, Brian Barry, at 561-617-5086. Unlisted Financial Instruments. Similarly, floating rate issuers and borrowers tend to prepay their obligations when spreads narrow. View Ashwin Vasan's profile on LinkedIn, the world's largest professional community. Margin requirements for transactions that are not bona fide hedging are significantly higher than for bona fide hedging transactions. Illiquidity. A copy of the Firms Allocation Policy can be obtained by contacting Trend Capital. This risk may cause some or all of the Funds gains to be unrealized. The UCITS is not open to U.S. investors. 44. Managed Account payment terms are specifically negotiated, with payment generally in arrears. 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. If the Funds invest in derivatives at inopportune times or incorrectly judge market conditions, the investments may lower the return of the Funds or result in a loss. The amount of borrowings and leverage which the Funds may have outstanding at any time may be substantial in relation to their capital. Conversely, when interest rates rise, the value of fixed-income instruments generally can be expected to decline. Trend Capital recognizes that certain potential conflicts of interests may arise in connection with the personal trading activities of individuals associated with Trend Capital. . If you review client accounts on other than a periodic basis, describe the factors that trigger a review. Some non-U.S. markets have a higher potential for price volatility and relative. Research and Other Soft Dollar Benefits. iITEM 3 TABLE OF CONTENTS iiITEM 4 ADVISORY BUSINESS 1ITEM 5 FEES AND COMPENSATION .. 4ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDEMANAGEMENT .. 8ITEM 7 TYPES OF CLIENTS .. 9ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIESAND RISK OF LOSS 10ITEM 9 DISCIPLINARY INFORMATION 29ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES ANDAFFILIATIONS 31ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST INCLIENT TRANSACTIONS AND PERSONAL TRADING . Trend Capital acts as the investment manager of the Funds. State whether these reports are written. The Funds expect to use and may use a high degree of, leverage as part of the Funds investment program. The adverse effects of prepayments may impact the Funds portfolio in two ways. While the Funds may enter into hedging transactions to seek to manage risk, such transactions may result in a poorer overall performance for the Funds than if it had not engaged in any such hedging transaction. Flexible Investment Approach. 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. ault Swaps; Other Derivatives. 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. . If you hold yourself out as specializing in a particular type of advisory service, such as financial planning, quantitative analysis, or market timing, explain the nature of that service in greater detail. If this occurs, Trend Capital may be unable to effectively use its forward trading programs and the Funds could experience significant losses. Trend Capital Opportunities GP LLC is the general partner of the Opportunities Onshore and Class M Shareholder of the Opportunities Master. 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. Each Funds offering documents contain a detailed description of the applicable Funds fee schedule.Management Fee. 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. Unlisted Financial Instrument Swaps and other derivatives instruments are subject to legal, tax and market uncertainties that present risks in entering into these derivatives. The AIF is not currently open to U.S. investors. Management fees from the Managed Accounts are payable monthly in arrears. . Prior to Shumway, Mr. Vasan was a Partner and Portfolio Manager at Tudor Investment Corporation from 1999 to 2009. There can be no assurance that Trend Capital will be able to locate investment opportunities or to exploit such trends. These instruments may offer higher yields than do higher rated instruments, but generally involve greater price volatility. Increases in interest rates may cause the value of the Funds investments to decline. The CFTC and certain exchanges and trading facilities have established speculative position limits on the maximum net long or net short positions that any person may hold or control in particular commodities. In order to manage this conflict of interest, Trend Capitals Code of Ethics requires related persons of Trend Capital to obtain prior written approval from the Compliance Department before engaging in securities transactions in their personal accounts. The Funds may invest in credit default swaps. This is intended to outline for Trend Capital the key variables that might influence itstrading strategy. Describe generally how you address conflicts that arise. Trend Capital need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost or spread. 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. 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. As a result, a relatively small price movement in a futures contract may result in substantial losses to the Funds. 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. The Funds may employ swaps for speculative purposes, such as to obtain the price performance of a security without purchasing it in cases where the security is illiquid, unavailable for direct investment or available only on less attractive terms. Source. At or before the maturity of a forward currency contract, the Funds may either make delivery of the currency, or terminate its contractual obligation to deliver the currency by buying an offsetting contract obligating it to buy, on the same maturity date, the same amount of the currency. Unfavorable economic conditions also could increase funding costs, limit access to the capital markets or result in a decision by lenders not to extend credit to the Funds. 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. Ashwin Vasan is an economist with over 25 years of investment experience. Trend Capital and its affiliate general partner entities are deemed to have custody by virtue of their status as investment manager and general partner, respectively, of the Funds. In this episode of the Tony Robbins Podcast, you will hear from Ashwin Vasan, CIO of macro hedge fund Trend Capital.Prior to starting Trend Capital in 2011, Ashwin helped to build a variety of large multi-million dollar businesses including Shumway Capital Partners, Tudor Investment Corporation, Oppenheimer Funds and Citibank. There also can be no assurance that the financial instruments necessary to cover a short position will be available for purchase at or near prices quoted in the market. Prior to Shumway, Mr. Vasan was a Partner and Portfolio Manager at Tudor Investment Corporation from 1999 to 2009. 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. In addition, governments from time to time intervene, directly and by regulation, in these markets, with the specific effect, or intention, of influencing prices which 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. 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. Trend Capital LLC is a Connecticut Foreign Limited-Liability Company filed on May 13, 2011. Market disruption events could also have a direct physical impact upon the Funds and/or the Advisers operations, including the destruction of their facilities and/or loss of life to key personnel. Each Fund is not limited as to the amount of capital or exposure which may be committed to any one issuer, industry, sector, strategy, country or geographic region. The business owners that power this multibillion dollar industry are changing, and a new era of the business of sports is underway. He founded Trend Capital in 2011 upon the closing of Shumway Capital Partners, where he had served as the Head of Macro Trading since July 2009. If you have custody of client funds or securities and a qualified custodian sends quarterly, or more frequent, account statements directly to your clients, explain that clients will receive account statements from the broker-dealer, bank or other qualified custodian and that clients should carefully review those statements. Describe the content and indicate the frequency of regular reports you provide to clients regarding their accounts. Trend Capital is headquartered in Boca Raton, Florida and maintains a branch office in Greenwich, Connecticut. 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. The Funds may take advantage of opportunities with respect to certain other derivative instruments that are not presently contemplated for use or are not currently available, but may be developed, to the extent such opportunities are deemed by Trend Capital to be consistent with the investment objective of the Funds. 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. 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. Call Options. The value of fixed-income securities in which the Funds may invest will change in response to fluctuations in interest rates. Before joining Tudor, he was a Portfolio Manager at Oppenheimer Funds with oversight of the international fixed income business. 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. Explain that you will provide a copy of your code of ethics to any client or prospective client upon request. 3. Explain the conflicts of interest that you or your supervised persons face by managing these accounts at the same time, including that you or your supervised persons have an incentive to favor accounts for which you or your supervised persons receive a performance-based fee and describe generally how you address these conflicts. The level of interest rates generally and the rates at which the Funds can borrow particularly, will affect the operating results of the Funds. First, particular investments may experience outright losses, as in the case of an interest-only instrument in an environment of faster actual or anticipated prepayments. 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. The Firm has adopted and implemented a compliance program, including a Valuation Committee that reviews performance tracking and position differences, to monitor its Funds and Managed Accounts for adherence to investment objectives and a fair allocation process to help mitigate any potential conflicts. Fundamental based analysis relies on the study of external factors to predict the price movement of a given investment. For simplicity, each fund or SP identified above may be referred to individually in this Brochure as a Fund and together as the Funds. To the extent any Managed Account applies a more stringent standard, Trend Capital will comply with the applicable restrictions.n. The Funds may trade forward contracts. Such services and items may influence Trend Capitals selection of brokers. 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). These contracts, unlike exchange-traded futures contracts and options on futures, are not regulated by the CFTC. All such compensation is fully disclosed to each prospective investor consistent with applicable law. C. A. 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. Explain that clients have the option to purchase investment products that you recommend through other brokers or agents that are not affiliated with you.Not applicable. If the Funds are required to liquidate all or a portion of its portfolio quickly, the Funds may realize significantly less than the value at which it previously recorded those investments. 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. A principal risk in trading currencies is the rapid fluctuation in the market prices of currency contracts. Exchanges. A short sale creates the risk of a theoretically unlimited loss, in that the price of the underlying financial instrument could theoretically increase without limit, thus increasing the cost to the Funds of buying those financial instruments to cover the short position. In general, third party solicitors may receive a portion of the fees otherwise payable to Trend Capital. There are 2 other people named Ashwin Vasan on AllPeople. The portfolio turnover rate of those investments may be significant and could involve substantial brokerage commissions and other transaction costs. Describe the procedures you follow before you assume this authority (e.g., execution of a power of attorney). There can be no assurance that future court decisions construing provisions in, or provisions similar to those in, any swap agreement or other related documents or new and additional regulations and laws governing swaps and other derivatives will not have a material adverse effect on the investments. If the Funds engage in an offsetting transaction, they may later enter into a new forward currency contract to sell the currency. Explain that by directing brokerage you may be unable to achieve most favorable execution of client transactions and that this practice may cost clients more money. Derivatives that may be purchased or sold by the Funds may include securities and instruments not traded on an exchange. Live market coverage co-anchored from Hong Kong and New York. Describe how you address conflicts of interest between you and your clients with respect to voting their securities. Interest Rate Risk. Derivatives typically allow an investor to hedge or speculate upon the price movements of a particular security, financial benchmark or index at a fraction of the cost of acquiring, borrowing or selling short the underlying asset. Such factors include government regulation, new technologies and political and economic events. 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. As described in Item 5.B above, each master funds general partner (or other Trend Capital affiliate) receives an incentive allocation, which is performance-based, and Trend Capital receives performancebased compensation for its services on behalf of the Managed Accounts, in each instance subject to a loss carryforward. Research and brokerage services obtained by the use of commissions arising from the Funds portfolio transactions may be used by Trend Capital in its other investment activities and thus, the Funds may not necessarily, in any particular instance, be the direct or indirect beneficiaries of the research or brokerage services provided. These transactions are not exchange-traded so that no clearinghouse or exchange stands ready to meet the obligations of the contract. If you and the brokerdealer are affiliates or have another economic relationship that creates a material conflict of interest, describe the relationship and discuss the conflicts of interest it presents. Trend Capital does not participate in wrap fee programs. The risk of nonperformance by the obligor on a security or instrument may be greater than and the ease with which the Funds can dispose of or enter into closing transactions with respect to a security or instrument may be less than, the risk associated with an exchange traded security. Please refer to the relevant offering documents for a detailed description of the material risks related to an investment. Some examples of the key drivers of trends for each asset class that are modeled are outlined below: Interest RatesInflation Model both the long-term trend in inflation as well as its short-term direction.Monetary Policy Model appropriate monetary policy settings via Taylor Rule analysis.Term Premium Model the term structure of interest rates to assess whether risk premiums are overstated or understated. Certain potential conflicts of interest between you and your clients with respect to voting their securities futures may... Fixed-Income securities in which the Funds may have outstanding at any time may be significant and could substantial! Involve greater price volatility and relative Funds engage in an offsetting transaction, they may later enter a! May invest will change in response to fluctuations in interest rates and maintains a branch office Greenwich! Or sold by the Funds may invest will change in response to fluctuations in interest rates may the... 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