Each SP of the Opportunities Funds pursues its own investment opportunities, as described further in Item 8.A. 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. 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. The material changes since Trend Capital submitted its most recent annual amendment to the Brochure on March 29, 2019 include: As of June 30, 2019, Trend Capital Gaucho Fund LP and its offshore feeder, Trend Capital Offshore LP were terminated and capital was returned to investors. Although outside the period referenced, Permal Ash Macro Ltd is expected to wind down as a Managed Account (defined below) and the underlying investors representing a majority of its net asset value will subscribe directly into Trend Macro Fund LP on April 1, 2020. The Firm has included as an additional risk factor in Item 8.B, Market Disruption Events, which addresses the potential impact of significant events such as the recent COVID-19 pandemic. B. The Opportunities Master Fund SPs may utilize such investment techniques as option transactions, margin transactions, short sales, leverage and derivatives trading, which may create or increase volatility and can increase the adverse impact to which the Opportunities Master Fund SPs investment portfolios may be subject. 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. These investments involve special risks not usually associated with investing in securities of U.S. companies or the Federal, state or local government. Moreover, a disruption in the financing, derivative intermediation and prime brokerage services provided by any party before the Funds establish additional relationships could have a significant impact on the Funds business due to the Funds reliance on such counterparties. Trend Capitals trading program relies on a fundamental-based approach in identifying potential investments. The management fee is payable without regard to the overall success or income earned by the Funds and therefore creates an incentive on the part of Trend Capital to raise or otherwise increase assets under management to a higher level than would be the case if Trend Capital were receiving a lower or no management fee. Second, particular investments may underperform relative to hedges that Trend Capital may have constructed for these investments, resulting in a loss to the Funds overall portfolio. Trend Capital has entered, and may again in the future enter, into letter agreements or other similar agreements (collectively, Side Letters) with one (1) or more investors in the Funds, which provide such investors with additional and/or different rights (including, without limitation, nonparticipation in certain investments due to regulatory or other reasons, currency denominations, the performance-based compensation and/or management fees, redemption rights, expense reimbursement from Trend Capital, minimum and additional subscription amounts, portfolios, information rights and other rights) than other investors in the Funds. For each significant investment strategy or method of analysis you use, explain the material risks involved. Please refer to the offering documents of the Funds for a detailed description of the material risks related in an investment in the Funds. Trend Capital does not participate in wrap fee programs. Margin requirements for transactions that are not bona fide hedging are significantly higher than for bona fide hedging transactions. 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. Found 2 colleagues at Trend Capital Management LP. Trend Capital does not manage any Advisory Client assets on a non-discretionary basis. 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. Trend Capital also compensates Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S) for its clients introduced to the Trend Macro Funds. 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 routinely recommend, request or require that a client direct you to execute transactions through a specified broker-dealer, describe your practice or policy. commission cost or spread.Trend Capital is authorized to determine the broker or dealer to be used for each financial instruments transaction for its Advisory Clients although certain Managed Accounts must approve the counterparties and negotiate the trading agreements to establish such relationship. . Short Sales. Thus, the Funds face the risk that their counterparties may not perform their obligations. Trend Capital acts as the investment manager of the Funds. 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. Choose the right Crunchbase solution for you Start Your Free Trial Hedging Transactions. 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. 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. Similarly, even if more than ten years have passed since the date of the event, you must disclose the event if it is so serious that it remains material to a clients or prospective clients evaluation. 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. The UCITS is not open to U.S. investors. In general, Trend Capital seeks to achieve this investment objective by taking both long and short positions in a variety of fixed income instruments and derivatives, foreign currencies,foreign exchange forwards and foreign exchange derivatives, as well as in various derivative products linked to credit and equity indices. The information contained in this Item 5 is a summary only and is qualified in its entirety by the relevant offering documents for each Advisory Client. (a) denying, suspending, or revoking the authorization of your firm or a management person to act in an investment-related business; (b) barring or suspending your firms or a management persons association with an investment-related business; (c) otherwise significantly limiting your firms or a management persons investment-related activities; or (d) imposing a civil money penalty of more than $2,500 on your firm or a management person. 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. 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. Industry Group Agriculture Banking & Financial Services Business Services Energy Coal Mining Electric Utilities Trend Capital provides investors with unaudited statements of the relevant Funds performance at least monthly and tax information and audited financial information annually. 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. Advisory Clients may be deemed to be paying for research and other services with soft or commission dollars. Currency swaps involve the exchange of cash flows on a notional amount of two or more currencies based on their relative future values. 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. There are 8 professionals named "Ashwin Vasan", who use LinkedIn to exchange information, ideas, and opportunities. Trading instructions may have to be modified and the Funds positions may need to be liquidated to avoid exceeding these limits. Describe the procedures you follow before you assume this authority (e.g., execution of a power of attorney). 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. Explain how often you bill clients or deduct your fees. The value of these financial instruments generally will vary with the performance of the issuer and movements in the equity markets. Trend Capital has discretionary authority to manage the investments of the Funds and the Managed Accounts. 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 Funds receive or pay, as the case may be, only the net amount of the two payments. While zero coupon bonds do not require the periodic payment of interest, deferred interest bonds generally provide for a period of delay before the regular payment of interest begins. 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. Restricted financial instruments may involve a high degree of business and financial risk which may result in substantial losses. Among other things, the Code of Ethics (i) requires that all employees comply with federal securities laws, (ii) requires that all employees submit to Trend Capital reports containing their personal securities holdings and transactions in reportable securities and that Trend Capital review such reports, (iii) requires all employees to obtain pre-approval of transactions in their personal accounts (except open-end mutual funds) and (iv) contains policies and procedures designed to prevent the misuse of material, non-public information. 44. A principal risk in trading currencies is the rapid fluctuation in the market prices of currency contracts. Repurchase and Reverse Repurchase Agreements. 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 you permit a client to direct brokerage, describe your practice. However, ETF shareholders are generally subject to the same risk as holders of the underlying securities they are designed to track. If you recommend primarily a particular type of security, explain the material risks involved. 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. Find out more, Asset managers interested in licensing Citywire Fund Manager Ratings should contact ratings@citywire.com. CreditDebt Sustainability Model the long-term solvency of a country.Fiscal Financing Outlook Model the gross and net issuance needs of a sovereign in a given year.Balance of Payments Model the ability of a country to pay back its foreign debt with foreign exchange earnings.EquityRisk Sentiment Model whether investors are actively seeking out or avoiding risky assets.Valuation Model the valuation of equity indices measured against longerterm measures of earnings. Explain whether (and, if so, how) you tailor your advisory services to the individual needs of clients. 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. Conversely, when interest rates rise, the value of fixed-income instruments generally can be expected to decline. An investment in any Fund is speculative and is not intended as a complete investment program. In such cases, 19 the Funds can be bought in (i.e., forced to repurchase financial instruments in the open market to return to the lender). 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. Trend Capital may utilize such leverage, position size, duration and other portfolio management techniques as it believes are appropriate for the Funds. If you or a related person recommends securities to clients, or buys or sells securities for client accounts, at or about the same time that you or a related person buys or sells the same securities for your own (or the related persons own) account, describe your practice and discuss the conflicts of interest it presents. 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. The buyer of a call option assumes the risk of losing its entire premium investment in the call option. The Firm has adopted aTrend Capital, its employees, affiliates or their related persons are invested in the Funds, either directly or through the Trend Capitals and/or general partners (or equivalent) investments in the Funds. Live market coverage co-anchored from Hong Kong and New York. Ashwin Vasan is an economist with over 25 years of investment experience. State whether these reports are written. Trend Capital LLC is a Connecticut Foreign Limited-Liability Company filed on May 13, 2011. Therefore, the Funds will not receive any benefit of CFTC regulation for these trading activities. 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. Opportunities Funds:The Opportunities Funds pay a monthly management fee with respect to each particular SP, equal to the product of the applicable management fee rate and each investors capital account balance or shares, as applicable. 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. Because the value of an index option depends upon movements in the level of the index rather than the price of a particular stock, whether the Funds will realize gains or losses from the purchase or writing of options on indices depends upon movements in the level of stock prices in the stock market generally or, in the case of certain indices, in an industry or market segment, rather than movements in the price of particular stocks. Changes in interest rates can affect the value of the Funds investments in fixed income instruments. Discuss whether and under what conditions you aggregate the purchase or sale of securities for various client accounts. 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. 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. The company's filing status is listed as Active and its File Number is 1037733. The adverse effects of prepayments may impact the Funds portfolio in two ways. 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. 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. 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. The market for these instruments may also be limited and some companies may limit the intervals for redemptions. The applicable fee share is disclosed in the Prospectus and related Prospectus Supplement. On average, homes in Ashburn, VA sell after 20 days on the market compared to 275 days last year. The Funds expect to use and may use a high degree of, leverage as part of the Funds investment program. Investing in these markets may involve heightened risks (some of which could be significant) and special considerations not typically associated with investing in other more established economies or securities markets. During periods of economic or financial instability, commodity-related instruments may be subject to broad price fluctuations, reflecting volatility of energy and basic material prices and possible instability of supply of various commodities. Because of the absence of any trading market for unlisted securities, it may take longer to liquidate, or it may not be possible to liquidate, positions in unlisted securities than would be the case for publicly traded securities. Stock Index Futures. Such 3 investment objectives, fee arrangements and terms are individually negotiated and it should be noted that any such Managed Account relationships are generally subject to significant account minimums. The practice of leveraging and the use of derivatives, swaps, futures and options, may subject an investment portfolio to greater risk of adverse impact. In general, neither Trend Capital nor the Funds will be required to notify any or all of the other investors in the Funds of any such Side Letters or any of the rights and/or terms or provisions thereof, except as specified in Trend Macro Funds MFN (most-favored nations) Policy Statement, which requires that Trend Capital notify certain investors of any new Side Letters and offer such investors equally favorable terms as those granted in the new Side Letter. Derivatives not traded on exchanges also are not subject to the same type of government regulation as exchange traded securities and many of the protections afforded to participants in a regulated environment may not be available in connection with the transactions. The Funds may also purchase credit default protection even in the case in which it does not own the referenced instrument if, in the judgment of Trend Capital, there is a high likelihood of credit deterioration. 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. 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. Trend Capital is permitted to use leverage in pursuing its investment objective and this leverage may be significant. 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. These transactions are not subject to exchange rules. Since they are new products, securities futures contracts have relatively low liquidity and no trading history. Prospective investors must also execute a subscription agreement and, in the case of the Trend Capital sponsored Funds, limited partnership agreements (where applicable). 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. Market disruption events could also affect the principal prime brokers that carry and clear the Funds trades and positions. 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. Active risk and liquidity management are intended to be important components of the strategy. The price of stock index futures contracts may not correlate perfectly with the movement in the underlying stock index because of certain market distortions. No credit card required. Explain whether clients may impose restrictions on investing in certain securities or types of securities. If you participate in wrap fee programs by providing portfolio management services, (1) describe the differences, if any, between how you manage wrap fee accounts and how you manage other accounts, and (2) explain that you receive a portion of the wrap fee for your services. Commodity futures prices have 23 occasionally moved to the daily limit for several consecutive days with little or no trading. 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. 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. 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. Stock Index Options. Also, the Funds may invest in financial instruments, such as structured products, derivatives and other types of unregistered financial instruments. Risk Disclosure. When used for hedging purposes, an imperfect or variable degree of correlation between price movements of the derivative and the underlying investment sought to be hedged may prevent the Funds from achieving the intended hedging effect or expose the Funds to risk of loss. [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. Credit Default Swaps; Other Derivatives. Trend Capital believes that high ethical standards are essential to its success and to maintain the confidence of its investors. The Advisory Board must also provide consent before Trend Capital GP LLC may take certain actions, as fully described in the Funds offering documents. The extent to which the Funds engage in short sales will depend upon Trend Capitals investment strategy and opportunities. 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. This website uses cookies to improve your experience. Securities futures contracts are subject to the same risks as other securities, as well as to the greater volatility and risks of futures trading. Explain how you will determine the amount of the refund.As described in Item 5.B above, investors in the Funds generally pay management fees in advance. 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. The production and marketing of commodities may be affected by actions and changes in governments. 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