Short Sales. The UCITS is not open to U.S. investors. If you review client accounts on other than a periodic basis, describe the factors that trigger a review. 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. Hedging Transactions. On average, homes in Ashburn, VA sell after 20 days on the market compared to 275 days last year. Ashwin Vasan Full Name: Ashwin Kumar Vasan Company: Trend Capital Management LP 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. 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. 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. These option hedges typically involve the purchase of short-dated options and/or option spreads, but may include other instruments. The Funds may invest in equities and equity derivatives. Advertisements. The incentive allocation ranges from 15% to 20% of net profits per annum, depending on the Fund andthe Class of Interests/Shares or SP in which an investor subscribes. If you are an SEC-registered adviser, briefly describe your code of ethics adopted pursuant to SEC rule 204A-1 or similar state rules. 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. In addition, neither Trend Capital nor the Funds will be required to offer such additional and/or different rights and/or terms to any or all of the other investors in the Funds, except as specified in the Trend Macro Fund MFN Policy Statement. The Funds may also utilize forward currency contracts and options to hedge against currency fluctuations, but there can be no assurance that such hedging transactions will be effective. The seller of an uncovered call option assumes the risk of a Theoretically unlimited increase in the market price of the underlying financial instrument above the exercise price of the option. Please let us know if you have any questions about, or would like to be provided with a copy of, our proxy voting procedures. Possible Effects of Speculative Position Limits. 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. As of March 30, 2020, Trend Capital is submitting its annual amendment to the Brochure. Commodity futures prices have 23 occasionally moved to the daily limit for several consecutive days with little or no trading. Disclose whether you use soft dollar benefits to service all of your clients accounts or only those that paid for the benefits. 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. The Firm currently provides discretionary investment advisory services including, but not limited to, managing and directing the investment and reinvestment of assets for private investment vehicles within the master-feeder structures, defined below. All fees charged to the sub-fund are disclosed in the Prospectus and Prospectus Supplement for the sub-fund. 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. Found 2 colleagues at Trend Capital Management LP. 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. 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. The instruments and borrowings utilized by the Funds to leverage investments may be collateralized by the Funds portfolio. It is critical that investors refer to the relevant offering documents for a complete understanding of how Trend Capital is compensated for its advisory services. 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. 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 buyer of a call option assumes the risk of losing its entire premium investment in the call option. Disclose that you may have an incentive to select or recommend a brokerdealer based on your interest in receiving client referrals, rather than on your clients interest in receiving most favorable execution. 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. Daily Price Fluctuation Limits. 2022 Trend Capital Management LP, All Rights Reserved. . Ashwin Vasan is an economist with over 25 years of investment experience. 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. Trend Capital provides discretionary investment advisory services to its Advisory Clients by managing and directing the investment and reinvestment of their assets. 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. All personnel of Trend Capital are required to certify their compliance with the Code of Ethics. Explain to clients that they may obtain a copy of your proxy voting policies and procedures upon request. 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. The value of fixed-income securities in which the Funds may invest will change in response to fluctuations in interest rates. 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. Securities Futures Contracts. 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. 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. Explain that directing brokerage may cost clients more money. 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. Price movements of derivative contracts are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments and national and international political and economic events and policies. 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. Ashburn, a city in Virginia's Loudoun County about 34 miles from Washington D.C., is widely known as the Data Center Capital of the World. 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. The Funds are designed only for experienced and sophisticated persons who are able to bear the risk of substantial impairment or total loss of their investment in the Funds. As explained in Item 4.C above, individual investors in the Funds do not have the ability to impose limitations on Trend Capitals discretionary authority. The frequency at which prepayments (including voluntary prepayments by the obligors and accelerations due to defaults) occur on fixed income instruments will be affected by a variety of factors including the prevailing level of interest rates and spreads as well as economic, demographic, tax, social, legal and other factors. We'll assume you're ok with this, but you can opt-out if you wish. Unless registered for sale, restricted financial instruments can be sold only in privately negotiated transactions or pursuant to an exemption from registration (e.g., under Rule 144A of the Securities Act). 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. (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. Each SP of the Opportunities Funds pursues its own investment opportunities, as described further in Item 8.A. Ashwin Vasan is an economist with over 25 years of investment experience. The value of a derivative depends largely upon price movements in the underlying asset. As noted above, an incentive fee is also received from the Managed Accounts and is payable annually, in arrears, subject to a loss carryforward provision. View company leaders and background information for Trend Capital Management Lp. Capital One Branch. 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. View limitations & usage restriction, Breaking news, analysis and cutting edge commentary from our award-winning team and leading industry voices, The latest news and other relevant content from selected Citywire partners, Alternative UCITS - Emerging Market Equity Including Asia. 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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