Daily Price Fluctuation Limits. Trend Capital may utilize such leverage, position size, duration and other portfolio management techniques as it believes are appropriate for the Funds. 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. 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. 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. 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. 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. Derivative Financial Instruments and Instruments Generally. As principal investment manager for the UCITS, UBP receives platform and other fees, including a percentage of Trend Capitals incentive allocation with respect to certain share classes. 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. 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. 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. 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. These indexes may either be broad-based, sector-based, or international. In addition, many nonU.S. Trend Capital is not currently aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. Trend Capital has discretionary authority to manage the investments of the Funds and the Managed Accounts. 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. They are treated as both futures and securities and, therefore, are subject to the joint jurisdiction of SEC and the CFTC. The market for many derivatives is, or suddenly can become, illiquid. 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. 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. Ashwin has 1 job listed on their profile. Disclose whether you use soft dollar benefits to service all of your clients accounts or only those that paid for the benefits. With respect to the Opportunities Funds, the minimum initial and additional investment amounts depend on the particular SP in which an investor subscribes. There may be limited information available about the issuers of the financial instruments which may make valuation of such financial instruments difficult or uncertain. This requires different skills and techniques than predicting changes in the price of individual stocks. 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. Companies whose securities are not publicly traded may not be subject to public disclosure and other investor protection requirements applicable to publicly traded securities. Thus, the Funds face the risk that their counterparties may not perform their obligations. If the Funds engage in an offsetting transaction, it will incur a gain or loss to the extent that there has been movement in forward currency contract prices. Swap transactions dependent upon credit events are priced incorporating many variables including the pricing and volatility of the common stock and potential loss upon default, among other factors. If you are an SEC-registered adviser, briefly describe your code of ethics adopted pursuant to SEC rule 204A-1 or similar state rules. 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. Like other leveraged investments, any purchase or sale of a futures contract may result in losses that exceed the amount invested. To the extent any Managed Account applies a more stringent standard, Trend Capital will comply with the applicable restrictions.n. CurrencyBalance of Payments Model the net flow of funds into or out of a country.Interest Rates Model real interest rate differentials between currencies.Risk Sentiment Model whether investors are actively seeking out or avoiding risky assets.Valuation Model the Real Effective Exchange Rate (REER) for any currency. Trading instructions may have to be modified and the Funds positions may need to be liquidated to avoid exceeding these limits. Trend Capital need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost or spread. These transactions are not exchange-traded so that no clearinghouse or exchange stands ready to meet the obligations of the contract. The Funds may engage in swap transactions. The price of stock index futures contracts may not correlate perfectly with the movement in the underlying stock index because of certain market distortions. 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. Ashwin Kumar Vasan - Trend Capital Management LP. 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. View Location. Advisory Clients participating in aggregated trades are allocated financial instruments based on the average price achieved for such trades or any other method deemed fair and equitable, in accordance with Trend Capitals Allocation Policy. 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. Trend Capital presently provides investment advisory services to the Funds and the Managed Accounts, which provide Trend Capital with varying levels of compensation due to varying compensation structures. Trend Capitals trading program relies on a fundamental-based approach in identifying potential investments. 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. 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. Trend Capital has broad latitude with respect to the management of the Funds risk parameters. Describe generally how you address conflicts that arise. 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. If you recommend or select other investment advisers for your clients and you receive compensation directly or indirectly from those advisers that creates a material conflict of interest, or if you have other business relationships with those advisers that create a material conflict of interest, describe these practices and discuss the material conflicts of interest these practices create and how you address them. 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. The terms for the Trend Macro Feeder Funds, the ERISA Offshore and the Opportunities Funds are disclosed in detail in the relevant Funds offering documents and supplement(s) (where applicable) provided to prospective investors prior to their investment. These commissions and costs reduce the Funds net profits. 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 respective general partner may, in its sole discretion, waive, reduce or calculate differently the management fee with respect to certain investors. As a result, a relatively small price movement in a futures contract may result in substantial losses to the Funds. Rather than meeting additional margin deposit requirements, market participants may close futures contracts through offsetting transactions that would distort the normal relationship between the index and futures markets. 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. 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