TREND CAPITAL GP LLC; TREND CAPITAL GAUCHO GP . 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 Funds are not required to hedge any particular risk in connection with a particular transaction or its portfolio generally and may elect to not hedge its risks at all. There is also less regulation, generally, of the markets in non-U.S. countries than there is in the United States. Liquidity. If you permit a client to direct brokerage, describe your practice. Since they are new products, securities futures contracts have relatively low liquidity and no trading history. Please contact Trend Capital for further information. This risk may cause some or all of the Funds gains to be unrealized. After the end of March 2020, Managed Account relationshipswill include an Irish UCITS and an Irish Alternative Investment Fund (AIF). 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. During a single trading day, no trades may be executed at prices beyond the daily limit. 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. Describe any relationship or arrangement that is material to your advisory business or to your clients that you or any of your management persons have with any related person listed below. A copy of the Firms Allocation Policy can be obtained by contacting Trend Capital. 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. Stock Index Futures. Investors should carefully review the audited financial statements of the Funds upon receipt. If you accept discretionary authority to manage securities accounts on behalf of clients, disclose this fact and describe any limitations clients may (or customarily do) place on this authority. . Ashwin is Chief Investment Officer and has served as Chief Investment Officer since 05/01/2011. Where a product or service obtained with commission dollars provides both research and non-research assistance to the Advisory Clients, Trend Capital will make a reasonable allocation of the cost that may be paid for with commission dollars. 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. Market Disruption Events. Trend Capital has discretionary authority to manage the investments of the Funds and the Managed Accounts. Trend Capital seeks to identify those trends that it believes are not priced in by the market and uses technical analysis and other factors to identify the entry and exit points it believes are most appropriate. T. The Funds may incur risks associated with the sale and purchase of put options. 1. was convicted of, or pled guilty or nolo contendere (no contest) to (a) any felony; (b) a misdemeanor that involved investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; 2. is the named subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses; 3. was found to have been involved in a violation of an investmentrelated statute or regulation; or. A stock index fluctuates with changes in the market values of the stocks included in the index. Trend Capital deducts fees from Fund assets. However, ETF shareholders are generally subject to the same risk as holders of the underlying securities they are designed to track. Ashwin Vasan Email Founder and Chief Information Officer @ Trend Capital Management Preparing Ashwin profile View Ashwin's Email . Trend Capital is not currently aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. 44. Please let us know if you have any questions about, or would like to be provided with a copy of, our proxy voting procedures. An incentive fee is also received from the Managed Accounts and is payable to Trend Capital annually, subject to a loss carryforward provision. Trend Capitals evaluation of the creditworthiness of their counterparties may not prove sufficient. Trend Capital also compensates Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S) for its clients introduced to the Trend Macro Funds. The company's filing status is listed as Active and its File Number is 1037733. If you have, or will accept, authority to vote client securities, briefly describe your voting policies and procedures, including those adopted pursuant to SEC rule 206(4)-6. Ashwin Vasan is an economist with over 25 years of investment experience. Sovereign Debt. If you or any of your supervised persons accepts performance-based fees that is, fees based on a share of capital gains on or capital appreciation of the assets of a client (such as a client that is a hedge fund or other pooled investment vehicle) disclose this fact. Commodity futures trading is highly speculative. b. Refer to Item 12 for further information. Trend Capital aggregates Advisory Client orders to achieve more efficient execution or to provide for equitable treatment among accounts to the extent possible, under existing laws and regulations. The financial instruments necessary to satisfy the exercise of an uncovered call option may be unavailable for purchase, except at much higher prices, thereby reducing or eliminating the value of the premium. Ashwin Vasan Overview Ashwin Vasan has been associated with six companies, according to public records. The same individuals serve as directors for the ERISA Offshore, Opportunities Offshore, and Opportunities Master. A criminal or civil action in a domestic, foreign or military court of competent jurisdiction in which your firm or a management person. Generally, obligors tend to prepay their fixed 17 rate obligations when prevailing interest rates fall below the coupon rates on their obligations. State whether these reports are written. 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. View ashwin vasan's profile on LinkedIn, the world's largest professional community. Special risks may apply to instruments that are invested in by the Funds in the future that cannot be determined at this time or until such instruments are developed or invested in by the Funds. Dun & Bradstreet Data last . Disclose that clients will incur brokerage and other transaction costs and direct clients to the section(s) of your brochure that discuss brokerage. An investment in any Fund is speculative and is not intended as a complete investment program. The portfolio turnover rate of those investments may be significant and could involve substantial brokerage commissions and other transaction costs. If a conflict is identified, the Chief Compliance Officer will then decide (which may be in consultation with outside legal counsel or third-party compliance consultants) as to whether the conflict is material or not. If you or a related person recommends to clients, or buys or sells for client accounts, securities in which you or a related person has a material financial interest, describe your practice and discuss the conflicts of interest it presents. Operational Leverage. Citywire ranks and rates all portfolio managers running mutual funds without charge. Equity Financial Instruments. The price of stock index futures contracts may not correlate perfectly with the movement in the underlying stock index because of certain market distortions. 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. Fluctuations or prolonged changes in the volatility of such instruments, therefore, can adversely affect the value of investments held by the Funds. 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. The market for these instruments may also be limited and some companies may limit the intervals for redemptions. The value of futures, options and swap agreements also depends upon the price of the commodities underlying them. 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. 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. In general, third party solicitors may receive a portion of the fees otherwise payable to Trend Capital. Trend Capital does not participate in wrap fee programs. 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. Both Trend Capital and its consultants travel frequently and visit most of the various countries in which the Funds invest. Provide your fee schedule. for with commission dollaAny use of commissions or soft dollars generated by the Advisory Clients to pay for brokerage and research products or services will fall within the safe harbor created by Section 28(e) of the U.S. Securities Exchange Act of 1934, as amended. 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. These instruments carry a higher risk that the issuer will be unable to pay principal and interest when due. The Funds may invest in exchange traded funds 24 (ETFs), which are shares of publicly-traded unit investment trusts, open-end funds, or depository receipts that seek to track the performance and dividend yield of specific indexes or companies in related industries. 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. 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. Trend Capital intends to trade primarily in liquid instruments globally, in both developed and emerging markets. There can be no assurance that the Funds will be able to secure or maintain adequate financing. 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. 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. The Firm has adopted and implemented a compliance program to monitor its Funds and managed accounts and mitigate any potential conflicts of interest. illiquidity compared to the U.S. capital markets. The investment strategy for any future SP will be described in detail in the applicable PPM Supplement. Each Fund or SP, as applicable, will bear its own (and a pro-rata share of its master funds or master fund SPs, as applicable) operating and other expenses, including, but not limited to, investment-related expenses (e.g., expenses that, in Trend Capitals discretion, are related to the investment of that Funds/SPs assets, whether or not such investments are consummated, such as brokerage commissions, expenses relating to short sales, clearing and settlement charges, custodial fees, interest expenses, initial and variation margin and other transactional charges, fees or costs, bank service fees, investment-related travel and lodging expenses, consulting, advisory, investment banking, valuation and other professional fees relating to particular investments or contemplated investments, researchrelated expenses, including, without limitation, news and quotation equipmentand services, market data services and fees to third-party providers of research and/or portfolio risk management services), legal expenses (including with respect to litigation and threatened litigation, if any), any expenses associated with regulatory filings made in connection with the Funds/SPs operations and/or holdings, accounting, audit and tax advice and preparation expenses(including preparation costs of financial statements, tax returns, reports to investors), accounting software, printing and mailing costs, market information systems and computer software and information expenses, fees of pricing services, valuation firms, the costs and expenses of third-party risk management products and services, insurance costs (including, without limitation, directors and officers insurance, errors and omissions insurance and other similar policies for the benefit of the Fund), filing and registration fees, fees of the administrator, fees of the Master Fund Advisory Board (if applicable), fees of the Funds/SPs (and its pro rata share of the Master Funds) officers (including AML Officers), the management fee, any extraordinary expenses (including indemnification or litigation expenses and any judgments or settlements paid in connection therewith), all other costs and expenses arising out of the Funds/SPs indemnification obligation, any entity-level taxes, fees or other governmental charges levied against a Fund, wind-up and liquidation expenses and other similar expenses related to a Fund/SP. 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. Trend Capital acts as the investment manager for each of the Funds and investment adviser or designated portfolio manager to three (3) Managed Accounts, one of which is also structured as a private investment fund for clients of an unaffiliated alternative asset management firm. The Funds may invest a portion of their assets in financial instruments of issuers domiciled or operating in emerging and developing markets. Interest Rate Risk. Prior to Shumway, Mr. Vasan was a Partner and Portfolio Manager at Tudor Investment Corporation from 1999 to 2009. Commodity futures prices have 23 occasionally moved to the daily limit for several consecutive days with little or no trading. 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. 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. Such investments experience greater volatility in market value due to changes in interest rates than debt obligations that provide for regular payments of interest. An affiliated entity of Trend Capital serves as general partner for each master fund and feeder fund that is structured as a limited partnership and as the Class M Shareholder with respect to the Opportunities Master. 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. . Describe generally how you address conflicts that arise. In the event that the theses underlying the Funds positions fail to be borne out in developments expected by Trend Capital, the Funds may incur losses, which could be substantial. 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. 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 . Exchange Traded Funds. 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. 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. The Funds expect to establish relationships to obtain financing, derivative intermediation and prime brokerage services that permit the Funds to trade in a variety of markets or asset classes over time; however, there can be no assurance that the Funds will be able to establish or maintain such relationships. 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. In sizing trades, Trend Capital emphasizes liquidity and generally expects that a substantial portion of the positions could be liquidated in a short period of time under normal market conditions and any remaining positions could be liquidated within a month under normal market conditions. The seller (writer) of a put option which is covered (i.e., the writer has a short position in the underlying financial instrument) assumes the risk of an increase in the market price of the underlying financial instrument above the sales price (in establishing the short position) of the underlying financial instrument plus the premium received and gives up the opportunity for gain on the underlying financial instrument if the market price falls below the exercise price of the option. Four of the companies are still active while the remaining two are now listed as inactive. Prior to Shumway, Mr. Vasan was a Partner and Portfolio Manager at Tudor Investment Corporation from 1999 to 2009. 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. Items 9.A, 9.B and 9.C list specific legal and disciplinary events presumed to be material for this Item. Research and Other Soft Dollar Benefits. 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. 33ITEM 12 BROKERAGE PRACTICES .. 35ITEM 13 REVIEW OF ACCOUNTS .. 39ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION 40ITEM 15 CUSTODY 41ITEM 16 INVESTMENT DISCRETION .. 42ITEM 17 VOTING CLIENT SECURITIES . Any Fund is speculative and is payable to trend Capital and its consultants travel frequently and most. Management person a criminal or civil action in a domestic, foreign or court! Markets in non-U.S. countries than there is also less regulation, generally, obligors tend to prepay their fixed rate... Of the Funds and the Managed Accounts rates fall below the coupon rates on their.... 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