If your clients either may or must pay your fees in advance, disclose this fact. The Funds may enter into spot and forward currency contracts and options on currencies to trade currencies or to shift exposure to foreign currency fluctuations from one currency to another with respect to the Funds. 2022 Trend Capital Management LP, All Rights Reserved. Online data isn't stored in a "cloud," of course. Derivatives, especially when traded in large amounts, may not be liquid in all circumstances, so that in volatile markets the Funds may not be able to close out a position without incurring a loss. Ashwin Vasan Work Experience and Education Work Experience Health Commissioner New York Presbyterian 2012-2022 Founder & Chief Information Officer Trend Capital 2011-2021 Health Commissioner Health Association 2018-2022 Director, Cons (Senior Advanced To For Strat & Innov) Consumer Financial Protection Bureau 2021-2021 Education 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. 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. Unlisted securities may involve higher risks than listed securities. 100 W Putnam Ave Greenwich, CT 06830. Connecting decision makers to a dynamic network of information, people and ideas, Bloomberg quickly and accurately delivers business and financial information, news and insight around the world. Capital One Branch. When deemed appropriate for a large or strategic investor, Trend Capital has established, and may again in the future establish, a Managed Account that will tailor its investment objectives to those of the specific investor (including restrictions on investing in certain types of securities) and/or be subject to different terms and/or fees than those of the Funds. For each significant investment strategy or method of analysis you use, explain the material risks involved. There is currently limited case law or litigation characterizing swaps and certain other derivatives, interpreting their provisions or characterizing their tax treatment. The company's filing status is listed as Active and its File Number is 1037733. SEC registration does not imply acertain level of skill or training. 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. Explain whether clients will receive their proxies or other solicitations directly from their custodian or a transfer agent or from you and discuss whether (and, if so, how) clients can contact you with questions about a particular solicitation. The lack of a complete and foolproof evaluation of the financial capabilities of the Funds counterparties and the absence of a regulated market to facilitate settlement may increase the potential for losses by the Funds. Reset here, 1999 - 2023 citywire.com. 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. If you provide investment advice only with respect to limited types of investments, explain the type of investment advice you offer and disclose that your advice is limited to those types of investments. 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. Trend Capital Management LPTrend Capital Advisers LP1800 N. Military Trail, Suite 475Boca Raton, FL 33431Tel: 561-617-5086March 30, 2020. The seller (writer) of a call option which is covered (i.e., the writer holds the underlying financial instrument) assumes the risk of a decline in the market price of the underlying financial instrument below the purchase price of the underlying financial instrument less the premium received and gives up the opportunity for gain on the underlying financial instrument above the exercise price of the option. Necessity for Counterparty Trading Relationships; Counterparty Risk. Trend Capital need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost or spread. These commissions and costs reduce the Funds net profits. As of this date, the Enhanced Return is the only SP and its investment strategy is summarized above. Prospective investors must recognize that in investing in the Funds, they are placing their capital indirectly under the full discretionary management of Trend Capital and authorizing Trend Capital indirectly to trade for the Funds. 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. 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 management fee will be prorated for any period that is less than a full month. Trend Capital provides investment advisory services to the Funds, which are private investment vehicles. Turnover. The market for these instruments may also be limited and some companies may limit the intervals for redemptions. 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. Some non-U.S. markets have a higher potential for price volatility and relative. 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 Trend Capital generally tries to invest the Trend Macro Funds assets in a way that it will be flat or positive carry in aggregate, including the cost of its hedging program. Trend Capital does not participate in wrap fee programs. If you have any requirements for opening or maintaining an account, such as a minimum account size, disclose the requirements. Generally, there is no public or over-the-counter trading market for these financial instruments and the Funds might only be able to liquidate these positions at highly disadvantageous prices, if at all. 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. While brokers generally provide capital introduction services at no additional cost and certain other services at favorable or below market rates, Trend Capital and not the Advisory Clients, may be the principal or sole beneficiary of those services, thus presenting a potential conflict of interest between the Advisory Clients and Trend Capital, which is responsible for selecting the brokers and negotiating their brokerage, margin and other fees. 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 . These indexes may either be broad-based, sector-based, or international. As further described in Item 8.A below, the Trend Macro Fund, ERISA Master, Enhanced Return and associated Managed Accounts, subject to applicable legal, regulatory or investment restrictions, invest to capitalize on fundamental trends in currencies, interest rates and credit and equity indices in both developed and emerging markets. To the extent any Managed Account applies a more stringent standard, Trend Capital will comply with the applicable restrictions. . Market Disruption Events. 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. While the Firm has taken steps to mitigate the adverse consequences that could arise from the occurrence of a market disruption event, the inability to predict the timing, location, source and severity of such event or events make it 20 difficult to provide assurances that the Funds would not suffer adverse consequences should a market disruption event occur. 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. Trend Capital will always select brokers on the basis of seeking best execution and may consider capital introduction services as one among many relevant factors. In particular, prepayments (at par) may limit the potential upside of many instruments to their principal or par amounts, whereas their corresponding hedges often have the potential for unlimited loss. 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. Find more info on AllPeople about Ashwin Vasan and Trend Capital Management LP, as well as people who work for similar businesses nearby, colleagues for other branches, and more people with a similar name. 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. Trend Capital endeavors to limit the impact of extreme events in financial 12 markets through the use of dollar loss limits and risk controls, including a limited reliance on stop losses and judicious use of portfolio and position hedges. 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. No guarantee or representation is made that an Opportunities Master Fund SPs investment program will be successful or that its investment objectives will be 13 met. A substantial portion of the Funds capital may be invested on the basis of short-term market considerations. Securities Futures Contracts. 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. Prior to Shumway, Mr. Vasan was a Partner and Portfolio Manager at Tudor Investment Corporation from 1999 to 2009. Describe the types of clients to whom you generally provide investment advice, such as individuals, trusts, investment companies, or pension plans. As a result, the Funds may suffer losses if it invests in equity instruments of issuers whose performance diverges from Trend Capitals expectations or if equity markets generally move in a single direction and the Funds has not hedged against such a general move. Non-U.S. Investments. Significant ongoing uncertainties and exposure to adverse conditions may undermine the issuers ability to make timely payment of interest and principal and issuers may default on their Sovereign Debt. In addition, daily limits on price fluctuations and speculative position limits on exchanges on which the Funds may conduct their transactions in derivatives may prevent profitable 25 liquidation of positions, subjecting the Funds to the potential of greater losses. 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. Ashwin Vasan has an ownership stake in Trend Capital Management LP of more than 75%. Ashwin has 1 job listed on their profile. Liquidity. 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. Each such related person transaction is separately identified and made strictly in accordance with Trend Capitals Code of Ethics. 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. Additionally, such events may have a substantial effect on economies and securities markets, and could adversely affect individual issuers or related groups of issuers, securities markets, interest rates, credit ratings, inflation, investor sentiment, and other factors affecting the value of the Funds investments. In addition, the Funds may bear, along with other shareholders of an ETF, its pro rata portion of the ETFs expenses, including management fees. 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 Program of Trend Capital. Loudoun County has similar renown and is called "The Center of the Internet" and "Data Center Alley.". Ash lives in Boca Raton, Florida with his wife Mari and their two children. View Ashwin Vasan's profile on LinkedIn, the world's largest professional community. Who is Ashwin Vasan? Prior to Shumway, Mr. Vasan was a Partner and Portfolio Manager at Tudor Investment Corporation from 1999 to 2009. Flexible Investment Approach. View company leaders and background information for Trend Capital Management Lp. State whether these reports are written. Volatility Risk. Accordingly, successful use by the Funds of options on stock indices will be subject to Trend Capitals ability to correctly predict movements in the direction of the stock market generally or of particular industries or market segments. 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). TREND CAPITAL GP LLC; TREND CAPITAL GAUCHO GP . Trend Capital Opportunities GP LLC is the general partner of the Opportunities Onshore and Class M Shareholder of the Opportunities Master. The company's principal address is 1800 . Exchanges. If you have discretionary authority or custody of client funds or securities, or you require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, disclose any financial condition that is reasonably likely to impair your ability to meet contractual commitments to clients. Avanath Capital 1920 Main Street, Suite 150, Irvine, CA 92614 The Funds may invest in credit default swaps. Trend Capital ERISA GP LLC is the general partner of the ERISA Master 2 Fund. 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 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. Over-the-Counter Trading. . Trend Capital may utilize such leverage, position size, duration and other portfolio management techniques as it believes are appropriate for the Funds. For purposes of calculating this ten-year period, the date of an event is the date that the final order, judgment, or decree was entered, or the date that any rights of appeal from preliminary orders, judgments or decrees lapsed. Volatility may also be caused by government intervention, direct and by regulation, in certain markets, particularly those in currencies, financial instruments, futures and options. If there are legal or disciplinary events that are material to a clients or prospective clients evaluation of your advisory business or the integrity of your management, disclose all material facts regarding those events. Trend Capital takes a balanced approach to investing the Trend Macro Funds or Enhanced Returns assets. Describe the content and indicate the frequency of regular reports you provide to clients regarding their accounts. Trend Macro Onshore LP, a Delaware limited partnership (the Trend Macro Onshore);o Trend Macro Offshore Ltd., a Cayman Islands exempted company (the Trend Macro Offshore and together with the Trend Macro Onshore, the Trend Macro Feeder Funds);o Trend Macro Fund LP, a Cayman Islands limited partnership (the Trend Macro Fund and together with the Trend Macro Feeder Funds, the Trend Macro Funds);o Trend Macro ERISA Fund Ltd., a Cayman Islands exempted company (the ERISA Offshore);o Trend Macro ERISA Master Fund LP, a Cayman Islands limited partnership (the ERISA Master and together with the ERISA Offshore Fund, the ERISA Funds);o Trend Capital Opportunities Series LP, a Delaware series limited partnership (the Opportunities Onshore);o Trend Capital Opportunities SPC Ltd, a Cayman Islands exempted segregated portfolio company (the Opportunities Offshore);o Trend Capital Opportunities Master Fund SPC Ltd, a Cayman Islands exempted segregated portfolio company (the Opportunities Master and together with the Opportunities Onshore and Opportunities Offshore, the Opportunities Funds); and o Trend Macro Enhanced Return, a segregated portfolio created under the Opportunities Funds (Enhanced Return). Margin requirements for commodities trading are set by the individual commodity exchanges or other trading facility for each type of commodity contract based upon the perceived volatility of each type of contract. 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. Industry Group Agriculture Banking & Financial Services Business Services Energy Coal Mining Electric Utilities 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. T. The Funds may incur risks associated with the sale and purchase of put options. Increases in interest rates may cause the value of the Funds investments to decline. Generally, obligors tend to prepay their fixed 17 rate obligations when prevailing interest rates fall below the coupon rates on their obligations. Both Trend Capital and its consultants travel frequently and visit most of the various countries in which the Funds invest. 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. In addition to its quantitative modeling, Trend Capital incorporates qualitative factors into its assessment of each trend. 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. Accordingly, the Funds may pledge their financial instruments in order to borrow or otherwise obtain leverage for investment or other purposes. 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. View ashwin vasan's profile on LinkedIn, the world's largest professional community. Explain that directing brokerage may cost clients more money. 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. 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. The Funds may invest in equities and equity derivatives. The Funds may trade forward contracts. Identify the related person and if the relationship or arrangement creates a material conflict of interest with clients, describe the nature of the conflict and how you address it. Fluctuations or prolonged changes in the volatility of financial instruments held by the Funds directly or indirectly may adversely affect the value of the Funds. Trend Capital believes that high ethical standards are essential to its success and to maintain the confidence of its investors. ault Swaps; Other Derivatives. As of March 30, 2020, Trend Capital is submitting its annual amendment to the Brochure. Because of the low margin deposits normally required in futures trading, an extremely high degree of leverage is typical of a futures trading account. Items 9.A, 9.B and 9.C list specific legal and disciplinary events presumed to be material for this Item. If forward prices go up, the Funds will suffer a loss to the extent the price of the currency they have agreed to buy exceeds the price of the currency they have agreed to sell. The Funds global macro investing consists primarily of trading in global interest rates, currencies, credit and equity indices and their related derivatives, in order to exploit fundamental, economic, financial and political trends that may exist in and between developed and emerging markets throughout the world. Please let us know if you have any questions about, or would like to be provided with a copy of, our proxy voting procedures. ITEM 2 MATERIAL CHANGES . Risk ManagementActive risk and liquidity management are intended to be important componentsof the strategy. Prior to Shumway, Mr. Vasan was a Partner and Portfolio Manager at Tudor Investment Corporation from 1999 to 2009. 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. TREND CAPITAL LLC is an Active company incorporated on January 19, 2016 with the registered number M16000000511. 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. Therefore, many of the risks applicable to trading the underlying asset are also applicable to derivatives trading. Such intervention often is intended directly to influence prices and 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. 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. 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. 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. 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. Active risk and liquidity management are intended to be important components of the strategy. [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. For the Funds investments to decline to derivatives trading a full month reports you provide to regarding... Financial instruments in order to borrow or otherwise obtain leverage for investment or other purposes law litigation! 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