Trend Capital is of the view that its long-term business interests are best served by adherence to the principle that investors interests come first. 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. Such employee transactions will be reviewed in the best interests of the Advisory Clients and will be denied by the Compliance Department if there is a risk of potential adverse consequences to the Advisory Clients. Trend Capital also serves as a sub-adviser to certain investment vehicles that are not offered to United States investors and the Firm relies on the principal investment manager for those investment vehicles to provide updates regarding offering materials and disclosures in compliance with applicable laws. Trend Capital also compensates Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S) for its clients introduced to the Trend Macro Funds. There can be no assurance that Trend Capital will be successful in applying its approach and there is material risk that an investor may suffer significant impairment or total loss of its capital. 3. Such factors include government regulation, new technologies and political and economic events. In addition, brokers may provide other services that are beneficial to Trend Capital, but not necessarily beneficial to the Funds, including, without limitation, capital introduction, marketing assistance, consulting with respect to technology, operations or equipment and other services or items. An affiliate entity of Trend Capital also serves as a general partner to the Master Funds and each feeder fund that is structured as a limited partnership and the Class M Shareholder with respect to the Opportunities Master. Founder and cio at Trend Capital Management LP Delray Beach . Trend Capitals evaluation of the creditworthiness of their counterparties may not prove sufficient. 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. 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. 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. Ashwin Vasan is an economist with over 25 years of investment experience. If you permit a client to direct brokerage, describe your practice. For simplicity, each fund or SP identified above may be referred to individually in this Brochure as a Fund and together as 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. These investments involve special risks not usually associated with investing in securities of U.S. companies or the Federal, state or local government. 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. Repurchase and Reverse Repurchase Agreements. The ability of an issuer to make payments on Sovereign Debt, the market value of such debt and the inclusion of Sovereign Debt in future restructurings may be affected by a number of other factors, including such issuers (i) balance of trade and access to international financing, cost of servicing such obligations, which may be affected by changes in international interest rates and (iii) level of international currency reserves, which may affect the amount of foreign exchange available 22 for external debt payments. There are 191 active home listings and 9 new homes for sale in Ashburn, VA. Homes in Ashburn, VA were selling for a median price of $685,000 in November 2022. 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. View Ashwin's Email (It's Free) 5 free lookups per month. 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. 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. Trading in derivatives can result in large amounts of operational leverage. Each such document constitutes a legal, valid and binding obligation of the investor, enforceable in accordance with their respective terms. Risks in investments in non-U.S. securities, futures, commodities and other financial instruments may also include reduced and less reliable information about issuers and markets, less stringent accounting standards, illiquidity of securities and markets, higher brokerage commissions and custody fees. In that event, it may be difficult for the Fund to trade and/or value the positions that trade in the affected markets, and the Fund may be exposed to significant movements in the perceived value of instruments without having the ability to trade or value those instruments as well as prohibit the ability to conduct in-person investment research. 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. Ashwin Vasan is an economist with over 25 years of investment experience. The Funds may invest in credit default swaps. Ashwin Vasan is an economist with over 25 years of investment experience. The instruments and borrowings utilized by the Funds to leverage investments may be collateralized by the Funds portfolio. Fluctuations or prolonged changes in the volatility of such instruments, therefore, can adversely affect the value of investments held by the Funds. For example, in a directed brokerage account, the client may pay higher brokerage commissions because you may not be able to aggregate orders to reduce transaction costs, or the client may receive less favorable prices. Similarly, floating rate issuers and borrowers tend to prepay their obligations when spreads narrow. Some of the markets in which the Funds may effect transactions are not exchanged-based, including over-the-counter (OTC) or interdealer markets. 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. Describe the procedures you follow before you assume this authority (e.g., execution of a power of attorney). Changes by lenders in any of the foregoing may result in large margin calls, loss of financing and forced liquidations of positions at disadvantageous prices. Securities Futures Contracts. C. A. Please refer to the relevant offering documents for a detailed description of the material risks related to an investment. Disclose whether the fees are negotiable.The Funds offer interests or shares, as applicable, only to certain qualified investors and admission in the Funds is not open to the general public. For purposes of this Item, economic benefits include any sales awards or other prizes. Leverage may take the form of, among other things, any of the financial instruments described herein, including, derivative instruments which are inherently leveraged and trading in products with embedded leverage such as options, short sales, swaps and forwards. The value of fixed-income securities in which the Funds may invest will change in response to fluctuations in interest rates. Trend Capital does not participate in wrap fee programs. Necessity for Counterparty Trading Relationships; Counterparty Risk. Once the price of a futures contract for a particular commodity has increased or decreased by an amount equal to the daily limit, positions in the commodity cannot be taken or liquidated unless traders are willing to effect trades at or within the limit. Ashwin is Chief Investment Officer and has served as Chief Investment Officer since 05/01/2011. A forward currency contract, which involves an obligation to purchase or sell a specific currency at a future date at a price set at the time of the contract, reduces the Funds exposure with respect to their investment to changes in the value of the currency it will deliver and increases its exposure to changes in the value of the currency it will receive for the duration of the contract. Liquidity. The success of Trend Capitals global macro investment strategy depends on Trend Capitals ability to identify and exploit such perceived trends. Disclose whether you use soft dollar benefits to service all of your clients accounts or only those that paid for the benefits. 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. An affiliate entity of Trend Capital serves as the general partner to the Funds. Such counterparty risk is accentuated for contracts with longer maturities where events may intervene to prevent settlement, or where the Funds have concentrated its transactions with a single or small group of counterparties. . 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. Similar elements of risk arise in the event of the bankruptcy or insolvency of the buyer. Describe the types of clients to whom you generally provide investment advice, such as individuals, trusts, investment companies, or pension plans. 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. Trend Capital recognizes that certain potential conflicts of interests may arise in connection with the personal trading activities of individuals associated with Trend Capital. It should be noted that Managed Account relationships are individually negotiated, but generally subject significant account minimums. Derivatives that may be purchased or sold by the Funds may include securities and instruments not traded on an exchange. Prior to Shumway, Mr. Vasan was a Partner and Portfolio Manager at Tudor Investment Corporation from 1999 to 2009. 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. Trend Capital has broad latitude with respect to the management of the Funds risk parameters. A substantial portion of the Funds capital may be invested on the basis of short-term market considerations. Ashwin Vasan has served as Chief Investment Officer of Trend Capital Management LP since 2011. While the Funds intend to invest a substantial portion of the portfolio in liquid securities, there can be no assurance that any of these securities will not become illiquid at some point in time. 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. Not applicable. Volatility may also be caused by government intervention, direct and by regulation, in certain markets, particularly those in currencies, financial instruments, futures and options. To the extent unhedged, the value of the Funds assets will fluctuate with U.S. dollar exchange rates as well as with price changes of their investments in the various local markets and currencies. Corporate debt securities, mortgagebacked securities, bank loans, mezzanine investments and certain other investments that may be purchased and sold are traded in private, unregistered transactions and subject to restrictions on resale. Purchasing financial instruments to close out a short position can itself cause the price of the financial instruments to rise further, thereby exacerbating the loss. 2. was found to have been involved in a violation of the SROs rules and was: (i) barred or suspended from membership or from association with other members, or was expelled from membership; (ii) otherwise significantly limited from investment-related activities; or (iii) fined more than $2,500. 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. 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. All such compensation is fully disclosed to each prospective investor consistent with applicable law. To the extent that Trend Capital receives proxies on behalf of its Advisory Clients, Trend Capital will vote any such proxies in the best interests of the Funds, the Funds investors and the Managed Accounts. Additional risks associated with derivatives trading include: Tracking. Describe how clients may obtain information from you about how you voted their securities. Margin requirements. Trend Capital provides investors with unaudited statements of the relevant Funds performance at least monthly and tax information and audited financial information annually. b. . Investors should carefully review the audited financial statements of the Funds upon receipt. Investment OverviewThe investment objective of each Trend Macro Fund, ERISA Master and Enhanced Return is to produce consistent, absolute returns on capital by pursuing a fundamental global macro strategy. The buyer of a put option assumes the risk of losing its entire investment in the put option. Show parenthetically the market or fair value of securities included at cost. An equity swap is an agreement to exchange streams of payments computed by reference to a notional amount based on the performance of a basket of stocks or a single stock. 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. A self-regulatory organization (SRO) proceeding in which your firm or a management person. 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. Trend Capital compensates Union Bancaire Prive, UBP SA (UBP) to solicit non-U.S. investors in designated jurisdictions for the Trend Macro Offshore. You must state clearly that you are discussing only material changes since the last annual update of your brochureand you must provide the date of the last annual update of your brochure. 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 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. . ashwin vasan Founder and cio at Trend Capital Management LP . 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. Futures prices are highly volatile. ITEM 2 MATERIAL CHANGES . Fixed-Income Financial Instruments. Also, the Funds may invest in financial instruments, such as structured products, derivatives and other types of unregistered financial instruments. 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. 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. The Funds may invest in equities and equity derivatives. If this occurs, Trend Capital may be unable to effectively use its forward trading programs and the Funds could experience significant losses. Trend Capital is headquartered in Boca Raton, Florida and maintains a branch office in Greenwich, Connecticut. 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. In the manner described above, credit default swaps can be used to hedge a portion of the default risk on a single corporate bond or a portfolio of bonds. 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. 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. 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. 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. Restricted Financial Instruments. 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. In general, premium securities (securities whose market values exceed their principal or par amounts) are adversely affected by faster than anticipated prepayments and discount securities (securities whose principal or par amounts exceed their market values) are adversely affected by slower than anticipated prepayments. 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. A credit default swap is a contract between two parties which transfers the risk of loss if a company fails to pay principal or interest on time or files for bankruptcy. Unlisted securities may involve higher risks than listed securities. 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. 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. To the extent any Managed Account applies a more stringent standard, Trend Capital will comply with the applicable restrictions. Describe the content and indicate the frequency of regular reports you provide to clients regarding their accounts. Trend Capital LLC is a Connecticut Foreign Limited-Liability Company filed on May 13, 2011. 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 GP LLC; TREND CAPITAL GAUCHO GP . Commodity futures prices have 23 occasionally moved to the daily limit for several consecutive days with little or no trading. 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 . Such intervention is often intended to influence prices directly. Live market coverage co-anchored from Hong Kong and New York. All Rights Reserved. If you have any questions about the contents of this Brochure, please contactBrian Barry at 561-617-5086 or by email at If you do not have authority to vote client securities, disclose this fact. During a single trading day, no trades may be executed at prices beyond the daily limit. Prior to Shumway, Mr. Vasan was a Partner and Portfolio Manager at Tudor Investment Corporation from 1999 to 2009. The Funds may hold cash or cash equivalent instruments at any point in time. Trend . financial markets are not as developed or as efficient as those in the U.S. and as a result, price volatility may be higher for the Funds investments. Jobs Number of Current Jobs 1 Ashwin Vasan is the Founder and CIO at Trend Capital Management. 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. 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. Who is Ashwin Vasan? Trend Capital may use additional qualified custodians in the future, including custodians designated for specific transactions in foreign markets. These transactions are not subject to exchange rules. Search our database of over 100 million company and executive profiles. Futures Contracts Risks. Trend Capital takes a balanced approach to investing the Trend Macro Funds or Enhanced Returns assets. 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. 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. Volatility. Ashburn Market Trends; Ashburn, VA, Summary. Describe the types of advisory services you offer. The balance sheet must be prepared in accordance with generally accepted accounting principles, audited by an independent public accountant and accompanied by a note stating the principles used to prepare it, the basis of securities included and any other explanations required for clarity. The Funds are expected to invest a significant portion of their capital outside the United States in non-dollar denominated instruments, including in instruments issued by non-U.S. companies and the governments of non-U.S. countries and in non-U.S. currency. 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. Restricted financial instruments (i.e., financial instruments that are purchased in connection with privately negotiated transactions that are not registered under relevant securities laws) cannot be sold to the public without registration under the Securities Act. A principal risk in trading currencies is the rapid fluctuation in the market prices of currency contracts. The Funds may trade forward contracts. Once Trend Capital has identified a trend, Trend Capital typically constructs macroeconomic models intended to quantify the drivers of that trend. Advertisements. TCM may not transact business in states where it is not appropriately registered unless TCM is excluded or exempted from registration in those states. If you have any . A stock index fluctuates with changes in the market values of the stocks included in the index. Examples: (1) You or a related person, as principal, buys securities from (or sells securities to) your clients; (2) you or a related person acts as general partner in a partnership in which you solicit client investments; or (3) you or a related person acts as an investment adviser to an investment company that you recommend to clients. As noted above, certain proposed legislation could limit the trading of speculators (such as the Funds) in the futures markets. Provide your fee schedule. 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. Thus, an increase in the value of the U.S. dollar compared to the other currencies in which the Funds may make investments will reduce the effect of increases and magnify the U.S. dollar equivalent of the effect of decreases in the prices of the Funds financial instruments in their local markets. 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. ADV PART 2A OF FORM ADV FIRM BROCHURE Trend Capital Management LPTrend Capital Advisers LP1800 N. Military Trail, Suite 475Boca Raton, FL 33431Tel: 561-617-5086March 30, 2020 This Brochure provides information about the qualifications and business practices of TrendCapital Management LP and Trend Capital Advisers LP (collectively, "Trend Capital" orthe "Firm"). Because investments in instruments issued by non-U.S. issuers involve non-U.S. dollar currencies and because the Funds may temporarily hold funds in bank deposits in such currencies during the completion of its investment program, the Funds may be affected favorably or unfavorably by changes in currency rates (including as a result of the devaluation of a non-U.S. currency) and in exchange control regulations and may incur transaction costs in connection with conversions between various currencies. Illiquidity. The UCITS is not open to U.S. investors. If you or any of your management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a brokerdealer, disclose this fact.
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