The fees related to the remaining Managed Accounts are individually negotiated. 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. Companies whose securities are not publicly traded may not be subject to public disclosure and other investor protection requirements applicable to publicly traded securities. Similarly, floating rate issuers and borrowers tend to prepay their obligations when spreads narrow. As of March 30, 2020, Trend Capital is submitting its annual amendment to the Brochure. Trend Capital also compensates Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S) for its clients introduced to the Trend Macro Funds. Market Disruption Events. The expiration or termination of available financing for leveraged positions and the requirement to post collateral in respect of changes in the fair value of leveraged exposures or changes in advance rates or other terms and conditions of the Funds repurchase agreements, can rapidly result in adverse effects to its access to liquidity and its ability to maintain leveraged positions and may cause the Funds to incur material losses. Credit Default Swaps; Other Derivatives. 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. 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. 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. Daily Price Fluctuation Limits. No advisory board has been established for Funds other than Trend Macro Fund. 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. The value of a derivative depends largely upon price movements in the underlying asset. Although these financial 28 instruments may be resold in privately negotiated transactions, because there is less liquidity for these financial instruments, the prices realized from these sales could be less than those originally paid by the Funds. 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. ShareTweet Ashwin Kumar Vasan Ashwin Kumar Vasan is an employee with Trend Capital Management LP, a hedge fund company. 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. Trend Capital Management, LLC (TCM) is a Registered Investment Advisor in the states of Kansas and Missouri. 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. Fixed-Income Financial Instruments. Describe the types of products and services you or any of your related persons acquired with client brokerage commissions (or markups or markdowns) within your last fiscal year. The Funds may invest a portion of their assets in financial instruments of issuers domiciled or operating in emerging and developing markets. 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. Restricted financial instruments may involve a high degree of business and financial risk which may result in substantial losses. ault Swaps; Other Derivatives. Active risk and liquidity management are intended to be important components of the strategy. Trend Capital applies rigorous fundamental macroeconomic analysis and a disciplined portfolio construction framework to generate absolute returns with low correlation to the markets. 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. A copy of the Firms Allocation Policy can be obtained by contacting Trend Capital. 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. The Funds will usually enter into swaps on a net basis (i.e., the two payment streams are netted out in a cash settlement on the payment date or dates specified in the agreement). 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. Prior to Shumway, Mr. Vasan was a Partner and Portfolio Manager at Tudor Investment Corporation from 1999 to 2009. 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. The Funds receive or pay, as the case may be, only the net amount of the two payments. Call Options. Trend Capitals trading program relies on a fundamental-based approach in identifying potential investments. If you are amending your brochure for your annual update and it contains material changes from your last annual update, identify and discuss those changes on the cover page of the brochure or on the page immediately following the cover page, or as a separate document accompanying the brochure. 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. With respect to the Opportunities Funds, the minimum initial and additional investment amounts depend on the particular SP in which an investor subscribes. 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. Derivatives that may be purchased or sold by the Funds may include securities and instruments not traded on an exchange. Generally, obligors tend to prepay their fixed 17 rate obligations when prevailing interest rates fall below the coupon rates on their obligations. Delray Beach, Florida, United States . 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. Although the ERISA Funds are in scope of the services agreement between Trend Capital and MLPF&S, the ERISA Funds have not been onboarded to the MLPF&S platform. 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. If you may cause clients to pay commissions (or markups or markdowns) higher than those charged by other broker-dealers in return for soft dollar benefits (known as paying-up), disclose this fact. Sovereign Debt. Combined with stop losses, such hedges are intended to protect the portfolio in the event trades move meaningfully against the direction the Trend Capital anticipated when making the investment. Leverage; Borrowing for Operations. 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. Trend Capital applies rigorous fundamental macroeconomic analysis and a disciplined portfolio construction framework to generate absolute returns with low correlation to the markets. . Trend Capital has broad investment authority, and may trade in any type of security, issuer or group of related issuers, country, region and sector that it believes will help the Funds achieve their investment objective. 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. Trend Capital takes a balanced approach to investing the Trend Macro Funds or Enhanced Returns assets. In exchange for a significant investment in the Trend Macro Feeder Funds at launch, a share of the gross revenue of Trend Capital and its affiliated general partner entities has been granted to affiliates of Shumway Capital. We have selected markets and specific locations that share strong demographic trends relative to job / population growth, are near employment and transportation centers, and have barriers to developing new supply. Historically, Managed Accounts were generally managed pari passu, subject to applicable legal, regulatory or investment restrictions, with the Trend Macro Fund, but more recent Managed Accounts have expanded mandates with respect to exposure to certain types of instruments, markets and/or leverage than the Trend Macro Fund. no role in management of the business). 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. 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. The minimum initial investment amount for the Enhanced Return SPs is $100,000,000and the minimum additional investment amount is $100,000, in each case subject to waiver, reduction or change at the discretion of Trend Capital, the respective general partner or the Board of Directors, as applicable. Commodity-Related Instruments. 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. The Funds may invest in equities and equity derivatives. There can be no assurance that the Funds will be able to maintain the ability to borrow financial instruments sold short. Market disruption events could also affect the principal prime brokers that carry and clear the Funds trades and positions. 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. 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. Also, please let us know if you would like detailed information about how any proxies were actually voted by calling the Chief Compliance Officer, Brian Barry, at 561-617-5086. 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. 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. Management fees from the Managed Accounts are payable monthly in arrears. The Registered Agent on file for this company is R Scott Beach and is located at Day Pitnet Llp One East Putnam Ave, Greenwich, CT . Ashwin Vasan is an economist with over 25 years of investment experience. Currency transactions made on a spot basis are for cash at the spot rate prevailing in the currency market for buying or selling currency. 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. In addition, because non-U.S. entities are not subject to uniform accounting, auditing and financial reporting standards, practices and requirements comparable with those applicable to U.S. companies, there may be different types of and lower quality, information 18 available about a non-U.S. company than a U.S. company. 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. 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. Trend Capital does not manage any Advisory Client assets on a non-discretionary basis. Trend Capital Management LP - Boca Raton - Ashwin Vasan in General Discussions Trend Capital Management LP is a discretionary global macro hedge fund manager. Choose the right Crunchbase solution for you Start Your Free Trial 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. Explain how often you bill clients or deduct your fees. 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. Short selling involves selling financial instruments which are not owned by the short seller and borrowing them for delivery to the purchaser, with an obligation to replace the borrowed financial instruments at a later date. 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. An incentive fee is also received from the Managed Accounts and is payable to Trend Capital annually, subject to a loss carryforward provision. Found 2 colleagues at Trend Capital Management LP. 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. Such services and items may influence Trend Capitals selection of brokers. For example, if the seller of financial instruments to the Funds under a reverse repurchase agreement defaults on its obligation to repurchase the underlying financial instruments, as a result of its bankruptcy or otherwise, the Funds will seek to dispose of such financial instruments, which action could involve costs or delays. 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. 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. Markets never sleep, and neither does Bloomberg. If the Funds invest in derivatives at inopportune times or incorrectly judge market conditions, the investments may lower the return of the Funds or result in a loss. Similarly, even if more than ten years have passed since the date of the event, you must disclose the event if it is so serious that it remains material to a clients or prospective clients evaluation. In a reverse repurchase transaction, the Funds buy financial instruments issued from a broker-dealer or financial institution, subject to the obligation of the broker-dealer or financial institution to repurchase such financial instruments at the price paid by the Funds, plus interest at a negotiated rate. Trend Capitals principal owner is Ashwin Vasan. Trend Capital also compensates Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S) for its clients introduced to the Trend Macro Funds. Governments from time to time intervene, directly and by regulation, in certain markets, particularly those dealing in precious metals. The practice of leveraging and the use of derivatives, swaps, futures and options, may subject an investment portfolio to greater risk of adverse impact. Founder and cio at Trend Capital Management LP Delray Beach . Trading in Currencies. 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. Trend Capital may utilize such leverage, position size, duration and other portfolio management techniques as it believes are appropriate for the Funds. Explain that you will provide a copy of your code of ethics to any client or prospective client upon request. Trend Capital can provide further details or a copy of the Firms Allocation Policy upon request. Trend Capital Management LP, 092120 DECH, 2019-0064-KSJM Document Cited in Precedent Map Related Vincent 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. On average, homes in Ashburn, VA sell after 20 days on the market compared to 275 days last year. 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. Investment Program of Trend Capital. Loudoun County has similar renown and is called "The Center of the Internet" and "Data Center Alley.". Explain how a client may obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period. 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. In fact, the Funds portfolio, at times, may be highly concentrated. 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. A substantial portion of the Funds capital may be invested on the basis of short-term market considerations. Possible Effects of Speculative Position Limits. In addition, the Funds assets are also subject to the risk of the failure of any of the exchanges on which its positions trade or of its clearinghouses or counterparties. First, all participants in the futures market are subject to margin deposit and maintenance requirements. To the extent any Managed Account applies a more stringent standard, Trend Capital will comply with the applicable restrictions.n. Trend Capital Management LP is a discretionary global macro hedge fund manager. Opportunities Funds:The Opportunities Funds pay a monthly management fee with respect to each particular SP, equal to the product of the applicable management fee rate and each investors capital account balance or shares, as applicable. However, there are a number of additional risks associated with derivatives trading. Thus, the leverage offered by trading in derivatives will magnify the gains and losses experienced by the Funds and could cause the Funds net asset value to be subject to wider fluctuations than would be the case if the Funds did not use the leverage feature of derivatives. In addition, new and additional regulations and laws may apply to swaps and other derivatives that have not heretofore been applied. Liquidity. Trend Capital may invest in zero coupon bonds and deferred interest bonds, which are debt obligations issued at a significant discount from face value. If applicable, explain that you may be unable to achieve most favorable execution of client transactions. Trend Capital is permitted to use leverage in pursuing its investment objective and this leverage may be significant. These instruments carry a higher risk that the issuer will be unable to pay principal and interest when due. This limit will be proportionally increased when applied to the Enhanced Return to achieve its leverage target. 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. Describe the types of clients to whom you generally provide investment advice, such as individuals, trusts, investment companies, or pension plans. 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 value of fixed-income securities in which the Funds may invest will change in response to fluctuations in interest rates. SEC registration does not imply acertain level of skill or training. 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, the Funds may bear, along with other shareholders of an ETF, its pro rata portion of the ETFs expenses, including management fees. In addition, as referenced in Item 2 above, the offering documents for the Funds disclose specific trade error policies. Repurchase and Reverse Repurchase Agreements. If you are an SEC-registered adviser, briefly describe your code of ethics adopted pursuant to SEC rule 204A-1 or similar state rules. Fundamental analysis produces positive results only to the extent that Trend Capital correctly predicts how external factors (such as government regulation, new technologies and political and economic events) will influence the market price of a given investment. Describe any other types of fees or expenses clients may pay in connection with your advisory services, such as custodian fees or mutual fund expenses. Even those markets which Trend Capital expects to be liquid can experience periods, possibly extended periods, of illiquidity. 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. 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. If you or any of your management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities, disclose this fact. Futures prices are highly volatile. Bloomberg Daybreak Asia. Conversely, a decrease in the value of the U.S. dollar will have the opposite effect of magnifying the effect of increases and reducing the effect of decreases in the prices of the Funds non-U.S. dollar financial instruments. Price movements of contracts are influenced by, among other things: changing supply and demand relationships; weather and climate conditions; trade, fiscal, monetary and exchange control programs and policies of governments; political and economic events and policies; changes in interest rates and rates of inflation; currency devaluations and revaluations; and emotions of the marketplace. Please see terms and conditions for restrictions on use of Citywire's Fund Manager database. 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 . The production and marketing of commodities may be affected by actions and changes in governments. 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. Generally, the Funds will not be restricted from dealing with any particular counterparties. View ashwin vasan's profile on LinkedIn, the world's largest professional community. Trend . If you have any requirements for opening or maintaining an account, such as a minimum account size, disclose the requirements. Industry Group Agriculture Banking & Financial Services Business Services Energy Coal Mining Electric Utilities Mr. Vasan began his career at Citibank in 1989 as an International Economist. The Funds may incur risks associated with the sale and purchase of call options. 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