Sep 3, 2017 | Fund Employees. 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. 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. Describe how you are compensated for your advisory services. If you have any questions about the contents of this Brochure, please contactBrian Barry at 561-617-5086 or by email at bbarry@trendcaplp.com. 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. 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. Securities Futures Contracts. Refer to Item 12 for further information. Investing in these markets may involve heightened risks (some of which could be significant) and special considerations not typically associated with investing in other more established economies or securities markets. Citywire ranks and rates all portfolio managers running mutual funds without charge. Trading instructions may have to be modified and the Funds positions may need to be liquidated to avoid exceeding these limits. Portfolio Manager at Shumway Capital . 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. If you are an SEC-registered adviser, briefly describe your code of ethics adopted pursuant to SEC rule 204A-1 or similar state rules. Price movements of futures and options contracts and payments pursuant to swap agreements are influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments and national and international political and economic events and policies. If your advisory firm or a management person has been involved in a legal or disciplinary event that is not listed in Items 9.A, 9.B, or 9.C, but nonetheless is material to a clients or prospective clients evaluation of your advisory business or the integrity of its management, you must disclose the event. Founder and cio at Trend Capital Management LP Delray Beach, FL. Non-U.S. Investments. 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. Thus, the Funds face the risk that their counterparties may not perform their obligations. Ashwin Kumar Vasan is an employee with Trend Capital Management LP, a hedge fund company. Ash lives in Boca Raton, Florida with his wife Mari and their two children. Volatility. In markets in which liquid options are available, Trend Capital often implements option hedges against trades in the Trend Macro Funds or Enhanced Returns portfolio. Trend Capital understands and appreciates the importance of proxy voting and ensuring that its proxy voting procedures are clearly described to investors. . 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. 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. There can be no assurance that future court decisions construing provisions in, or provisions similar to those in, any swap agreement or other related documents or new and additional regulations and laws governing swaps and other derivatives will not have a material adverse effect on the investments. Ashburn. As of the date of this Brochure, the qualified custodians utilized by Trend Capital for the Funds are: Credit Suisse Securities (USA) LLC11 Madison AvenueNew York, NY 10010, JP Morgan Chase Bank NA270 Park AvenueNew York, NY 10017, J.P. Morgan Securities LLC383 Madison AvenueNew York, New York 10179, Northern Trust International Banking Corporation3 Second StreetHarborside Financial Center Plaza 10Suite 1401Jersey City, NJ 07311-3988, The Bank of New York Mellon101 Barclay Street, 3rd FloorNew York, NY 10007. The seller of an uncovered put option assumes the risk of a decline in the market price of the underlying financial instrument 27 below the exercise price of the option. 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. Short selling allows the seller to profit from a decline in market price to the extent such decline exceeds the transaction costs and the costs of borrowing the financial instruments. During periods of economic or financial instability, commodity-related instruments may be subject to broad price fluctuations, reflecting volatility of energy and basic material prices and possible instability of supply of various commodities. 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. Explain the procedures you used during your last fiscal year to direct client transactions to a particular broker-dealer in return for client referrals. The buyer of a put option assumes the risk of losing its entire investment in the put option. Phone (703) 729-1500. Advertisements. Describe the content and indicate the frequency of regular reports you provide to clients regarding their accounts. Trend Capital takes a balanced approach to investing the Trend Macro Funds or Enhanced Returns assets. An incentive fee is also received from the Managed Accounts and is payable to Trend Capital annually, 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. 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. Because the value of an index option depends upon movements in the level of the index rather than the price of a particular stock, whether the Funds will realize gains or losses from the purchase or writing of options on indices depends upon movements in the level of stock prices in the stock market generally or, in the case of certain indices, in an industry or market segment, rather than movements in the price of particular stocks. Ashwin Vasan is an economist with over 25 years of investment experience. 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. 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. The Funds may trade forward contracts. 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. 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). In addition to its quantitative modeling, Trend Capital incorporates qualitative factors into its assessment of each trend. Ashwin Vasan is an economist with over 25 years of investment experience. Explain how often you bill clients or deduct your fees. ashwin has 1 job listed on their profile. If more than 50% of your revenue from advisory clients results from commissions and other compensation for the sale of investment products you recommend to your clients, including asset-based distribution fees from the sale of mutual funds, disclose that commissions provide your primary or, if applicable, your exclusive compensation.Not applicable. 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. 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. 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. 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. Ashburn, a city in Virginia's Loudoun County about 34 miles from Washington D.C., is widely known as the Data Center Capital of the World. Restricted Financial Instruments. The Funds also may be exposed to risks that issuers will not fulfill contractual obligations such as, in the case of convertible financial instruments or private placements, delivering marketable common stock upon conversions of convertible financial instruments and registering restricted financial instruments for public resale. Currency swaps involve the exchange of cash flows on a notional amount of two or more currencies based on their relative future values. Ashwin Vasan - Senior Advisor to the Director - Consumer Financial Protection Bureau | LinkedIn View Ashwin Vasan's profile on LinkedIn, the world's largest professional community. All personnel of Trend Capital are required to certify their compliance with the Code of Ethics. Mr. Vasan began his career at Citibank in 1989 as an International Economist. 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. There can be no assurance that the Funds will be able to maintain the ability to borrow financial instruments sold short. Some of the markets in which the Funds may effect transactions are not exchanged-based, including over-the-counter (OTC) or interdealer markets. Ashwin is Chief Investment Officer and has served as Chief Investment Officer since 05/01/2011. Leverage; Borrowing for Operations. Over-the-Counter Trading. Trend Capital believes that high ethical standards are essential to its success and to maintain the confidence of its investors. For Trend Macro Fund and the ERISA Fund, the management fee is computed at the annual rate of 2.0% of each capital account or share class established in connection with Class A Interests/Shares. As such, there is a potential conflict of interest related to managing accounts that provide Trend Capital with higher performance-based compensation alongside accounts that provide lower performance-based compensation. 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. 29 Aug 2019 by Joel St.Germain. 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. Exchange Traded Funds. 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. Trend Capital Management LP - Boca Raton - Ashwin Vasan in General Discussions Trend Capital Management LP is a discretionary global macro hedge fund manager. The investment strategy for any future SP will be described in detail in the applicable PPM Supplement. SEC registration does not imply acertain level of skill or training. The Funds may trade on exchanges or markets located outside the U.S. Trading on such exchanges or markets is not regulated by the Securities and Exchange Commission (the SEC) and the Commodity Futures Trading Commission (the CFTC) and may, therefore, be subject to more risks than trading on U.S. exchanges, such as the risks of exchange controls, expropriation, burdensome taxation, moratoria and political or diplomatic events. 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. 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. The Firm has adopted and implemented a compliance program to monitor its Funds and managed accounts and mitigate any potential conflicts of interest. 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 does not participate in wrap fee programs. 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. In general, third party solicitors may receive a portion of the fees otherwise payable to Trend Capital. 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. The Funds may purchase and sell call and put options on stock indices listed on securities exchanges or traded in the over-the-counter market. Such services and items may influence Trend Capitals selection of brokers. To the extent any Managed Account applies a more stringent standard, Trend Capital will comply with the applicable restrictions. The minimum and additional subscription amounts are reduced for each investor introduced to one of the Trend Macro Funds by Merrill Lynch. For simplicity, each fund or SP identified above may be referred to individually in this Brochure as a Fund and together as the Funds. 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. 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. Currency and Exchange Rate Risks. Ashburn Market Trends; Ashburn, VA, Summary. 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. The value of fixed-income securities in which the Funds may invest will change in response to fluctuations in interest rates. 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. Four of the companies are still active while the remaining two are now listed as inactive. Explain that you will provide a copy of your code of ethics to any client or prospective client upon request. 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. Active risk and liquidity management are intended to be important components of the strategy. Live from New York and Hong Kong, bringing you the essential stories from the close of the U.S. markets to the open of trading across Asia. It is anticipated that the Funds may invest in financial instruments issued by a government, its agencies, instrumentalities or its central bank (Sovereign Debt). Restricted financial instruments may involve a high degree of business and financial risk which may result in substantial losses. Describe the types of advisory services you offer. Derivatives that may be purchased or sold by the Funds may include securities and instruments not traded on an exchange. ShareTweet Ashwin Kumar Vasan Ashwin Kumar Vasan is an employee with Trend Capital Management LP, a hedge fund company. 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. Describe generally how you address conflicts that arise. 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. The applicable fee share is disclosed in the Prospectus and related Prospectus Supplement. 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. 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 fees related to the remaining Managed Accounts are individually negotiated. There are 8 professionals named "Ashwin Vasan", who use LinkedIn to exchange information, ideas, and opportunities. 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. The adverse effects of prepayments may impact the Funds portfolio in two ways. 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. Bloomberg Daybreak Asia. Trend Capital deducts fees from Fund assets. 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. 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. 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. Forward Trading. Delray Beach, Florida, United States . Such factors include government regulation, new technologies and political and economic events. Forgot your password? Contents of this Brochure, please contactBrian Barry at 561-617-5086 or by email at bbarry trendcaplp.com. Regulation, new technologies and political and economic events how often you clients. To avoid exceeding these limits by the Funds will be described in detail in the option. Applicable fee share is disclosed in the over-the-counter market or by email at bbarry @ trendcaplp.com prepayments impact... 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