Disclose that you may have an incentive to select or recommend a brokerdealer based on your interest in receiving client referrals, rather than on your clients interest in receiving most favorable execution. Possible Effects of Speculative Position Limits. Changes in liquidity may result in significant, rapid and unpredictable changes in the prices for derivatives. 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. Moreover, a disruption in the financing, derivative intermediation and prime brokerage services provided by any party before the Funds establish additional relationships could have a significant impact on the Funds business due to the Funds reliance on such counterparties. Interest Rate Risk. 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. Such risks may include, but are not limited to: (i) increased risk of nationalization or expropriation of assets or confiscatory taxation; (ii) greater social, economic and political uncertainty including war; (iii) higher dependence on exports and the corresponding importance of international trade; (iv) greater volatility, less liquidity and smaller capitalization of securities markets; (v) greater volatility in currency exchange rates; (vi) greater risk of inflation; (vii) greater controls on foreign investment and limitations on repatriation of invested capital and on the ability to exchange local currencies for U.S. dollars; (viii) increased likelihood of governmental involvement in and control over the economies; (ix) governmental decisions to cease support of economic reform programs or to impose centrally planned economies; (x) differences in auditing and financial reporting standards which may result in the unavailability of material information about issuers; (xi) less extensive regulation of the securities markets; (xii) less established tax laws and procedures; (xiii) longer settlement periods for securities transactions and less reliable clearance and custody arrangements; (xiv) less developed corporate laws regarding fiduciary duties of officers and directors and the protection of investors; and (xv) certain considerations regarding the maintenance of Fund securities and cash with non-U.S. brokers and securities depositories. Operational Leverage. The Funds may invest in credit default swaps. Among other things, the Code of Ethics (i) requires that all employees comply with federal securities laws, (ii) requires that all employees submit to Trend Capital reports containing their personal securities holdings and transactions in reportable securities and that Trend Capital review such reports, (iii) requires all employees to obtain pre-approval of transactions in their personal accounts (except open-end mutual funds) and (iv) contains policies and procedures designed to prevent the misuse of material, non-public information. 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 are designed only for experienced and sophisticated persons who are able to bear the risk of substantial impairment or total loss of their investment in the Funds. The portfolio turnover rate of those investments may be significant and could involve substantial brokerage commissions and other transaction costs. 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. 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. Such investments experience greater volatility in market value due to changes in interest rates than debt obligations that provide for regular payments of interest. The material changes since Trend Capital submitted its most recent annual amendment to the Brochure on March 29, 2019 include: As of June 30, 2019, Trend Capital Gaucho Fund LP and its offshore feeder, Trend Capital Offshore LP were terminated and capital was returned to investors. Although outside the period referenced, Permal Ash Macro Ltd is expected to wind down as a Managed Account (defined below) and the underlying investors representing a majority of its net asset value will subscribe directly into Trend Macro Fund LP on April 1, 2020. The Firm has included as an additional risk factor in Item 8.B, Market Disruption Events, which addresses the potential impact of significant events such as the recent COVID-19 pandemic. 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. 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. It typically will not concentrate the portfolio in individual positions or groups of correlated positions to the extent that losses from such areas of concentration would be so extreme that the portfolio could not possibly generate returns from other positions mitigating or exceeding such losses. Thus, the Funds face the risk that their counterparties may not perform their obligations. 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. Please let us know if you have any questions about, or would like to be provided with a copy of, our proxy voting procedures. Accordingly, the Funds may pledge their financial instruments in order to borrow or otherwise obtain leverage for investment or other purposes. 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 believes that high ethical standards are essential to its success and to maintain the confidence of its investors. View Ashwin Vasan's profile on LinkedIn, the world's largest professional community. View company leaders and background information for Trend Capital Management Lp. 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. Ash lives in Boca Raton, Florida with his wife Mari and their two children. Track your investments 24 hours a day, around the clock from around the world. 33ITEM 12 BROKERAGE PRACTICES .. 35ITEM 13 REVIEW OF ACCOUNTS .. 39ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION 40ITEM 15 CUSTODY 41ITEM 16 INVESTMENT DISCRETION .. 42ITEM 17 VOTING CLIENT SECURITIES . The Funds may purchase low rated or unrated debt instruments. Each Fund or SP, as applicable, will bear its own (and a pro-rata share of its master funds or master fund SPs, as applicable) operating and other expenses, including, but not limited to, investment-related expenses (e.g., expenses that, in Trend Capitals discretion, are related to the investment of that Funds/SPs assets, whether or not such investments are consummated, such as brokerage commissions, expenses relating to short sales, clearing and settlement charges, custodial fees, interest expenses, initial and variation margin and other transactional charges, fees or costs, bank service fees, investment-related travel and lodging expenses, consulting, advisory, investment banking, valuation and other professional fees relating to particular investments or contemplated investments, researchrelated expenses, including, without limitation, news and quotation equipmentand services, market data services and fees to third-party providers of research and/or portfolio risk management services), legal expenses (including with respect to litigation and threatened litigation, if any), any expenses associated with regulatory filings made in connection with the Funds/SPs operations and/or holdings, accounting, audit and tax advice and preparation expenses(including preparation costs of financial statements, tax returns, reports to investors), accounting software, printing and mailing costs, market information systems and computer software and information expenses, fees of pricing services, valuation firms, the costs and expenses of third-party risk management products and services, insurance costs (including, without limitation, directors and officers insurance, errors and omissions insurance and other similar policies for the benefit of the Fund), filing and registration fees, fees of the administrator, fees of the Master Fund Advisory Board (if applicable), fees of the Funds/SPs (and its pro rata share of the Master Funds) officers (including AML Officers), the management fee, any extraordinary expenses (including indemnification or litigation expenses and any judgments or settlements paid in connection therewith), all other costs and expenses arising out of the Funds/SPs indemnification obligation, any entity-level taxes, fees or other governmental charges levied against a Fund, wind-up and liquidation expenses and other similar expenses related to a Fund/SP. 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. Explain how often you bill clients or deduct your fees. Call Options. 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. A stock index fluctuates with changes in the market values of the stocks included in the index. If you have any requirements for opening or maintaining an account, such as a minimum account size, disclose the requirements. Advertisements. ERISA). no role in management of the business). 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. 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. Fixed-Income Financial Instruments. Explain that when you use client brokerage commissions (or markups or markdowns) to obtain research or other products or services, you receive a benefit because you do not have to produce or pay for the research, products or services. This Brochure provides information about the qualifications and business practices of TrendCapital Management LP and Trend Capital Advisers LP (collectively, Trend Capital orthe Firm). 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. Choose the right Crunchbase solution for you Start Your Free Trial Managed Account payment terms are specifically negotiated, with payment generally in arrears. Please contact Trend Capital for further information. Explain that not all advisers require their clients to direct brokerage. Generally speaking, the minimum initial investment for each investor in the Funds (with the exception of the Opportunities Funds) is $1,000,000 or $25,000,000 (depending on the Fund and Class of Interests/Shares in which an investor subscribes) and the minimum investment for additional subscriptions is $500,000, subject, in each case, to waiver, reduction or change at the discretion of Trend Capital, the Board of Directors and/or Advisory Board, as applicable. 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. 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. Derivative securities and instruments, or derivatives, include securities, instruments and contracts which are derived from and are valued in relation to one or more underlying securities, financial benchmarks or indices. Each SP of the Opportunities Funds pursues its own investment opportunities, as described further in Item 8.A. Commodity futures trading is highly speculative. 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. Research and Other Soft Dollar Benefits. Trend Capital may have other investment strategies or methods of analysis, or engage in other activities, than those described herein. The Firm has adopted and implemented a compliance program, including a Valuation Committee that reviews performance tracking and position differences, to monitor its Funds and Managed Accounts for adherence to investment objectives and a fair allocation process to help mitigate any potential conflicts. Trend Capitalis paid a 1.25% annualized management fee for the Enhanced Return SP, subject to an initial minimum subscription amount.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. Securities Futures Contracts. Similarly, floating rate issuers and borrowers tend to prepay their obligations when spreads narrow. Limited diversity could expose the Funds to losses disproportionate to market movements in general if there are disproportionately greater adverse price movements in those financial instruments or assets. Trend Capital Management LP has been registered with the CFTC as a commodity pool operator under the Commodity Exchange Act and has been a member of the National Futures Association since January 2, 2013; Trend Capital GP LLC has also been registered with the CFTC as a commodity pool operator under the Commodity Exchange Act and has been a member of the National Futures Association since January 2, 2013; and Trend Capital Advisers LP has been registered with the CFTC as a commodity pool operator under the Commodity Exchange Act and has been a member of the National Futures Association since October 16, 2017. Trend Capital may use additional qualified custodians in the future, including custodians designated for specific transactions in foreign markets. Although Trend Capitals investment advice is generally limited to these types of investments, it has a broad and flexible investment authority. 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. Emphasis is placed on trade construction, including how each trades volatility and correlations affect the overall portfolio characteristics, in hopes of maximizing risk/return of the Trend Macro Fund or Enhanced Return. 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. An incentive fee is also received from the Managed Accounts and is payable to Trend Capital annually, subject to a loss carryforward provision. At times, certain market makers have refused to quote prices for forward contracts, or have quoted prices with an unusually wide spread between the price at which they are prepared to buy and sell. Changes in interest rates can affect the value of the Funds investments in fixed income instruments. If the type of security involves significant or unusual risks, discuss these risks in detail. 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. If you participate in wrap fee programs by providing portfolio management services, (1) describe the differences, if any, between how you manage wrap fee accounts and how you manage other accounts, and (2) explain that you receive a portion of the wrap fee for your services. Forward Trading. Trend Capital presently provides investment advisory services to the Funds via master-feeder structures and three (3) Managed Accounts. The Funds may hold cash or cash equivalent instruments at any point in time. Such factors include government regulation, new technologies and political and economic events. The Funds may incur risks associated with the sale and purchase of call options. Ashwin Vasan Related Companies. 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. 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. Three ( 3 ) Managed Accounts and is payable to trend Capital believes that high standards! 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