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 may invest in zero coupon bonds and deferred interest bonds, which are debt obligations issued at a significant discount from face value. Operational Leverage. 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. If the only thing you know about sports is who wins and who loses, you are missing the highest stakes action of all. There may be limited information available about the issuers of the financial instruments which may make valuation of such financial instruments difficult or uncertain. 100 W Putnam Ave Greenwich, CT 06830. Repurchase and Reverse Repurchase Agreements. In addition, governmental or regulatory authorities may impose trading or travel restrictions that could adversely affect the Firms ability to effectively conduct the Funds business or conduct investment related travel to the countries in which the Funds invest. Trend Capital can provide further details or a copy of the Firms Allocation Policy upon request. 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 Funds may hold cash or cash equivalent instruments at any point in time. 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. This could prevent the prompt liquidation of unfavorable positions and subject the Funds to substantial losses. The instruments and borrowings utilized by the Funds to leverage investments may be collateralized by the Funds portfolio. Avanath Capital 1920 Main Street, Suite 150, Irvine, CA 92614 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. Found 2 colleagues at Trend Capital Management LP. Describe how you are compensated for your advisory services. 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. 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. The Funds may invest in equities and equity derivatives. . 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. 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. Portfolio No one trade idea, 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. 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. This requires different skills and techniques than predicting changes in the price of individual stocks. Fixed-Income Financial Instruments. As explained in Item 10.C above, Trend Capital currently acts as the investment manager for each of the Funds and investment adviser or designated portfolio manager to three (3) Managed Accounts. 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. 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. The market for many derivatives is, or suddenly can become, illiquid. 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. Get Directions. The inability of key marketplace intermediaries to function could have an adverse impact upon liquidity as well as the ability of the Funds to trade positions. Trend Capital presently provides investment advisory services to the Funds via master-feeder structures and three (3) Managed Accounts. If you have been the subject of a bankruptcy petition at any time during the past ten years, disclose this fact, the date the petition was first brought and the current status. The receipt of an incentive allocation creates an incentive for Trend Capital to make investments that are riskier or more speculative than it otherwise would. . . 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. For purposes of this Item, economic benefits include any sales awards or other prizes. The use of repurchase and reverse repurchase agreements by the Funds involves certain risks. Trend Capital also compensates Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S) for its clients introduced to the Trend Macro Funds. The level of interest rates generally and the rates at which the Funds can borrow particularly, will affect the operating results of the Funds. Commodity-Related Instruments. Risk Disclosure. 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. Commodity futures trading is highly speculative. Trend Capital Management LPTrend Capital Advisers LP1800 N. Military Trail, Suite 475Boca Raton, FL 33431Tel: 561-617-5086March 30, 2020. The Funds receive or pay, as the case may be, only the net amount of the two payments. 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. rend Macro Funds assets in a way that it will be flat or positive carry in aggregate, including the cost of its hedging program. All futures positions held by all accounts owned or controlled by Trend Capital and its principals will be aggregated with the Funds positions for purposes of determining compliance with these limits. These indexes may either be broad-based, sector-based, or international. 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. 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. The buyer of a put option assumes the risk of losing its entire investment in the put option. Restricted financial instruments may involve a high degree of business and financial risk which may result in substantial losses. In general, neither Trend Capital nor the Funds will be required to notify any or all of the other investors in the Funds of any such Side Letters or any of the rights and/or terms or provisions thereof, except as specified in Trend Macro Funds MFN (most-favored nations) Policy Statement, which requires that Trend Capital notify certain investors of any new Side Letters and offer such investors equally favorable terms as those granted in the new Side Letter. Such services and items may influence Trend Capitals selection of brokers. 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. 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. If you have any requirements for opening or maintaining an account, such as a minimum account size, disclose the requirements. Prior to Shumway, Mr. Vasan was a Partner and Portfolio Manager at Tudor Investment Corporation from 1999 to 2009. Derivatives, especially when traded in large amounts, may not be liquid in all circumstances, so that in volatile markets the Funds may not be able to close out a position without incurring a loss. 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 participants in such markets are typically not subject to the credit 16 evaluation and regulatory oversight to which members of exchange-based markets are subject. 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. The practice of leveraging and the use of derivatives, swaps, futures and options, may subject an investment portfolio to greater risk of adverse impact. 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. Disclose whether you use soft dollar benefits to service all of your clients accounts or only those that paid for the benefits. Choose the right Crunchbase solution for you Start Your Free Trial The incentive allocation, if any, will be determined as of each fiscal year end and, with respect to capital withdrawn/redeemed other than as of a fiscal year end, as of the time of such withdrawal/redemption with respect to the withdrawn/redeemed amount. View company leaders and background information for Trend Capital Management Lp. The companies were formed over a two year period with the most recent being incorporated four years ago in May of 2018. Founder and cio at Trend Capital Management LP Delray Beach, FL. 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. 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. If forward prices go down during the period between the date the Funds enter into a forward currency contract for the sale of a currency and the date they enter into an offsetting contract for the purchase of the currency, the Funds will realize a gain to the extent that the price of the currency they have agreed to sell exceeds the price of the currency they have agreed to buy. These actions could adversely affect the Funds operations and profitability. 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. Regardless, the Firm does not direct order flow for client referrals. 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. When used for hedging purposes, an imperfect or variable degree of correlation between price movements of the derivative and the underlying investment sought to be hedged may prevent the Funds from achieving the intended hedging effect or expose the Funds to risk of loss. It is possible that as a result of war, terrorist act, natural disaster, outbreaks of infectious disease, epidemic, pandemic or other serious public health concern, or geopolitical or other extraordinary or unforeseen circumstance or event, one or more of these markets may cease operating for a limited or indeterminate period of time. Sovereign Debt. Managed account trade error policies are the subject of negotiated agreements and may vary. No credit card required. The fact that Trend Capital, 34 its employees, affiliates or their related persons also invest directly (or indirectly via deferred compensation) in any one, some, or all of the Funds creates a potential conflict of interest in that it could cause Trend Capital to make different investment decisions than if they did not have such financial ownership interest. The buyer of a call option assumes the risk of losing its entire premium investment in the call option. Turnover. This limit will be proportionally increased when applied to the Enhanced Return to achieve its leverage target. The information in thisBrochure has not been approved or verified by the United States Securities and ExchangeCommission (the SEC) or by any state securities authority.Additional information about Trend Capital is also available on the SECs website atwww.adviserinfo.sec.gov.Trend Capital is registered as an investment adviser with the SEC under the U.S. InvestmentAdvisers Act of 1940, as amended (the Advisers Act). Changes in liquidity may result in significant, rapid and unpredictable changes in the prices for derivatives. Ashwin Vasan (born November 15, 1980) is an American physician and epidemiologist serving as the 44th commissioner of the New York City Department of Health and Mental Hygiene. The Funds trade in different markets and different kinds of instrument types. 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. Commodity Interest Trading may be Volatile. Trend Capital applies rigorous fundamental macroeconomic analysis and a disciplined portfolio construction framework to generate absolute returns with low correlation to the markets. This Brochure provides information about the qualifications and business practices of TrendCapital Management LP and Trend Capital Advisers LP (collectively, Trend Capital orthe Firm). 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. 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. 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. Indicate whether you periodically review client accounts or financial plans. 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. 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. Address 44151 Ashburn Shopping Plaza. Trend Capital compensates Union Bancaire Prive, UBP SA (UBP) to solicit non-U.S. investors in designated jurisdictions for the Trend Macro Offshore. The Enhanced Return sizing due to additional leverage and resulting liquidity is expected to differ from Trend Macro Fund from time-to-time, depending on the portfolio assets. 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. 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. 4. was the subject of any order, judgment, or decree permanently or temporarily enjoining, or otherwise limiting, your firm or a management person from engaging in any investment-related activity, or from violating any investment-related statute, rule, or order Not applicable. Ashwin Vasan has an ownership stake in Trend . Interest Rate Risk. Ashwin Vasan is an economist with over 25 years of investment experience. Successful use of stock index futures contracts by the Funds also is subject to Trend Capitals ability to correctly predict movements in the direction of the market. Markets never sleep, and neither does Bloomberg. Where a product or service obtained with commission dollars provides both research and non-research assistance to the Advisory Clients, Trend Capital will make a reasonable allocation of the cost that may be paid for with commission dollars. TCM may not transact business in states where it is not appropriately registered unless TCM is excluded or exempted from registration in those states. Prior to voting any proxies, Trend Capital seeks to identify any potential conflicts of interest related to the proxy in question and, if required for certain Managed Accounts, escalate to the appropriate personnel for such Managed Account. Additional risks associated with derivatives trading include: Tracking. Ashwin Vasan Work Experience and Education Work Experience Health Commissioner New York Presbyterian 2012-2022 Founder & Chief Information Officer Trend Capital 2011-2021 Health Commissioner Health Association 2018-2022 Director, Cons (Senior Advanced To For Strat & Innov) Consumer Financial Protection Bureau 2021-2021 Education Ashwin Vasan Related Companies. If you and the brokerdealer are affiliates or have another economic relationship that creates a material conflict of interest, describe the relationship and discuss the conflicts of interest it presents. 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. 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. 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. The Opportunities Master Fund SPs may utilize such investment techniques as option transactions, margin transactions, short sales, leverage and derivatives trading, which may create or increase volatility and can increase the adverse impact to which the Opportunities Master Fund SPs investment portfolios may be subject. At bbarry @ trendcaplp.com UBP ) to solicit non-U.S. investors in designated jurisdictions for the trend Macro Offshore ago. Or suddenly can become, illiquid 1999 to 2009 may involve a high degree of business and financial which... Funds involves certain risks are the subject of negotiated agreements and may vary this Brochure, please Barry. Its entire premium investment in the call option Raton, FL services and items influence! 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