If you have any requirements for opening or maintaining an account, such as a minimum account size, disclose the requirements. Currency and Exchange Rate Risks. Describe how you address conflicts of interest between you and your clients with respect to voting their securities. 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. 44. Who is Ashwin Vasan? Regardless, the Firm does not direct order flow for client referrals. 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. 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 . 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. Ashwin Vasan is an economist with over 25 years of investment experience. 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. Ashwin Vasan is the Founder and CIO of Trend Capital Management LP. The prices and trading volumes for certain commodities can be volatile. Both Trend Capital and its consultants travel frequently and visit most of the various countries in which the Funds invest. For purposes of this Brochure, each such account is referred to as a Managed Account and together with the Funds, the Advisory Clients. Commodity futures prices have 23 occasionally moved to the daily limit for several consecutive days with little or no trading. There can be no assurance that the Funds will be able to maintain the ability to borrow financial instruments sold short. Trend Capital places trades for execution for the Advisory Clients with broker-dealers on the basis of seeking best execution and in consideration of relevant factors, including, but not limited to, commission rates, reliability, financial responsibility, strength of the broker and the ability of the broker to efficiently execute transactions, the brokers facilities and the brokers provision or payment of the costs of brokerage and research services that are of benefit to the Advisory Clients or Trend Capital. Ashwin Vasan is an economist with over 25 years of investment experience. 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. Prospective investors must also execute a subscription agreement and, in the case of the Trend Capital sponsored Funds, limited partnership agreements (where applicable). Loudoun County has similar renown and is called "The Center of the Internet" and "Data Center Alley.". Ashwin Vasan Related Companies. Explain that investing in securities involves risk of loss that clients should be prepared to bear.Trend Macro Fund, ERISA Master and Enhanced Return. Futures prices are highly volatile. If clients may select either method, disclose this fact. Therefore, increased participation by speculators in the futures market also may cause price distortions. Ashwin Kumar Vasan - Trend Capital Management LP. However, ETF shareholders are generally subject to the same risk as holders of the underlying securities they are designed to track. 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. Futures Contracts Risks. Explain that not all advisers require their clients to direct brokerage. While zero coupon bonds do not require the periodic payment of interest, deferred interest bonds generally provide for a period of delay before the regular payment of interest begins. Citywire ranks and rates all portfolio managers running mutual funds without charge. In general, Trend Capital seeks to achieve this investment objective by taking both long and short positions in a variety of fixed income instruments and derivatives, foreign currencies,foreign exchange forwards and foreign exchange derivatives, as well as in various derivative products linked to credit and equity indices. ashwin vasan Founder and cio at Trend Capital Management LP . 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. Margin requirements for transactions that are not bona fide hedging are significantly higher than for bona fide hedging transactions. If you or a related person recommends to clients, or buys or sells for client accounts, securities in which you or a related person has a material financial interest, describe your practice and discuss the conflicts of interest it presents. (a) denying, suspending, or revoking the authorization of your firm or a management person to act in an investment-related business; (b) barring or suspending your firms or a management persons association with an investment-related business; (c) otherwise significantly limiting your firms or a management persons investment-related activities; or (d) imposing a civil money penalty of more than $2,500 on your firm or a management person. Avanath Capital 1920 Main Street, Suite 150, Irvine, CA 92614 Leverage; Borrowing for Operations. Trend Capital acts as the investment manager of the Funds. 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. Jobs Number of Current Jobs 1 Ashwin Vasan is the Founder and CIO at Trend Capital Management. 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. Portfolio No one trade idea, 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. 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. Trading in derivatives can result in large amounts of operational leverage. 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. Trend Capital provides discretionary investment advisory services to its Advisory Clients by managing and directing the investment and reinvestment of their assets. 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. Trend Capital, while using reasonable efforts to liquidate all positions using such considerations and within such aforementioned time frame, is under no obligation to liquidate any positions within a predetermined time or at a particular price. Live market coverage co-anchored from Hong Kong and New York. Trend Capital also compensates Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S) for its clients introduced to the Trend Macro Funds. Margin requirements. 1. was convicted of, or pled guilty or nolo contendere (no contest) to (a) any felony; (b) a misdemeanor that involved investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses; 2. is the named subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses; 3. was found to have been involved in a violation of an investmentrelated statute or regulation; or. . 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. 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. As a result, the Funds may suffer losses if it invests in equity instruments of issuers whose performance diverges from Trend Capitals expectations or if equity markets generally move in a single direction and the Funds has not hedged against such a general move. Disclose the date as of which you calculated the amounts. 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. Trend . In periods of rising commodity prices, such instruments may rise at a faster rate; and conversely, in times of falling commodity prices, such instruments may suffer a greater price decline. Explain that clients have the option to purchase investment products that you recommend through other brokers or agents that are not affiliated with you.Not applicable. The buyer of a put option assumes the risk of losing its entire investment in the put option. 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. Trend Capital has broad latitude with respect to the management of the Funds risk parameters. Secondly, from the point of view of speculators, the deposit requirements in the futures market are less onerous than margin requirements in the securities market. For documentation purposes, Trend Capital will always provide the date of the last annual update of the Brochure. In addition, the Funds will have 15 the authority to borrow money for cash management purposes and to meet withdrawals that would otherwise result in the premature liquidation of their investments. Ashburn Market Trends; Ashburn, VA, Summary. For purposes of this Item, economic benefits include any sales awards or other prizes. 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. 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. Before joining Tudor, he was a Portfolio Manager at Oppenheimer Funds with oversight of the international fixed income business. Commodity-Related Instruments. Although Trend Capitals investment advice is generally limited to these types of investments, it has a broad and flexible investment authority. Some non-U.S. markets have a higher potential for price volatility and relative. 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. 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. 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 production and marketing of commodities may be affected by actions and changes in governments. State whether these reports are written. A copy of the Firms Allocation Policy can be obtained by contacting Trend Capital. The Funds receive or pay, as the case may be, only the net amount of the two payments. The relevant offering documents contain a detailed description of applicable fees. In this episode of the Tony Robbins Podcast, you will hear from Ashwin Vasan, CIO of macro hedge fund Trend Capital.Prior to starting Trend Capital in 2011, Ashwin helped to build a variety of large multi-million dollar businesses including Shumway Capital Partners, Tudor Investment Corporation, Oppenheimer Funds and Citibank. 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. Ashburn. 2. 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. Explain whether clients may impose restrictions on investing in certain securities or types of securities. 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. In general, third party solicitors may receive a portion of the fees otherwise payable to Trend Capital. Explain whether (and, if so, how) you tailor your advisory services to the individual needs of clients. 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. 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 Opportunities GP LLC is the general partner of the Opportunities Onshore and Class M Shareholder of the Opportunities Master. 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. These instruments carry a higher risk that the issuer will be unable to pay principal and interest when due. This requires different skills and techniques than predicting changes in the price of individual stocks. The Funds may engage in swap transactions. It should be noted that the fact that a Funds general partner (or other Trend Capital affiliate)receives performance-based compensation creates a potential conflict of interest in that it may create an incentive for Trend Capital to effectuate larger and riskier transactions than would be the case in the absence of such form of compensation. If you permit a client to direct brokerage, describe your practice. 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. 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. View Ashwin's Email (It's Free) 5 free lookups per month. Where the Funds and/or Managed Accounts are managed pari passu (subject to legal, regulatory and investment guideline restrictions or expanded exposure limits), Trend Capital addresses the potential conflict by making any allocation decisions based upon the best interests of all Advisory Clients on a fair and equitable basis consistent with Trend Capitals fiduciary obligations to the extent possible, under existing laws and regulations in accordance with the Firms Allocation Policy. Such intervention is often intended to influence prices directly. Currency swaps involve the exchange of cash flows on a notional amount of two or more currencies based on their relative future values. Describe the types of clients to whom you generally provide investment advice, such as individuals, trusts, investment companies, or pension plans. If you have any questions about the contents of this Brochure, please contactBrian Barry at 561-617-5086 or by email at [email protected]. The Funds may trade forward contracts. The Funds trade in different markets and different kinds of instrument types. 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. TREND CAPITAL GP LLC; TREND CAPITAL GAUCHO GP . Trend Capitals principal owner is Ashwin Vasan. The minimum and additional subscription amounts are reduced for each investor introduced to one of the Trend Macro Funds by Merrill Lynch. Generally, obligors tend to prepay their fixed 17 rate obligations when prevailing interest rates fall below the coupon rates on their obligations. 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. Ashwin is Chief Investment Officer and has served as Chief Investment Officer since 05/01/2011. Each Fund is not limited as to the amount of capital or exposure which may be committed to any one issuer, industry, sector, strategy, country or geographic region. Qualifications of the independent public accountant and any accompanying independent public accountants report must conform to Article 2 of SEC Regulation S-X. The value of fixed-income securities in which the Funds may invest will change in response to fluctuations in interest rates. Advisory Clients may be deemed to be paying for research and other services with soft or commission dollars. 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. If the method of analysis or strategy involves significant or unusual risks, discuss these risks in detail. Similar elements of risk arise in the event of the bankruptcy or insolvency of the buyer. Should the financial instruments pledged to lenders to secure the Funds margin accounts decline in value, the Funds could be subject to a margin call, pursuant to which the Funds must either deposit additional funds or financial instruments with the lender or suffer mandatory liquidation of the pledged financial instruments to compensate for the decline in value. In addition, daily limits on price fluctuations and speculative position limits on exchanges on which the Funds may conduct their transactions in derivatives may prevent profitable 25 liquidation of positions, subjecting the Funds to the potential of greater losses. The Advisory Board provides advice and counsel to Trend Capital and its affiliate general partner entity, Trend Capital GP LLC, on various matters, including assisting in the identification and resolution of any actual or potential conflicts of interest involving Trend Capital and/or any of its affiliates with respect to Trend Macro Fund. Trend Capital LLC is a Connecticut Foreign Limited-Liability Company filed on May 13, 2011. The same individuals serve as directors for the ERISA Offshore, Opportunities Offshore, and Opportunities Master. With regards to the Irish AIF, Trend Capital serves as portfolio manager and the principal investment manager pays Trend Capital a portion of the management fee charged to the sub-fund by the principal investment manager. Founder and cio at Trend Capital Management LP Delray Beach . 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. 1. 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. Find more info on AllPeople about Ashwin Vasan and Trend Capital Management LP, as well as people who work for similar businesses nearby, colleagues for other branches, and more people with a similar name. 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. Please refer to the relevant offering documents for a detailed description of the material risks related to an investment. 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. ashwin has 1 job listed on their profile. Exchanges. Describe generally how you address conflicts that arise. View limitations & usage restriction, Breaking news, analysis and cutting edge commentary from our award-winning team and leading industry voices, The latest news and other relevant content from selected Citywire partners, Alternative UCITS - Emerging Market Equity Including Asia. Such 3 investment objectives, fee arrangements and terms are individually negotiated and it should be noted that any such Managed Account relationships are generally subject to significant account minimums. With respect to the Opportunities Funds, the minimum initial and additional investment amounts depend on the particular SP in which an investor subscribes. 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. The market for these instruments may also be limited and some companies may limit the intervals for redemptions. Prior to Shumway, Mr. Vasan was a Partner and Portfolio Manager at Tudor Investment Corporation from 1999 to 2009. Disclose whether you use soft dollar benefits to service all of your clients accounts or only those that paid for the benefits. Similarly, floating rate issuers and borrowers tend to prepay their obligations when spreads narrow. If your advisory firm or a management person has been involved in one of these events, you must disclose it under this Item for ten years following the date of the event, unless (1) the event was resolved in your or the management persons favor, or was reversed, suspended or vacated, or (2) you have rebutted the presumption of materiality to determine that the event is not material (see Note below). Executive Officer Director Promoter Clarification of Response (if Necessary): Manager of the General Partner Relationship: Executive Officer Director X Promoter Clarification of Response (if Necessary): Investment Manager 4. Risk Disclosure. Ashwin has. It is possible, in a bankruptcy or liquidation scenario, that the Funds may not be able to substantiate its interest in the underlying financial instruments. The Funds and the Managed Accounts have broad and flexible investment authority. Governments from time to time intervene, directly and by regulation, in certain markets, particularly those dealing in precious metals. Blue Sky Digital Outdoor Advertising Fund Fund Data, Sarasin Ie Global Equity Opportunities (Usd) Fund Data, Themelios Ventures Ii-A, L.P. Fund Data. 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 are an SEC-registered adviser, briefly describe your code of ethics adopted pursuant to SEC rule 204A-1 or similar state rules. 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