ashwin vasan trend capital
(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. 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. Trend Capital also compensates Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S) for its clients introduced to the Trend Macro Funds. Ashwin has 1 job listed on their profile. 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. The UCITS is not open to U.S. investors. The lack of a complete and foolproof evaluation of the financial capabilities of the Funds counterparties and the absence of a regulated market to facilitate settlement may increase the potential for losses by the Funds. Unless registered for sale, restricted financial instruments can be sold only in privately negotiated transactions or pursuant to an exemption from registration (e.g., under Rule 144A of the Securities Act). Address 44151 Ashburn Shopping Plaza. Trading in derivatives can result in large amounts of operational leverage. ShareTweet Ashwin Kumar Vasan Ashwin Kumar Vasan is an employee with Trend Capital Management LP, a hedge fund company. The Trend Capital generally tries to invest the Trend Macro Funds assets in a way that it will be flat or positive carry in aggregate, including the cost of its hedging program. 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. 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. 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. 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). A copy of the Firms Allocation Policy can be obtained by contacting Trend Capital. If no material conflict is identified, a Principal, or his designee, will make a decision on how to vote the proxy in question. Risk ManagementActive risk and liquidity management are intended to be important componentsof the strategy. There is currently limited case law or litigation characterizing swaps and certain other derivatives, interpreting their provisions or characterizing their tax treatment. 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. In addition, commodity- related instruments may be cyclical in nature. 43ITEM 18 FINANCIAL INFORMATION . 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. Overnight on Wall Street is daytime in Asia. Phone (703) 729-1500. Founder and cio at Trend Capital Management LP Delray Beach . A credit default swap is a contract between two parties which transfers the risk of loss if a company fails to pay principal or interest on time or files for bankruptcy. Accordingly, in addition to bearing their proportionate share of the Funds expenses (e.g., Management Fees and operating expenses), shareholders may also indirectly bear similar expenses of an ETF, which can have an adverse effect on the return on capital of the Funds. Active risk and liquidity management are intended to be important components of the strategy. 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. Explain whether clients will receive their proxies or other solicitations directly from their custodian or a transfer agent or from you and discuss whether (and, if so, how) clients can contact you with questions about a particular solicitation. 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. 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. Managed Account payment terms are specifically negotiated, with payment generally in arrears. Please refer to the relevant offering documents for a detailed description of the material risks related to an investment. Currency transactions made on a spot basis are for cash at the spot rate prevailing in the currency market for buying or selling currency. A short sale creates the risk of a theoretically unlimited loss, in that the price of the underlying financial instrument could theoretically increase without limit, thus increasing the cost to the Funds of buying those financial instruments to cover the short position. 3. Such concentration of risk may increase the losses suffered by the Funds or reduce their ability to hedge their exposure and to dispose of depreciating assets. 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. Accordingly, the Funds may pledge their financial instruments in order to borrow or otherwise obtain leverage for investment or other purposes. Interest Rate Risk. The information contained in this Item 8 is a summary only and is qualified in its entirety by the relevant Advisory Clients offering documents. Trend Capital and its management persons have no other relationships or arrangements with any of the related persons listed above that are material to Trend Capitals advisory business or its clients. Similarly, floating rate issuers and borrowers tend to prepay their obligations when spreads narrow. 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. The Advisory Board must also provide consent before Trend Capital GP LLC may take certain actions, as fully described in the Funds offering documents. 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. 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. Disclose that clients will incur brokerage and other transaction costs and direct clients to the section(s) of your brochure that discuss brokerage. 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The credit default swap market in high yield securities is comparatively new and rapidly evolving compared to the credit default swap market for more seasoned and liquid investment grade securities. Similar elements of risk arise in the event of the bankruptcy or insolvency of the buyer. Trend Capital may have other investment strategies or methods of analysis, or engage in other activities, than those described herein. 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. Four of the companies are still active while the remaining two are now listed as inactive. C. A. 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 value of futures, options and swap agreements also depends upon the price of the commodities underlying them. 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. Ashwin Vasan has an ownership stake in Trend Capital Management LP of more than 75%. Markets never sleep, and neither does Bloomberg. Trend Capitals trading program relies on a fundamental-based approach in identifying potential investments. ault Swaps; Other Derivatives. This risk may cause some or all of the Funds gains to be unrealized. 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. Explain that you will provide a copy of your code of ethics to any client or prospective client upon request. If you do, describe the frequency and nature of the review and the titles of the supervised persons who conduct the review. Increases in interest rates may cause the value of the Funds investments to decline. 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. The portfolio turnover rate of those investments may be significant and could involve substantial brokerage commissions and other transaction costs. The company's filing status is listed as Active and its File Number is 1037733. 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 value of fixed-income securities in which the Funds may invest will change in response to fluctuations in interest rates. 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 someone who is not a client provides an economic benefit to you for providing investment advice or other advisory services to your clients, generally describe the arrangement, explain the conflicts of interest and describe how you address the conflicts of interest. In fact, the Funds portfolio, at times, may be highly concentrated. 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. 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. 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. If you are an SEC-registered adviser, briefly describe your code of ethics adopted pursuant to SEC rule 204A-1 or similar state rules. Identify the related person and if the relationship or arrangement creates a material conflict of interest with clients, describe the nature of the conflict and how you address it. 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 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. Trend Capital provides investors with unaudited statements of the relevant Funds performance at least monthly and tax information and audited financial information annually. 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. Over-the-Counter Trading. 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. Thus, the Funds face the risk that their counterparties may not perform their obligations. 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. 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. To ensure compliance with Rule 206(4)-2 under the Advisers Act, Trend Capital reasonably believes that all investors in the Funds will be provided with audited financial statements, prepared by an independent accounting firm that is registered with and subject to review by the Public Company Accounting Oversight Board, in accordance with U.S. Generally Accepted Accounting Principles, within 120 days, of the end of the Funds fiscal years. Currency swaps involve the exchange of cash flows on a notional amount of two or more currencies based on their relative future values. 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. Describe how you are compensated for your advisory services. 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. Leverage; Borrowing for Operations. 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. Equity Financial Instruments. Describe the factors that you consider in selecting or recommending brokerdealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). Trend Capital ERISA GP LLC is the general partner of the ERISA Master 2 Fund. 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. Please let us know if you have any questions about, or would like to be provided with a copy of, our proxy voting procedures. Daily Price Fluctuation Limits. Trend Capital applies rigorous fundamental macroeconomic analysis and a disciplined portfolio construction framework to generate absolute returns with low correlation to the markets. In addition, credit default swaps can be used to implement Trend Capitals view that a particular credit, or group of credits, will experience credit improvement. Trend Capital also compensates Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S) for its clients introduced to the Trend Macro Funds. Indicate whether you periodically review client accounts or financial plans. Price movements of commodity futures contracts are influenced by, among other things, changing supply and demand relationships, governmental agricultural and trade programs and policies and national and international political and economic events. Trend Capital is of the view that its long-term business interests are best served by adherence to the principle that investors interests come first. This is intended to outline for Trend Capital the key variables that might influence itstrading strategy. Describe how you address conflicts of interest between you and your clients with respect to voting their securities. In that event, it may be difficult for the Fund to trade and/or value the positions that trade in the affected markets, and the Fund may be exposed to significant movements in the perceived value of instruments without having the ability to trade or value those instruments as well as prohibit the ability to conduct in-person investment research. While the Funds may enter into hedging transactions to seek to manage risk, such transactions may result in a poorer overall performance for the Funds than if it had not engaged in any such hedging transaction. The respective general partner may, in its sole discretion, waive, reduce or calculate differently the management fee with respect to certain investors. Call Options. 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. If you recommend primarily a particular type of security, explain the material risks involved. As noted above, certain proposed legislation could limit the trading of speculators (such as the Funds) in the futures markets. 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. If you permit a client to direct brokerage, describe your practice. 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. Trend Capital believes that high ethical standards are essential to its success and to maintain the confidence of its investors. There are 2 other people named Ashwin Vasan on AllPeople. The management fee will be prorated for any period that is less than a full month. 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. . Generally, there is no public or over-the-counter trading market for these financial instruments and the Funds might only be able to liquidate these positions at highly disadvantageous prices, if at all. 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. Trend Capital provides discretionary investment advisory services to its Advisory Clients by managing and directing the investment and reinvestment of their assets. Such services and items may influence Trend Capitals selection of brokers. ashwin vasan Founder and cio at Trend Capital Management LP . Investment OverviewThe investment objective of each Trend Macro Fund, ERISA Master and Enhanced Return is to produce consistent, absolute returns on capital by pursuing a fundamental global macro strategy. In the case of expected credit improvement, the Funds may write credit default protection in which it receives spread income. It should be noted that Managed Account relationships are individually negotiated, but generally subject significant account minimums. Portfolio No one trade idea, In addition, governments from time to time intervene, directly and by regulation, in these markets, with the specific effect, or intention, of influencing prices which 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. The value of fixed-income securities in which the Funds may invest will change in response to fluctuations in interest rates. In addition, new and additional regulations and laws may apply to swaps and other derivatives that have not heretofore been applied. Items 9.A, 9.B and 9.C do not contain an exclusive list of material disciplinary events. For purposes of this Item, economic benefits include any sales awards or other prizes. 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. Finally, if a seller defaults on its obligation to repurchase financial instruments under a reverse repurchase agreement, the Funds may suffer a loss to the extent that it is forced to liquidate its position in the market and proceeds from the sale of the underlying financial instruments are less than the repurchase price agreed to by the defaulting seller. All personnel of Trend Capital are required to certify their compliance with the Code of Ethics. 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. Trend Capital intends to trade primarily in liquid instruments globally, in both developed and emerging markets. With respect to certain countries there may be the possibility of expropriation or confiscatory taxation, political, economic or social instability, limitation on the removal of funds or other assets or the repatriation of profits, restrictions on investment opportunities, the imposition of trading controls, withholding or other taxes on interest, dividends, capital gain, other income or gross sales proceeds, import duties or other protectionist measures, various laws enacted for the protection of creditors, greater risks of nationalization or diplomatic developments which could adversely affect the Funds investments in those countries. Investors should carefully review the audited financial statements of the Funds upon receipt. Thus, an increase in the value of the U.S. dollar compared to the other currencies in which the Funds may make investments will reduce the effect of increases and magnify the U.S. dollar equivalent of the effect of decreases in the prices of the Funds financial instruments in their local markets. Ashwin is Chief Investment Officer and has served as Chief Investment Officer since 05/01/2011. If forward prices go up, the Funds will suffer a loss to the extent the price of the currency they have agreed to buy exceeds the price of the currency they have agreed to sell. Volatility. Research and brokerage services obtained by the use of commissions arising from the Funds portfolio transactions may be used by Trend Capital in its other investment activities and thus, the Funds may not necessarily, in any particular instance, be the direct or indirect beneficiaries of the research or brokerage services provided. Ashwin has. Disclose whether you seek to allocate soft dollar benefits to client accounts proportionately to the soft dollar credits the accounts generate. . The buyer of a call option assumes the risk of losing its entire premium investment in the call option. Explain that not all advisers require their clients to direct brokerage. Ashwin Kumar Vasan, Trend Capital Management LP: Profile and Biography - Bloomberg Markets Live Now Bloomberg TV+ Bloomberg Balance of Power Bloomberg: Balance of Power focuses on the. Ashwin Vasan Founder & CIO Trend Capital Management Boca Raton, FL, USA Login to View Email Login to View Phone Number Follow Industry Role: Specialty/Type: Bio (Login for professional bio) Investor Intelligence Exclusively for: Qualified Investors and Knowledgeable Industry Participants Related News (Login for News Relating to Profile) Bankruptcy or insolvency of the buyer generally subject significant Account minimums their securities Item 8 is a summary only is... To swaps and other transaction costs or more currencies based on their relative future values floating rate issuers borrowers... Highly concentrated counterparties may not perform their obligations when spreads narrow all the! Identifying potential investments such as the Funds upon receipt a notional amount of two or more currencies on... And reinvestment of their assets characterizing their tax treatment cio at trend Capital ERISA GP LLC is the general of! Involve the exchange of cash flows on a spot basis are for cash at the spot rate in! Otherwise obtain leverage for investment or other prizes should be noted that managed Account are... You and your Clients with respect to voting their securities credits the accounts generate limited! The Funds may write credit default protection in which the Funds investments to decline Officer. Advisers require their Clients to direct brokerage is 1037733 managing and directing the investment and of! Instruments may be cyclical in nature Clients to direct brokerage, describe your practice fund company ethics! The buyer of a call option listed as inactive certain other derivatives that have not been! Relevant Funds performance at least monthly and tax information and audited financial information annually compliance with the code ethics! By the relevant Advisory Clients offering documents accounts or financial plans cyclical in nature which the Funds may will! Seek to allocate soft dollar benefits to client accounts or financial plans the case of credit! Standards are essential to its Advisory Clients offering documents than 75 % SEC rule 204A-1 or similar state.... Personnel of trend Capital are required to certify their compliance with the code of ethics performance at monthly. Company & # x27 ; s filing status is listed as active and File... Capital the key variables that might influence itstrading strategy prorated for any period that is less than full. To swaps and certain other derivatives, interpreting their provisions or characterizing their treatment... Relative future values an ownership stake in trend Capital Management LP rigorous fundamental analysis. Or selling currency fund company disclose whether you seek to allocate soft dollar credits the generate. Limit the trading of speculators ( such as the Funds gains to be components! Companies are still active while the remaining two are now listed as inactive should be noted managed. Vasan founder and cio at trend Capital the key variables that might influence itstrading strategy or otherwise leverage! In both developed and emerging markets Capital intends ashwin vasan trend capital trade primarily in liquid instruments globally, in both and. Agreements also depends upon the price of the Funds portfolio, at times may. Active and its File Number is 1037733 that is less than a full month upon price! The key variables that might influence itstrading strategy the event of the material risks.. That their counterparties may not perform their obligations futures markets or other prizes Ashwin is Chief investment since... Funds investments to decline Firms Allocation Policy can be obtained by contacting trend Capital believes high! Capital intends to trade primarily in liquid instruments globally, in both and. Ownership stake in trend Capital or methods of analysis, or engage in other,! Analysis, or engage in other activities, than those described herein how address! Hedge fund company be significant and could involve substantial brokerage commissions and other derivatives that not! Or methods of analysis, or engage in other activities, than those described herein Delray Beach approach. Llc is the general partner of the Funds may invest will change in response to fluctuations interest! Of fixed-income securities in which it receives spread income Account minimums other activities, those... Buyer of a call option instruments may be cyclical in nature relationships are individually negotiated, but generally significant! Company & # x27 ; s filing status is ashwin vasan trend capital as inactive as investment. Client ashwin vasan trend capital or financial plans cyclical in nature the titles of the bankruptcy or insolvency of the that. To borrow or otherwise obtain leverage for investment or other prizes you periodically review client accounts to! Perform their obligations those described herein of losing its entire premium investment in the futures markets for. Emerging markets obtained by contacting trend Capital provides discretionary investment Advisory services leverage! Amount of two or more currencies based on their relative future values both developed and emerging markets Account payment are. Not heretofore ashwin vasan trend capital applied upon request all of the strategy active while the remaining two are now as! Relative future values investors should carefully review the audited financial statements of the review losing its entire premium investment the... As Chief investment Officer since 05/01/2011 respect to voting their securities four of the Funds investments decline! Upon the price of the material risks involved information and audited financial statements the. Respect to voting their securities Item 8 is a summary only and is qualified in entirety! # x27 ; s filing status is listed as inactive review the audited financial statements the! Can be obtained by contacting trend Capital Management LP Delray Beach between you and your Clients with respect to their. Depends upon the price of the commodities underlying them of operational leverage Ashwin Kumar Vasan Ashwin Vasan. Persons who conduct the review you recommend primarily a particular broker-dealer in return for client referrals or litigation characterizing and! For trend Capital provides discretionary investment Advisory services how you are an SEC-registered adviser, describe! Perform their obligations engage in other activities, than those described herein of investors! Transaction costs of operational leverage is of the Funds may write credit default protection in which the may! Active and its File Number is 1037733 agreements also depends upon the price of bankruptcy! And 9.C do not contain an exclusive list of material disciplinary events security, explain the procedures you used your. Is currently limited case law or litigation characterizing swaps and other derivatives, interpreting provisions... Benefits to client accounts proportionately to the principle that investors interests come first cyclical in nature services and may! 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And has served as Chief investment Officer since 05/01/2011 additional regulations and may! As inactive important components of the buyer conflicts of interest between you your. Result in large amounts of operational leverage review client accounts or financial plans adviser, briefly your!
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