In addition, significant disparities may exist between bid and asked prices for derivatives that are not traded on an exchange. Short selling involves selling financial instruments which are not owned by the short seller and borrowing them for delivery to the purchaser, with an obligation to replace the borrowed financial instruments at a later date. The Funds may invest in exchange traded funds 24 (ETFs), which are shares of publicly-traded unit investment trusts, open-end funds, or depository receipts that seek to track the performance and dividend yield of specific indexes or companies in related industries. commission cost or spread.Trend Capital is authorized to determine the broker or dealer to be used for each financial instruments transaction for its Advisory Clients although certain Managed Accounts must approve the counterparties and negotiate the trading agreements to establish such relationship. In sizing trades, Trend Capital emphasizes liquidity and generally expects that a substantial portion of the positions could be liquidated in a short period of time under normal market conditions and any remaining positions could be liquidated within a month under normal market conditions. 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. This website uses cookies to improve your experience. As of the date of this Brochure, the qualified custodians utilized by Trend Capital for the Funds are: Credit Suisse Securities (USA) LLC11 Madison AvenueNew York, NY 10010, JP Morgan Chase Bank NA270 Park AvenueNew York, NY 10017, J.P. Morgan Securities LLC383 Madison AvenueNew York, New York 10179, Northern Trust International Banking Corporation3 Second StreetHarborside Financial Center Plaza 10Suite 1401Jersey City, NJ 07311-3988, The Bank of New York Mellon101 Barclay Street, 3rd FloorNew York, NY 10007. Discuss whether and under what conditions you aggregate the purchase or sale of securities for various client accounts. 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. These transactions are not exchange-traded so that no clearinghouse or exchange stands ready to meet the obligations of the contract. Trend Capital applies rigorous fundamental macroeconomic analysis and a disciplined portfolio construction framework to generate absolute returns with low correlation to the markets. The Funds also could experience losses if derivatives are poorly correlated with its other investments. All Rights Reserved. The management fee is payable without regard to the overall success or income earned by the Funds and therefore creates an incentive on the part of Trend Capital to raise or otherwise increase assets under management to a higher level than would be the case if Trend Capital were receiving a lower or no management fee. Changes in liquidity may result in significant, rapid and unpredictable changes in the prices for derivatives. The information contained in this Item 5 is a summary only and is qualified in its entirety by the relevant offering documents for each Advisory Client. If no material conflict is identified, a Principal, or his designee, will make a decision on how to vote the proxy in question. Ashwin Vasan Email Founder and Chief Information Officer @ Trend Capital Management Preparing Ashwin profile View Ashwin's Email . The UCITS is not open to U.S. investors. 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. If you or a related person recommends securities to clients, or buys or sells securities for client accounts, at or about the same time that you or a related person buys or sells the same securities for your own (or the related persons own) account, describe your practice and discuss the conflicts of interest it presents. 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. Prospective investors are provided with an offering memorandum prior to their investment and are encouraged to carefully review the offering memorandum, along with all other relevant offering documents and to be sure that the proposed investment is consistent with their investment goals and tolerance for risk. Citywire ranks and rates all portfolio managers running mutual funds without charge. The prices and trading volumes for certain commodities can be volatile. 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. Margin requirements. 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. TCM may not transact business in states where it is not appropriately registered unless TCM is excluded or exempted from registration in those states. Trend Capital Advisers LP is a Delaware limited partnership that was formed in February 2017 to advise certain managed accounts, the Opportunities Funds and their SPs. These transactions are not subject to exchange rules. 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). 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. If you charge advisory fees in addition to commissions or markups, disclose whether you reduce your advisory fees to offset the commissions or markups.Not applicable. Trading instructions may have to be modified and the Funds positions may need to be liquidated to avoid exceeding these limits. If the Funds engage in an offsetting transaction, it will incur a gain or loss to the extent that there has been movement in forward currency contract prices. This Foreign Limited Liability company is located at 1800 N. MILITARY TRAIL, SUITE 475, BOCA RATON, FL, 33431, US and has been running for seven years. In addition, many nonU.S. Credit Default Swaps; Other Derivatives. However, ETF shareholders are generally subject to the same risk as holders of the underlying securities they are designed to track. To the extent any Managed Account applies a more stringent standard, Trend Capital will comply with the applicable restrictions. Sovereign Debt may include securities that Trend Capital believes are likely to be included in restructurings of the external debt obligations of the issuer in question. 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. 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. 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. Describe the methods of analysis and investment strategies you use in formulating investment advice or managing assets. Such intervention is often intended to influence prices directly. 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. Ashwin Vasan has an ownership stake in Trend Capital Management LP of more than 75%. 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. Ashwin Vasan Software Engineer at Amazon Web Services (AWS) Seattle, Washington, United States500+ connections Join to connect University of Colorado Boulder Activity I had a conversation with. 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. 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. 2022 Trend Capital Management LP, All Rights Reserved. These indexes may either be broad-based, sector-based, or international. 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. The Funds may trade on exchanges or markets located outside the U.S. Trading on such exchanges or markets is not regulated by the Securities and Exchange Commission (the SEC) and the Commodity Futures Trading Commission (the CFTC) and may, therefore, be subject to more risks than trading on U.S. exchanges, such as the risks of exchange controls, expropriation, burdensome taxation, moratoria and political or diplomatic events. 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. Phone (703) 729-1500. Restricted financial instruments may involve a high degree of business and financial risk which may result in substantial losses. Search our database of over 100 million company and executive profiles. There is also less regulation, generally, of the markets in non-U.S. countries than there is in the United States. Also, the Funds may invest in financial instruments, such as structured products, derivatives and other types of unregistered financial instruments. Generally, obligors tend to prepay their fixed 17 rate obligations when prevailing interest rates fall below the coupon rates on their obligations. C. A. The Funds may experience increased interest rate risk to the extent they invest, if at all, in lower rated instruments, debt instruments with longer maturities, debt instruments paying no interest (such as zero coupon debt instruments) or debt instruments paying non-cash interest in the form of other debt instruments. The Funds may invest in financial instruments denominated in currencies other than the U.S. dollar or in financial instruments which are determined with references to currencies other than 21 the U.S. dollar. As such, there are many factors upon which market participants may have divergent views. The value of futures, options and swap agreements also depends upon the price of the commodities underlying them. The effect of the use of leverage by the Funds in a market that moves adversely to its investments could result in substantial losses to the Funds, which would be greater than if the Funds were not leveraged. The limitation of potential (and actual) loss in any period of time is pivotal to the investment framework of the Trend Macro Fund or Enhanced Return. If you or any of your supervised persons accepts compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds, disclose this fact and respond to Items 5.E.1, 5.E.2, 5.E.3 and 5.E.4. Explain whether clients may impose restrictions on investing in certain securities or types of securities. Trend Macro Funds and ERISA Funds:Trend Capital is paid by the respective master fund a monthly management fee computed on the value of the Partnerships capital accounts/net asset value of the Fund. Conversely, when interest rates rise, the value of fixed-income instruments generally can be expected to decline. If you or any of your management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities, disclose this fact. 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. 1. However, manager ratings logos and full ratings performance data are only shown for groups that license the ratings for marketing purposes. 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. After the end of March 2020, Managed Account relationshipswill include an Irish UCITS and an Irish Alternative Investment Fund (AIF). Commodity futures trading is highly speculative. An incentive fee is also received from the Managed Accounts and is payable to Trend Capital annually, subject to a loss carryforward provision. If you hold yourself out as specializing in a particular type of advisory service, such as financial planning, quantitative analysis, or market timing, explain the nature of that service in greater detail. Unlisted Financial Instrument Swaps and other derivatives instruments are subject to legal, tax and market uncertainties that present risks in entering into these derivatives. Trend Capital Management LP is a discretionary global macro hedge fund manager. Describe whether you deduct fees from clients assets or bill clients for fees incurred. The Opportunities Offshore and Opportunities Onshore will each create a separate SP for each investment opportunity it offers to investors, each of which will invest all of its investable assets in a corresponding SP of the Opportunities Master Fund. The Opportunities Master Fund SPs invest in and trade securities and other financial instruments using investment techniques with risk characteristics, including risks of the debt and equity markets, the risks of borrowings and short sales, the potential illiquidity of securities and other financial instruments and the risk of loss from counterparty defaults. 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. Founder and cio at Trend Capital Management LP Delray Beach, FL. Location. View Ashwin Vasan's profile on LinkedIn, the world's largest professional community. 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. 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. Ashburn Market Trends; Ashburn, VA, Summary. 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. All personnel of Trend Capital are required to certify their compliance with the Code of Ethics. Please see terms and conditions for restrictions on use of Citywire's Fund Manager database. 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. 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. As of this date, the Enhanced Return is the only SP and its investment strategy is summarized above. The adverse effects of prepayments may impact the Funds portfolio in two ways. 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 value of fixed-income securities in which the Funds may invest will change in response to fluctuations in interest rates. 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. 1. broker-dealer, municipal securities dealer, or government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or hedge fund, and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading advisor, 11. sponsor or syndicator of limited partnerships. Identification and exploitation of such trends involves significant uncertainties. The ability of an issuer to make payments on Sovereign Debt, the market value of such debt and the inclusion of Sovereign Debt in future restructurings may be affected by a number of other factors, including such issuers (i) balance of trade and access to international financing, cost of servicing such obligations, which may be affected by changes in international interest rates and (iii) level of international currency reserves, which may affect the amount of foreign exchange available 22 for external debt payments. If you permit a client to direct brokerage, describe your practice. Please refer to the relevant offering documents for a detailed description of the material risks related to an investment. If you have any . If you do, describe the frequency and nature of the review and the titles of the supervised persons who conduct the review. Trend Capital does not manage any Advisory Client assets on a non-discretionary basis. Trend Capital Opportunities GP LLC is the general partner of the Opportunities Onshore and Class M Shareholder of the Opportunities Master. 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. The fees related to the remaining Managed Accounts are individually negotiated. Live from New York and Hong Kong, bringing you the essential stories from the close of the U.S. markets to the open of trading across Asia. It 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. 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. Ashwin Vasan is the Founder and CIO of Trend Capital Management LP. 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. [1] [2] Vasan is also a public health professor and was most recently the president and CEO of Fountain House, a national mental health nonprofit. 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. In addition, brokers may provide other services that are beneficial to Trend Capital, but not necessarily beneficial to the Funds, including, without limitation, capital introduction, marketing assistance, consulting with respect to technology, operations or equipment and other services or items. Describe how you are compensated for your advisory services. Once Trend Capital has identified a trend, Trend Capital typically constructs macroeconomic models intended to quantify the drivers of that trend. Management fees from the Managed Accounts are payable monthly in arrears. Dun & Bradstreet Data last . 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. A forward currency contract, which involves an obligation to purchase or sell a specific currency at a future date at a price set at the time of the contract, reduces the Funds exposure with respect to their investment to changes in the value of the currency it will deliver and increases its exposure to changes in the value of the currency it will receive for the duration of the contract. Trend Capital compensates Union Bancaire Prive, UBP SA (UBP) to solicit non-U.S. investors in designated jurisdictions for the Trend Macro Offshore. Trend Capital also provides discretionary investment advisory services to three (3) additional accounts, as either the investment adviser or portfolio manager. View company leaders and background information for Trend Capital Management Lp. Derivative Financial Instruments and Instruments Generally. 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. 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. 100 W Putnam Ave Greenwich, CT 06830. Prices of currency contracts traded by the Funds are affected generally by relative interest rates, which in turn are influenced by a wide variety of complex and difficult to predict factors such as money supply and demand, balance of payments, inflation levels, fiscal policy and political and economic events. Stock Index Futures. Interests/Shares are sold only to qualified investors who are accredited investors under Rule 501 of Regulation D of the Securities Act of 1933, as amended, and qualified purchasers as such term is defined in Section 2(a)(51)of the Investment Company Act of 1940, as amended. Swap Transactions. 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 market prices, if any, for such financial instruments tend to be volatile and the Funds may not be able to sell them when it desires to do so or to realize what it perceives to be their fair value in the event of a sale. The minimum and additional subscription amounts are reduced for each investor introduced to one of the Trend Macro Funds by Merrill Lynch. 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. 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. Trend Capital acts as the investment manager for each of the Funds and investment adviser or designated portfolio manager to three (3) Managed Accounts, one of which is also structured as a private investment fund for clients of an unaffiliated alternative asset management firm. If you are an SEC-registered adviser, briefly describe your code of ethics adopted pursuant to SEC rule 204A-1 or similar state rules. 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. Exchange Traded Funds. T. The Funds may incur risks associated with the sale and purchase of put options. 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. During a single trading day, no trades may be executed at prices beyond the daily limit. Trend Capital may retain an independent third party to vote proxies in certain situations (including situations where a material conflict of interest is identified). Trend . Trend Capital GP LLC is the general partner of Trend Macro Onshore and Trend Macro Fund. These instruments may offer higher yields than do higher rated instruments, but generally involve greater price volatility. 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. 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 Firm has adopted and implemented a compliance program to monitor its Funds and managed accounts and mitigate any potential conflicts of interest. These actions could adversely affect the Funds operations and profitability. 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. 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. This risk may cause some or all of the Funds gains to be unrealized. Commodity-Related Instruments. a. View Ashwin Vasan's profile on LinkedIn, the world's largest professional community. If your clients either may or must pay your fees in advance, disclose this fact. 2. An inability to establish or maintain such relationships is likely to limit the Funds trading activities or their ability to engage in certain transactions, could result in losses and might prevent the Funds from trading at optimal rates and terms. As described in Item 12.A.1 above, brokers may provide other services that are beneficial to Trend Capital, but not necessarily beneficial to the Advisory Clients, including capital introduction. 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. The original discount approximates the total amount of interest the bonds will accrue and compound over the period until maturity or the first interest accrual date at a rate of interest reflecting the market rate of the security at the time of issuance. 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. During periods of economic or financial instability, commodity-related instruments may be subject to broad price fluctuations, reflecting volatility of energy and basic material prices and possible instability of supply of various commodities. The Funds will usually enter into swaps on a net basis (i.e., the two payment streams are netted out in a cash settlement on the payment date or dates specified in the agreement). The level of interest rates generally and the rates at which the Funds can borrow particularly, will affect the operating results of the Funds. 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. As described in Item 5.B above, each master funds general partner (or other Trend Capital affiliate) receives an incentive allocation, which is performance-based, and Trend Capital receives performancebased compensation for its services on behalf of the Managed Accounts, in each instance subject to a loss carryforward. 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. Ash lives in Boca Raton, Florida with his wife Mari and their two children. Prior to Shumway, Mr. Vasan was a Partner and Portfolio Manager at Tudor Investment Corporation from 1999 to 2009. Commodity-related instruments may also experience greater price fluctuations than the relevant commodity. Some non-U.S. markets have a higher potential for price volatility and relative. Ashwin Vasan is an economist with over 25 years of investment experience. In addition, the Funds may bear, along with other shareholders of an ETF, its pro rata portion of the ETFs expenses, including management fees. 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. . 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. 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. Explain the conflicts of interest that you or your supervised persons face by managing these accounts at the same time, including that you or your supervised persons have an incentive to favor accounts for which you or your supervised persons receive a performance-based fee and describe generally how you address these conflicts. Rather than meeting additional margin deposit requirements, market participants may close futures contracts through offsetting transactions that would distort the normal relationship between the index and futures markets. Explain the procedures you used during your last fiscal year to direct client transactions to a particular broker-dealer in return for client referrals. Ashwin Vasan ~ Background Report ~ Principal Excel Known Addresses for Trend Capital Management Lp. The Funds may invest in equities and equity derivatives. Trend Capital may use additional qualified custodians in the future, including custodians designated for specific transactions in foreign markets. Prospective investors must also execute a subscription agreement and, in the case of the Trend Capital sponsored Funds, limited partnership agreements (where applicable). Turnover. ETFs are also subject to certain additional risks, including, without limitation, the risk that their prices may not correlate perfectly with changes in the prices of the underlying securities they are designed to track and the risk of trading in an ETF halting due to market conditions or other reasons, based on the policies of the exchange upon which the ETF trades. A criminal or civil action in a domestic, foreign or military court of competent jurisdiction in which your firm or a management person. 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. Refer to Item 12 for further information. TREND CAPITAL LLC is an Active company incorporated on January 19, 2016 with the registered number M16000000511. Currency swaps involve the exchange of cash flows on a notional amount of two or more currencies based on their relative future values. Commodity exchanges and trading facilities limit fluctuations in certain commodity futures contract prices during a single day by regulations referred to as daily price fluctuation limits or daily limits. 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. Such investments experience greater volatility in market value due to changes in interest rates than debt obligations that provide for regular payments of interest. Securities Futures Contracts. For documentation purposes, Trend Capital will always provide the date of the last annual update of the Brochure. 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. 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. The frequency at which prepayments (including voluntary prepayments by the obligors and accelerations due to defaults) occur on fixed income instruments will be affected by a variety of factors including the prevailing level of interest rates and spreads as well as economic, demographic, tax, social, legal and other factors. Four of the companies are still active while the remaining two are now listed as inactive. The investment manager may also invest up to 10% of the applicable master funds net asset value (determined as of the date of the last purchase) in single-name corporate CDS and other credit securities. Lenders providing financing to the Funds can apply essentially discretionary margin, haircut, and financing and collateral valuation policies. Provide your fee schedule. Describe the content and indicate the frequency of regular reports you provide to clients regarding their accounts. If the seller becomes insolvent and subject to liquidation or reorganization under applicable bankruptcy or other laws, the Funds ability to dispose of the underlying financial instruments may be restricted. If you accept discretionary authority to manage securities accounts on behalf of clients, disclose this fact and describe any limitations clients may (or customarily do) place on this authority. Regardless, the Firm does not direct order flow for client referrals. Choose the right Crunchbase solution for you Start Your Free Trial 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. 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. 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. 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. Delray Beach, Florida, United States . Conversely, when interest rates rise, the value of fixed-income instruments generally can be expected to decline. Margin requirements for commodities trading are set by the individual commodity exchanges or other trading facility for each type of commodity contract based upon the perceived volatility of each type of contract. Equity Financial Instruments. 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. Market Disruption Events. If clients may select either method, disclose this fact. In the case of expected credit improvement, the Funds may write credit default protection in which it receives spread income. The production and marketing of commodities may be affected by actions and changes in governments. 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. Source. Swap transactions dependent upon credit events are priced incorporating many variables including the pricing and volatility of the common stock and potential loss upon default, among other factors. Volatility may also be caused by government intervention, direct and by regulation, in certain markets, particularly those in currencies, financial instruments, futures and options. The lack of evaluation and oversight of over-the-counter markets exposes the Funds to the risk that a counterparty will not settle a transaction in accordance with its terms and conditions because of a dispute over the terms of the contract (whether or not bona fide) or because of a credit or liquidity problem, thus causing the Funds to suffer a loss. With respect to the Opportunities Funds, the minimum initial and additional investment amounts depend on the particular SP in which an investor subscribes. 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. Describe generally how you address conflicts that arise. Possible Effects of Speculative Position Limits. 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. If you manage client assets, disclose the amount of client assets you manage discretionary basis and the amount of client assets you manage on a non- discretionary basis. Concentration of Investments. Disclose whether you seek to allocate soft dollar benefits to client accounts proportionately to the soft dollar credits the accounts generate. In particular, prepayments (at par) may limit the potential upside of many instruments to their principal or par amounts, whereas their corresponding hedges often have the potential for unlimited loss. Trend Capital also serves as a sub-adviser to certain investment vehicles that are not offered to United States investors and the Firm relies on the principal investment manager for those investment vehicles to provide updates regarding offering materials and disclosures in compliance with applicable laws. Describe how clients may obtain information from you about how you voted their securities. 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. In general, premium securities (securities whose market values exceed their principal or par amounts) are adversely affected by faster than anticipated prepayments and discount securities (securities whose principal or par amounts exceed their market values) are adversely affected by slower than anticipated prepayments. Price movements of derivative contracts are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments and national and international political and economic events and policies. If your advisory firm or a management person has been involved in 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). Leverage; Borrowing for Operations. These investments involve special risks not usually associated with investing in securities of U.S. companies or the Federal, state or local government. Securities futures contracts include both futures contracts on single stocks and futures contracts on narrow-based securities indices. b. Trend Capital provides discretionary investment advisory services to its Advisory Clients by managing and directing the investment and reinvestment of their assets. Leverage may take the form of, among other things, any of the financial instruments described herein, including, derivative instruments which are inherently leveraged and trading in products with embedded leverage such as options, short sales, swaps and forwards. Examples: (1) You or a related person, as principal, buys securities from (or sells securities to) your clients; (2) you or a related person acts as general partner in a partnership in which you solicit client investments; or (3) you or a related person acts as an investment adviser to an investment company that you recommend to clients. Relatively small futures positions have the potential to significantly erode or erase the Funds gains in other investments. Derivatives typically allow an investor to hedge or speculate upon the price movements of a particular security, financial benchmark or index at a fraction of the cost of acquiring, borrowing or selling short the underlying asset. Similar elements of risk arise in the event of the bankruptcy or insolvency of the buyer. 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. A stock index fluctuates with changes in the market values of the stocks included in the index. Ashwin is Chief Investment Officer and has served as Chief Investment Officer since 05/01/2011. 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. 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. The Funds expect to borrow or utilize other forms of leverage (on a secured or unsecured basis) for any purpose, including to increase investment capacity, cover operating expenses, or for clearance of transactions. Market disruption events could also affect the principal prime brokers that carry and clear the Funds trades and positions. . Despite this, the pace at which the Trend Capital will actually liquidate any position will take into account its assessment of the potential price impact. All fees charged to the sub-fund are disclosed in the Prospectus and Prospectus Supplement for the sub-fund. 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. The market for many derivatives is, or suddenly can become, illiquid. Sovereign Debt. 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. IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE 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. Notwithstanding the foregoing, in Trend Macro Offshore, ERISA Offshore or Opportunities Offshore, the minimum initial investment may never be less than the then-current minimum as prescribed by the Mutual Funds Law (as amended) of the Cayman Islands (currently $100,000USD). No advisory board has been established for Funds other than Trend Macro Fund. First, all participants in the futures market are subject to margin deposit and maintenance requirements. Combined with stop losses, such hedges are intended to protect the portfolio in the event trades move meaningfully against the direction the Trend Capital anticipated when making the investment. Trend Capital Management, LLC (TCM) is a Registered Investment Advisor in the states of Kansas and Missouri. In addition, as referenced in Item 2 above, the offering documents for the Funds disclose specific trade error policies. The portfolio turnover rate of those investments may be significant and could involve substantial brokerage commissions and other transaction costs. 29 Aug 2019 by Joel St.Germain. r-dealer might charge or apply.If Trend Capital concludes that the commissions charged by a broker or the 36 spreads applied by a dealer are reasonable in relation to the quality of services rendered by such broker or dealer (including, without limitation, the value of the brokerage and research products or services provided by such broker or dealer), the Advisory Clients may pay commissions to or be subject to spreads applied by such broker-dealer in an amount greater than the amount another broker-dealer might charge or apply. Ashwin has 1 job listed on their profile. 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. Describe whether (and, if so, how) your clients can direct your vote in a particular solicitation. 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. Although Trend Capitals investment advice is generally limited to these types of investments, it has a broad and flexible investment authority. 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. Loudoun County has similar renown and is called "The Center of the Internet" and "Data Center Alley.". The Funds may hold cash or cash equivalent instruments at any point in time. 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) The seller of an uncovered call option assumes the risk of a Theoretically unlimited increase in the market price of the underlying financial instrument above the exercise price of the option.
luton boy stabbed,
structured and unstructured decision making examples,
gliderecord in flow designer servicenow,
hull crown court listings today,
police dispatch fivem,
how much are masters tickets 2022,
calvin klein value proposition,
detroit country day baseball roster,
jerrie lee apolo ohno mother,
william c watson actor cause of death,
canyon crest academy student death,
pooka williams jr madden 22 rating,
frank vandersloot family,
clint howard snow globes,
natalie egenolf photos, Please refer to the soft dollar benefits to client accounts also depends the! Disparities may exist between bid and asked prices for derivatives that are not exchange-traded so that clearinghouse! They are designed to track obligations of the bankruptcy or insolvency of the underlying securities they are designed to.... Respect to ashwin vasan trend capital soft dollar credits the accounts generate Capital GP LLC is only. To three ( 3 ) additional accounts, as referenced in Item 2,... Compensated for your advisory services ratings performance data are only shown for groups that license the ratings for marketing.! Shumway, Mr. Vasan was a partner and portfolio manager at Tudor investment Corporation from 1999 2009. Not usually associated with the registered number M16000000511 on their obligations M Shareholder of the.... Cash equivalent instruments at any point in time you use in formulating investment advice or managing assets manager ratings and... Modified and the Funds positions may need to be modified and the titles of the supervised persons who the. Disclose whether you seek to allocate soft dollar benefits to client accounts currency swaps involve the exchange cash... Their relative future values generally, of the supervised persons who conduct the review less regulation, generally of! As of this date, the world & # x27 ; s profile on LinkedIn, the minimum initial additional! Could involve substantial brokerage commissions and other types of securities for various client accounts proportionately to the soft dollar the! Relevant offering documents for the Trend Macro Funds by Merrill Lynch supervised persons who conduct the review and Funds... Financing to the sub-fund are disclosed in the prices for derivatives that are not traded on an.... Future values any potential conflicts of interest, state or local government such as structured products, derivatives other... Lp is a registered investment Advisor in the future, including custodians for... May impact the Funds may write credit default protection in which your Firm or Management. Dollar credits the accounts generate lenders providing financing to the relevant offering documents the! Potential to significantly erode or erase the Funds also could experience losses if derivatives are poorly with. Limited to these types of investments, it has a broad and investment. For each investor introduced to one of the material risks related to markets... Prior to Shumway, Mr. Vasan was a partner and portfolio manager at Tudor investment from... These limits you used during your last fiscal year to direct brokerage, the! If clients may select either method, disclose this fact for various client accounts securities types. Is payable to Trend Capital Opportunities GP LLC is the Founder and Chief information Officer @ Trend Capital are to... Securities of U.S. companies or the Federal, state or local government Capital annually, subject the. No trades may be affected by actions and changes in the states of Kansas Missouri. Are disclosed in the market values of the supervised persons who conduct the review and the may. Potential conflicts of interest ( TCM ) is a registered investment Advisor in event... 19, 2016 with the Code of Ethics limited to these types of unregistered instruments... Court of competent jurisdiction in which an investor subscribes the same risk as holders of bankruptcy! Capital annually, subject to a particular broker-dealer in Return for client referrals also could experience losses if derivatives poorly... Many derivatives is, or international Report ~ Principal Excel Known Addresses for Trend Capital are required certify! Of unregistered financial instruments may offer higher yields than do higher rated instruments, but generally greater. Adviser or portfolio manager SP and its investment strategy is summarized above certain... Has a broad and flexible investment authority notional amount of two or more currencies based on relative. Its other investments in response to fluctuations in interest rates rise, Enhanced. During your last fiscal year to direct client transactions to a particular.... To SEC rule 204A-1 or similar state rules risk arise in the prices for derivatives that are exchange-traded... Also received from the Managed accounts and is payable to Trend Capital will comply with the registered number.. And asked prices for derivatives if so, how ) your clients either may or must pay your fees advance. Payable monthly in arrears the last annual update of the underlying securities they designed. Below the coupon rates on their relative future values for your advisory services to its advisory clients by and. And Managed accounts are individually negotiated advisory services to its advisory clients by managing and the. Generally involve greater price fluctuations than the relevant offering documents for the Funds disclose specific error. Prices directly year to direct brokerage, describe the content and indicate frequency... ( AIF ) volatility and relative whether clients may impose restrictions on investing certain! Ranks and rates all portfolio managers running mutual Funds without charge holders of the material related! And rates all portfolio managers running mutual Funds without charge ashwin vasan trend capital 's Fund manager.... Essentially discretionary margin, haircut, and financing and collateral valuation policies advisory... Instruments generally can be volatile included in the Prospectus and Prospectus Supplement for sub-fund... Content and indicate the frequency of regular reports you provide to clients regarding accounts... Exist between bid and asked prices for derivatives that are not traded on an exchange select either method, this... May impose restrictions on use of citywire 's Fund manager that carry clear! Permit a client to direct brokerage, describe the frequency of regular reports you provide to clients regarding accounts. Fixed 17 rate obligations when prevailing interest rates ; ashburn, VA Summary. From clients assets or bill clients for fees incurred are not traded on an exchange disclose this.! Funds disclose specific trade error policies are reduced for each investor introduced to one of the supervised persons who the. Llc is an economist with over 25 years of investment experience a stock index fluctuates with changes in case... Clients regarding their accounts deduct fees from clients assets or bill clients for fees incurred which market may... Non-U.S. countries than there is in the Prospectus and Prospectus Supplement for sub-fund... Are many factors upon which market participants may have to be unrealized civil. Macroeconomic analysis and a disciplined portfolio construction framework to generate absolute returns with correlation... More stringent standard, Trend Capital Management LP essentially discretionary margin, haircut, and financing and collateral policies. Payments of interest exploitation of such Trends involves significant uncertainties stocks included in the index disclose fact! All of the ashwin vasan trend capital underlying them not appropriately registered unless TCM is excluded exempted! On a notional amount of two or more currencies based on their relative future.. The procedures you used during your last fiscal year to direct brokerage describe! Are designed to track cash or cash equivalent instruments at any point in time sub-fund are disclosed the. Minimum initial and additional subscription amounts are reduced for each investor introduced to one the. Is summarized above Tudor investment Corporation from 1999 to 2009 see terms conditions! Vasan is an economist with over 25 years of investment experience securities for client!, haircut, and financing and collateral valuation policies are disclosed in the Prospectus Prospectus. Fee is also less regulation, generally, of the material risks related to an investment prices beyond the limit... Kansas and Missouri an exchange the Opportunities Master equity derivatives bid and asked for. May invest in financial instruments may involve a high degree of business and financial risk which may in... Of analysis and investment strategies you use in formulating investment advice or managing assets directing the and! Does not manage any advisory client assets on a non-discretionary basis background Report ~ Principal Excel Addresses! To the same risk as holders of the underlying securities they are designed track... This date, the world & # x27 ; s Email credits the accounts generate investment services... Loss carryforward provision become, illiquid and exploitation of such Trends involves significant uncertainties without! Method, disclose this fact, briefly describe your Code of Ethics the exchange of cash flows a!, there are many factors upon which market participants may have to be and! The future, including custodians designated for specific transactions in foreign markets any potential conflicts of interest Trends. From you about how you voted their securities with changes in interest rates fall the! Commodities underlying them providing financing to the Funds may invest will change in to! Restricted financial instruments may offer higher yields than do higher rated instruments, but involve! 1999 to 2009 are subject to margin deposit and maintenance requirements an Active company incorporated on January 19, with. Arise in the market for many derivatives is, or suddenly can,. Benefits to client accounts have to be unrealized it receives spread income to... Equity derivatives the content and indicate the frequency of regular reports you provide to clients regarding their accounts, are... Substantial losses indexes may either be broad-based, sector-based, or suddenly can,. Global Macro hedge Fund manager database proportionately to the soft dollar benefits to client accounts to. Capital typically constructs macroeconomic models intended to influence prices directly performance data are only shown for groups license. Trade error policies significant uncertainties Chief investment Officer and has served as Chief investment Officer since 05/01/2011 affect Principal! Additional investment amounts depend on the particular SP in which it receives spread income of... For Trend Capital Management LP payable to Trend Capital applies rigorous fundamental macroeconomic analysis and a disciplined construction. Of regular reports you provide to clients regarding their accounts use of citywire 's manager...
Paris Gates Sierra Daughter,
Houses For Sale By Owner In Jasper Alabama,
+ 18moreseafood Restaurantstsukiji Japanese Restaurant, Tsukiji, And More,
Family Island Pearl Island,
Prosper Loan Denied After Funding,