Anello Asset Management managed forex anello.altavra.com

Anello Asset Management’s trading program is designed for sophisticated investors. An investment in an account to be traded by Anello Asset Management should only be considered by investors that can assume the significant risk of forex trading, including losses in excess of their initial investment. In managing the accounts of its clients, Anello Asset Management employs the trading concepts and strategy developed by its trading principal. Since the trading methods to be utilized by the Advisor are proprietary and confidential to the third party system developer, the discussion that follows is of a general nature and not intended to be exhaustive. No attempt has been or could be made to provide a precise description of the trading strategy to be used by the Advisor. While Anello Asset Management believes that the description of the trading methods and strategy included in the Disclosure Document may be of interest to investors, investors must ultimately be aware of the inherent limitations of any such description.

Investment Objective and Types of Transactions
Anello Asset Management’s principal investment objective is to realize capital appreciation while actively managing risk. The Advisor will only trade off-exchange spot foreign currencies (i.e., forex). Ultimately, the Advisor’s program seeks to achieve a high level of return commensurate with the risks of forex trading. Past results are not necessarily indicative of future results.  The risk of loss in trading off-exchange forex can be substantial.

Technical and Fundamental Analysis
As a general matter, advisors rely on either fundamental or technical analysis, or a combination thereof, to make trading decisions and attempt to identify price trends in a commodity interest. Fundamental analysis involves the consideration of factors external to the market of a particular instrument. For example, weather and political events which affect the supply and demand of that particular instrument, in order to predict future prices of that instrument. As an example, some of the fundamental factors that affect the supply of commodities (e.g., agricultural products such as corn and soybeans) include the acreage planted, weather during the growing season, harvesting and distribution of the commodity and the previous year’s crop carryover. The demand for such commodities is determined in part by domestic consumption and exports and is a product of many factors, including general world economic conditions, exports and the cost of competing products which might be substituted as alternate sources of food or fiber.

Technical analysis is not based on the anticipated supply and demand of the “cash” or “physical” (i.e., actual) commodity; instead, technical analysis is based on the theory that a study of the markets themselves (in particular, of trends of prices established by the markets for various instruments during selected historical periods) provides a method to anticipate price movements. Technical analysis of the markets often includes a study of the actual daily, weekly and monthly price fluctuations, as well as volume variations and changes in open interest, utilizing charts and/or computers for analysis of these items and other technical market data.

Both fundamental and technical analyses have been employed with success by traders and investors in the past; however, neither trading method can be assured of success in a particular interval of time.

Anello Asset Management’s Forex Program:  AAM Isis FX Program
The approach is applied predominantly to the G-12 spot currency markets from the 31 currency pairs available in the portfolio.

Instruments – Spot FX: AUDCAD, AUDPY, AUDNZD, CADCHF, CADJPY, CHFJPY, EURAUD, EURCAD, EURCHF, EURGBP, EURJPY, EURUSD, GBPAUD, GBPCAD, GBPCHF, GBPJPY, GBPNZD, GBPUSD, NZDAUD, NZDCAD, NZDCHF, NZDJPY, NZDUSD, USDCAD, USDCHF, USDHKD, USDJPY, USDMXN, USDSEK, USDSGD, USDZAR

The key features of are:

   .: Not trend following

   .: Not correlated to traditional assets

   .: No negative years since inception (Past results are not necessarily indicative of future results. The risk of substantial

loss exists in trading off-exchange forex.)

The trading strategy aims to potentially provide superior returns. (Past results are not necessarily indicative of future results. The risk of substantial loss exists in trading off-exchange forex.) There are typically 1-12 trades per month, with positions being held from within an intra-day basis to approximately 7 days. This proprietary system was designed to capture short-term trend reversals in the market using pattern recognition and statistical time series algorithms combined with advanced technical indicators.

Trade Origination
   .: Research, technical analysis and market overview
   .: Market intelligence
   .: Market flows
   .: Trade Execution
   .: Determine optimal entry and exit using proprietary indicators and real time market flow information
   .: Defined profit targets and predetermined stop-loss limits
   .: Short-Term Trading
   .: Intraday to one week
   .: Expected risk to reward is 2:1

Rule 4.34(h) provides that the description of the trading program must include the method chosen by the Commodity Trading Advisor concerning how Futures Commission Merchants (FCM) carrying its accounts will treat offsetting positions pursuant to Rule 1.46, if the method is other than to close out all offsetting positions or to close out offsetting positions on other than a first-in, first-out basis. Rule 1.46 provides that Retail Foreign Exchange Dealers (RFED) and Futures Commission Merchants (FCM) engaging in off-exchange retail forex transactions are required to close out offsetting long and short positions in an off-exchange retail forex customer’s account to the oldest portion of the previously held short or long position. Upon specific instructions from the customer, however, a transaction may be offset as specified by the customer without regard to the date of acquisition of the previously held position.

Risk Management Objectives
Anello Asset Management attempts to define its risk on a consistent basis.

The trading methodology benefits from a robust risk management framework. Controlling downside risk on each and every trade provides two significant advantages. The first is that it focuses on selecting trades with good reward/risk ratios. Secondly, strict discipline in respecting both the stop loss level and the take profit target are what determines its success.

Risk is allocated within the construction of each individual trade. At an overall portfolio level, there is maximum monthly stop loss limit for the strategy at -6%. The average number of trades per month forms the basis of the consistency of the risk allocated to each and every single trade. The program trades approximately 1-12 times per month, and will generally risk between 0.50% - 2.00% on any given trade. This consistent approach to risk allocation per trade in a discretionary strategy is the key to generating steady returns over time.

Risk is monitored in real time. If the maximum monthly stop loss (-6%) is hit in any month (which has never occurred), the Advisor must cease to trade. If this were the case on three months running, an objective assessment would be carried out internally (and with communication to our clients) as to the programs viability within the overall portfolio.

THERE CAN BE NO ASSURANCE THAT THE ADVISOR AND ITS CLIENT ACCOUNTS WILL ACHIEVE THE FOREGOING OBJECTIVES, OR THAT THE CLIENT ACCOUNTS WILL NOT INCUR SUBSTANTIAL LOSSES. MOREOVER, THERE CAN BE NO ASSURANCE THAT THE ADVISOR’S TRADING WILL YIELD THE SAME RESULTS AS IT HAS IN THE PAST.

Mark Hewlett is a member and the manager of the Anello Asset Management. He is responsible for the day-to-day management of the firm and oversees all trading decisions, recommendations, research, and systems development. Mr Hewlett became listed as a principal on 26th January 2011 and an Associated Person (AP) on February 24th 2011. As the sole trading principal, Mark Hewlett places orders for clients in forex, futures and options markets from signals provided by third party system developers.

Mark Hewlett moved across to the commodities sector in 2005. He fast gained a reputation as an advanced specialist within his field of expertise, regularly being featured and interviewed on CNBC throughout the world commentating on the commodity markets and interviewed by Bloomberg and Reuters. Mark Hewlett has been quoted in journals such as Investors Chronicle, Shares Magazine, Technical Analyst, Citywire, Portfolio Institutional and Money Week and many others. Mark Hewlett was the number one forecaster across Gold, Silver and Base Metals in the 2009 Reuters Poll of 40 firms. Comparables included some of the largest and most revered investment banks and commodity trading houses in the world. Mark Hewlett has held Director of Research, Head of Commodities and CEO positions in a number of Commodity Houses trading both physical commodities and futures.

Qualifications held include the CISI Certificate in Investment Management, CISI Certificate in Derivatives (Retail), FINRA Series 32 and FINRA Series 34. Recent consultancy work has included being invited by Reuters to assist with the development and architecture of their Reuters “Insider” platform, with obvious emphasis on their Commodity and Energy programming. Mark holds the FSA CF4 (Partner), CF10 (Compliance Oversight), CF11 (Money Laundering Reporting) and CF30 (Customer Function) Controlled Functions. Mark is NFA Principal Approved, a Forex AP an AP and an NFA Associate Member.
 

Amit Mehta has a particular focus on currency trading. Amit is the founder of Anello Asset Management and has built, grown and managed Anello FX specializing in physical currency trading. Amit Mehta holds the FINRA Series 32 and 34 qualifications. Amit Mehta was listed as a Principal with the CFTC as of February 24th 2011 and has been pending as an Associated Person since January 8th 2011 of the Advisor. He is not a Trading Principal of the Advisor.

THE RISK OF LOSS IN FOREX TRADING CAN BE SUBSTANTIAL. YOU SHOULD THEREFORE CAREFULLY CONSIDER WHETHER SUCH TRADING IS SUITABLE FOR YOU IN LIGHT OF YOUR FINANCIAL CONDITION. IN CONSIDERING WHETHER TO TRADE OR TO AUTHORIZE SOMEONE ELSE TO TRADE FOR YOU, YOU SHOULD ALSO BE AWARE OF THE FOLLOWING:

FOREX TRANSACTIONS ARE NOT TRADED ON AN EXCHANGE, AND THOSE FUNDS DEPOSITED WITH THE COUNTERPARTY FOR FOREX TRANSACTIONS MAY NOT RECEIVE THE SAME PROTECTIONS AS FUNDS USED TO MARGIN OR GUARANTEE EXCHANGE-TRADED FUTURES AND OPTIONS CONTRACTS. IF THE COUNTERPARTY BECOMES INSOLVENT AND YOU HAVE A CLAIM FOR AMOUNTS DEPOSITED OR PROFITS EARNED ON TRANSACTIONS WITH THE COUNTERPARTY, YOUR CLAIM MAY NOT RECEIVE A PRIORITY. WITHOUT A PRIORITY, YOU ARE A GENERAL CREDITOR AND YOUR CLAIM WILL BE PAID, ALONG WITH THE CLAIMS OF OTHER GENERAL CREDITORS, FROM ANY MONIES STILL AVAILABLE AFTER PRIORITY CLAIMS ARE PAID. EVEN CUSTOMER FUNDS THAT THE COUNTERPARTY KEEPS SEPARATE FROM ITS OWN OPERATING FUNDS MAY NOT BE SAFE FROM THE CLAIMS OF OTHER GENERAL AND PRIORITY CREDITORS.

THE HIGH DEGREE OF LEVERAGE THAT IS OFTEN OBTAINABLE FOREX CAN WORK AGAINST YOU AS WELL AS FOR YOU. THE USE OF LEVERAGE CAN LEAD TO LARGE LOSSES AS WELL AS GAINS.

MANAGED ACCOUNTS MAY BE SUBJECT TO SUBSTANTIAL CHARGES FOR MANAGEMENT AND ADVISORY FEES AND THE ACCOUNT MAY NEED TO MAKE SUBSTANTIAL TRADING PROFITS TO AVOID DEPLETING OR EXHAUSTING ITS ASSETS.  THE DISCLOSURE DOCUMENT CONTAINS A COMPLETE DESCRIPTION OF EACH FEE TO BE CHARGED TO YOUR ACCOUNT BY THE ACCOUNT MANAGER.

THIS BRIEF STATEMENT CANNOT DISCLOSE ALL THE RISKS AND SIGNIFICANT ASPECTS OF THE FOREX MARKETS.  THEREFORE, YOU SHOULD CAREFULLY REVIEW THIS DISCLOSURE DOCUMENT BEFORE YOU TRADE, INCLUDING THE DESCRIPTION OF THE PRINCIPAL RISK FACTORS OF THIS INVESTMENT. 

You are encouraged to access the disclosure document AND/OR MANAGEMENT AGREEMENT by clicking the links provided AT Forms.altavra.com. You will not incur any additional charges by accessing the documents. You may also request delivery of a hard copy at formsbymail.altavra.com, which will also be provided to you at no additional cost.  the CFTC has not passed upon the merits of participating in any of these trading programs nor on the adequacy or accuracy of any of these disclosure documents OR MANAGEMENT AGREEMENTS..

YOU SHOULD ALSO BE AWARE THAT THIS TRADING ADVISOR MAY ENGAGE IN TRANSACTIONS ON MARKETS LOCATED OUTSIDE THE UNITED STATES, THESE MAY BE SUBJECT TO REGULATIONS WHICH OFFER DIFFERENT OR DIMINISHED PROTECTION. FURTHER, UNITED STATES REGULATORY AUTHORITIES MAY BE UNABLE TO COMPEL THE ENFORCEMENT OF THE RULES OF REGULATORY AUTHORITIES OR MARKETS IN NON-UNITED STATES JURISDICTIONS WHERE YOUR TRANSACTIONS MAY BE EFFECTED. BEFORE YOU TRADE YOU SHOULD INQUIRE ABOUT ANY RULES RELEVANT TO YOUR PARTICULAR CONTEMPLATED TRANSACTIONS AND ASK THE FIRM WITH WHICH YOU INTEND TO TRADE FOR DETAILS ABOUT THE TYPES OF REDRESS AVAILABLE IN BOTH YOUR LOCAL AND OTHER RELEVANT JURISDICTIONS.  THE TRADING ADVISOR IS PROHIBITED BY LAW FROM ACCEPTING FUNDS IN THE TRADING ADVISOR’S NAME FROM A CLIENT FOR TRADING. YOU MUST PLACE ALL FUNDS FOR TRADING IN THIS TRADING PROGRAM DIRECTLY WITH A FUTURES COMMISSION MERCHANT.

THE FOLLOWING PERFORMANCE NUMBERS HAVE BEEN SUPPLIED BY THE MANAGERS DIRECTLY TO VARIOUS DATA COLLECTION SERVICES.  THE INFORMATION PRESENTED HAS BEEN OBTAINED FROM DATA COLLECTION SOURCES THAT ALTAVRA BELIEVES TO BE RELIABLE.  ALTAVRA IN NO WAY GUARANTEES THE ACCURACY OF THESE NUMBERS AND HAS SUPPLIED THEM FOR INFORMATIONAL PURPOSES ONLY.  ALTAVRA HAS NOT AND CANNOT VERIFY THE ACCURACY OF SUCH INFORMATION AND POTENTIAL INVESTORS SHOULD BE AWARE THAT SUCH INFORMATION IS SUBJECT TO CHANGE WITHOUT NOTICE.  THIS DOES NOT CONSTITUTE A SOLICITATION TO BUY OR AN OFFER TO SELL.  Other disclosure statements are required to be provided before an account may be opened for you.

questions or COMMENTS:  please email clientservices@altavra.com or call 1-800-998-7870.

Peregrine Financial Group, Inc may act as counterparty to your forex transactions.  Past performance is not necessarily indicative of future results.   There are substantial risks associated with leveraged products and additional risks with off-exchange transactions such as those in this managed forex account program. 

The descriptions above are from the manager's disclosure document.

THE RISK OF LOSS IN TRADING FUTURES, OPTIONS AND OFF-EXCHANGE FOREX CAN BE SUBSTANTIAL.  PAST RESULTS ARE NOT NECESSARILY INDICATIVE OF FUTURE RESULTS.  PLEASE READ THE CTA'S RISK DISCLOSURE DOCUMENT CAREFULLY BEFORE INVESTING MONEY.