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Disclosure Statement

Disclosure Document:

Cervino Capital Management: Disclosure Document Management Agreement: Cervino Capital Management: Management Agreement

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:: Program Descriptions

.:: Overview of Advisor's Methodology

The Advisor currently offers three separate investment programs: Diversified Options Strategy 1X, Diversified Options Strategy 2X, and a Commodity Options Program. Each investment strategy involves trading in derivatives and is intended primarily for sophisticated investors. The overarching goal of the Advisor’s money management services is the capital appreciation of its clients’ investments through speculation mainly in exchange traded derivative contracts such as futures1 and options on futures2. No assurance can be given that this objective will be met, and any investments in an account to be traded by the Advisor should only be considered by investors that can assume the  significant risk of trading futures and options on futures, including losses in excess of their initial investments. The Advisor will attempt to meet the objective of capital appreciation for this investment program by making trading decisions based upon proprietary trading methodologies.  

 

The Advisor generally relies on fundamental, technical or quantitative analysis, or a combination of each, in making trading decisions and attempting to anticipate price movements.

 

Fundamental analysis looks at the factors that affect the supply and demand of a particular commodity or financial asset in order to predict the expected market price for that asset. Such factors include, but are not limited to, government actions (e.g., Federal Reserve discount rate, imposition of embargoes, price controls, etc.), the release of information concerning weather conditions (e.g., reports of frost in certain growing areas), or the release of economic statistics (e.g., Consumer Price Index, Housing Starts, Unemployment Rate, etc.) resulting in actual or probable significant price movements.  

 

Technical analysis is not based on the anticipated supply and demand of the cash (actual) commodity or financial asset; instead, it is based on the theory that a study of the movement of markets themselves will provide a means of anticipating future prices. Technical analysis often includes the study of intra-day, daily, weekly, and monthly prices, volume and open interest data, and utilizes charts and/or computers for analysis of these items. Another type of technical analysis is market sentiment which is based on the theory of contrary opinion and assumes that when investors swing to emotional extremes they are likely to be overreacting. Sentiment indicators such as short sales or put and call activity is used to highlight junctures of bullish excess (overbought) and bearish excess (oversold), which are useful leading indicators of trend exhaustion.

 

In addition to fundamental and technical analysis, trading decisions may be based on quantitative analysis, a technique that seeks to understand price behavior by using complex mathematical and statistical modeling, measurement and research. For example, since an option’s price is a function of its strike price, time to expiration, underlying asset’s price and volatility, and short-term interest rates, it is logical that a formula can calculate option prices from these variables.  Therefore, utilizing statistical analysis, a model of price variation on a particular futures contract may be used to theoretically determine the fair value of an option on such futures contract.

 

In developing its market opinion and evaluating potential trades, the Advisor generally uses a blended combination of mechanical signals and subjective interpretation of fundamental studies, technical and sentiment indicators, as well as  statistical probability analysis. This research includes, but is not limited to, continuous analysis of short- and long-term price series, the impact of seasonal and cyclical price movements upon the underlying price trend, fundamental factors affecting supply and demand influences, and application of statistical models in order to consider risk factors associated with various trading opportunities. The intent is to identify and arbitrage price discrepancies that reflect under- and over-valuations as well as directional trend bias or trend-reversal/mean reversion opportunities, and to produce a replicable trade execution process consisting of positions with statistically high probabilities of positive outcomes. To accomplish this goal, the Advisor utilizes options to structure complex positions that within one or across several underlying asset exposures can tactically reflect one or more trading perspectives, such as hedged relative value, fundamentally-based, or volatility/opportunistic investment strategies.  

 

Risk control is achieved through a variety of means which should in most, but not necessarily all, market conditions help minimize the impact of drawdowns. The first is portfolio constructions and diversification such as the use of hedged positions across several underlying assets; second is controlling leverage through position sizing adjusted according to account size, market volatility and risk-reward analysis; and third is stops based on money management rules. Risk management is deemed to be an ongoing process and therefore the Advisor continually monitors all positions.  Occasionally the Advisor may adjust positions either by entering into new positions which hedge existing market exposure, or by liquidating and/or covering existing positions in order to reduce market exposure or reset a position at different strike price(s) and/or contract expiration(s).

 

Prospective investors should be aware that the Advisor's trading programs may be more aggressive than most other trading programs. This is due to the fact that the Advisor's trading strategy primarily utilizes options on futures, and the Advisor will typically adjust its positions on a regular basis. As a result, it is anticipated that the velocity, or turnover rate, may be substantially higher than the turnover in other money management programs. Accordingly, the Advisor’s trading strategy can result in substantially greater commission charges that may rapidly deplete the equity in a client's account in the event the Advisor's strategies are not successful.  The trading methods employed by the Advisor may be profitable overall, however, there may be periods in which such trading methods may result in substantial trading losses.

 

.:: Diversified Options Strategy 1X and 2X

The Advisor’s Diversified Options Strategy 1X and 2X involve trading in a diversified portfolio of option on futures contracts including options on equity index futures. Diversified Options Strategy 1X is a baseline program and the past performance of this program is set forth in Section 7 Performance. Diversified Options Strategy 2X is leverage at two  times the Diversified Options Strategy 1X program; in other words, the 2X program will trade twice as many contracts as the 1X program for the same nominal account size. Accordingly, the additional leverage of the 2X program is expected to result in increased account volatility, and therefore an increased potential for higher returns as well as an increased potential for larger drawdowns. The Advisor previously has not directed any accounts in the Diversified Options Strategy 2X program. 

 

These programs are designed to be an absolute return program focused mainly on premium capture strategies with the objective of generating positive returns in most market conditions regardless of whether the underlying market(s) is up or down. Both of these programs focus their trading activities on a portfolio of options on futures contracts diversified across a variety of underlying financial assets. Opportunity and risk exposure is further diversified through the use of different types of option combinations including, but not limited to, bear spreads, bull spreads, condors, ratio spreads, strangles and calendar spreads as well as naked puts and calls. The variety of position combinations that are possible with options contributes to the creation of multifaceted and versatile investment strategies tailored to market conditions and trading outlook. Generally, both the Diversified Options Strategy 1X and 2X are counter-trend biased in the sense that these programs will, for example, write calls into rallies and write puts into declines. While the Advisor will utilize mechanical signals as a component of its investment process, unlike certain technical traders the Advisor does not purely follow any systematic entry and exit signals in implementing its trading strategy for Diversified Options Strategy 1X and 2X. Rather, there is a significant element of discretion involved with Advisor’s formulation and execution of its trading ideas for these programs.

 

The underlying asset classes and futures contracts upon which both the Diversified Options Strategy 1X and 2X focus their options trading consists primarily of the S&P 500 equity index, with additional portfolio exposure, but to a lesser degree, in currencies (e.g., Euro, Yen), and U.S. Treasuries (e.g., 10 Year U.S. Treasury Note) and precious metals (e.g., gold, silver). In addition, the Advisor may for accounts funded with Actual Funds (see Section 2.5 Broker, Account Size, and Funding) invest in fixed income securities that are fungible for margin purposes. The forementioned list of  underlying asset classes is not meant to be exclusive, and the Advisor may trade in other markets in its own discretion in order to gain exposure to opportunities in the majority of actively traded markets, and to achieve a balance across economic sectors while simultaneously limiting, to the extent possible, undue concentration in any particular economic sector. The intent of such discretion is to increase opportunities for gain, decrease risk and provide more consistent returns.

 

The trading strategy largely involves, but is not limited to, the implementation of option combinations such as bear spreads, bull spreads, condors, ratio spreads, strangles and calendar spreads. The writing of “naked options,” is another strategy that the Advisor may utilize from time to time. In addition the Advisor may establish outright long option positions, or establish long or short futures positions under certain market conditions. Options on futures may be used by the Advisor on both a covered basis and an uncovered basis, but in the vast majority of circumstances positions will not be “covered” by the underlying futures contract(s). Both put and call options will be traded.  

 

Due to the nature of the Advisor's trading methods and the experience of its trading principal, the portfolio often may not be diversified; in fact, on occasion, there may be a heavy concentration of a given position or a position complex, which could result in a greater return or risk to the account. While the Advisor may utilize contingent orders such as “stop-loss” or “stop-limit” orders, such orders will not necessarily limit losses to intended amounts since market conditions may make it impossible to execute such orders.

 

The foregoing investment principles are factors upon which the Advisor bases its trading decisions for both the Diversified Options Strategy 1X and 2X. Such trading strategies have been and will be enhanced or revised from time to time. The research and trading methods of the Advisor are proprietary and confidential. The description of this  program is, of necessity, general and is not intended to be exhaustive.

 

.:: Commodity Options Program

The Advisor’s Commodity Options Program involves trading in a diversified portfolio of option on futures contracts based on commodity interests, and excludes options on equity index futures. It is designed to be substantially more  aggressive than the Diversified Options Strategy 1X resulting in increase account volatility, and therefore an increased potential for higher returns as well as an increased potential for larger drawdowns. To the extent that there is an overlap in underlying asset exposure, the Commodity Options Program will frequently deploy different option strategies or tactics with different objectives in mind than the Diversified Options Strategy 1X or 2X. For example, the Diversified Options Strategy is oriented toward premium capture strategies and generally counter-trend biased, whereas the Commodity Options Program will, in addition to premium capture strategies, seek to take advantage of trending markets through speculative positions such as debit spreads, synthetic futures and occasionally outright long option potions.

 

This program is designed to monitor and regularly trade derivatives based on commodity interests in an effort to be non-correlated to trading of derivatives based on financial assets. The first step and primary analysis will be based on market fundamentals. This research helps validate the likelihood of trends persisting or reversing. Technical analysis is the second analytical step and helps ensure timely trade entries as well as identify support and resistance areas for stop adjustments. Ideas will be executed by looking at the option book for tactical opportunities. The overall portfolio will work on two levels: (i) approximately half of the portfolio will be focused on premium capture strategies with the aim of generating income from positions, and (ii) the remainder of the portfolio will be dedicated to speculative directional trades in the form of debit spreads, synthetic futures and occasionally outright long option positions. Premium capture strategies may on occasion be converted into directional bets. While the Advisor will utilize mechanical signals as a component of its investment process, unlike certain technical traders the Advisor does not purely follow any systematic entry and exit signals in implementing its trading strategy for Commodity Options Program. Rather, there is a significant element of discretion involved with Advisor’s formulation and execution of its trading ideas for this program.

 

The underlying asset classes and futures contracts upon which the Commodity Options Program focuses its options trading will consist of energy (e.g., crude oil, natural gas), grains (e.g., corn, wheat), industrial and precious metals (e.g., copper, silver), softs (e.g., coffee, sugar), and commodity-based currencies (e.g., Australian dollar, Canadian dollar). In addition, the Advisor may for accounts funded with Actual Funds (see Section 2.5 Broker, Account Size, and Funding) invest in fixed income securities that are fungible for margin purposes. With the exception of equity indices such as the S&P 500 which will not be traded in the Commodity Options Program, the forementioned list of underlying asset classes is not exclusive, and the Advisor may trade in other markets in its own discretion in order to gain exposure to opportunities in the majority of actively traded markets, and to achieve a balance across economic sectors while simultaneously limiting, to the extent possible, undue concentration in any particular economic sector. The intent of such discretion is to increase opportunities for gain, decrease risk and provide more consistent returns.  

 

The trading strategy largely involves, but is not limited to, the implementation of option combinations such as bear spreads, bull spreads, condors, ratio spreads, strangles and calendar spreads. The writing of “naked options” or synthetic futures are other strategies that the Advisor may utilize from time to time. In addition the Advisor may establish outright long option positions, or establish long or short futures positions under certain market conditions. Options on futures may be used by the Advisor on both a covered basis and an uncovered basis, but in the vast majority of circumstances positions will not be “covered” by the underlying futures contract(s). Both put and call options will be traded. 

 

Due to the nature of the Advisor's trading methods and the experience of its trading principal, the portfolio often may not be diversified; in fact, on occasion, there may be a heavy concentration of a given position or a position complex, which could result in a greater return or risk to the account. While the Advisor may utilize contingent orders such as “stop-loss” or “stop-limit” orders, such orders will not necessarily limit losses to intended amounts since market conditions may make it impossible to execute such orders.

 

The foregoing investment principles are factors upon which the Advisor bases its trading decisions for the Commodity Options Program. Such trading strategies have been and will be enhanced or revised from time to time. The research and trading methods of the Advisor are proprietary and confidential.  The description of this program is, of necessity, general and is not intended to be exhaustive.

 

:: Management Information

.:: Davide Accomazzo

Davide Accomazzo has been trading professionally since 1996. From July 1996 through December 1997 he was employed as a Euro-convertible bond/international equities sales trader for Jefferies and Company, Inc., an investment bank. In this position, he covered many international funds, including: Arca, La Generali, Hansberger, New Africa Fund/NCM, Cranberry Rock, Pontaray, Weston Group, and Oppenheimer retail international desk. In January 1998 he left to trade his own capital and in November 1999 he started Kensington Offshore Limited, a speculative hedge fund which outperformed the S&P 500 market benchmark during the 1999 through 2002 equity markets’ boom and bust cycles. In February 2001 he launched Kensington Capital Management, LLC, a commodity trading advisor that focused on trading options on futures and currency futures. Mr. Accomazzo was signed on by UBS Wealth Management USA, a broker-dealer, in October 2004 to manage the portfolios of high net worth investors, and withdrew as principal and associated person of Kensington Capital Management, LLC in November 2004. In October 2005, Mr. Accomazzo resigned from UBS having co-founded Cervino Capital Management LLC with Michael Frankfurter.  Mr. Accomazzo received a Laurea in Political Sciences and International Relations at Universita' degli Studi Genova in 1990, a Masters in Arts in Mass Communication from California State University Northridge in 1992, and his MBA in Finance at the School of Business and Management at Pepperdine University in June 1996. During his academic career he worked in collaboration with Investment Technology Group (“ITG”) on projects that focused on automated portfolio management  through Quantex, ITG’s electronic execution system. Since August 2007 Mr. Accomazzo has also served as an adjunct professor at Pepperdine University, Graziadio School of Business and Management, where he teaches courses on global capital markets and portfolio investment management.

 

.:: Michael W. Frankfurter

Michael “Mack” Frankfurter started his career in the financial services industry in 1989 with Bank of America, a commercial bank. In July 1991 he was recruited by private equity boutique The Echelon Group, Inc. (subsequently  restructured as The Echelon Group of Companies, LLC) as vice president in charge of operations of Echelon’s managed futures business. As an associated person, Mr. Frankfurter was involved with the startup, accounting, client services, compliance, backoffice and marketing of multiple Echelon-related joint venture commodity trading advisors including Ark Capital Management, Dreiss Research Corporation, Echelon Capital Advisors, Jackson Grain Management, Longview Capital Management, Range Wise and Royal Union Petroleum Group. Mr. Frankfurter was also involved in activities related to the establishment of other Echelon-related ventures including Dignity Partners, Inc., a viatical settlement business. Dignity Partners institutionalized the viatical settlement industry by successfully completing a private placement of $50 million in securitized notes (voted “1995 Private Deal of the Year” by Investment Dealers Digest), and a subsequent initial public offering in 1996. Later renamed Point West Capital Corporation, the company launched a venture capital subsidiary, a correspondent broker subsidiary and a specialty business-lender subsidiary. During this time Mr. Frankfurter was responsible for implementing and maintaining both Echelon’s and Point West’s information systems while continuing to administer to Echelon’s managed futures business.  

 

Mr. Frankfurter left Echelon and Point West in January 1999. After spending some time off sailing and traveling, he worked as a consultant on projects for FleetBoston Robertson Stephens. In January 2000 he briefly became an associated person of The Pixley Group, an introducing broker, prior to being recruited in July 2000 by The Capital Markets Company (Capco) as senior consultant to work as project manager for an online private banking startup and joint venture between Scudder Kemper and Thomas Weisel Partners. That long-term project was followed by an international inter-company trading systems implementation for Commerzbank involving Royalblue fidessa, and a T+1/STP readiness assessment for Bank of Montreal. He left Capco in April 2002 and in May 2002 founded NextStep Strategies, LLC which focused on consulting and headhunting for financial services companies. NextStep Strategies was also registered as a commodity trading advisor and commodity pool operator from March 2003 to July 2004. Mr. Frankfurter joined UBS Financial Services, Inc., a broker-dealer, in May 2004 in their Beverly Hills office and provided financial advisory services to clients until June 2005. He rejoined NextStep Strategies, LLC in July 2005 and co-founded Cervino Capital Management LLC with Davide Accomazzo in August 2005. In September 2007, Mr. Frankfurter became an associated person of Managed Account Research, Inc. (“MARI”), an introducing broker, where he functions in an operational and administrative capacity.

 

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. 

 

Disclosure Statement

 

 

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The risk of loss in trading futures, options and off-exchange forex can be substantial.

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