Series 3: 7.4.2.4. Performance Disclosures

Taken from our Series 3

7.4.2.4. Performance Disclosures

A pool’s past performance must be disclosed as follows:

General principles for pools. Disclosure of the past performance of a pool must include the following information net of any fees, expenses, or allocations to the CPO:

  • The name of the pool
  • A statement as to whether the pool is privately offered, a multi-advisor pool, or a principal-protected pool
  • The date of inception of trading
  • The aggregate gross capital subscriptions to the pool
  • The pool’s current net asset value
  • The largest monthly drawdown (losses) during the most recent five calendar years and year to date, expressed as a percentage of the pool’s net asset value and indicating the month and year of the drawdown
  • The worst peak-to-valley drawdown during the most recent five calendar years and year to date, expressed as a percentage of the pool’s net asset value and indicating the months and year of the drawdown
  • The annual and year-to-date rate of return for the pool for the most recent five calendar years and year to date, computed on a compounded monthly basis

General principles for accounts. Disclosure of the past performance of an account must include the following performance information:

  • The name of the CTA or other person trading the account and the name of the trading program
  • The date on which the person began trading customer accounts and the date when customer funds began being traded pursuant to the trading program
  • The number of accounts directed by the person trading the account pursuant to the specified trading program
  • The total assets under the management of the person trading the account and the total assets traded pursuant to the specified trading program
  • The largest monthly drawdown for the trading program specified during the most recent five calendar years and year to date expressed as a percentage

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