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DISCLOSURE DOCUMENT

OF
CIF-ACTIVE ALPHA

CIF-Active Alpha is a trading name of CIF, a licensed Investment Firm, regulated by the
Cyprus Securities and Exchange Commission with License Number /and Company
Registration Number HE.

CIF

1st Floor , Nicosia


Cyprus

TRADING MAY CAUSE THE LOSS OF THE CAPITAL INVESTED

The information and opinions contained herein are subject to change or


revision subsequent to the date of this Disclosure Document.

THE DATE OF THIS DISCLOSURE DOCUMENT

IS:

1st March 2017


RISK WARNING AND LEGAL DISCLAIMER:
Investment in financial instruments involves a high degree of risk. As such, they
may not be suitable for all investors. Investors should ensure they fully
understand the risks associated with investing in financial instruments before
deciding to invest as they may lose partial or all invested capital. The information
contained in this document is for general information purposes only and should
not be viewed as offering any personal investment service. Investors may choose
to seek independent advice and should not risk more than they are prepared to
lose. Past performance is no guarantee of future returns.

The material herein is issued by CIF( CIF) (authorized and regulated by Cyprus
Securities and Exchange Commission as a Cyprus Investment Firm with License
Number /(CySEC). Registered office: ---, 1st Floor --- Nicosia, Cyprus. Tel: ---. For
your protection, telephone calls are usually recorded. The material is not directed
to, or intended for distribution to, or use by, any person or entity who is a citizen
or resident of, or located in any locality, state, country or other jurisdiction where
such distribution, publication, availability or use would be contrary to law or
regulation or which would subject CIFto any registration or licensing
requirement within such jurisdiction. The material is for information purposes
only and does not constitute an offer or invitation to anyone to invest in any
CIFinvestment programs and has not been prepared in connection with any such
offer. No part of this document may be reproduced, stored in retrieval system or
transmitted in any form or by any means, electronic, mechanical, recording or
otherwise, without the prior written consent of CIFThe CIF-Active Alpha
Managed Account is an account where clients assets are owned and held on a
fully disclosed basis in the name of the client and CIFacts as the external
manager. Any decision to invest in the products or investment programs
discussed here should be made on the basis of the information contained in the
Disclosure Document, Portfolio Management Client Agreement and any
Supplemental Documents. Participation in the CIFActive Alpha Managed Account
program are valid only if made on the basis of the Client Application Form, Client
Questionnaire, and the Portfolio Management Client Agreement including the Risk
Disclosure, Terms and Conditions, General Investment Services Agreement,
Investor Compensation Fund, Client Categorization Policy, Pillar III Disclosures,
Complaints Policy and Privacy Policy which are available on our website. No sale
will be made in any jurisdiction in which the offer, solicitation, or sale is not
authorized or to any person to whom it is unlawful to make the offer, solicitation
or sale. It is your responsibility to be aware of the applicable laws and regulations
of your country of residence. Past performance is not a guide to future
performance and should not be the sole factor of consideration when selecting a
product. All financial investments involve an element of risk therefore, the value
of your investment and the income from it will vary and your initial investment
amount cannot be guaranteed. Changes in the rates of exchange between
currencies may cause the value of investments to go up and down. Levels and
basis of taxation may change from time to time. Any research in this document
has been procured and may have been acted on by CIFfor its own purpose. The
results of such research are being made available only incidentally. All
information provided is gathered from reputable sources and any information
containing an indication of past performance is not a guarantee or reliable
indicator of future performance. CIF takes no responsibility for the accuracy of

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any information on this communication. The views expressed do not constitute
investment or any other advice and are subject to change. CIFdoes not provide
tax, accounting or legal advice. If you require advice in relation to these matters,
you should consult your respective tax, accounting or legal advisers.

Contents
RISK WARNING AND LEGAL DISCLAIMER:................................................................1
INTRODUCTION:...................................................................................................... 3
THE MANAGER:........................................................................................................ 3
THE TRADER:........................................................................................................... 3
ACCOUNT PROVIDER:.............................................................................................. 3
INTRODUCING BROKER:.......................................................................................... 4
LITIGATION:............................................................................................................. 4
PRIVACY POLICY:...................................................................................................... 4
PRINCIPAL RISK FACTORS OF THE TRADING PROGRAM:...........................................4
TRADING PROGRAM: CIF-ACTIVE ALPHA.................................................................5
ACCOUNT SIZE:....................................................................................................... 7
MARKETS TRADED:.................................................................................................. 7
FEE STRUCTURE:..................................................................................................... 7
CONFLICTS OF INTEREST:........................................................................................ 8
NOTIONALLY FUNDED ACCOUNTS DISCLOSURE:.....................................................8
OWN ACCOUNT:....................................................................................................... 9
PERFORMANCE RECORDS:....................................................................................... 9

Exhibits
- Client Questionnaire
- Active Alpha Portfolio Management Agreement

Supplemental

-Notional Funded Accounts Disclosure


-Client Notional Funding Agreement
-Active Alpha Fact Sheet

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INTRODUCTION:
CIF, a licensed Investment Firm, regulated by the Cyprus Securities and Exchange
Commission (CySEC) with License Number /and Company Registration Number
HE, whose registered address is 1st Floor ---, Nicosia Cyprus (The Manager).
The Manager relies on the skills and experience of its Authorized Trader, John Knobel
(The Trader). Mr. Knobel is registered and listed in the Cyprus Securities and
Exchange Commissions Public Register of Certified Persons with Advanced
Certificate Number CN1583 and he is responsible for the overall trading strategy of
the CIF-Active Alpha program (The Program).
THE MANAGER:
The Manager is licensed by the CySEC as a Cyprus Investment Firm under the Law
which Provides for the Provision of Investment Services, the Exercise of Investment
Activities, the Operation of Regulated Markets, and Other Related Matters Law
144(I)/2007 (the IF Law) with authority to provide Investment and Ancillary
Services in accordance with its license number ---.
The Manger is currently licensed to provide Portfolio Management, Investment
Advice, Reception & Transmission of Orders and Execution of Orders on Behalf of
Clients.
In addition, the Manager is licensed for the provision of the ancillary services of
Safekeeping and Administration of Financial Instruments, including Custodianship
and Foreign exchange services as these are connected to the provision of the
investment services.

THE TRADER:
John Knobel, born in 1976, is listed in the Cyprus Securities and Exchange
Commission public register of certified persons with advanced certification number
CN1583 and is the Authorized Trader for the CIF-Active Alpha managed account
service. Mr. Knobel qualified to manage futures funds, commodity trading and
operate commodity pools by the NFA in 04/2000, qualified by New York Stock
Exchange as Stockbroker in 02/2000, as options principal in 01/2005, as NYSE
member-firm principal in 04/2005, and certified as Portfolio Manager in 12/2006 by
Cyprus Ministry of Finance. He is a past Associate Member of the UK Chartered
Institute for Securities & Investment, and past Associate Member of the UK Society
of Technical Analysis. His professional experience spans over seventeen years with
investment experience on the buy-side and sell side as a Stockbroker, Financial
Advisor, Fund Manager, Proprietary Trader, Senior Currency Strategist, and Head of
Brokerage for companies including Morgan Stanley, Wall Street Financial Group, K&S

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Capital Partners, Westminster Securities Corporation, Hotforex and Cyprus based
Proprietary Trading firm YESFX.
ACCOUNT PROVIDER:
Each client of The Manager must select a broker (Account Provider) of their
choice, who will hold each clients funds and through which transactions will be
executed. When trades are executed they will all be cleared by Interactive Brokers
(U.K.) Limited, either directly for clients who use Interactive Brokers (U.K.) Limited
as their Account Provider, or by the give-up process commonly used by brokers
who are not with Interactive Brokers (U.K.) Limited. Brokerage fees and other
charges to accounts by the Account Provider may vary significantly and are
negotiated between the client and its Account Provider. The Manager maintains
relationships with Interactive Brokers (U.K.) Limited and reserves the right to
maintain relationships with other oor brokers on various exchanges who may not
be associated with a clients clearing broker. The Manager reserves the right to
direct all transactions to any broker or oor broker it chooses for execution with
instructions to give-up the clients clearing broker. The clearing broker will then
pay oor brokerage and any additional administrative or give-up fees to the
executing broker from the clients account.
The Clients Account Provider will maintain the clients account and provide the
client with trade confirmations and monthly statements reecting all account
activity in each month. Account Providers now typically provide online account
access, enabling clients to see the status of their account at any time over the
Internet.
The Account Provider will charge the client brokerage commissions, in addition to
the Management and performance fees. The clients monthly statement will disclose
the total brokerage commissions charged to the clients account.
The Trader believes that clients benefit from having a managed account
investment rather than participating in a pooled fund, for the following reasons: (i)
Transparency: The Managers clients have their own account, in their own name,
with an established and highly regulated Account Provider selected by the client.
Clients will receive complete information regarding the investments in their
account, and the value of those investments, at any time, directly from the Account
Provider. (ii) Financial Security: An established and highly regulated Account
Provider has custody of each clients assets, providing the benefit of the financial
strength of a well-capitalized firm.

INTRODUCING BROKER:
The Manager does not require clients to use any introducing broker (IB), but a
client may select one to introduce transactions for the clients account. The client
should know that the use of an IB may increase commission charges.
The Trader does not benefit directly or indirectly from a clients choice of a
particular Account Provider and/or IB.

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LITIGATION:
There has been no administrative, civil or criminal litigation against The Manager or
The Trader in the last five years and there is none pending, on appeal or concluded.
PRIVACY POLICY:
The Managers Privacy Policy can be found online at -----
PRINCIPAL RISK FACTORS OF THE TRADING PROGRAM:
In addition to The Managers Risk Disclosure found online at, there exist additional
risk factors, including those described below, in connection with a customer
participating in the CIF-Active Alpha Managed Account Program. Prospective
customers should consider all of the risk factors described below and elsewhere
before participating in any Program.
Computer Trading: The Trader may utilize a method of trading in which he uses
computer-generated information to determine trending markets. If The Trader is
incorrect in the interpretation of this information, the account may suffer a loss.
Further, although steps are taken by The Trader to minimize such problems, be
aware that in certain situations such as power failures, virus attacks, loss of hard
drives, etc, computer systems can be vulnerable.

Investing in Commodity Interests Is Speculative and Volatile: Commodity Interest


prices and other contract prices are volatile. Price movements of Commodity
Interests are inuenced by, among other things, changing supply and demand
relationships, governmental, agricultural and trade programs and policies, climate
and national and international political and economic events. Financial instruments
and foreign currency futures and forward and spot contract prices are inuenced by,
among other things, interest rates, changes in balances of payments and trade,
domestic and international rates of ination, international trade restrictions and
currency devaluations and revaluations. None of these factors can be controlled by
The Manager or The Trader.

Opening an account with The Manager should be considered a long-term investment


and may be very volatile. It is important that clients understand that client accounts
may experience volatility and losses. Substantial draw-downs, either from initial
Account Value or from peak levels of Account Value, do not necessarily indicate a
failure in the investment strategy, but rather are to be expected. Clients must,
therefore, be prepared to withstand these periods of unprofitable investing, and in
this regard, should be further prepared to maintain their account for at least three
years from the date opened.

It is the intention of The Trader, to minimize the risk of a complete loss of capital
and to cease trading and consult with the Client before proceeding upon any 15%
drawdown.

The Trader is an Active Trader: The trading activities of The Trader may be quite
active and the turnover rate of the managed account substantial. With aggressive
trading, day trading or multiple trading strategies, the commissions that the
customer pays may be more than what is considered normal for trading. Although

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it is difficult to estimate the number of trades that may be made since technical
factors will determine the trades, it is possible that a trade, or trades, may be made
several days in a row, then no trades may occur for several days. The potential
customer should consider this carefully before investing.

It is the intention of The Trader, to follow clear money managed rules that would
limit the number of trades to a maximum of 3 trades per day.

Stop orders: If stop orders are used to enter or exit the market, the customer should
be aware that such orders become market orders when triggered and do not
ensure that the order will be filled at the price stated on the stop order.

TRADING PROGRAM: CIF-ACTIVE ALPHA


The CIF-Active Alpha program is based on a discretionary intra-day trading system
that trades within a focused universe of commodity futures markets. The system
follows clear money management rules per below:
Margin to equity of no more than 12%
Positions are opened and closed from 0600 to 2300 hours (EET-Eastern
European Time).
Minimum of 0 to a maximum of 3 trades per session
Maximum daily stop loss set not to exceed 1.8% of account trading level
Markets traded: Energy, equity indices, interest rate, currency and metals

The programs model encompasses a single asset class, Futures (Exchange Traded
Standardized Futures Contracts). The primary aim of The Traders investment style is
to capture market moves at their inception and continue to adapt as cycles change.
The Trader trades intra-day with a clear view of the bigger picture; positions that are
closed at the end of the trading session can be reopened during the following
session, allowing The Trader to follow the trend while eliminating the risk of
unexpected overnight draw-down. The Traders approach to closing positions at the
end of a trading session may work in the Programs favor or against it, in that there
is always the risk of missing an important overnight market event.

The Programs investment style aims to capture market moves through exposure to
a momentum investment process: a rule based methodology derived by a set of
market timing tools:

Focus on inter market trading patterns: cautious positioning for low


probability high impact events
Focus on the expected value approach: continuous appraisal of probability
versus payoff
Focus on dynamic risk scaling at portfolio level: emphasis on capturing or
avoiding sudden shocks in the markets
To account for low probability high impact events, The Trader appraises
investments in terms of expected value. For example, the Aussie dollar is
expected to move up, but the expected value is negative. Thus, a short
position is in order.

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The Programs position sizing:
Positions are fixed according to client account trading level and not to exceed a
margin to equity ratio of 12% and they are optimized to replicate the intended risk
level.

Most positions are associated with a minimum of 2-1 risk-reward target, although
sometimes this may not the case as it depends on the relevant support and
resistance levels that may not match exactly to The Traders indented risk-reward
targets within certain time frames.
P/L volatility is measured constantly with the aim to manage risk at both the right
tail and left tail of the VaR distribution, in order to scale back on draw downs and
rescale on over performance.
Position Selection:
The Program trades actively a momentum strategy with a macro overlay. The
Traders strategy aims to capture expected movements in line with the prevailing
trend as well as capturing counter trend retracements by employing decision trees
based on probabilities and payoffs.

The Trader may employ from time to time a research driven strategy based on
technical and fundamental analysis reports that are acquired from independent
trusted sources.

The Trader may employ from time to time a Currency macro strategy based on
Equity indices: It aims to exploit the relative relatedness of equity indexes to
currencies. Moves in these equity indexes can be used as a leading indicator to
trade those currencies and vice versa.

The Trader may employ from time to time a Currency macro strategy based on
Commodity prices: It aims to exploit the relative relatedness of commodity prices to
currencies. Moves in commodity prices can be used as a leading indicator to trade
those currencies and vice versa.

ACCOUNT SIZE:
The minimum account size for the CIF-Active Alpha program is 125,000 or
equivalent. However, the Manager reserves the right to waive the requirements on
a case-by-case basis. A fully funded account will have a trading level equal to actual
funds. Partially funded accounts will have a trading level higher than actual funds
and requires a signed notional funding agreement.
MARKETS TRADED:
The primary markets traded will be Exchange Traded Standardized Futures
Contracts.
However, the client reserves the right to request to trade all financial instruments
offer through the Account Provider, if deemed necessary. In this case, The Manger
will require the Client to sign a new Portfolio Management Agreement.

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FEE STRUCTURE:
In return for services, The Manager intends to charge the following range of fees:
A. Performance fee
The Manager may charge at his discretion a maximum monthly performance fee of
30% of net new profits. Net new profits include profits, if any, on all closed
positions and profits, if any, on open positions. The profits on open positions are not
realized profits and they are carried over into the following month. In the
following month, these unrealized profits could be lost or realize a further gain.
Gains and losses will be net after commissions. The account will also be adjusted for
any deposits or withdrawals. In order for a performance fee to be payable, the net
new profit value at the end of the month must exceed the highest adjusted net new
high profit value of any previous month. Therefore, no performance fee will be due
unless and until all losses are recouped. The highest adjusted net new high profit
simply means the highest profit achieved in the account after being adjusted down
for the fees charged to the account. The performance fee will be calculated on the
last trading day of each month. The performance fee shall be paid from funds in the
client's account after the end of each period. Accounts closed before the end of a
calendar month will pay any fees due at the time the account is closed.
B. Management Fee: The monthly Management Fee shall be 1/12th of the
annualized Management Fee level payable as set out below plus any applicable VAT.
Base Currency Trading Level
EUR 1,000,000 or less 1,000,001 or more
Annual Management fee 1.75% 1.50%

The performance fee shall not be repaid if subsequent losses occur. If an account is
opened during a month and a performance fee is due at the end of a month, the
performance fee is payable in full without prorating.

The performance and management fees shall be based upon the final net asset
value of the account including notional. The Manager will require each client to sign
an authorization directed to the Account Provider authorizing the Account Provider
to pay The Managers fees directly from the client's account.

C. Commissions:
For the CIF-Active Alpha program, The Manager will add a maximum //$1.00
commission mark-up over and above an Account Providers standard commission
rate per contract, per side, for exchange traded futures contracts.
CONFLICTS OF INTEREST:
The Manager may pay persons or firms who introduce accounts to it a portion of the
fees it receives from such accounts. Thus, persons or firms who introduce your
account to the CIF-Active Alpha program may have an incentive to do so based on
the payments they will receive. This fee would be a part of the maximum
commission, and/or performance fees disclosed in this document.
PERFORMANCE FEES. A conict of interest exists insofar as both The Manager and
The Trader is compensated on a performance fee basis, which may increase the

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likelihood that The Trader may engage in trading which is riskier than that which is
described in the trading program. However, neither The Manager or The Trader have
any intention of engaging in trading in any manner not consistent with the trading
program described herein.

NOTIONALLY FUNDED ACCOUNTS DISCLOSURE:


You should request The Manager to advise you of the amount of cash or other
assets (Actual Funds) which should be deposited to the Program for your account to
be considered Fully-Funded. This is the amount upon which The Manager will
determine the position exposure to be traded in your account and should be an
amount sufficient to make it unlikely that any further cash deposits would be
required from you over the course of your participation in the program. You are
reminded that the account size you have agreed to in writing (the nominal or
notional account size) is not the maximum possible loss that your account may
experience. You should consult the account statements received from your Account
Provider in order to determine the actual activity in your account, including profits,
losses and current cash equity balance. To the extent that the equity in your
account is at any time less than the nominal account size you should be aware of
the following:

I. Although your gains and losses, fees and commissions measured in your base
currency will be the same, they will be greater when expressed as a
percentage of account equity;
II. you may receive more frequent and larger margin calls; and
III. the conversion chart below may be used to convert actual rates of return
(RORs) to the corresponding RORs for particular funding levels.

100% 75% 50% 25%


Rate of funde funde funde funde
Return d d d d
-20% -20% -30% -40% -80%
-10% -10% -15% -20% -40%
-5% -5% -7.5% -10% -20%
0% 0% 0% 0% 0%
5% 5% 7.5% 10% 20%
10% 10% 15% 20% 40%
20% 20% 30% 40% 80%

Note that net profits and losses will affect the nominal account size and additions
and withdrawals will not affect the nominal account size.

Additions or withdrawals will materially affect RORs of notionally funded accounts.


This is because the Manager will continue to trade the account at the agreed
trading level without taking into consideration additions or withdrawals (unless
instructed otherwise by the Client), and thus any additions or withdrawals of actual
funds will not result in a corresponding proportional increase or decrease in the
nominal funding of an account. For example, assume that a Client opens an account

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with an actual funding level of 100,000, and instructs The Manager to trade the
account at a nominal level of 200,000. If the Client withdraws 50,000 of actual
funds from the account, The Manager will continue to trade the account at a
nominal level of 200,000. Before the withdrawal, the account would be traded at a
50% funding level, but after the withdrawal the account would be traded at a 25%
funding level. If the trading program were to experience a -5% rate of return, then if
that performance occurred before the withdrawal the actual performance would be
-10% return but if that performance occurred after the withdrawal the actual
performance would be -20%.

It is not anticipated that changes in account equity attributable to trading profits


and losses will materially affect RORs of notionally funded accounts. This is because
any trading profits and losses in actual funds will result in a corresponding
proportional increase or decrease in the nominal funding of an account. For
example, assuming that a Client opens an account with an actual funding level of
100,000 and instructs The Manager to trade the account at a nominal level of
200,000, if a Clients account achieves actual trading profits of 100,000 resulting
in an actual funding level of 200,000, The Manager will trade the account at
nominal level of 400,000. Further, if Clients account sustains actual trading losses
of 50,000 resulting in an actual funding level of 50,000, The Manager will trade
the account at nominal level of 100,000. However, the RORs experienced by the
account would be the same following the losses because the proportion of actual to
notional funding will remain the same.

Please note that the increased leverage resulting from notional funding may lead to
more frequent and larger margin calls in the event of a draw-down in an account.

OWN ACCOUNT:
The Manager and/or The Trader may trade for their own account(s). You should be
aware that the trading activity in these account(s) might significantly differ from the
trading activity in a clients account. There is no assurance that the trading results
in The Traders proprietary account(s) will be the same as the performance in a
customers Account since The Manager and/or The Trader may trade more
aggressively or use his account(s) for testing new concepts. If trades of The
Manager and/or its Traders are blocked, with those of its customers, The Manager
will, in accordance with ethical trading practice, ensure that assignment of any
split fills is consistent and equitable. The records for the proprietary account(s) of
The Manager and its Traders will be available for review by customers of the
Manager during normal business hours at the Managers place of business by
appointment only.
PERFORMANCE RECORDS:
THE TRADER HAS NOT DIRECTED ANY ACCOUNTS SINCE JANUARY 2015.
THIS GAP IN TIME IS SINCE THE TRADER TOOK TIME OFF FROM TRADING
TO BE EMPLOYEED AS THE SENIOR CURRENCY STRATEGIST, AND DEALER
ON BEHALF OF EUROPEAN INVESTMENT FIRM(S) FROM JANUARY 2015 TO
FEBUARY 2017.
IT IS THE INTENTION FOR THE TRADER TO RESUME THE STRATEGY FROM
APRIL 2017.

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This below performance does not take into consideration of any
management and performance fees.

Strategy Statistics

Strategy has a proven track record over a period of time in 2014 and 2015. The
trader will apply the same risk management principles that generated the following
statistics during the track record generation. Active Alpha Strategy statistics reveal
consistency and a tendency to produce positive returns.

Cumulative return: 7.47% Max. consecutive losing days:


4
Daily mean return: 0.10% Max. consecutive winning days:
10
Annualized return: 26.7% Max. drawdown:
3.43%
Annualized volatility: 8.79% Days to recovery:
9
Sharpe ratio: 3.07 Expected shortfall:
-1.14%
Days profitable: 64% VAR (1 day): -0.84%

Source: Proprietary 50,000 account. Trader: John Joseph Knobel Jr Trader Daily Report 31/01/2015.
Fundseeder Analytics 17/09/2014 - 30/01/2015 a/c TA8032190.

Projected annualized returns and drawdowns at various levels of funding based on


the above actual trading statistics

PAST PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS


No representation is being made that a customers account will or is likely to achieve
profits or incur losses similar to those shown.

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RISK WARNING: Investment in financial instruments involves a high degree of risk. As such, they may not be
suitable for all investors. Investors should ensure they fully understand the risks associated with investing in
financial instruments before deciding to invest as they may lose partial or all invested capital. The information
contained in this document is for general information purposes only and should not be viewed as offering any
personal investment service. Investors may choose to seek independent advice and should not risk more than
they are prepared to lose. Past performance is no guarantee of future returns.

12

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