← Capula Investment Management Llp
Form ADV (full filing)
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FORM ADV
UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS
Primary Business Name: CAPULA INVESTMENT MANAGEMENT LLP CRD Number: 163364
Annual Amendment - All Sections Rev. 10/2021
6/12/2026 11:41:22 AM
WARNING: Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal
prosecution. You must keep this form updated by filing periodic amendments. See Form ADV General Instruction 4.
Item 1 Identifying Information
Responses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the
information in Item 1 should be provided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.
A. Your full legal name (if you are a sole proprietor, your last, first, and middle names):
CAPULA INVESTMENT MANAGEMENT LLP
B. (1) Name under which you primarily conduct your advisory business, if different from Item 1.A.
CAPULA INVESTMENT MANAGEMENT LLP
List on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.
(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box
If you check this box, complete a Schedule R for each relying adviser.
C. If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the
name change is of
your legal name or your primary business name:
D. (1) If you are registered with the SEC as an investment adviser, your SEC file number:
(2) If you report to the SEC as an exempt reporting adviser, your SEC file number: 802-75433
(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers:
CIK Number
1351450
E. (1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 163364
If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.
(2) If you have additional CRD Numbers, your additional CRD numbers:
No Information Filed
F. Principal Office and Place of Business
(1) Address (do not use a P.O. Box):
Number and Street 1: Number and Street 2:
7 CLARGES STREET
City: State: Country: ZIP+4/Postal Code:
LONDON United Kingdom W1J 8AE
If this address is a private residence, check this box:
List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If
you are applying for registration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to
which you are applying for registration or with whom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are reporting to the SEC as an exempt reporting adviser, list the largest twenty-five offices in terms of numbers of employees as of the end of your
most recently completed fiscal year.
(2) Days of week that you normally conduct business at your principal office and place of business:
Monday - Friday Other:
Normal business hours at this location:
8AM - 5PM
(3) Telephone number at this location:
+4420 707 10900
(4) Facsimile number at this location, if any:
+4420 7071 0950
(5) What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of
the end of your most recently completed fiscal year?
0
G. Mailing address, if different from your principal office and place of business address:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
H. If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
Yes No
I. Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and
LinkedIn)?
If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D.
If a website address serves as a portal through which to access other information you have published on the web, you may list the portal without listing
addresses for all of the other information. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly
available social media platforms where you do not control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the
addresses of employee accounts on publicly available social media platforms.
J. Chief Compliance Officer
(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact
information for your Chief Compliance Officer, if you have one. If not, you must complete Item 1.K. below.
Name: Other titles, if any:
Telephone number: Facsimile number, if any:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
Electronic mail (e-mail) address, if Chief Compliance Officer has one:
(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered
under the Investment Company Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS
Employer Identification Number (if any):
Name:
IRS Employer Identification Number:
K. Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions
about this Form ADV, you may provide that information here.
Name: Titles:
Telephone number: Facsimile number, if any:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
Electronic mail (e-mail) address, if contact person has one:
Yes No
L. Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law,
somewhere other than your principal office and place of business?
If "yes," complete Section 1.L. of Schedule D.
Yes No
M. Are you registered with a foreign financial regulatory authority?
Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial
regulatory authority. If "yes," complete Section 1.M. of Schedule D.
Yes No
N. Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?
Yes No
O. Did you have $1 billion or more in assets on the last day of your most recent fiscal year?
If yes, what is the approximate amount of your assets:
$1 billion to less than $10 billion
$10 billion to less than $50 billion
$50 billion or more
For purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using
the total assets shown on the balance sheet for your most recent fiscal year end.
P. Provide your Legal Entity Identifier if you have one:
NYUQZJ2GTTMDCT7UWF49
A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity
identifier.
SECTION 1.B. Other Business Names
No Information Filed
SECTION 1.F. Other Offices
No Information Filed
SECTION 1.I. Website Addresses
List your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not
limited to, Twitter, Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available
social media platform.
Address of Website/Account on Publicly Available Social Media Platform: http://www.capulaglobal.com
SECTION 1.L. Location of Books and Records
Complete the following information for each location at which you keep your books and records, other than your principal office and place of business. You
must complete a separate Schedule D, Section 1.L. for each location.
Name of entity where books and records are kept:
INTERNATIONAL FUND SERVICES (IRELAND) LIMITED
Number and Street 1: Number and Street 2:
78 SIR JOHN ROGERSON'S QUAY
City: State: Country: ZIP+4/Postal Code:
DUBLIN Ireland
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
+35 317075000 +35 317075100
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
FUND-RELATED BOOKS AND RECORDS
Name of entity where books and records are kept:
DATA PROTECT UK LIMITED
Number and Street 1: Number and Street 2:
UNIT 5 FITZROY BUSINESS PARK SANDY LANE
City: State: Country: ZIP+4/Postal Code:
SIDCUP United Kingdom DA14 5NL
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
+447709 399859
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN CAPULA INVESTMENT MANAGEMENT LLP BOOKS AND RECORDS; FUND RELATED BOOKS AND RECORDS
Name of entity where books and records are kept:
AMAZON WEB SERVICES, INC.
Number and Street 1: Number and Street 2:
410 TERRY AVENUE NORTH
City: State: Country: ZIP+4/Postal Code:
SEATTLE Washington United States 98109
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
+1206 266 4064
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN CAPULA INVESTMENT MANAGEMENT LLP BOOKS AND RECORDSS
Name of entity where books and records are kept:
ADVISER COMPLIANCE ASSOCIATES, LLC
Number and Street 1: Number and Street 2:
685 3RD AVENUE
City: State: Country: ZIP+4/Postal Code:
NEW YORK New York United States 10017
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
+1212 951 1030
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN CAPULA INVESTMENT MANAGEMENT LLP BOOKS AND RECORDS
Name of entity where books and records are kept:
APEX CORPORATE AND BUSINESS SERVICES UK LIMITED
Number and Street 1: Number and Street 2:
4TH FLOOR PHOENIX HOUSE 1 STATION HILL
City: State: Country: ZIP+4/Postal Code:
READING United Kingdom RG1 1NB
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
+44118939 3200 +44118939 3162
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN CAPULA INVESTMENT MANAGEMENT LLP BOOKS AND RECORDS
Name of entity where books and records are kept:
SS&C FUND SERVICES (CAYMAN) LTD.
Number and Street 1: Number and Street 2:
39 MARKET STREET SUITE 3205, 2ND FLOOR, GARDENIA COURT, CAMANA BAY
City: State: Country: ZIP+4/Postal Code:
GRAND CAYMAN Cayman Islands KY1-9003
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
+345 9433330
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
FUND-RELATED BOOKS AND RECORDS
Name of entity where books and records are kept:
SYMPHONY COMMUNICATIONS SERVICES LLC
Number and Street 1: Number and Street 2:
640 W CALIFORNIA AVE
City: State: Country: ZIP+4/Postal Code:
SUNNYVALE California United States 94086
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
(650) 733-6660
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN CAPULA INVESTMENT MANAGEMENT LLP BOOKS AND RECORDS
Name of entity where books and records are kept:
MICROSOFT LIMITED
Number and Street 1: Number and Street 2:
2 THAMES VALLEY PARK
City: State: Country: ZIP+4/Postal Code:
BERKSHIRE United Kingdom RG6 1WG
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
+44 3448002400
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN CAPULA INVESTMENT MANAGEMENT LLP BOOKS AND RECORDS
Name of entity where books and records are kept:
GLOBAL RELAY COMMUNICATIONS INC.
Number and Street 1: Number and Street 2:
45 CANNON STREET
City: State: Country: ZIP+4/Postal Code:
LONDON United Kingdom EC4M 5SB
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
+44 2031399064
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN CAPULA INVESTMENT MANAGEMENT LLP BOOKS AND RECORDS
Name of entity where books and records are kept:
MIMECAST SERVICES LIMITED
Number and Street 1: Number and Street 2:
1 FINSBURY AVENUE
City: State: Country: ZIP+4/Postal Code:
LONDON United Kingdom EC4M 5SB
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
+44 2078478700
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CERTAIN CAPULA INVESTMENT MANAGEMENT LLP BOOKS AND RECORDS
Name of entity where books and records are kept:
CITCO FUND ADMINISTRATION (CAYMAN ISLANDS) LIMITED
Number and Street 1: Number and Street 2:
2ND FLOOR, 89 NEXUS WAY CAMANA BAY, PO BOX 31106
City: State: Country: ZIP+4/Postal Code:
GRAND CAYMAN Cayman Islands KY1-1205
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
+1 345 9493977
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
FUND-RELATED BOOKS AND RECORDS
SECTION 1.M. Registration with Foreign Financial Regulatory Authorities
List the name and country, in English, of each foreign financial regulatory authority with which you are registered. You must complete a separate Schedule D
Section 1.M. for each foreign financial regulatory authority with whom you are registered.
Name of Country/Foreign Financial Regulatory Authority:
Other
Other:
UNITED KINGDOM - FINANCIAL CONDUCT AUTHORITY
Item 2 SEC Registration/Reporting
SEC Reporting by Exempt Reporting Advisers
B. Complete this Item 2.B. only if you are reporting to the SEC as an exempt reporting adviser. Check all that apply. You:
(1) qualify for the exemption from registration as an adviser solely to one or more venture capital funds, as defined in rule 203(l)-1;
(2) qualify for the exemption from registration because you act solely as an adviser to private funds and have assets under management, as defined
in rule 203(m)-1, in the United States of less than $150 million;
(3) act solely as an adviser to private funds but you are no longer eligible to check box 2.B.(2) because you have assets under management, as
defined in rule 203(m)-1, in the United States of $150 million or more.
If you check box (2) or (3), complete Section 2.B. of Schedule D.
SECTION 2.B. Private Fund Assets
If you check Item 2.B.(2) or (3), what is the amount of the private fund assets that you manage? $0
NOTE: "Private fund assets" has the same meaning here as it has under rule 203(m)-1. If you are an investment adviser with its principal office and place of
business outside the United States only include private fund assets that you manage at a place of business in the United States.
Item 3 Form of Organization
If you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.
A. How are you organized?
Corporation
Sole Proprietorship
Limited Liability Partnership (LLP)
Partnership
Limited Liability Company (LLC)
Limited Partnership (LP)
Other (specify):
If you are changing your response to this Item, see Part 1A Instruction 4.
B. In what month does your fiscal year end each year?
MARCH
C. Under the laws of what state or country are you organized?
State Country
United Kingdom
If you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the
name of the state or country where you reside.
If you are changing your response to this Item, see Part 1A Instruction 4.
Item 6 Other Business Activities
In this Item, we request information about your firm's other business activities.
A. You are actively engaged in business as a (check all that apply):
(1) broker-dealer (registered or unregistered)
(2) registered representative of a broker-dealer
(3) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(4) futures commission merchant
(5) real estate broker, dealer, or agent
(6) insurance broker or agent
(7) bank (including a separately identifiable department or division of a bank)
(8) trust company
(9) registered municipal advisor
(10) registered security-based swap dealer
(11) major security-based swap participant
(12) accountant or accounting firm
(13) lawyer or law firm
(14) other financial product salesperson (specify):
If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D.
Yes No
B. (1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)?
(2) If yes, is this other business your primary business?
If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name.
Yes No
(3) Do you sell products or provide services other than investment advice to your advisory clients?
If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name.
SECTION 6.A. Names of Your Other Businesses
No Information Filed
SECTION 6.B.(2) Description of Primary Business
Describe your primary business (not your investment advisory business):
If you engage in that business under a different name, provide that name:
SECTION 6.B.(3) Description of Other Products and Services
Describe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above.
If you engage in that business under a different name, provide that name:
Item 7 Financial Industry Affiliations
In this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may
occur between you and your clients.
A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your
advisory affiliates and any person that is under common control with you.
You have a related person that is a (check all that apply):
(1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered)
(2) other investment adviser (including financial planners)
(3) registered municipal advisor
(4) registered security-based swap dealer
(5) major security-based swap participant
(6) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(7) futures commission merchant
(8) banking or thrift institution
(9) trust company
(10) accountant or accounting firm
(11) lawyer or law firm
(12) insurance company or agency
(13) pension consultant
(14) real estate broker or dealer
(15) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(16) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Note that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a
broker-dealer. The number of your firm's employees who perform investment advisory functions should be disclosed under Item 5.B.(1). The number of your
firm's employees who are registered representatives of a broker-dealer should be disclosed under Item 5.B.(2).
Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete
Section 7.A. in Schedule D for your relying advisers. You should complete a Schedule R for each relying adviser.
For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of
Schedule D.
You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with
advisory services you provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the
related person, and the related person does not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the
related person; and (5) you have no reason to believe that your relationship with the related person otherwise creates a conflict of interest with your clients.
You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your
clients (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be
operationally independent under rule 206(4)-2 of the Advisers Act.
SECTION 7.A. Financial Industry Affiliations
Complete a separate Schedule D Section 7.A. for each related person listed in Item 7.A.
1. Legal Name of Related Person:
CAPULA INVESTMENT MANAGEMENT ASIA LIMITED
2. Primary Business Name of Related Person:
CAPULA INVESTMENT MANAGEMENT ASIA LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
802 - 76916
or
Other
4. Related Person's
(a) CRD Number (if any):
164564
(b) CIK Number(s) (if any):
CIK Number
2054478
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the
presumption that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required
to obtain a surprise examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
RULE 203(M)-1 PRIVATE FUND ADVISER EXEMPTION
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Hong Kong - Securities and Futures Commission
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
CAPULA INVESTMENT US LP
2. Primary Business Name of Related Person:
CAPULA INVESTMENT US LP
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 73189
or
Other
4. Related Person's
(a) CRD Number (if any):
157589
(b) CIK Number(s) (if any):
CIK Number
1633019
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the
presumption that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required
to obtain a surprise examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
CAPULA INVESTMENT MANAGEMENT SINGAPORE PTE.LTD.
2. Primary Business Name of Related Person:
CAPULA INVESTMENT MANAGEMENT SINGAPORE PTE.LTD.
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
802 - 120621
or
Other
4. Related Person's
(a) CRD Number (if any):
312483
(b) CIK Number(s) (if any):
CIK Number
2054353
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the
presumption that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required
to obtain a surprise examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
RULE 203(M)-1 PRIVATE FUND ADVISER EXEMPTION
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Singapore - Monetary Authority of Singapore
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
CAPULA INVESTMENT MANAGEMENT SWITZERLAND SARL
2. Primary Business Name of Related Person:
CAPULA INVESTMENT MANAGEMENT SWITZERLAND SARL
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
802 - 134338
or
Other
4. Related Person's
(a) CRD Number (if any):
338211
(b) CIK Number(s) (if any):
CIK Number
2088130
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the
presumption that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required
to obtain a surprise examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
RULE 203(M)-1 PRIVATE FUND ADVISER EXEMPTION
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Switzerland - Swiss Financial Market Supervisory Authority
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
CAPULA INVESTMENT JAPAN LIMITED
2. Primary Business Name of Related Person:
CAPULA INVESTMENT JAPAN LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
802 - 75440
or
Other
4. Related Person's
(a) CRD Number (if any):
163365
(b) CIK Number(s) (if any):
CIK Number
2054428
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the
presumption that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required
to obtain a surprise examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
RULE 203(M)-1 PRIVATE FUND ADVISER EXEMPTION
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Japan - Financial Services Agency
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
CAPULA MANAGEMENT LIMITED
2. Primary Business Name of Related Person:
CAPULA MANAGEMENT LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
802 - 113693
or
Other
4. Related Person's
(a) CRD Number (if any):
163729
(b) CIK Number(s) (if any):
CIK Number
1557017
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the
presumption that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required
to obtain a surprise examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
RULE 203(M)-1 PRIVATE FUND ADVISER EXEMPTION
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
CAPULA GENERAL PARTNER LIMITED
2. Primary Business Name of Related Person:
CAPULA GENERAL PARTNER LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
4. Related Person's
(a) CRD Number (if any):
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the
presumption that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required
to obtain a surprise examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
CAPULA INVESTMENT MANAGEMENT (ME) LIMITED
2. Primary Business Name of Related Person:
CAPULA INVESTMENT MANAGEMENT (ME) LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
802 - 135949
or
Other
4. Related Person's
(a) CRD Number (if any):
341256
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the
presumption that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required
to obtain a surprise examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
RULE 203(M)-1 PRIVATE FUND ADVISER EXEMPTION
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Other - UAE - ADGM /FINANCIAL SERVICES REGULATORY AUTHORITY
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
Item 7 Private Fund Reporting
Yes No
B. Are you an adviser to any private fund?
If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next
sentence and in Instruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt
reporting adviser, and another SEC-registered adviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section
7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser), do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must,
instead, complete Section 7.B.(2) of Schedule D.
In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical
code, or similar designation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or
designation in place of the fund's name.
SECTION 7.B.(1) Private Fund Reporting
Funds per Page: 15 Total Funds: 7
A. PRIVATE FUND
Information About the Private Fund
1. (a) Name of the private fund:
CAPUA VOLATILITY OPPORTUNITIES MASTER FUND LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-3991946405
2. Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
3. (a) Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee, or Director
CAPULA MANAGEMENT LIMITED
(b) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund.
No Information Filed
4. The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940
5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement?
(b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
Name of private fund Private fund identification number
CAPULA VOLATILITY OPPORTUNITIES FUND LIMITED 805-8228558787
CAPULA VOLATILITY OPPORTUNITIES TRUST 805-5003535440
Yes No
(c) Is this a "feeder fund" in a master-feeder arrangement?
(d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
Name of private fund:
Private fund identification number:
(include the "805-" prefix also)
NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1)
for the master-feeder arrangement or reporting on the funds separately.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of
the feeder funds answer the following questions:
Additional Feeder Fund Information : 2 Record(s) Filed.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA VOLATILITY OPPORTUNITIES FUND LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-8228558787
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
CAPULA MANAGEMENT LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA VOLATILITY OPPORTUNITIES TRUST
(b) Private fund identification number:
(include the "805-" prefix also)
805-5003535440
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
INTERTRUST SPV (CAYMAN) LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their
assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued
multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
Yes No
8. (a) Is this private fund a "fund of funds"?
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment
vehicles, regardless of whether they are also private funds or registered investment companies.
(b) If yes, does the private fund invest in funds managed by you or by a related person?
Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment
Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)?
10. What type of fund is the private fund?
hedge fund liquidity fund private equity fund real estate fund securitized asset fund venture capital fund Other private fund:
NOTE: For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
11. Current gross asset value of the private fund:
$ 17,823,611,754
Ownership
12. Minimum investment commitment required of an investor in the private fund:
$ 1,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the
organizational documents of the fund).
13. Approximate number of the private fund's beneficial owners:
46
14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
2%
15. (a) What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
18%
Yes No
(b) If the private fund qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment
Company Act of 1940, are sales of the fund limited to qualified clients?
16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
13%
Your Advisory Services
Yes No
17. (a) Are you a subadviser to this private fund?
(b) If the answer to question 17.(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to
question 17.(a) is "no," leave this question blank.
No Information Filed
Yes No
18. (a) Do any investment advisers (other than the investment advisers listed in Section 7.B.(1).A.3.(b)) advise the private fund?
(b) If the answer to question 18.(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer
to question 18.(a) is "no," leave this question blank.
Name of Other Adviser to private fund SEC file number CRD number
CAPULA INVESTMENT MANAGEMENT ASIA LIMITED 802-76916 164564
CAPULA INVESTMENT JAPAN LIMITED 802-75440 163365
CAPULA INVESTMENT MANAGEMENT (ME) LIMITED 802-135949 341256
CAPULA INVESTMENT MANAGEMENT SINGAPORE PTE.LTD. 802-120621 312483
CAPULA INVESTMENT US LP 801-73189 157589
Yes No
19. Are your clients solicited to invest in the private fund?
NOTE: For purposes of this question, do not consider feeder funds of the private fund.
20. Approximately what percentage of your clients has invested in the private fund?
0%
Private Offering
Yes No
21. Has the private fund ever relied on an exemption from registration of its securities under Regulation D of the Securities Act of 1933?
22. If yes, provide the private fund's Form D file number (if any):
Form D file number
021-322819
B. SERVICE PROVIDERS
Auditors
Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit?
(2) If the answer to question 23.(a)(1) is "yes," are the financial statements prepared in accordance with U.S. GAAP?
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm,
you must complete questions (b) through (f) separately for each auditing firm.
Additional Auditor Information : 1 Record(s) Filed.
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing
firm, you must complete questions (b) through (f) separately for each auditing firm.
(b) Name of the auditing firm:
ERNST & YOUNG LTD.
(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):
City: State: Country:
GRAND CAYMAN Cayman Islands
Yes No
(d) Is the auditing firm an independent public accountant?
(e) Is the auditing firm registered with the Public Company Accounting Oversight Board?
If yes, Public Company Accounting Oversight Board-Assigned Number:
1655
(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in
accordance with its rules?
Yes No
(g) Are the private fund's audited financial statements for the most recently completed fiscal year distributed to the private fund's
investors?
(h) Do all of the reports prepared by the auditing firm for the private fund since your last annual updating amendment contain unqualified opinions?
Yes No Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.
Prime Broker
Yes No
24. (a) Does the private fund use one or more prime brokers?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private
fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
Additional Prime Broker Information : 7 Record(s) Filed.
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BARCLAYS BANK PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BARCLAYS CAPITAL INC.
(c) If the prime broker is registered with the SEC, its registration number:
8 - 41342
CRD Number (if any):
19714
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BNP PARIBAS, LONDON BRANCH
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BOFA SECURITIES, INC.
(c) If the prime broker is registered with the SEC, its registration number:
8 - 69787
CRD Number (if any):
283942
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
J.P. MORGAN SECURITIES LLC
(c) If the prime broker is registered with the SEC, its registration number:
8 - 35008
CRD Number (if any):
79
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
J.P. MORGAN SECURITIES PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
SOCIETE GENERALE INTERNATIONAL LIMITED
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
Custodian
Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets?
If the answer to question 25.(a) is "yes," respond to questions (b) through (g) below for each custodian the private fund uses. If the private fund
uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
Additional Custodian Information : 10 Record(s) Filed.
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BARCLAYS BANK PLC
(c) Primary business name of custodian:
BARCLAYS BANK PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
G5GSEF7VJP5I7OUK5573
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BARCLAYS CAPITAL INC.
(c) Primary business name of custodian:
BARCLAYS CAPITAL INC.
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 41342
CRD Number (if any):
19714
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BNP PARIBAS, LONDON BRANCH
(c) Primary business name of custodian:
BNP PARIBAS, LONDON BRANCH
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BOFA SECURITIES, INC.
(c) Primary business name of custodian:
BOFA SECURITIES, INC.
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 69787
CRD Number (if any):
283942
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
HSBC BANK PLC
(c) Primary business name of custodian:
HSBC BANK PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
MP6I5ZYZBEU3UXPYFY54
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
J.P. MORGAN SECURITIES LLC
(c) Primary business name of custodian:
J.P. MORGAN SECURITIES LLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 35008
CRD Number (if any):
79
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
J.P. MORGAN SECURITIES PLC
(c) Primary business name of custodian:
J.P. MORGAN SECURITIES PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
K6Q0W1PS1L1O4IQL9C32
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
SOCIETE GENERALE INTERNATIONAL LIMITED
(c) Primary business name of custodian:
SOCIETE GENERALE INTERNATIONAL LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
0IKLU6X1B10WK7X42C15
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
THE BANK OF NEW YORK MELLON (INTERNATIONAL) LIMITED
(c) Primary business name of custodian:
THE BANK OF NEW YORK MELLON (INTERNATIONAL) LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
549300KP56LL8NKKFL47
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
THE BANK OF NEW YORK MELLON, LONDON BRANCH
(c) Primary business name of custodian:
THE BANK OF NEW YORK MELLON, LONDON BRANCH
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
Administrator
Yes No
26. (a) Does the private fund use an administrator other than your firm?
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you
must complete questions (b) through (f) separately for each administrator.
Additional Administrator Information : 1 Record(s) Filed.
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one
administrator, you must complete questions (b) through (f) separately for each administrator.
(b) Name of administrator:
SS&C FUND SERVICES (CAYMAN) LTD
(c) Location of administrator (city, state and country):
City: State: Country:
GRAND CAYMAN Cayman Islands
Yes No
(d) Is the administrator a related person of your firm?
(e) Does the administrator prepare and send investor account statements to the private fund's investors?
Yes (provided to all investors) Some (provided to some but not all investors) No (provided to no investors)
(f) If the answer to question 26.(e) is "no" or "some," who sends the investor account statements to the (rest of the) private fund's
investors? If investor account statements are not sent to the (rest of the) private fund's investors, respond "not applicable."
27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not
your related person?
100%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any
relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including
allocations) was the valuation determined by such person.
Marketers
Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes?
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or
similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund
uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.
Additional Marketer Information : 1 Record(s) Filed.
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor,
or similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private
fund uses. If the private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.
Yes No
(b) Is the marketer a related person of your firm?
(c) Name of the marketer:
MITSUBISHI UFJ ALTERNATIVE INVESTMENTS CO LTD.
(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
-
and CRD Number (if any):
(e) Location of the marketer's office used principally by the private fund (city, state and country):
City: State: Country:
TOKYO Japan
Yes No
(f) Does the marketer market the private fund through one or more websites?
(g) If the answer to question 28.(f) is "yes," list the website address(es):
No Information Filed
A. PRIVATE FUND
Information About the Private Fund
1. (a) Name of the private fund:
CAPULA ALTERNATIVE MARKETS ALPHA MASTER FUND LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-8730518305
2. Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
3. (a) Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee, or Director
CAPULA MANAGEMENT LIMITED
(b) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund.
No Information Filed
4. The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940
5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement?
(b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
Name of private fund Private fund identification number
CAPULA ALTERNATIVE MARKETS ALPHA FUND LIMITED 805-3938665420
Yes No
(c) Is this a "feeder fund" in a master-feeder arrangement?
(d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
Name of private fund:
Private fund identification number:
(include the "805-" prefix also)
NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1)
for the master-feeder arrangement or reporting on the funds separately.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of
the feeder funds answer the following questions:
Additional Feeder Fund Information : 1 Record(s) Filed.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA ALTERNATIVE MARKETS ALPHA FUND LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-3938665420
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
CAPULA MANAGEMENT LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their
assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued
multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
Yes No
8. (a) Is this private fund a "fund of funds"?
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment
vehicles, regardless of whether they are also private funds or registered investment companies.
(b) If yes, does the private fund invest in funds managed by you or by a related person?
Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment
Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)?
10. What type of fund is the private fund?
hedge fund liquidity fund private equity fund real estate fund securitized asset fund venture capital fund Other private fund:
NOTE: For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
11. Current gross asset value of the private fund:
$ 2,000,000
Ownership
12. Minimum investment commitment required of an investor in the private fund:
$ 5,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the
organizational documents of the fund).
13. Approximate number of the private fund's beneficial owners:
1
14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
0%
15. (a) What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
0%
Yes No
(b) If the private fund qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment
Company Act of 1940, are sales of the fund limited to qualified clients?
16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%
Your Advisory Services
Yes No
17. (a) Are you a subadviser to this private fund?
(b) If the answer to question 17.(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to
question 17.(a) is "no," leave this question blank.
No Information Filed
Yes No
18. (a) Do any investment advisers (other than the investment advisers listed in Section 7.B.(1).A.3.(b)) advise the private fund?
(b) If the answer to question 18.(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer
to question 18.(a) is "no," leave this question blank.
Name of Other Adviser to private fund SEC file number CRD number
CAPULA INVESTMENT MANAGEMENT LLP 802-75433 163364
CAPULA INVESTMENT US LP 801-73189 157589
Yes No
19. Are your clients solicited to invest in the private fund?
NOTE: For purposes of this question, do not consider feeder funds of the private fund.
20. Approximately what percentage of your clients has invested in the private fund?
0%
Private Offering
Yes No
21. Has the private fund ever relied on an exemption from registration of its securities under Regulation D of the Securities Act of 1933?
22. If yes, provide the private fund's Form D file number (if any):
No Information Filed
B. SERVICE PROVIDERS
Auditors
Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit?
(2) If the answer to question 23.(a)(1) is "yes," are the financial statements prepared in accordance with U.S. GAAP?
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm,
you must complete questions (b) through (f) separately for each auditing firm.
Additional Auditor Information : 1 Record(s) Filed.
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing
firm, you must complete questions (b) through (f) separately for each auditing firm.
(b) Name of the auditing firm:
AUDITORS ERNST & YOUNG LTD.
(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):
City: State: Country:
GRAND CAYMAN Cayman Islands
Yes No
(d) Is the auditing firm an independent public accountant?
(e) Is the auditing firm registered with the Public Company Accounting Oversight Board?
If yes, Public Company Accounting Oversight Board-Assigned Number:
1655
(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in
accordance with its rules?
Yes No
(g) Are the private fund's audited financial statements for the most recently completed fiscal year distributed to the private fund's
investors?
(h) Do all of the reports prepared by the auditing firm for the private fund since your last annual updating amendment contain unqualified opinions?
Yes No Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.
Prime Broker
Yes No
24. (a) Does the private fund use one or more prime brokers?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private
fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
Additional Prime Broker Information : 6 Record(s) Filed.
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BARCLAYS BANK PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BARCLAYS CAPITAL INC.
(c) If the prime broker is registered with the SEC, its registration number:
8 - 41342
CRD Number (if any):
19714
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BOFA SECURITIES, INC.
(c) If the prime broker is registered with the SEC, its registration number:
8 - 69787
CRD Number (if any):
283942
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
J.P. MORGAN SECURITIES LLC
(c) If the prime broker is registered with the SEC, its registration number:
8 - 35008
CRD Number (if any):
79
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
J.P. MORGAN SECURITIES PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
MORGAN STANLEY & CO. INTERNATIONAL PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
Custodian
Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets?
If the answer to question 25.(a) is "yes," respond to questions (b) through (g) below for each custodian the private fund uses. If the private fund
uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
Additional Custodian Information : 8 Record(s) Filed.
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BARCLAYS BANK PLC
(c) Primary business name of custodian:
BARCLAYS BANK PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
G5GSEF7VJP5I7OUK5573
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BARCLAYS CAPITAL INC.
(c) Primary business name of custodian:
BARCLAYS CAPITAL INC.
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 41342
CRD Number (if any):
19714
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BOFA SECURITIES, INC.
(c) Primary business name of custodian:
BOFA SECURITIES, INC.
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 69787
CRD Number (if any):
283942
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
HSBC BANK PLC
(c) Primary business name of custodian:
HSBC BANK PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
MP6I5ZYZBEU3UXPYFY54
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
J.P. MORGAN SECURITIES LLC
(c) Primary business name of custodian:
J.P. MORGAN SECURITIES LLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New Jersey United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 35008
CRD Number (if any):
79
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
J.P. MORGAN SECURITIES PLC
(c) Primary business name of custodian:
J.P. MORGAN SECURITIES PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
K6Q0W1PS1L1O4IQL9C32
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
MORGAN STANLEY & CO. INTERNATIONAL PLC
(c) Primary business name of custodian:
MORGAN STANLEY & CO. INTERNATIONAL PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
4PQUHN3JPFGFNF3BB653
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
THE BANK OF NEW YORK MELLON (INTERNATIONAL) LIMITED
(c) Primary business name of custodian:
THE BANK OF NEW YORK MELLON (INTERNATIONAL) LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
549300KP56LL8NKKFL47
Administrator
Yes No
26. (a) Does the private fund use an administrator other than your firm?
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you
must complete questions (b) through (f) separately for each administrator.
Additional Administrator Information : 1 Record(s) Filed.
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one
administrator, you must complete questions (b) through (f) separately for each administrator.
(b) Name of administrator:
CITCO FUND ADMINISTRATION (CAYMAN ISLANDS) LIMITED
(c) Location of administrator (city, state and country):
City: State: Country:
GRAND CAYMAN Cayman Islands
Yes No
(d) Is the administrator a related person of your firm?
(e) Does the administrator prepare and send investor account statements to the private fund's investors?
Yes (provided to all investors) Some (provided to some but not all investors) No (provided to no investors)
(f) If the answer to question 26.(e) is "no" or "some," who sends the investor account statements to the (rest of the) private fund's
investors? If investor account statements are not sent to the (rest of the) private fund's investors, respond "not applicable."
27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not
your related person?
0%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any
relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including
allocations) was the valuation determined by such person.
Marketers
Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes?
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or
similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund
uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.
No Information Filed
A. PRIVATE FUND
Information About the Private Fund
1. (a) Name of the private fund:
CAPULA ENHANCED FIXED INCOME MASTER FUND LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-8757523610
2. Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
3. (a) Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee, or Director
CAPULA MANAGEMENT LIMITED
(b) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund.
No Information Filed
4. The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940
5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement?
(b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
Name of private fund Private fund identification number
CAPULA EFI I LIMITED 805-6632758963
CAPULA EFI II LIMITED 805-8895731176
CAPULA ENHANCED FIXED INCOME TRUST 805-8049741955
Yes No
(c) Is this a "feeder fund" in a master-feeder arrangement?
(d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
Name of private fund:
Private fund identification number:
(include the "805-" prefix also)
NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1)
for the master-feeder arrangement or reporting on the funds separately.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of
the feeder funds answer the following questions:
Additional Feeder Fund Information : 3 Record(s) Filed.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA EFI I LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-6632758963
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
CAPULA MANAGEMENT LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA EFI II LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-8895731176
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
CAPULA MANAGEMENT LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA ENHANCED FIXED INCOME TRUST
(b) Private fund identification number:
(include the "805-" prefix also)
805-8049741955
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
INTERTRUST SPV (CAYMAN) LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their
assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued
multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
Yes No
8. (a) Is this private fund a "fund of funds"?
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment
vehicles, regardless of whether they are also private funds or registered investment companies.
(b) If yes, does the private fund invest in funds managed by you or by a related person?
Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment
Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)?
10. What type of fund is the private fund?
hedge fund liquidity fund private equity fund real estate fund securitized asset fund venture capital fund Other private fund:
NOTE: For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
11. Current gross asset value of the private fund:
$ 23,435,535,837
Ownership
12. Minimum investment commitment required of an investor in the private fund:
$ 50,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the
organizational documents of the fund).
13. Approximate number of the private fund's beneficial owners:
92
14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
1%
15. (a) What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
2%
Yes No
(b) If the private fund qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment
Company Act of 1940, are sales of the fund limited to qualified clients?
16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
0%
Your Advisory Services
Yes No
17. (a) Are you a subadviser to this private fund?
(b) If the answer to question 17.(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to
question 17.(a) is "no," leave this question blank.
No Information Filed
Yes No
18. (a) Do any investment advisers (other than the investment advisers listed in Section 7.B.(1).A.3.(b)) advise the private fund?
(b) If the answer to question 18.(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer
to question 18.(a) is "no," leave this question blank.
Name of Other Adviser to private fund SEC file number CRD number
CAPULA INVESTMENT MANAGEMENT ASIA LIMITED 802-76916 164564
CAPULA INVESTMENT JAPAN LIMITED 802-75440 163365
CAPULA INVESTMENT MANAGEMENT (ME) LIMITED 802-135949 341256
CAPULA INVESTMENT MANAGEMENT SINGAPORE PTE.LTD. 802-120621 312483
CAPULA INVESTMENT US LP 801-73189 157589
Yes No
19. Are your clients solicited to invest in the private fund?
NOTE: For purposes of this question, do not consider feeder funds of the private fund.
20. Approximately what percentage of your clients has invested in the private fund?
0%
Private Offering
Yes No
21. Has the private fund ever relied on an exemption from registration of its securities under Regulation D of the Securities Act of 1933?
22. If yes, provide the private fund's Form D file number (if any):
No Information Filed
B. SERVICE PROVIDERS
Auditors
Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit?
(2) If the answer to question 23.(a)(1) is "yes," are the financial statements prepared in accordance with U.S. GAAP?
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm,
you must complete questions (b) through (f) separately for each auditing firm.
Additional Auditor Information : 1 Record(s) Filed.
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing
firm, you must complete questions (b) through (f) separately for each auditing firm.
(b) Name of the auditing firm:
ERNST & YOUNG LTD.
(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):
City: State: Country:
GRAND CAYMAN Cayman Islands
Yes No
(d) Is the auditing firm an independent public accountant?
(e) Is the auditing firm registered with the Public Company Accounting Oversight Board?
If yes, Public Company Accounting Oversight Board-Assigned Number:
1655
(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in
accordance with its rules?
Yes No
(g) Are the private fund's audited financial statements for the most recently completed fiscal year distributed to the private fund's
investors?
(h) Do all of the reports prepared by the auditing firm for the private fund since your last annual updating amendment contain unqualified opinions?
Yes No Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.
Prime Broker
Yes No
24. (a) Does the private fund use one or more prime brokers?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private
fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
Additional Prime Broker Information : 4 Record(s) Filed.
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BARCLAYS BANK PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BOFA SECURITIES, INC.
(c) If the prime broker is registered with the SEC, its registration number:
8 - 69787
CRD Number (if any):
283942
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
J.P. MORGAN SECURITIES LLC
(c) If the prime broker is registered with the SEC, its registration number:
8 - 35008
CRD Number (if any):
79
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
SOCIETE GENERALE INTERNATIONAL LIMITED
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
Custodian
Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets?
If the answer to question 25.(a) is "yes," respond to questions (b) through (g) below for each custodian the private fund uses. If the private fund
uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
Additional Custodian Information : 7 Record(s) Filed.
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BARCLAYS BANK PLC
(c) Primary business name of custodian:
BARCLAYS BANK PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
G5GSEF7VJP5I7OUK5573
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BOFA SECURITIES, INC.
(c) Primary business name of custodian:
BOFA SECURITIES, INC.
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 69787
CRD Number (if any):
283942
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
549300HN4UKV1E2R3U73
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
HSBC BANK PLC
(c) Primary business name of custodian:
HSBC BANK PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
MP6I5ZYZBEU3UXPYFY54
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
J.P. MORGAN SECURITIES LLC
(c) Primary business name of custodian:
J.P. MORGAN SECURITIES LLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 35008
CRD Number (if any):
79
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
SOCIETE GENERALE INTERNATIONAL LIMITED
(c) Primary business name of custodian:
SOCIETE GENERALE INTERNATIONAL LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
0IKLU6X1B10WK7X42C15
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
THE BANK OF NEW YORK MELLON (INTERNATIONAL) LIMITED
(c) Primary business name of custodian:
THE BANK OF NEW YORK MELLON (INTERNATIONAL) LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
549300KP56LL8NKKFL47
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
THE BANK OF NEW YORK MELLON, LONDON BRANCH
(c) Primary business name of custodian:
THE BANK OF NEW YORK MELLON, LONDON BRANCH
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
Administrator
Yes No
26. (a) Does the private fund use an administrator other than your firm?
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you
must complete questions (b) through (f) separately for each administrator.
Additional Administrator Information : 1 Record(s) Filed.
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one
administrator, you must complete questions (b) through (f) separately for each administrator.
(b) Name of administrator:
SS&C FUND SERVICES (CAYMAN) LTD
(c) Location of administrator (city, state and country):
City: State: Country:
GRAND CAYMAN Cayman Islands
Yes No
(d) Is the administrator a related person of your firm?
(e) Does the administrator prepare and send investor account statements to the private fund's investors?
Yes (provided to all investors) Some (provided to some but not all investors) No (provided to no investors)
(f) If the answer to question 26.(e) is "no" or "some," who sends the investor account statements to the (rest of the) private fund's
investors? If investor account statements are not sent to the (rest of the) private fund's investors, respond "not applicable."
27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not
your related person?
100%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any
relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including
allocations) was the valuation determined by such person.
Marketers
Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes?
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or
similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund
uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.
No Information Filed
A. PRIVATE FUND
Information About the Private Fund
1. (a) Name of the private fund:
CAPULA GLOBAL RELATIVE VALUE MASTER FUND LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-2162872270
2. Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
3. (a) Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee, or Director
CAPULA MANAGEMENT LIMITED
(b) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund.
No Information Filed
4. The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940
5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Other - CAYMAN ISLANDS MONETARY AUTHORITY
Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement?
(b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
Name of private fund Private fund identification number
CAPULA GLOBAL RELATIVE VALUE FUND L.P. 805-3454369038
CAPULA GLOBAL RELATIVE VALUE FUND LIMITED 805-5717491750
CAPULA GLOBAL RELATIVE VALUE TRUST 805-6820198155
CAPULA GRV III LIMITED 805-4665177252
Yes No
(c) Is this a "feeder fund" in a master-feeder arrangement?
(d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
Name of private fund:
Private fund identification number:
(include the "805-" prefix also)
NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1)
for the master-feeder arrangement or reporting on the funds separately.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of
the feeder funds answer the following questions:
Additional Feeder Fund Information : 4 Record(s) Filed.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA GLOBAL RELATIVE VALUE FUND L.P.
(b) Private fund identification number:
(include the "805-" prefix also)
805-3454369038
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
CAPULA GENERAL PARTNER LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Other - CAYMAN ISLANDS MONETARY AUTHORITY
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA GLOBAL RELATIVE VALUE FUND LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-5717491750
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
CAPULA MANAGEMENT LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Other - CAYMAN ISLANDS MONETARY AUTHORITY
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA GLOBAL RELATIVE VALUE TRUST
(b) Private fund identification number:
(include the "805-" prefix also)
805-6820198155
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
INTERTRUST SPV (CAYMAN) LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Other - CAYMAN ISLANDS MONETARY AUTHORITY
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA GRV III LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-4665177252
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
CAPULA MANAGEMENT LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Other - CAYMAN ISLANDS MONETARY AUTHORITY
NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their
assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued
multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
Yes No
8. (a) Is this private fund a "fund of funds"?
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment
vehicles, regardless of whether they are also private funds or registered investment companies.
(b) If yes, does the private fund invest in funds managed by you or by a related person?
Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment
Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)?
10. What type of fund is the private fund?
hedge fund liquidity fund private equity fund real estate fund securitized asset fund venture capital fund Other private fund:
NOTE: For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
11. Current gross asset value of the private fund:
$ 446,509,825,782
Ownership
12. Minimum investment commitment required of an investor in the private fund:
$ 5,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the
organizational documents of the fund).
13. Approximate number of the private fund's beneficial owners:
466
14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
15%
15. (a) What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
13%
Yes No
(b) If the private fund qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment
Company Act of 1940, are sales of the fund limited to qualified clients?
16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
27%
Your Advisory Services
Yes No
17. (a) Are you a subadviser to this private fund?
(b) If the answer to question 17.(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to
question 17.(a) is "no," leave this question blank.
No Information Filed
Yes No
18. (a) Do any investment advisers (other than the investment advisers listed in Section 7.B.(1).A.3.(b)) advise the private fund?
(b) If the answer to question 18.(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer
to question 18.(a) is "no," leave this question blank.
Name of Other Adviser to private fund SEC file number CRD number
CAPULA INVESTMENT MANAGEMENT ASIA LIMITED 802-76916 164564
CAPULA INVESTMENT JAPAN LIMITED 802-75440 163365
CAPULA INVESTMENT MANAGEMENT (ME) LIMITED 802-135949 341256
CAPULA INVESTMENT MANAGEMENT SINGAPORE PTE.LTD. 802-120621 312483
CAPULA INVESTMENT US LP 801-73189 157589
Yes No
19. Are your clients solicited to invest in the private fund?
NOTE: For purposes of this question, do not consider feeder funds of the private fund.
20. Approximately what percentage of your clients has invested in the private fund?
11%
Private Offering
Yes No
21. Has the private fund ever relied on an exemption from registration of its securities under Regulation D of the Securities Act of 1933?
22. If yes, provide the private fund's Form D file number (if any):
Form D file number
021-107437
021-107439
B. SERVICE PROVIDERS
Auditors
Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit?
(2) If the answer to question 23.(a)(1) is "yes," are the financial statements prepared in accordance with U.S. GAAP?
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm,
you must complete questions (b) through (f) separately for each auditing firm.
Additional Auditor Information : 1 Record(s) Filed.
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing
firm, you must complete questions (b) through (f) separately for each auditing firm.
(b) Name of the auditing firm:
ERNST & YOUNG LTD.
(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):
City: State: Country:
GRAND CAYMAN Cayman Islands
Yes No
(d) Is the auditing firm an independent public accountant?
(e) Is the auditing firm registered with the Public Company Accounting Oversight Board?
If yes, Public Company Accounting Oversight Board-Assigned Number:
1655
(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in
accordance with its rules?
Yes No
(g) Are the private fund's audited financial statements for the most recently completed fiscal year distributed to the private fund's
investors?
(h) Do all of the reports prepared by the auditing firm for the private fund since your last annual updating amendment contain unqualified opinions?
Yes No Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.
Prime Broker
Yes No
24. (a) Does the private fund use one or more prime brokers?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private
fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
Additional Prime Broker Information : 11 Record(s) Filed.
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BARCLAYS BANK PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BARCLAYS CAPITAL INC.
(c) If the prime broker is registered with the SEC, its registration number:
8 - 41342
CRD Number (if any):
19714
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BARCLAYS CAPITAL SECURITES LIMITED
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BNP PARIBAS, LONDON BRANCH
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BOFA SECURITIES, INC.
(c) If the prime broker is registered with the SEC, its registration number:
8 - 69787
CRD Number (if any):
283942
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
J.P. MORGAN SECURITIES LLC
(c) If the prime broker is registered with the SEC, its registration number:
8 - 35008
CRD Number (if any):
79
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
J.P. MORGAN SECURITIES PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
MERRILL LYNCH INTERNATIONAL
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
MORGAN STANLEY & CO. INTERNATIONAL PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
SG AMERICAS SECURITIES, LLC
(c) If the prime broker is registered with the SEC, its registration number:
8 - 66125
CRD Number (if any):
128351
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
SOCIETE GENERALE INTERNATIONAL LIMITED
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
Custodian
Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets?
If the answer to question 25.(a) is "yes," respond to questions (b) through (g) below for each custodian the private fund uses. If the private fund
uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
Additional Custodian Information : 13 Record(s) Filed.
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BARCLAYS BANK PLC
(c) Primary business name of custodian:
BARCLAYS BANK PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
G5GSEF7VJP5I7OUK5573
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BARCLAYS CAPITAL INC.
(c) Primary business name of custodian:
BARCLAYS CAPITAL INC.
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 41342
CRD Number (if any):
19714
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
AC28XWWI3WIBK2824319
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BARCLAYS CAPITAL SECURITIES LIMITED
(c) Primary business name of custodian:
BARCLAYS CAPITAL SECURITIES LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
K9WDOH4D2PYBSLSOB
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BNP PARIBAS, LONDON BRANCH
(c) Primary business name of custodian:
BNP PARIBAS, LONDON BRANCH
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BOFA SECURITIES, INC.
(c) Primary business name of custodian:
BOFA SECURITIES, INC.
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 69787
CRD Number (if any):
283942
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
8NAV47T0Y26Q87Y0QP81
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
HSBC BANK PLC
(c) Primary business name of custodian:
HSBC BANK PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
MP6I5ZYZBEU3UXPYFY54
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
J.P. MORGAN SECURITIES LLC
(c) Primary business name of custodian:
J.P. MORGAN SECURITIES LLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 35008
CRD Number (if any):
79
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
J.P. MORGAN SECURITIES PLC
(c) Primary business name of custodian:
J.P. MORGAN SECURITIES PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
K6Q0W1PS1L1O4IQL9C32
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
MERRILL LYNCH INTERNATIONAL
(c) Primary business name of custodian:
MERRILL LYNCH INTERNATIONAL
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
GGDZP1UYGU9STUHRDP48
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
MORGAN STANLEY & CO. INTERNATIONAL PLC
(c) Primary business name of custodian:
MORGAN STANLEY & CO. INTERNATIONAL PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
4PQUHN3JPFGFNF3BB653
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
SOCIETE GENERALE INTERNATIONAL LIMITED
(c) Primary business name of custodian:
SOCIETE GENERALE INTERNATIONAL LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
0IKLU6X1B10WK7X42C15
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
STATE STREET BANK AND TRUST COMPANY
(c) Primary business name of custodian:
STATE STREET BANK AND TRUST COMPANY
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
BOSTON Massachusetts United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
571474TGEMMWANRLN572
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
THE BANK OF NEW YORK MELLON, LONDON BRANCH
(c) Primary business name of custodian:
THE BANK OF NEW YORK MELLON, LONDON BRANCH
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
Administrator
Yes No
26. (a) Does the private fund use an administrator other than your firm?
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you
must complete questions (b) through (f) separately for each administrator.
Additional Administrator Information : 1 Record(s) Filed.
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one
administrator, you must complete questions (b) through (f) separately for each administrator.
(b) Name of administrator:
SS&C FUND SERVICES (CAYMAN) LTD.
(c) Location of administrator (city, state and country):
City: State: Country:
GRAND CAYMAN Cayman Islands
Yes No
(d) Is the administrator a related person of your firm?
(e) Does the administrator prepare and send investor account statements to the private fund's investors?
Yes (provided to all investors) Some (provided to some but not all investors) No (provided to no investors)
(f) If the answer to question 26.(e) is "no" or "some," who sends the investor account statements to the (rest of the) private fund's
investors? If investor account statements are not sent to the (rest of the) private fund's investors, respond "not applicable."
27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not
your related person?
100%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any
relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including
allocations) was the valuation determined by such person.
Marketers
Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes?
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or
similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund
uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.
Additional Marketer Information : 1 Record(s) Filed.
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor,
or similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private
fund uses. If the private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.
Yes No
(b) Is the marketer a related person of your firm?
(c) Name of the marketer:
MITSUBISHI UFJ ALTERNATIVE INVESTMETNT CO LTD.
(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
-
and CRD Number (if any):
(e) Location of the marketer's office used principally by the private fund (city, state and country):
City: State: Country:
TOKYO Japan
Yes No
(f) Does the marketer market the private fund through one or more websites?
(g) If the answer to question 28.(f) is "yes," list the website address(es):
No Information Filed
A. PRIVATE FUND
Information About the Private Fund
1. (a) Name of the private fund:
CAPULA MULTI STRATEGY MASTER FUND LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-9868516114
2. Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
3. (a) Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee, or Director
CAPULA MANAGEMENT LIMITED
(b) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund.
No Information Filed
4. The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940
5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement?
(b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
Name of private fund Private fund identification number
CAPULA MULTI STRATEGY FUND LIMITED 805-4044430695
CAPULA MULTI STRATEGY I LIMITED 805-2646479353
CAPULA MULTI STRATEGY TRUST 805-7279431445
Yes No
(c) Is this a "feeder fund" in a master-feeder arrangement?
(d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
Name of private fund:
Private fund identification number:
(include the "805-" prefix also)
NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1)
for the master-feeder arrangement or reporting on the funds separately.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of
the feeder funds answer the following questions:
Additional Feeder Fund Information : 3 Record(s) Filed.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA MULTI STRATEGY FUND LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-4044430695
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
CAPULA MANAGEMENT LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA MULTI STRATEGY I LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-2646479353
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
CAPULA MANAGEMENT LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA MULTI STRATEGY TRUST
(b) Private fund identification number:
(include the "805-" prefix also)
805-7279431445
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
INTERTRUST SPV (CAYMAN) LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their
assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued
multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
Yes No
8. (a) Is this private fund a "fund of funds"?
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment
vehicles, regardless of whether they are also private funds or registered investment companies.
(b) If yes, does the private fund invest in funds managed by you or by a related person?
Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment
Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)?
10. What type of fund is the private fund?
hedge fund liquidity fund private equity fund real estate fund securitized asset fund venture capital fund Other private fund:
NOTE: For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
11. Current gross asset value of the private fund:
$ 22,847,950,200
Ownership
12. Minimum investment commitment required of an investor in the private fund:
$ 5,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the
organizational documents of the fund).
13. Approximate number of the private fund's beneficial owners:
143
14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
3%
15. (a) What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
9%
Yes No
(b) If the private fund qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment
Company Act of 1940, are sales of the fund limited to qualified clients?
16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
6%
Your Advisory Services
Yes No
17. (a) Are you a subadviser to this private fund?
(b) If the answer to question 17.(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to
question 17.(a) is "no," leave this question blank.
No Information Filed
Yes No
18. (a) Do any investment advisers (other than the investment advisers listed in Section 7.B.(1).A.3.(b)) advise the private fund?
(b) If the answer to question 18.(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer
to question 18.(a) is "no," leave this question blank.
Name of Other Adviser to private fund SEC file number CRD number
BLUE SWELL ASSET MANAGEMENT PRIVATE LIMITED 801-117552 297731
CAPULA INVESTMENT MANAGEMENT ASIA LIMITED 802-76916 164564
CAPULA INVESTMENT JAPAN LIMITED 802-75440 163365
CAPULA INVESTMENT MANAGEMENT (ME) LIMITED 802-135949 341256
CAPULA INVESTMENT MANAGEMENT SINGAPORE PTE.LTD. 802-120621 312483
CAPULA INVESTMENT MANAGEMENT SWITZERLAND SARL 802-134338 338211
CAPULA INVESTMENT US LP 801-73189 157589
CINCTIVE CAPITAL MANAGEMENT LP 801-116962 304726
REDHEDGE ASSET MANAGEMENT LLP 802-131366 331762
Yes No
19. Are your clients solicited to invest in the private fund?
NOTE: For purposes of this question, do not consider feeder funds of the private fund.
20. Approximately what percentage of your clients has invested in the private fund?
0%
Private Offering
Yes No
21. Has the private fund ever relied on an exemption from registration of its securities under Regulation D of the Securities Act of 1933?
22. If yes, provide the private fund's Form D file number (if any):
Form D file number
021-455966
B. SERVICE PROVIDERS
Auditors
Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit?
(2) If the answer to question 23.(a)(1) is "yes," are the financial statements prepared in accordance with U.S. GAAP?
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm,
you must complete questions (b) through (f) separately for each auditing firm.
Additional Auditor Information : 1 Record(s) Filed.
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing
firm, you must complete questions (b) through (f) separately for each auditing firm.
(b) Name of the auditing firm:
ERNST & YOUNG LTD.
(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):
City: State: Country:
GRAND CAYMAN Cayman Islands
Yes No
(d) Is the auditing firm an independent public accountant?
(e) Is the auditing firm registered with the Public Company Accounting Oversight Board?
If yes, Public Company Accounting Oversight Board-Assigned Number:
1655
(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in
accordance with its rules?
Yes No
(g) Are the private fund's audited financial statements for the most recently completed fiscal year distributed to the private fund's
investors?
(h) Do all of the reports prepared by the auditing firm for the private fund since your last annual updating amendment contain unqualified opinions?
Yes No Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.
Prime Broker
Yes No
24. (a) Does the private fund use one or more prime brokers?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private
fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
Additional Prime Broker Information : 8 Record(s) Filed.
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BARCLAYS BANK PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BARCLAYS CAPITAL INC.
(c) If the prime broker is registered with the SEC, its registration number:
8 - 41342
CRD Number (if any):
19714
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BNP PARIBAS, LONDON BRANCH
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BOFA SECURITIES, INC.
(c) If the prime broker is registered with the SEC, its registration number:
8 - 69787
CRD Number (if any):
283942
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
J.P. MORGAN SECURITIES LLC
(c) If the prime broker is registered with the SEC, its registration number:
8 - 35008
CRD Number (if any):
79
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
J.P. MORGAN SECURITIES PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
MORGAN STANLEY & CO. INTERNATIONAL PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
SOCIETE GENERALE INTERNATIONAL LIMITED
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
Custodian
Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets?
If the answer to question 25.(a) is "yes," respond to questions (b) through (g) below for each custodian the private fund uses. If the private fund
uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
Additional Custodian Information : 11 Record(s) Filed.
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BARCLAYS BANK PLC
(c) Primary business name of custodian:
BARCLAYS BANK PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
G5GSEF7VJP5I7OUK5573
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BARCLAYS CAPITAL INC.
(c) Primary business name of custodian:
BARCLAYS CAPITAL INC.
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 41342
CRD Number (if any):
19714
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
AC28XWWI3WIBK2824319
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BNP PARIBAS, LONDON BRANCH
(c) Primary business name of custodian:
BNP PARIBAS, LONDON BRANCH
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BOFA SECURITIES, INC.
(c) Primary business name of custodian:
BOFA SECURITIES, INC.
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 69787
CRD Number (if any):
283942
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
HSBC BANK PLC
(c) Primary business name of custodian:
HSBC BANK PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
MP6I5ZYZBEU3UXPYFY54
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
J.P. MORGAN SECURITIES LLC
(c) Primary business name of custodian:
J.P. MORGAN SECURITIES LLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 35008
CRD Number (if any):
79
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
J.P. MORGAN SECURITIES PLC
(c) Primary business name of custodian:
J.P. MORGAN SECURITIES PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
K6Q0W1PS1L1O4IQL9C32
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
MORGAN STANLEY & CO. INTERNATIONAL PLC
(c) Primary business name of custodian:
MORGAN STANLEY & CO. INTERNATIONAL PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
4PQUHN3JPFGFNF3BB653
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
SOCIETE GENERALE INTERNATIONAL LIMITED
(c) Primary business name of custodian:
SOCIETE GENERALE INTERNATIONAL LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
0IKLU6X1B10WK7X42C15
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
THE BANK OF NEW YORK MELLON (INTERNATIONAL) LIMITED
(c) Primary business name of custodian:
THE BANK OF NEW YORK MELLON (INTERNATIONAL) LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
549300KP56LL8NKKFL47
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
THE BANK OF NEW YORK MELLON, LONDON BRANCH
(c) Primary business name of custodian:
THE BANK OF NEW YORK MELLON, LONDON BRANCH
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
Administrator
Yes No
26. (a) Does the private fund use an administrator other than your firm?
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you
must complete questions (b) through (f) separately for each administrator.
Additional Administrator Information : 1 Record(s) Filed.
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one
administrator, you must complete questions (b) through (f) separately for each administrator.
(b) Name of administrator:
CITCO FUND ADMINISTRATION (CAYMAN ISLANDS) LIMITED
(c) Location of administrator (city, state and country):
City: State: Country:
GRAND CAYMAN Cayman Islands
Yes No
(d) Is the administrator a related person of your firm?
(e) Does the administrator prepare and send investor account statements to the private fund's investors?
Yes (provided to all investors) Some (provided to some but not all investors) No (provided to no investors)
(f) If the answer to question 26.(e) is "no" or "some," who sends the investor account statements to the (rest of the) private fund's
investors? If investor account statements are not sent to the (rest of the) private fund's investors, respond "not applicable."
27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not
your related person?
100%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any
relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including
allocations) was the valuation determined by such person.
Marketers
Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes?
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or
similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund
uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.
No Information Filed
A. PRIVATE FUND
Information About the Private Fund
1. (a) Name of the private fund:
CAPULA TACTICAL MACRO MASTER FUND LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-4981722839
2. Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
3. (a) Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee, or Director
CAPULA MANAGEMENT LIMITED
(b) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund.
No Information Filed
4. The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940
5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Other - CAYMAN ISLANDS MONETARY AUTHORITY
Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement?
(b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
Name of private fund Private fund identification number
CAPULA TACTICAL MACRO FUND LIMITED 805-2980399972
CAPULA TACTICAL MACRO TRUST 805-4963989445
Yes No
(c) Is this a "feeder fund" in a master-feeder arrangement?
(d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
Name of private fund:
Private fund identification number:
(include the "805-" prefix also)
NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1)
for the master-feeder arrangement or reporting on the funds separately.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of
the feeder funds answer the following questions:
Additional Feeder Fund Information : 2 Record(s) Filed.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA TACTICAL MACRO FUND LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-2980399972
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
CAPULA MANAGEMENT LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA TACTICAL MACRO TRUST
(b) Private fund identification number:
(include the "805-" prefix also)
805-4963989445
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
CAPULA MANAGEMENT LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Other - CAYMAN ISLANDS MONETARY AUTHORITY
NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their
assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued
multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
Yes No
8. (a) Is this private fund a "fund of funds"?
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment
vehicles, regardless of whether they are also private funds or registered investment companies.
(b) If yes, does the private fund invest in funds managed by you or by a related person?
Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment
Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)?
10. What type of fund is the private fund?
hedge fund liquidity fund private equity fund real estate fund securitized asset fund venture capital fund Other private fund:
NOTE: For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
11. Current gross asset value of the private fund:
$ 27,006,481,454
Ownership
12. Minimum investment commitment required of an investor in the private fund:
$ 5,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the
organizational documents of the fund).
13. Approximate number of the private fund's beneficial owners:
77
14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
26%
15. (a) What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
57%
Yes No
(b) If the private fund qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment
Company Act of 1940, are sales of the fund limited to qualified clients?
16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
42%
Your Advisory Services
Yes No
17. (a) Are you a subadviser to this private fund?
(b) If the answer to question 17.(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to
question 17.(a) is "no," leave this question blank.
No Information Filed
Yes No
18. (a) Do any investment advisers (other than the investment advisers listed in Section 7.B.(1).A.3.(b)) advise the private fund?
(b) If the answer to question 18.(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer
to question 18.(a) is "no," leave this question blank.
Name of Other Adviser to private fund SEC file number CRD number
CAPULA INVESTMENT JAPAN LIMITED 802-75440 163365
CAPULA INVESTMENT MANAGEMENT (ME) LIMITED 802-135949 341256
CAPULA INVESTMENT US LP 801-73189 157589
Yes No
19. Are your clients solicited to invest in the private fund?
NOTE: For purposes of this question, do not consider feeder funds of the private fund.
20. Approximately what percentage of your clients has invested in the private fund?
30%
Private Offering
Yes No
21. Has the private fund ever relied on an exemption from registration of its securities under Regulation D of the Securities Act of 1933?
22. If yes, provide the private fund's Form D file number (if any):
Form D file number
021-386665
B. SERVICE PROVIDERS
Auditors
Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit?
(2) If the answer to question 23.(a)(1) is "yes," are the financial statements prepared in accordance with U.S. GAAP?
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm,
you must complete questions (b) through (f) separately for each auditing firm.
Additional Auditor Information : 1 Record(s) Filed.
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing
firm, you must complete questions (b) through (f) separately for each auditing firm.
(b) Name of the auditing firm:
ERNST & YOUNG LTD.
(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):
City: State: Country:
GRAND CAYMAN Cayman Islands
Yes No
(d) Is the auditing firm an independent public accountant?
(e) Is the auditing firm registered with the Public Company Accounting Oversight Board?
If yes, Public Company Accounting Oversight Board-Assigned Number:
1655
(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in
accordance with its rules?
Yes No
(g) Are the private fund's audited financial statements for the most recently completed fiscal year distributed to the private fund's
investors?
(h) Do all of the reports prepared by the auditing firm for the private fund since your last annual updating amendment contain unqualified opinions?
Yes No Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.
Prime Broker
Yes No
24. (a) Does the private fund use one or more prime brokers?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private
fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
Additional Prime Broker Information : 6 Record(s) Filed.
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BARCLAYS BANK PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BARCLAYS CAPITAL INC.
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BNP PARIBAS, LONDON BRANCH
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BOFA SECURITIES, INC.
(c) If the prime broker is registered with the SEC, its registration number:
8 - 69787
CRD Number (if any):
283942
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
J.P. MORGAN SECURITIES LLC
(c) If the prime broker is registered with the SEC, its registration number:
8 - 35008
CRD Number (if any):
79
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
SOCIETE GENERALE INTERNATIONAL LIMITED
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
Custodian
Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets?
If the answer to question 25.(a) is "yes," respond to questions (b) through (g) below for each custodian the private fund uses. If the private fund
uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
Additional Custodian Information : 9 Record(s) Filed.
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BARCLAYS BANK PLC
(c) Primary business name of custodian:
BARCLAYS BANK PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
G5GSEF7VJP5I7OUK5573
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BARCLAYS CAPITAL INC.
(c) Primary business name of custodian:
BARCLAYS CAPITAL INC.
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
AC28XWWI3WIBK2824319
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BNP PARIBAS, LONDON BRANCH
(c) Primary business name of custodian:
BNP PARIBAS, LONDON BRANCH
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BOFA SECURITIES, INC.
(c) Primary business name of custodian:
BOFA SECURITIES, INC.
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 69787
CRD Number (if any):
283942
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
HSBC BANK PLC
(c) Primary business name of custodian:
HSBC BANK PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
MP6I5ZYZBEU3UXPYFY54
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
J.P. MORGAN SECURITIES LLC
(c) Primary business name of custodian:
J.P. MORGAN SECURITIES LLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 35008
CRD Number (if any):
79
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
SOCIETE GENERALE INTERNATIONAL LIMITED
(c) Primary business name of custodian:
SOCIETE GENERALE INTERNATIONAL LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
0IKLU6X1B10WK7X42C15
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
THE BANK OF NEW YORK MELLON (INTERNATIONAL) LIMITED
(c) Primary business name of custodian:
THE BANK OF NEW YORK MELLON (INTERNATIONAL) LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
549300KP56LL8NKKFL47
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
THE BANK OF NEW YORK MELLON, LONDON BRANCH
(c) Primary business name of custodian:
THE BANK OF NEW YORK MELLON, LONDON BRANCH
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
Administrator
Yes No
26. (a) Does the private fund use an administrator other than your firm?
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you
must complete questions (b) through (f) separately for each administrator.
Additional Administrator Information : 1 Record(s) Filed.
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one
administrator, you must complete questions (b) through (f) separately for each administrator.
(b) Name of administrator:
SS&C FUND SERVICES (CAYMAN) LTD
(c) Location of administrator (city, state and country):
City: State: Country:
GRAND CAYMAN Cayman Islands
Yes No
(d) Is the administrator a related person of your firm?
(e) Does the administrator prepare and send investor account statements to the private fund's investors?
Yes (provided to all investors) Some (provided to some but not all investors) No (provided to no investors)
(f) If the answer to question 26.(e) is "no" or "some," who sends the investor account statements to the (rest of the) private fund's
investors? If investor account statements are not sent to the (rest of the) private fund's investors, respond "not applicable."
27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not
your related person?
100%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any
relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including
allocations) was the valuation determined by such person.
Marketers
Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes?
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or
similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund
uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.
Additional Marketer Information : 1 Record(s) Filed.
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor,
or similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private
fund uses. If the private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.
Yes No
(b) Is the marketer a related person of your firm?
(c) Name of the marketer:
MITSUBISHI UFJ ALTERNATIVE INVESTMENTS CO LTD.
(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
-
and CRD Number (if any):
(e) Location of the marketer's office used principally by the private fund (city, state and country):
City: State: Country:
TOKYO Japan
Yes No
(f) Does the marketer market the private fund through one or more websites?
(g) If the answer to question 28.(f) is "yes," list the website address(es):
No Information Filed
A. PRIVATE FUND
Information About the Private Fund
1. (a) Name of the private fund:
CAPULA TAIL RISK MASTER FUND LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-9956713521
2. Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
3. (a) Name(s) of General Partner, Manager, Trustee, or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee, or Director
CAPULA MANAGEMENT LIMITED
(b) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund.
No Information Filed
4. The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of 1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of 1940
5. List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Other - CAYMAN ISLANDS MONETARY AUTHORITY
Yes No
6. (a) Is this a "master fund" in a master-feeder arrangement?
(b) If yes, what is the name and private fund identification number (if any) of the feeder funds investing in this private fund?
Name of private fund Private fund identification number
CAPULA ENHANCED EQUITY FUND LIMITED 805-7101756104
CAPULA ENHANCED EQUITY TRUST 805-1239208269
CAPULA TAIL RISK FUND LIMITED 805-9903304586
CAPULA TAIL RISK TRUST 805-2760619751
CAPULA TRF II LIMITED 805-6881383654
CAPULA TRF III LP 805-4068392554
Yes No
(c) Is this a "feeder fund" in a master-feeder arrangement?
(d) If yes, what is the name and private fund identification number (if any) of the master fund in which this private fund invests?
Name of private fund:
Private fund identification number:
(include the "805-" prefix also)
NOTE: You must complete question 6 for each master-feeder arrangement regardless of whether you are filing a single Schedule D, Section 7.B.(1)
for the master-feeder arrangement or reporting on the funds separately.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for each of
the feeder funds answer the following questions:
Additional Feeder Fund Information : 6 Record(s) Filed.
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA ENHANCED EQUITY FUND LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-7101756104
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
CAPULA MANAGEMENT LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA ENHANCED EQUITY TRUST
(b) Private fund identification number:
(include the "805-" prefix also)
805-1239208269
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
INTERTRUST SPV (CAYMAN) LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA TAIL RISK FUND LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-9903304586
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
CAPULA MANAGEMENT LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Other - CAYMAN ISLANDS MONETARY AUTHORITY
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA TAIL RISK TRUST
(b) Private fund identification number:
(include the "805-" prefix also)
805-2760619751
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
INTERTRUST SPV (CAYMAN) LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Other - CAYMAN ISLANDS MONETARY AUTHORITY
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA TRF II LIMITED
(b) Private fund identification number:
(include the "805-" prefix also)
805-6881383654
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Cayman Islands
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
CAPULA MANAGEMENT LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Cayman Islands - Cayman Islands Monetary Authority
7. If you are filing a single Schedule D, Section 7.B.(1) for a master-feeder arrangement according to the instructions to this Section 7.B.(1), for
each of the feeder funds answer the following questions:
(a) Name of the private fund:
CAPULA TRF III LP
(b) Private fund identification number:
(include the "805-" prefix also)
805-4068392554
(c) Under the laws of what state or country is the private fund organized:
State: Country:
Delaware United States
(d) (1) Name(s) of General Partner, Manager, Trustee or Directors (or persons serving in a similar capacity):
Name of General Partner, Manager, Trustee or Director
CAPULA GENERAL PARTNER LIMITED
(d) (2) If filing an umbrella registration, identify the filing adviser and/or relying adviser(s) that sponsor(s) or manage(s) this private fund:
No Information Filed
(e) The private fund (check all that apply; you must check at least one):
(1) qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment Company Act of
1940
(2) qualifies for the exclusion from the definition of investment company under section 3(c)(7) of the Investment Company Act of
1940
(f) List the name and country, in English, of each foreign financial regulatory authority with which the private fund is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
Other - DELAWARE
NOTE: For purposes of questions 6 and 7, in a master-feeder arrangement, one or more funds ("feeder funds") invest all or substantially all of their
assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued
multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
Yes No
8. (a) Is this private fund a "fund of funds"?
NOTE: For purposes of this question only, answer "yes" if the fund invests 10 percent or more of its total assets in other pooled investment
vehicles, regardless of whether they are also private funds or registered investment companies.
(b) If yes, does the private fund invest in funds managed by you or by a related person?
Yes No
9. During your last fiscal year, did the private fund invest in securities issued by investment companies registered under the Investment
Company Act of 1940 (other than "money market funds," to the extent provided in Instruction 6.e.)?
10. What type of fund is the private fund?
hedge fund liquidity fund private equity fund real estate fund securitized asset fund venture capital fund Other private fund:
NOTE: For definitions of these fund types, please see Instruction 6 of the Instructions to Part 1A.
11. Current gross asset value of the private fund:
$ 31,251,168,119
Ownership
12. Minimum investment commitment required of an investor in the private fund:
$ 5,000,000
NOTE: Report the amount routinely required of investors who are not your related persons (even if different from the amount set forth in the
organizational documents of the fund).
13. Approximate number of the private fund's beneficial owners:
45
14. What is the approximate percentage of the private fund beneficially owned by you and your related persons:
2%
15. (a) What is the approximate percentage of the private fund beneficially owned (in the aggregate) by funds of funds:
18%
Yes No
(b) If the private fund qualifies for the exclusion from the definition of investment company under section 3(c)(1) of the Investment
Company Act of 1940, are sales of the fund limited to qualified clients?
16. What is the approximate percentage of the private fund beneficially owned by non-United States persons:
40%
Your Advisory Services
Yes No
17. (a) Are you a subadviser to this private fund?
(b) If the answer to question 17.(a) is "yes," provide the name and SEC file number, if any, of the adviser of the private fund. If the answer to
question 17.(a) is "no," leave this question blank.
No Information Filed
Yes No
18. (a) Do any investment advisers (other than the investment advisers listed in Section 7.B.(1).A.3.(b)) advise the private fund?
(b) If the answer to question 18.(a) is "yes," provide the name and SEC file number, if any, of the other advisers to the private fund. If the answer
to question 18.(a) is "no," leave this question blank.
Name of Other Adviser to private fund SEC file number CRD number
BLACKROCK FINANCIAL MANAGEMENT, INC 801-48433 107105
BLACKROCK INVESTMENT MANAGEMENT (UK) LIMITED 802-76129 162379
CAPULA INVESTMENT MANAGEMENT ASIA LIMITED 802-76916 164564
CAPULA INVESTMENT JAPAN LIMITED 802-75440 163365
CAPULA INVESTMENT MANAGEMENT (ME) LIMITED 802-135949 341256
CAPULA INVESTMENT MANAGEMENT SINGAPORE PTE.LTD. 802-120621 312483
CAPULA INVESTMENT US LP 801-73189 157589
Yes No
19. Are your clients solicited to invest in the private fund?
NOTE: For purposes of this question, do not consider feeder funds of the private fund.
20. Approximately what percentage of your clients has invested in the private fund?
0%
Private Offering
Yes No
21. Has the private fund ever relied on an exemption from registration of its securities under Regulation D of the Securities Act of 1933?
22. If yes, provide the private fund's Form D file number (if any):
Form D file number
021-204196
021-395857
B. SERVICE PROVIDERS
Auditors
Yes No
23. (a) (1) Are the private fund's financial statements subject to an annual audit?
(2) If the answer to question 23.(a)(1) is "yes," are the financial statements prepared in accordance with U.S. GAAP?
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing firm,
you must complete questions (b) through (f) separately for each auditing firm.
Additional Auditor Information : 1 Record(s) Filed.
If the answer to question 23.(a)(1) is "yes," respond to questions (b) through (h) below. If the private fund uses more than one auditing
firm, you must complete questions (b) through (f) separately for each auditing firm.
(b) Name of the auditing firm:
ERNST & YOUNG LTD.
(c) The location of the auditing firm's office responsible for the private fund's audit (city, state and country):
City: State: Country:
GRAND CAYMAN Cayman Islands
Yes No
(d) Is the auditing firm an independent public accountant?
(e) Is the auditing firm registered with the Public Company Accounting Oversight Board?
If yes, Public Company Accounting Oversight Board-Assigned Number:
1655
(f) If "yes" to (e) above, is the auditing firm subject to regular inspection by the Public Company Accounting Oversight Board in
accordance with its rules?
Yes No
(g) Are the private fund's audited financial statements for the most recently completed fiscal year distributed to the private fund's
investors?
(h) Do all of the reports prepared by the auditing firm for the private fund since your last annual updating amendment contain unqualified opinions?
Yes No Report Not Yet Received
If you check "Report Not Yet Received," you must promptly file an amendment to your Form ADV to update your response when the report is available.
Prime Broker
Yes No
24. (a) Does the private fund use one or more prime brokers?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the private
fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
Additional Prime Broker Information : 10 Record(s) Filed.
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BARCLAYS BANK PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BARCLAYS CAPITAL INC.
(c) If the prime broker is registered with the SEC, its registration number:
8 - 41342
CRD Number (if any):
19714
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BARCLAYS CAPITAL SECURITES LIMITED
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BNP PARIBAS, LONDON BRANCH
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
BOFA SECURITIES, INC.
(c) If the prime broker is registered with the SEC, its registration number:
8 - 69787
CRD Number (if any):
283942
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
J.P. MORGAN SECURITIES LLC
(c) If the prime broker is registered with the SEC, its registration number:
8 - 35008
CRD Number (if any):
79
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
J.P. MORGAN SECURITIES PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
MERRILL LYNCH INTERNATIONAL
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
MORGAN STANLEY & CO. INTERNATIONAL PLC
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
If the answer to question 24.(a) is "yes," respond to questions (b) through (e) below for each prime broker the private fund uses. If the
private fund uses more than one prime broker, you must complete questions (b) through (e) separately for each prime broker.
(b) Name of the prime broker:
SOCIETE GENERALE INTERNATIONAL LIMITED
(c) If the prime broker is registered with the SEC, its registration number:
-
CRD Number (if any):
(d) Location of prime broker's office used principally by the private fund (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Does this prime broker act as custodian for some or all of the private fund's assets?
Custodian
Yes No
25. (a) Does the private fund use any custodians (including the prime brokers listed above) to hold some or all of its assets?
If the answer to question 25.(a) is "yes," respond to questions (b) through (g) below for each custodian the private fund uses. If the private fund
uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
Additional Custodian Information : 14 Record(s) Filed.
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BARCLAYS BANK PLC
(c) Primary business name of custodian:
BARCLAYS BANK PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
G5GSEF7VJP5I7OUK5573
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BARCLAYS CAPITAL INC.
(c) Primary business name of custodian:
BARCLAYS CAPITAL INC.
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 41342
CRD Number (if any):
19714
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
AC28XWWI3WIBK2824319
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BARCLAYS CAPITAL SECURITIES LIMITED
(c) Primary business name of custodian:
BARCLAYS CAPITAL SECURITIES LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
K9WDOH4D2PYBSLSOB
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BNP PARIBAS, LONDON BRANCH
(c) Primary business name of custodian:
BNP PARIBAS, LONDON BRANCH
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
BOFA SECURITIES, INC.
(c) Primary business name of custodian:
BOFA SECURITIES, INC.
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 69787
CRD Number (if any):
283942
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
8NAV47T0Y26Q87Y0QP81
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
HSBC BANK PLC
(c) Primary business name of custodian:
HSBC BANK PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
MP6I5ZYZBEU3UXPYFY54
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
J.P. MORGAN SECURITIES LLC
(c) Primary business name of custodian:
J.P. MORGAN SECURITIES LLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
NEW YORK New York United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
8 - 35008
CRD Number (if any):
79
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
J.P. MORGAN SECURITIES PLC
(c) Primary business name of custodian:
J.P. MORGAN SECURITIES PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
K6Q0W1PS1L1O4IQL9C32
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
MERRILL LYNCH INTERNATIONAL
(c) Primary business name of custodian:
MERRILL LYNCH INTERNATIONAL
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
GGDZP1UYGU9STUHRDP48
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
MORGAN STANLEY & CO. INTERNATIONAL PLC
(c) Primary business name of custodian:
MORGAN STANLEY & CO. INTERNATIONAL PLC
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
4PQUHN3JPFGFNF3BB653
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
SOCIETE GENERALE INTERNATIONAL LIMITED
(c) Primary business name of custodian:
SOCIETE GENERALE INTERNATIONAL LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
0IKLU6X1B10WK7X42C15
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
STATE STREET BANK AND TRUST COMPANY
(c) Primary business name of custodian:
STATE STREET BANK AND TRUST COMPANY
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
BOSTON Massachusetts United States
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
571474TGEMMWANRLN572
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
THE BANK OF NEW YORK MELLON (INTERNATIONAL) LIMITED
(c) Primary business name of custodian:
THE BANK OF NEW YORK MELLON (INTERNATIONAL) LIMITED
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
HPFHU0OQ28E4N0NFVK49
If the answer to question 25.(a) is "yes," respond to questions (b) through g) below for each custodian the private fund uses. If the private
fund uses more than one custodian, you must complete questions (b) through (g) separately for each custodian.
(b) Legal name of custodian:
THE BANK OF NEW YORK MELLON, LONDON BRANCH
(c) Primary business name of custodian:
THE BANK OF NEW YORK MELLON, LONDON BRANCH
(d) The location of the custodian's office responsible for custody of the private fund's assets (city, state and country):
City: State: Country:
LONDON United Kingdom
Yes No
(e) Is the custodian a related person of your firm?
(f) If the custodian is a broker-dealer, provide its SEC registration number (if any):
-
CRD Number (if any):
(g) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity
identifier (if any)
Administrator
Yes No
26. (a) Does the private fund use an administrator other than your firm?
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one administrator, you
must complete questions (b) through (f) separately for each administrator.
Additional Administrator Information : 1 Record(s) Filed.
If the answer to question 26.(a) is "yes," respond to questions (b) through (f) below. If the private fund uses more than one
administrator, you must complete questions (b) through (f) separately for each administrator.
(b) Name of administrator:
SS&C FUND SERVICES (CAYMAN) LTD.
(c) Location of administrator (city, state and country):
City: State: Country:
GRAND CAYMAN Cayman Islands
Yes No
(d) Is the administrator a related person of your firm?
(e) Does the administrator prepare and send investor account statements to the private fund's investors?
Yes (provided to all investors) Some (provided to some but not all investors) No (provided to no investors)
(f) If the answer to question 26.(e) is "no" or "some," who sends the investor account statements to the (rest of the) private fund's
investors? If investor account statements are not sent to the (rest of the) private fund's investors, respond "not applicable."
27. During your last fiscal year, what percentage of the private fund's assets (by value) was valued by a person, such as an administrator, that is not
your related person?
100%
Include only those assets where (i) such person carried out the valuation procedure established for that asset, if any, including obtaining any
relevant quotes, and (ii) the valuation used for purposes of investor subscriptions, redemptions or distributions, and fee calculations (including
allocations) was the valuation determined by such person.
Marketers
Yes No
28. (a) Does the private fund use the services of someone other than you or your employees for marketing purposes?
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor, or
similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private fund
uses. If the private fund uses more than one marketer you must complete questions (b) through (g) separately for each marketer.
Additional Marketer Information : 1 Record(s) Filed.
You must answer "yes" whether the person acts as a placement agent, consultant, finder, introducer, municipal advisor or other solicitor,
or similar person. If the answer to question 28.(a) is "yes," respond to questions (b) through (g) below for each such marketer the private
fund uses. If the private fund uses more than one marketer, you must complete questions (b) through (g) separately for each marketer.
Yes No
(b) Is the marketer a related person of your firm?
(c) Name of the marketer:
MITSUBISHI UFJ ALTERNATIVE INVESTMENTS CO LTD.
(d) If the marketer is registered with the SEC, its file number (e.g., 801-, 8-, or 866-):
-
and CRD Number (if any):
(e) Location of the marketer's office used principally by the private fund (city, state and country):
City: State: Country:
TOKYO Japan
Yes No
(f) Does the marketer market the private fund through one or more websites?
(g) If the answer to question 28.(f) is "yes," list the website address(es):
No Information Filed
Funds per Page: 15 Total Funds: 7
SECTION 7.B.(2) Private Fund Reporting
No Information Filed
Item 10 Control Persons
In this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are filing an umbrella registration, the information in Item 10
should be provided for the filing adviser only.
If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners
and executive officers. Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported
on either Schedule A or Schedule B (or both) that you filed with your initial application or report, you must complete Schedule C.
Yes No
A. Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies?
If yes, complete Section 10.A. of Schedule D.
B. If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities
Exchange Act of 1934, please complete Section 10.B. of Schedule D.
SECTION 10.A. Control Persons
No Information Filed
SECTION 10.B. Control Person Public Reporting Companies
B. If any person named in Schedules A, B, or C, or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities
Exchange Act of 1934, please provide the following information (you must complete a separate Schedule D Section 10.B. for each public reporting
company):
(1) Full legal name of the public reporting company: AFFILIATED MANAGERS GROUP,
INC.
(2) The public reporting company's CIK number (Central Index Key number that the SEC assigns to each reporting 1004434
company):
B. If any person named in Schedules A, B, or C, or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities
Exchange Act of 1934, please provide the following information (you must complete a separate Schedule D Section 10.B. for each public reporting
company):
(1) Full legal name of the public reporting company: DAI-ICHI LIFE GROUP,
INC.
(2) The public reporting company's CIK number (Central Index Key number that the SEC assigns to each reporting 948518
company):
Item 11 Disclosure Information
In this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to
determine whether to grant your application for registration, to decide whether to revoke your registration or to place limitations on your activities as an
investment adviser, and to identify potential problem areas to focus on during our on-site examinations. One event may result in "yes" answers to more than
one of the questions below. In accordance with General Instruction 5 to Form ADV, "you" and "your" include the filing adviser and all relying advisers under an
umbrella registration.
Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all
of your officers, partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you.
If you are a "separately identifiable department or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are.
If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years
following the date of the event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your
disclosure to ten years following the date of an event only in responding to Items 11.A.(1), 11.A.(2), 11.B.(1), 11.B.(2), 11.D.(4), and 11.H.(1)(a). For purposes of
calculating this ten-year period, the date of an event is the date the final order, judgment, or decree was entered, or the date any rights of appeal from preliminary
orders, judgments, or decrees lapsed.
You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11.
Yes No
Do any of the events below involve you or any of your supervised persons?
For "yes" answers to the following questions, complete a Criminal Action DRP:
A. In the past ten years, have you or any advisory affiliate: Yes No
(1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?
(2) been charged with any felony?
If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.A.(2) to
charges that are currently pending.
B. In the past ten years, have you or any advisory affiliate:
(1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving:
investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury,
forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses?
(2) been charged with a misdemeanor listed in Item 11.B.(1)?
If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.B.(2) to
charges that are currently pending.
For "yes" answers to the following questions, complete a Regulatory Action DRP:
C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: Yes No
(1) found you or any advisory affiliate to have made a false statement or omission?
(2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?
(3) found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) entered an order against you or any advisory affiliate in connection with investment-related activity?
(5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?
D. Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority:
(1) ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?
(2) ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?
(3) ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business
denied, suspended, revoked, or restricted?
(4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?
(5) ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory
affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity?
E. Has any self-regulatory organization or commodities exchange ever:
(1) found you or any advisory affiliate to have made a false statement or omission?
(2) found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule
violation" under a plan approved by the SEC)?
(3) found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you
or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities?
F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or
suspended?
G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C.,
11.D., or 11.E.?
For "yes" answers to the following questions, complete a Civil Judicial Action DRP:
H. (1) Has any domestic or foreign court: Yes No
(a) in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?
(b) ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?
(c) ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a
state or foreign financial regulatory authority?
(2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)?
Schedule A
Direct Owners and Executive Officers
1. Complete Schedule A only if you are submitting an initial application or report. Schedule A asks for information about your direct owners and executive
officers. Use Schedule C to amend this information.
2. Direct Owners and Executive Officers. List below the names of:
(a) each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer(Chief Compliance Officer is
required if you are registered or applying for registration and cannot be more than one individual), director, and any other individuals with similar
status or functions;
(b) if you are organized as a corporation, each shareholder that is a direct owner of 5% or more of a class of your voting securities, unless you are a
public reporting company (a company subject to Section 12 or 15(d) of the Exchange Act);
Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a
class of your voting securities. For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild,
parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing
the same residence; or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the
security.
(c) if you are organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or
have contributed, 5% or more of your capital;
(d) in the case of a trust that directly owns 5% or more of a class of your voting securities, or that has the right to receive upon dissolution, or has
contributed, 5% or more of your capital, the trust and each trustee; and
(e) if you are organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5%
or more of your capital, and (ii) if managed by elected managers, all elected managers.
3. Do you have any indirect owners to be reported on Schedule B? Yes No
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or
"I" if the owner or executive officer is an individual.
5. Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or
member; and for shareholders or members, the class of securities owned (if more than one is issued).
6. Ownership codes are: NA - less than 5% B - 10% but less than 25% D - 50% but less than 75%
A - 5% but less than 10% C - 25% but less than 50% E - 75% or more
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does
not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are
control persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
FULL LEGAL NAME (Individuals: Last DE/FE/I Title or Status Date Title or Status Ownership Control PR CRD No. If None: S.S. No. and Date
Name, First Name, Middle Name) Acquired MM/YYYY Code Person of Birth, IRS Tax No. or Employer ID
No.
HUO, YAN I CHIEF INVESTMENT 10/2005 C Y N 6015494
OFFICER, MEMBER
ASAI, MASAO I MEMBER 10/2005 A Y N 5074569
BLOOM, JONATHAN, SIMON I CHIEF LEGAL 07/2011 NA Y N 5853891
OFFICER
WU, BING-LE I MEMBER 04/2008 NA N N 2780250
CML HOLDINGS LLC FE MEMBER 10/2017 B N N
CAPULA INVESTMENT SERVICES LTD FE MEMBER 06/2005 NA Y N
DHAWAN, SALIL I CHIEF OPERATING 07/2024 NA Y N 7580650
OFFICER, DEPUTY
CEO
BEDWIN, MICHELLE, ANNE I CHIEF COMPLIANCE 04/2023 NA Y N 6684678
OFFICER
CORSALINI, ENRICO, JOSEPH I CHIEF EXECUTIVE 07/2024 NA Y N 2303118
OFFICER
POWELL, MARK, JOHN I CHIEF FINANCIAL 01/2025 NA Y N 8125850
OFFICER
DAIICHI LIFE GROUP, INC. FE SHAREHOLDER 05/2025 B N N
Schedule B
Indirect Owners
1. Complete Schedule B only if you are submitting an initial application or report. Schedule B asks for information about your indirect owners; you must first
complete Schedule A, which asks for information about your direct owners. Use Schedule C to amend this information.
2. Indirect Owners. With respect to each owner listed on Schedule A (except individual owners), list below:
(a) in the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct
the sale of, 25% or more of a class of a voting security of that corporation;
For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent,
grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence;
or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security.
(b) in the case of an owner that is a partnership, all general partners and those limited and special partners that have the right to receive upon
dissolution, or have contributed, 25% or more of the partnership's capital;
(c) in the case of an owner that is a trust, the trust and each trustee; and
(d) in the case of an owner that is a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have
contributed, 25% or more of the LLC's capital, and (ii) if managed by elected managers, all elected managers.
3. Continue up the chain of ownership listing all 25% owners at each level. Once a public reporting company (a company subject to Sections 12 or 15(d) of
the Exchange Act) is reached, no further ownership information need be given.
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or
"I" if the owner is an individual.
5. Complete the Status column by entering the owner's status as partner, trustee, elected manager, shareholder, or member; and for shareholders or
members, the class of securities owned (if more than one is issued).
6. Ownership codes are: C - 25% but less than 50% E - 75% or more
D - 50% but less than 75% F - Other (general partner, trustee, or elected manager)
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does
not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are
control persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
FULL LEGAL NAME (Individuals: Last DE/FE/I Entity in Which Status Date Status Ownership Control PR CRD No. If None: S.S. No. and
Name, First Name, Middle Name) Interest is Owned Acquired Code Person Date of Birth, IRS Tax No. or
MM/YYYY Employer ID No.
CAPULA MANAGEMENT LIMITED FE CAPULA SHAREHOLDER 06/2005 F Y N
INVESTMENT
SERVICES LTD
HUO, YAN I CAPULA SHAREHOLDER 08/2005 C Y N 6015494
MANAGEMENT
LIMITED
AMG CONCEPTION HOLDINGS 3 LTD. FE CML HOLDINGS MEMBER 10/2017 E Y N
LLC
AMG GAMMA HOLDINGS LTD. FE AMG CONCEPTION MEMBER 06/2016 E Y N
HOLDINGS 3 LTD.
AFFILIATED MANAGERS GROUP, INC. DE AMG GAMMA MEMBER 06/2016 E Y Y
HOLDINGS LTD.
Schedule D - Miscellaneous
You may use the space below to explain a response to an Item or to provide any other information.
IN SECTION 7.B.(1), THE INFORMATION RELATING TO GROSS ASSET VALUES OF PRIVATE FUNDS IS REPORTED AS OF MARCH 31, 2026, WITH RESPECT TO
CAPULA GLOBAL RELATIVE VALUE MASTER FUND LIMITED, CAPULA TAIL RISK MASTER FUND LIMITED, CAPULA ENHANCED FIXED INCOME MASTER FUND
LIMITED, CAPULA VOLATILITY OPPORTUNITIES MASTER FUND LIMITED, CAPULA TACTICAL MACRO MASTER FUND LIMITED, CAPULA MULTI STRATEGY MASTER
FUND LIMITED, CAPULA ALTERNATIVE MARKETS ALPHA MASTER FUND LIMITED AND THEIR RESPECTIVE FEEDER FUNDS.
DRP Pages
CRIMINAL DISCLOSURE REPORTING PAGE (ADV)
No Information Filed
REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV)
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
OR
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
CHICAGO BOARD OF TRADE ("CBOT")
2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
NOT APPLICABLE
3. Date Initiated (MM/DD/YYYY):
05/18/2021 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
CBOT 20-1343-BC
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
Futures - Commodity
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
PURSUANT TO AN OFFER OF SETTLEMENT IN WHICH CAPULA NEITHER ADMITTED NOR DENIED THE RULE VIOLATION OR FACTUAL FINDINGS UPON
WHICH THE PENALTY IS BASED, A PANEL OF THE CHICAGO BOARD OF TRADE ("CBOT") BUSINESS CONDUCT COMMITTEE ("PANEL") FOUND THAT ON
TWO DATES BETWEEN FEBRUARY AND JUNE 2020, CAPULA EXECUTED CERTAIN EXCHANGE FOR RELATED POSITION ("EFRP") TRANSACTIONS IN
CERTAIN US TREASURY FUTURES CONTRACTS THAT WERE CONTINGENT UPON THE EXECUTION OF OTHER EFRP TRANSACTIONS. THE PANEL FURTHER
FOUND THAT CAPULA EXECUTED THE EFRPS FOR THE PURPOSE OF REBALANCING POSITIONS HELD BY VARIOUS CAPULA FUNDS AND THAT THESE
ORDERS WERE STRUCTURED SUCH THAT THEY WERE EXECUTED WITHOUT THE INCURRENCE OF MATERIAL MARKET RISK. THE PANEL CONCLUDED THAT
CAPULA THEREBY VIOLATED CBOT RULE 538.C.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
05/18/2021 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 40,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived:
FINE $ 40,000.00 PAID 05/21/2021
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
PURSUANT TO AN OFFER OF SETTLEMENT IN WHICH CAPULA NEITHER ADMITTED NOR DENIED THE RULE VIOLATION OR FACTUAL FINDINGS UPON
WHICH THE PENALTY IS BASED, THE PANEL FOUND THAT ON TWO DATES BETWEEN FEBRUARY AND JUNE 2020, CAPULA EXECUTED CERTAIN EFRP
TRANSACTIONS IN CERTAIN US TREASURY FUTURES CONTRACTS THAT WERE CONTINGENT UPON THE EXECUTION OF OTHER EFRP TRANSACTIONS. THE
PANEL FURTHER FOUND THAT CAPULA EXECUTED THE EFRPS FOR THE PURPOSE OF REBALANCING POSITIONS HELD BY VARIOUS CAPULA FUNDS AND
THAT THESE ORDERS WERE STRUCTURED SUCH THAT THEY WERE EXECUTED WITHOUT THE INCURRENCE OF MATERIAL MARKET RISK. THE PANEL
CONCLUDED THAT CAPULA THEREBY VIOLATED CBOT RULE 538.C.
CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV)
No Information Filed
Execution Pages
DOMESTIC INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to
the SEC and all amendments.
Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint the Secretary of State or other legally designated officer, of the
state in which you maintain your principal office and place of business and any other state in which you are submitting a notice filing, as your agents to
receive service, and agree that such persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand
for arbitration, or other process or papers, and you further agree that such service may be made by registered or certified mail, in any federal or state
action, administrative proceeding or arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding, or
arbitration (a) arises out of any activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b)
is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939,
the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of the state
in which you maintain your principal office and place of business or of any state in which you are submitting a notice filing.
Signature
I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the investment adviser. The investment adviser and I both certify, under
penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other
information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having
custody or possession of these books and records to make them available to federal and state regulatory representatives.
Signature: Date: MM/DD/YYYY
Printed Name: Title:
Adviser CRD Number:
163364
NON-RESIDENT INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to
the SEC and all amendments.
1. Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint each of the Secretary of the SEC, and the Secretary of State or
other legally designated officer, of any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such
persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or
papers, and you further agree that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or
arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding or arbitration (a) arises out of any
activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly,
upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of
1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of any state in which you are submitting a
notice filing.
2. Appointment and Consent: Effect on Partnerships
If you are organized as a partnership, this irrevocable power of attorney and consent to service of process will continue in effect if any partner withdraws
from or is admitted to the partnership, provided that the admission or withdrawal does not create a new partnership. If the partnership dissolves, this
irrevocable power of attorney and consent shall be in effect for any action brought against you or any of your former partners.
3. Non-Resident Investment Adviser Undertaking Regarding Books and Records
By signing this Form ADV, you also agree to provide, at your own expense, to the U.S. Securities and Exchange Commission at its principal office in
Washington D.C., at any Regional or District Office of the Commission, or at any one of its offices in the United States, as specified by the Commission,
correct, current, and complete copies of any or all records that you are required to maintain under Rule 204-2 under the Investment Advisers Act of 1940.
This undertaking shall be binding upon you, your heirs, successors and assigns, and any person subject to your written irrevocable consents or powers of
attorney or any of your general partners and managing agents.
Signature
I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the non-resident investment adviser. The investment adviser and I both
certify, under penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits
and any other information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having
custody or possession of these books and records to make them available to federal and state regulatory representatives.
Signature: Date: MM/DD/YYYY
MICHELLE BEDWIN 06/12/2026
Printed Name: Title:
MICHELLE BEDWIN CHIEF COMPLIANCE OFFICER
Adviser CRD Number:
163364