ITEM 7: TYPES OF CLIENTS
Diorite Capital Management provides investment advisory services to the Fund and the
Sub-Advised Funds and not individually to the Investors in the Fund or in any of the Sub-Advised
Funds. The Fund requires newly admitted Investors to be “accredited investors” under Regulation
D of the Securities Act and “qualified clients” under the Advisers Act. The Sub-Advised Funds
require newly admitted Investors to be “accredited investors” under Regulation D of the Securities
Act and “qualified purchasers” under the ICA. Additionally, the Fund has a minimum investment
requirement of $500,000 for Investors, although this minimum may be waived or reduced as
provided in the Fund’s offering documents. The Sub-Advised Funds similarly have minimum
investment amounts as set forth in their respective Investment Management Agreements.
ITEM 8: METHOD OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
All Investors in the Fund receive a Private Placement Memorandum (“PPM”) and other
offering documents before being given the opportunity to invest in the Fund. The PPM for the
Fund discusses in detail the investment objectives, investment strategy and risk factors relating to
an investment in the Fund. The following is a summary of the information that appears in more
detail in the PPM, which should be reviewed by all potential Investors.
Introduction
The Fund’s objective is to maximize absolute returns in variable market and economic
conditions, while managing risk and preserving capital. The Fund seeks absolute returns and does
not target its returns against any stock or other market index.
INVESTMENT STRATEGY
Diorite Capital Management utilizes proprietary quantitative models based on statistical
analysis to select and execute trades for the Fund. To date, these strategies have focused around
the statistical patterns or trends that persist in the period following dissemination of earnings
reports and how that information is likely to be digested and reflected in stock prices in the several
days following announcement. The strategies attempt to identify and profit from momentum and
reversion during the post-earnings period. Diorite Capital Management has developed and refined
these models over many years and has implemented them with actual capital, not computer
simulations. The models are designed to continuously adjust to be approximately market neutral
and to initiate and trade in positions based on market factors as they continue to unfold.
Diorite Capital Management believes that by utilizing this type of systematic and
quantitative investment platform that selects securities and executes trades in an unbiased manner,
subjective judgments that often dilute manager performance are eliminated. Diorite Capital
Management’s focus is on statistical accuracy, investment discipline and consistent
implementation.
Risk management processes are incorporated in the strategies in the form of concentration
limits on positions in each company and limits based on the average volume of particular securities
in which the Fund is invested. Directional market exposure is mitigated through use of broad
market-based ETFs to counterweight the particular directional bent of the portfolio at any
particular time.
In pursuit of its investment objective the Fund and the Sub-Advised Funds may typically
hold, sell, sell short, and otherwise deal in U.S. equity securities, foreign equity securities, and
other financial instruments such as ETFs (exchange traded funds). The Fund the Sub-Advised
Funds do not typically buy, sell, write, or trade options and other derivative instruments.
Depending on conditions and trends in the financial markets, Diorite Capital Management may
pursue other strategies or employ other techniques it considers appropriate and in the best interests
of its clients. The Investment Management Agreements with clients typically does not impose
specific limits on the types or amounts of securities or other instruments in which the Fund may
invest, the types of positions it may take, the concentration of its investments (whether by sector,
industry, asset class or otherwise), or the amount of leverage it may employ.
Diorite Capital Management incorporates the use of leverage to attempt to maximize
returns. In essence, Diorite Capital Management seeks to create investment returns which
demonstrate a high SHARPE ratio (reward achieved for the given risk taken) and to leverage those
returns by a factor of 5-6 times the amount of actual capital invested. This type of leveraged
investment approach is fairly typical with quantitative based strategies. The use of leverage
increases both the proportionate amount of potential gain, as well as potential loss, relative to
invested capital. If the value of a margin position declines, the securities serving as collateral for
such margin position may be liquidated, resulting in a loss proportionately greater than would be
the case absent such use of leverage.
Although Diorite Capital Management invests primarily in publicly-traded equity
securities (including exchange traded funds), in the interest of both preserving capital and taking
advantage of profit opportunities, Diorite Capital Management retains the flexibility to invest in a
broad range of securities, asset classes and situations and use a broad range of specialized
investment techniques.
The investment strategies typically involve active trading and it is expected that its
managed portfolios will turnover many times during the course of each year. The portfolios are
not managed with a view toward tax efficiency and it is expected that trading profits will be
substantially all short term capital gains which are currently taxed at rates equivalent to ordinary
income.
RISKS RELATING TO INVESTMENT STRATEGY AND TECHNIQUE
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