NOTWITHSTANDING ANYTHING WHICH MAY INDICATE OTHERWISE ON THIS WEBSITE, BLUECREST DOES NOT
CURRENTLY OFFER SHARES OR INTERESTS IN ANY BLUECREST-MANAGED FUNDS OR ACCOUNTS TO
OUTSIDE OR THIRD PARTY INVESTORS. NOTHING ON THIS WEBPAGE SHOULD BE CONSTRUED TO INDICATE OTHERWISE.
As a firm authorised and regulated by the FCA, BlueCrest Capital Management (UK) LLP is required to either disclose its compliance with or explain its non-compliance with the principles set out in the UK Financial Reporting Council's Stewardship Code (the "Stewardship Code").
The BlueCrest group manages assets across a number of discretionary and systematic strategies, however the investment processes do not involve significant engagement with underlying investee companies in any of these strategies. The discretionary strategies do not take an activist shareholder approach, and investment decisions within the systematic strategies are generated by algorithms. BCM (UK) LLP therefore does not consider the Stewardship Code or its principles to be appropriate for the funds that it and other members of the BlueCrest group manage.
In order to comply with Rules 506(d) and (e) under the Securities Act of 1933 (the "Bad Actor Rules") BlueCrest is required to provide disclosure of any Disqualification Events (as defined in the Bad Actor Rules) by any persons/entities covered under the Bad Actor Rules. One of the categories of persons/entities covered under the Rules is paid solicitors of the BlueCrest-managed Fund. Such Fund may engage solicitors that have Disqualification Events under the Bad Actor Rules that occurred prior to September 23, 2013. Such solicitors and the applicable solicitors' Disqualification Event(s) are disclosed below:
AllBlue L.P. and AllBlue Limited
On June 27, 2012, Barclays PLC, Barclays Bank PLC ("BBPLC"), and Barclays Capital Inc. ("Barclays") announced that they had reached a settlement with the U.S. Commodity Futures Trading Commission ("CFTC") regarding conduct in connection with submissions made by Barclays to the bodies that set or compile various financial benchmarks, such as the London Interbank Offered Rate (LIBOR) and the Euro Interbank Offered Rate (EURIBOR). The settlement was made by entry into a Settlement Order Agreement with the CFTC (the "CFTC Order"). In addition to a $200 million civil monetary penalty paid by BBPLC, the CFTC Order requires Barclays to cease and desist from further violations of specified provisions of the Commodity Exchange Act and take specified steps to ensure the integrity and reliability of its benchmark interest rate submissions, including LIBOR and EURIBOR, and improve related internal controls. For additional information regarding the CFTC Order, please see Barclays Capital Inc.’s Form ADV Part 2A: Firm Brochure, publicly available at http://www.adviserinfo.sec.gov/IAPD/Content/Search/iapd_Search.aspx.
On August 26, 2004, in connection with the 2002 industry-wide governmental and regulatory investigations into research and analysts practices, Deutsche Bank Securities Inc. ("DBSI") reached a settlement agreement with the Securities and Exchange Commission, the National Association of Securities Dealers, the New York Stock Exchange and the New York Attorney General, and with other state regulators arising from an investigation of research analyst independence. Under the terms of the settlement, DBSI agreed to pay $87.5 million.
On June 3, 2009, DBSI settled proceedings with the U.S. Securities and Exchange Commission, the New Jersey Department of Securities and the New York Attorney General in connection with various claims under the federal securities laws and state common law arising out of the sale of auction rate preferred securities and auction rate securities (together, "ARS"). Under the terms of the settlements, DBSI was required to, among other things, offer to buy back ARS purchased by certain customers from DBSI, reimburse certain customers who took out loans secured by ARS and compensate eligible customers who sold their ARS below par value. In connection with the settlements, a number of state securities commissions issued final orders against DBSI.
BlueCrest’s Form ADV is available on the SEC website, and can be accessed here.