Qpula Trading Management Lp

QPULA Trading Management LP is an investment adviser based in New York, established on October 23, 2020. The firm specializes in providing investment advisory services on a discretionary basis to a pooled investment vehicle intended for sophisticated and institutional investors. As of December 31, 2021, the firm had approximately $195,319,003 in regulatory assets under management. QPULA charges a performance fee of 25% based on gross investment returns net of expenses, subject to a high watermark provision. Clients are subject to various expenses related to investments and operations, including transaction costs, research expenses, legal and accounting fees, and regulatory compliance expenses. The firm focuses on developing and deploying systematic quantitative investment strategies to seek superior risk-adjusted returns. Investment strategies are technical and data-driven, employing various analytical tools and models. Risks associated with the firm's strategies include volatility, international investing risks, leverage, and interest rate risks. QPULA is affiliated with qPULA LLC, which licenses the trading algorithm used by the firm. The firm has adopted a Code of Ethics to ensure fair dealings with clients and compliance with securities laws. Clients receive regular reports from the pooled investment vehicle. QPULA has custody of client assets and provides investment advisory services on a discretionary basis, with the authority to determine securities transactions for clients. The firm does not vote proxies with respect to client securities.