Professional Documents
Culture Documents
Prepared
for
Marco Consulting Group
August 2005
TABLE OF CONTENTS
Items (Page #)
Performance (17)
Administration/Operations (56)
Compliance/Legal (57)
Page 2
LIST OF ATTACHMENTS
Items
Bios:
Biographies of Key Personnel
Org Chart:
Organizational chart of various groups within PARADIGM and the personnel
involved
Fund Performance:
Historical performance data for a selection of products, including monthly returns,
standard deviation, and drawdown analyses
Client Reporting:
Sample client account statement
Page 3
BACKGROUND INFORMATION
CONTACT INFORMATION
Company name: PARADIGM Global Advisors, LLC
Address: 650 Fifth Avenue, 17th Floor, New York, NY 10019
Telephone: 212.271.3388
Fax: 212.271.3395
E-mail: info@paradigm-ny.com
Website: www.paradigmhedgefunds.com
Name of contacts: Jean-Michel Savre
Title of contacts: SVP, Marketing & Structured Products
Telephone of contacts: 212.271.3388 Ext. 303
STAFF INFORMATION
E-mail of contacts: nm@paradigm-ny.com
How many employees does the firm currently
28 employees
have?
NO. OF
AREA
EMPLOYEES
Management 3
Portfolio Managers 3{2}
Research 3 {4}
Show the number of employees by working
Marketing 11{1}
area:
Risk Management 1
Administration 5{1}
IT Support 2
Please note that the bracketed values include those employees who
perform multiple functions at the firm.
What is the greatest and least number of
Over the last three years, the greatest number of employees the firm
employees the firm has had in the last three
has had is 28, and the least number of employees is 13.
years?
Michael Natbony, co-founder and co-chairman of PARADIGM since
inception, retired in 2003. We also made several new additions to
the firm in 2003, 2004 and 2005.
NAME POSITION START DATE
Partner & Managing Director of
Stephane Farouze 2003
Marketing & Structured Products
Computer Programmer
Denis Bychov 2003
Research Department
Vice President
Gerald Toledano 2003
Explain any significant employee turnover: Marketing & Structured Products
Senior Vice President
Jean-Michel Savre 2004
Marketing & Structured Products
Senior Vice President
Jeffry Schneider 2004
Marketing & Structured Products
Vice President
Rafael Castellanos 2004
Marketing & Structured Products
Analyst
Robin Liu 2004
Asset Allocation
Senior Vice President
Louis Hanna 2005
Marketing & Structured Products
Senior Vice President
Nick Markola 2005
Marketing & Structured Products
Page 4
PARADIGM attracts new people with its very competitive
compensation scheme and the competitive edge in its investment
strategy.
Provide a brief background of key personnel Please see “Bios” attachment and the biographies section of the
(education, professional background): marketing presentation.
Explain the compensation scheme for key PARADIGM employees are compensated in line with industry
people: standards, which include salary plus bonus and a profit sharing plan
based upon position, tenure and performance.
COMPANY STRUCTURE
From 1992 through 1995, Dr. Park completed his Ph.D. in Financial
Economics at Columbia Business School. His doctoral thesis on
hedge funds as an asset class was the first work of its kind, and The
Journal of Futures Markets published a portion of this landmark
paper in 1996. In that same year, PARADIGM launched its second
fund of funds program, PARADIGM Equities Ltd., and Markus Karr
Page 5
joined as Managing Director of Asset Allocation to assist Dr. Park in
implementing the company’s research in areas of manager selection
and portfolio management. Topics from Dr. Park’s thesis include but
are not limited to statistical algorithms and the Diversification of
hedge funds, as well as subsequent research conducted by the firm.
Dr. Park’s research has been ingrained in and apply to PARADIGM
portfolios’s construction ans risk management process.
Page 6
And finally, Key Bank and its subsidiary McDonald Financial,
selected three funds of hedge funds in 2004 that are now being
distributed through their network of Investment Advisors in the US.
These funds are managed by Citigroup, PARADIGM and Lazard.
PARADIGM Holding
Corporation
100%
100%
PARADIGM
Founders, LLC
100%
PARADIGM
PARADIGM
Employee Compensation
Companies, LLC
Plan, LLC
Page 7
ASSET MANAGEMENT ACTIVITIES
Does the firm manage funds of funds in Yes, the firm manages fund of funds in different strategies. Please
different strategies? If so, describe: find below a chart detailing our range of products:
Onshore/
Investment Programs Style Number of managers AUM (*)
Offshore
Multi strategy
PARADIGM Equities Fund I Onshore 93 $18.4 MM
Concentration+leverage
Managers trading
PARADIGM Asian Fund Offshore 10 $18.6 MM
Asian markets only
Multi strategy
PARADIGM Equities Fund Offshore 93 $139.7 MM
Concentration+leverage
Note B Includes Notional Amount of funds levered via off balance sheet transactions
Page 8
PARADIGM is entirely focused on designing portfolios of hedge
funds. All of our discretionary assets under management are in
PARADIGM’s funds of hedge funds. Our discretionary assets
What percentage of assets under management
represent approximately 49% of total assets under management.
is in funds of funds?
Non-discretionary assets (51% of total assets under management)
represent consulting clients, who utilize our services for portfolio
construction, asset allocation, due diligence, etc.
Institutions including Pension Funds, Insurance Companies,
Foundations, Endowments and Family offices.
Which investor group does the firm primarily
High Net Worth Investors through financial intermediary channels
target?
including Private Banking, Broker Dealer and Registered Investment
Advisor.
SIZE OF DURATION OF
CLIENT CLIENT TYPE
ASSETS RELATIONSHIP
A Family Office (Consulting) 300 Million 4 Years
B Family Office (Consulting) 300 Million 6 Years
C Family Office (Consulting) 300 Million 6 Years
Provide a list of main clients (incl. size of
assets, duration of client relationship): D Institutional (Discretionary) 150 Million 2 Years
E Institutional (Discretionary) 130 Million 2 Years
F Institutional (Discretionary) 60 Million 2 Years
G Family Office (Consulting) 27 Million 3 Years
H Institutional (Discretionary) 18 Million 2 Years
Provide three client references: Jean Marc Spitalier (Lehman Brothers London): 44-77-4777-7380
Inna White (Lehman Brothers New York): 212-526-6601
Maria Healy (Beta Capital Management): 305-358-8178
Bernard Abdo (Goldman Sachs): 917-697-2777
Page 9
Show a breakdown of assets under
BREAKDOWN OF ASSETS BY CLIENT GROUP
management by:
CLIENT GROUP ASSETS (MIL $)
EXTERNAL
• Client group
DIRECT investment
Institutional
Total employee benefit / pension 71
Foundation, endowment & hospital 9
Financial institution (Banks, Insurance Companies, etc.) 245
Total Institutional 325
High Net Worth & Family office 383
Other - specify:
Total DIRECT investment 708
INDIRECT investment (Consulting Assets)
Total INDIRECT Investment 927
TOTAL EXTERNAL (DIRECT + INDIRECT) 1635
INTERNAL
G.P. (all employees / principals) 1
Affiliated entities: Name(s): PARADIGM Feeder Funds 53
TOTAL INTERNAL 54
GRAND 1689
*As of March 2005
• Strategy
Page 10
Consulting assets:
• Single largest client represents 32% of consulting assets
• Three largest clients represent 73% of consulting assets
What is the greatest percentage of assets
under management represented by any single
Discretionary assets:
and by the three largest clients?
• Single largest client represents 18% of discretionary assets
• Three largest clients represent 34% of discretionary assets
Page 11
PRODUCT INFORMATION
PARADIGM Master Fund, LP (PMF)
• Investment Objective: The fund aims to achieve stable, low-
volatility returns. This is achieved through broad diversification.
The fund does not employ leverage and seeks to achieve 7%-10%
in returns with 3%-4% volatility.
• Target investors: US institutions and private customers.
• Legal Structure: Georgia Limited Partnership.
• Number of Funds: 63
• Current Size: $174.5 Million
• Date of Inception: April 1991
• Fee Structure: 1% management fee, 10% incentive fee, 0.40%
expenses
• Monthly subscriptions. Monthly redemptions with a 35-day notice.
Page 12
PARADIGM Enhanced Master Fund, LLC (PEMF)
• Investment Objective: The fund’s objective is to provide enhanced
returns by leveraging PARADIGM’s diversified Master Fund core
program. The fund seeks to achieve 18%-22% in returns with 7-
10% volatility and employs a leverage factor, whose range is
between 2x and 4x.
• Target investors: US institutions and private customers.
• Legal Structure: Delaware Limited Liability Company
• Number of Funds: 91
• Current Size: $92.5 Million
• Date of Inception: May 2002
• Fee Structure: 1% management fee, 10% incentive fee, 0.40%
expenses
• Monthly subscriptions. Monthly redemptions with a 35-day notice.
Page 13
PARADIGM Futures Fund I, LLC (PFF)
• Investment Objective: The fund is single strategy fund of funds,
investing only in CTAs, through managed accounts exclusively.
The funds employ a leverage factor, currently around 4x. The
objective is 15%-20% per year with 15%-20% volatility.
• Target investors: US Institutions and Private Customers through
Registered Investment Advisors.
• Legal Structure: Delaware Limited Liability Company
• Number of Funds: 19 (Managed Accounts Exclusively)
• Current Size: $20.5 Million
• Date of Inception: January 1999
• Fee Structure: 1% management fee, 10% incentive fee, 0.40%
expenses
• Monthly subscriptions. Monthly redemptions with 35-day notice.
Page 14
ADVISORY MANDATES/CLIENTS PORTFOLIOS
STRUCTURED PRODUCTS
Page 16
PERFORMANCE
Provide historical performance data for all
products (in electronic form, where possible),
including:
• Monthly returns
• Standard deviation (annualized) Please see “Fund Performance” attachment.
• Three largest drawdowns and
recovery periods
• Percentage of positive/negative
months
The current fee structure for all the funds is 1% management fee,
10% incentive fee, and 0.40% estimated charge for operating
expenses.
Page 17
PARADIGM Asian Fund, Ltd. (PAFL): Prior to August 2004,
performance is based on pro forma returns derived from actual
returns of the 6 underlying funds that were in the portfolio on
August 1, 2004, adjusted for the current fee structure. From August
2004, rates of return reflect actual performance, adjusted for the
current fee structure.
Page 18
ASSET ALLOCATION / STYLE ALLOCATION
A - INVESTMENT PHILOSOPHY
PARADIGM believes the best approach to capturing the premium of
the hedge fund asset class is to apply the time-tested principles of
Modern Portfolio Theory to hedge funds. PARADIGM implements its
investment philosophy in the defined, disciplined, multi-step
approach outlined below.
Page 19
PARADIGM corrects for these shocks at the time global crises
occur, which can have a dramatic effect on the shape and
movement of certain benchmarks.
Bull/Bear-Market Bias – Many hedge funds have not operated
outside of the bull or bear market, and their inclusion in hedge-
fund databases can somewhat skew the data. According to
PARADIGM’s model, a portfolio of hedge funds should have no
correlation or beta with any conventional market index.
Page 20
Our research shows that skill, or HF Alpha, along with Park Ratio,
generally persists over time and can therefore be indicative of future
performance. Our model rewards managers, who consistently beat
their peer group on a risk-adjusted basis and who consistently
demonstrate exceptional levels of skill at processing information.
Page 21
Consistent with the Efficient Market Hypothesis, we do not view
discretionary sector/strategy weightings as the main component of
optimal portfolio management. It is our view that macroeconomic and
sector/strategy performance predictions do not yield excess return.
There is simply no statistical evidence that one can predict which
sector/strategy will outperform in any given year. Although we do not
view sector/strategy allocation as a main component in portfolio
construction, we do conduct monthly sector tilting, based on
quantitative methods and our view of the financial markets, as well as
expectations for each particular sector/strategy.
Risk Management
Page 22
B - ASSET ALLOCATION PROCESS
The construction of our multi-manager portfolios consists of a
rigorous manager selection process, coupled with the ongoing
monitoring of managers that have already received allocations.
The Asset Allocation Process consists of 5 steps:
Nikolay Fedorovskiy
Markus Karr - Gordon Kelly
Robin Liu - Matteo Solbiati
7,500 Active Funds
Quantitative Filtering
Gordon Kelly - Robin Liu
Markus Karr - James Park
Matteo Solbiati
-1 Qualitative Analysis
600 Managers
-2 Due Diligence
Shirley Xian
-3 Manager Approval Jim HIrchak
100 Managers
Gordon Kelly -Robin Liu
Markus Karr – Shirley Xian
James Park
Data
Page 23
Automated Methods: (these methods are described in more detail in steps
2, 4 and 5).
The fist step in our quantitative analysis involves the ranking of funds,
according to the Overall Park Ratio, which is calculated by regressing
manager track records against PARADIGM’s aggregate hedge fund
index and adjusted for leverage. Each fund receives a Park score,
ranging from 0 to 100, and PARADIGM performs further analysis on
the top three deciles.
At this stage some managers are screened out for the following
reasons:
Page 24
In the second stage, PARADIGM runs additional analyses to better
understand the investment process of each manager and obtain
additional rankings:
Page 25
pickers, fixed beta managers, trend-followers or directional risk
takers.
James Park
Markus Karr
Portfolios Shirley Xian
Gordon Kelly
Robin Liu
~ 100 Managers
A List Invest.
A List
Comm.
Level
Due Diligence
600
Head of Dr. Park/M. Karr
Managers need to meet
Allocation
Under Monitoring
Watch and Wait
James Park/Markus Karr Needs to Meet
James Park/Markus Karr Approved
Investment Committee to Approve
Due Diligence to be performed
A List
Page 26
by senior members of the asset allocation team. A manager will
typically have two or three meetings with various members of the our
analyst team, one or two meetings with Markus Karr, our head of
asset allocation, as well as one or two meetings with Dr. James
Park, the Chief Investment Officer.
Initial Allocation
Page 27
Portfolio Construction
On-Going Monitoring
Page 28
Section 2 : Detailed Performance (annual and monthly),
compared with the relevant sector index;
Page 29
Section 5 – Summary of the major performance indicators;
Page 30
produces a cluster analysis report on a
quarterly basis.
Page 31
Once managers have been approved, PARADIGM calculates an
optimal allocation for each manager. This allocation model does not
rely on an equal-dollar approach, but a more meaningful volatility-
weighted approach, i.e. more volatile managers receive smaller
allocations. In addition, in order to build diversified portfolios,
PARADIGM applies limits to the allocation to each manager and
sector/strategy. These limits are shown in the table below on page 35
in PARADIGM’s Guidelines Section: 3. Diversification.
MANAGER ALLOCATION
Investment
Scores Comments
Instructions
Initiate or increase
> 3.0 BUY
allocation
Allocation cannot be
HOLD increased at this time
Page 32
Similarly, a DECREASE instruction can be issued if the
Investment Committee feels that our exposure to a manager or a
hedge fund sector is too large and needs trimming down (which is
not directly related to the manager scoring system)
A “FIRE” instruction can be triggered by non-quantitative red
flags (ex. Regulatory Concerns or Industry Reputation);
PARADIGM also monitors the behavior pattern of the returns
and look for signs of performance that is uncharacteristic of what
we believe the manager should be trading;
We may delay termination if we have a particular conviction on
the short-term outlook for the manager and attempt to exit the
allocation at a higher level.
SECTOR/STRATEGY ALLOCATION
All these analyses, combined with our view on the financial markets,
contribute to our final decision on strategy allocation. Modifications
for strategy allocation are implemented gradually, taking advantage
of subscriptions and redemptions. For instance, strategies we favor
will receive more assets and vice versa for strategies we do not
favor.
For example, 2004 was a difficult year for the merger arbitrage
sector, mainly due to the lack of opportunities. This sector
represented 2%-5% in various PARADIGM products at the end of
2004, compared to our 10% exposure in January 2004. Another
Page 33
example is the Mortgage-Backed sector, where a series of bad news
involving both managers and instruments increased our concerns as
to the extent to which manager-supervised (as opposed to
independently-verified) pricing of portfolios pervaded the asset-
backed industry; thus, in 2004, a gradual slight paring down of our
exposure to this sector was initiated. The sector was trimmed from
12% in early 2003 to 5%-7% in 2004.
On what periodicity is the asset allocation of
The portfolio is reviewed on a monthly basis.
the portfolios reviews?
A - PARADIGM’S GUIDELINES
1. Manager profile
Page 34
2. Not Allowed strategies
STRATEGIES WE AVOID REASON FOR AVOIDANCE
3. Diversification
* L/S equity strategy, as a whole can represent more than 20%, but
there are regional subsets. For example, at the end of March 2005,
the regional breakdown for the PARADIGM Master Fund was the
following: L/S US (70%), L/S Europe (15%) and L/S Japan (15%).
thus, the allocation to L/S US was about 17%, compared to L/S
Europe and Japan, which were at about 3.5% each, which is still
below the maximum of 20%.
Page 35
B - INVESTMENT BANKS’ GUIDELINES
1. Allowed Instruments
In addition, for hedging purposes only, the Fund may invest in (e)
forward positions in one or more of the following currencies against
the US Dollar: Euro, British Pound, Swiss Franc, Canadian Dollar
and Japanese Yen. The portfolio denomination currency is USD.
Furthermore, the Fund may have (f) residual cash balances in the
following currencies: US Dollar, Euro, British Sterling, Swiss Franc,
Canadian Dollar and Japanese Yen.
For the purpose of earning interest on any cash balance, the Fund
may invest in (g) money market cash instruments with a maturity of
183 days at most and with counterparty rated at least A-1 by
Standard & Poor's or P-1 by Moody's Investors Service, and (h)
shares or units in money market cash instruments funds.
2. Allowed strategies
Page 36
Investment in multi-strategy managers is allowed, as long as the
underlying strategies are part of the list above.
3. Diversification
Page 37
5. General Concentration Rules
7. Managers’ Experience
The Fund will not at any time allocate more than 25% of its net asset
value to Permitted Funds whose investment managers have less
than 12 months of track record in the strategy followed.
For the purpose of this guideline, the banks reserve all discretion to
decide whether a previous track record of one or more managers, in
the same or in different fund management companies, applies to the
Permitted Fund being considered.
Page 38
It is hereby acknowledged that on a case per case basis, the banks
may approve a Permitted Fund proposed by the Fund pursuant to
guideline #13 (Amendments and Waivers), whose experience does
not satisfy the above provision on the basis of official track record,
but which is acceptable to the banks because of other parameters
(.e.g. industry experience or recognition).
• In any calendar year, the Fund can invest into any new single Fund
without prior approval of the banks, if the initial allocation in the
particular fund is less that 4% of the net asset value of the Portfolio.
• In any calendar year, the sum total of the investments in new funds
cannot exceed 25% of the net asset value of the Portfolio.
Once the above mentioned limit is utilized for the given calendar
year, any further investments in new single funds will need the prior
consent of the banks.
This prior consent is, in effect, a limited veto right, as it does not
affect the validity of other guidelines (such as, for instance, #3
Diversification and #7 Managers’ Experience). Procedure of getting
the consent will be as follows:
• If the new single fund has not obtained prior consent of the banks,
then the Allocation advisor should provide the banks all the relevant
information (such as the fund fact sheet, historical performance,
Fund Manager bio, due diligence sheet filled by Allocation advisor,
revised portfolio allocation, etc). Once the complete set of
information is received, the banks will get back to the Allocation
Advisor with the final decision within 3 business days.
However, the above mentioned cases for exercising veto rights are
not a comprehensive list. Nevertheless, for the avoidance of doubt,
provided the Allocation Advisor is operating within these guidelines,
the banks shall not unreasonably withhold consent with respect to
new Permitted Funds.
9. Leverage
The Fund may have borrowings of up to 15% of the net asset value
of the Portfolio at any time. In addition, this limit may be increased to
a maximum of 25%, on a temporary basis (no more than four
consecutive weeks), for settlement facilities or in order to meet
temporary shortages of liquidity caused by the need to satisfy
redemption requests by investors.
Page 39
This borrowing limit does not cover any leverage, which might be
used by individual portfolio managers within their own funds; it only
covers direct leverage at the Fund level.
10. Liquidity
• At least 55% of the net asset value of the Fund shall be invested in
Permitted Funds that offer liquidity no greater than 66 days (including
most funds with an advertised 'monthly' redemption frequency with a
35 days notice period).
• At least 75% of the net asset value of the Fund shall be invested in
Permitted Funds that offer liquidity no greater than 150 days
(including most funds with advertised 'quarterly' redemption
frequency with a 60 days notice period).
• No more than 5% of the net asset value of the Fund shall be
invested in funds that have lock up period of greater than 180 days.
• The Fund shall not invest in Permitted Funds with a remaining lock-
up period greater than 365 days.
• No more than 30% of the net asset value of the Fund shall be
invested in Permitted Funds that apply redemption fees policy with a
redemption fee greater than 2.5%.
• The Fund shall not invest in Permitted Funds with a redemption fee
higher than 5%.
Page 40
business days (the 'Cure Period') to take action to remedy the issue
and re-establish compliance.
In any case, the banks shall reserve the right to subsequently revert
to the original guideline(s), as set out in this document, provided that
it gives sufficient notice to the Fund, so that it does not break the
Cure Period (as set forth in #12 above), while proceeding to unwind
or reallocate some investments as a result of that change.
How can the guidelines be altered? Please see Guideline 13 (Amendments & Waivers) above.
Page 41
DUE DILIGENCE / MANAGER SELECTION
PARADIGM’s due diligence process is based on a theoretical model
that defines hedge funds as skill based, profit-maximizing entities,
not as diversified investment vehicles. Hedge funds are companies
which seek to generate what PARADIGM calls an Information
Processing Premium. Just as stock and bond mutual funds diversify
risk by investing in many companies across different
sectors/strategies, PARADIGM funds seek to diversify the
idiosyncratic risk of individual hedge funds by holding a large number
of hedge funds across many different strategies. In PARADIGM's
view, hedge funds, like stocks and bonds, are Information Age
companies and comprise an independent asset class; therefore, a
On what principles are the firm’s due diligence fund of hedge funds is analogous to a mutual fund. By viewing a
process based? hedge fund as a company, PARADIGM performs thorough due
diligence checks on our underlying managers, as one would in
assessing the value of any investment opportunity.
Page 42
through our qualitative analysis and their past experience;
Superb credentials, superior intelligence, and highly
experienced;
Independent operation and ownership (signals self-confidence)
Single strategy focus (signals expertise);
High percentage of manager's net worth invested in own fund;
Able to articulate the fundamental phenomenon the manager
attempts to capture.
Do you conduct on-site visits with the
Yes.
managers?
How much time is spent with each manager Often, a manager will have three or four meetings with different
during the due diligence process? members of the PARADIGM team as well as one or two meetings
with Dr. Park. Onsite visits are also conducted prior to an allocation.
• Before initial investment The due diligence process usually takes about 4 to 8 weeks before
the test account stage.
PARADIGM communicates with managers on a weekly, bi-weekly
• Every following year and monthly basis via e-mail, telephone and fax. Face-to-face
meetings occur as needed and average once to twice a year in a
manager’s office and several more times per year at PARADIGM’s
office in New York.
PARADIGM performs quantitative analysis on all the active funds in
its database twice a year, currently 6,600 funds, which are managed
by about 3,000 different managers. This first quantitative screening
enables use to reduce the universe of eligible managers. This
reduced list comprises both managers already on our A List and
potential managers.
Page 43
Most of our underlying managers have $50-$500 million under
management, which leaves substantial room for additional
investments with these funds. We currently have 95 managers on our
approved list, of which 72 are open for additional investment with
capacity of approximately $5 billion. This capacity broken down by
How much capacity is available from strategy is as follows:
managers on the approved list? Please
STRATEGY CAPACITY
provide breakdown by strategy:
CTAs $1 billion
Page 44
PORTFOLIO CONSTRUCTION
Manager Selection - Quantitative Criteria
Hedge Fund Alpha measures
Hedge Fund Alpha Score (1)
manager’s ability to outperform
Park Ratio Score (1)
the overall hedge fund
Calculated from the regression
industry, his/her peer group, or
of each manager’s returns
his/her cluster group.
Performance against the following:
• Overall Hedge Fund Index;
Park Ratio accounts for
• Sector/Strategy Indices;
leverage, serving as a more
• Cluster Indices;
accurate measure of relative
• PARADIGM’s portfolios
skill.
Beta and correlation against Beta and Correlation
about 100 different indices: calculation helps us to:
• PARADIGM proprietary • better understand the
indices: Global, Sector, investment strategy and
Cluster Indices; confirm the skill set of a
• Long-only industry manager;
Correlation benchmarks; • exclude managers that have
high exposures to stock or
• Hedge Fund and Fund of
bond markets or a certain
Hedge Funds Indices; style; we do not allocate to
• PARADIGM’s own stock pickers, fixed beta
portfolios. managers, trend-followers or
directional risk takers.
Explain the qualitative and quantitative criteria Statistical grouping of Identifies best managers within
Cluster
used in your portfolio construction process: managers, according to the a group and also helps us
Analysis
past 36 months of returns detect style drift
We tend to favor young
Assets Under
Between $50 and $500 million managers, who have
Management
remaining capacity.
Assets Under
Asset Growth Rapid growth is a red flag
Management
Managers with less than 2
years performance statistics
Track Record 2-3 years can also be considered
through our qualitative analysis
and their past experience
Manager
High percentage of manager's net worth invested in own fund
Commitment
Score between 1.0 and 5.0
calculated for each manager, Managers in A List Score must
Manager resulting from a multi-factor be higher than 3.0 for initiating,
Scoring algorithm taking into account maintaining or increasing their
Park Ratio, Performance, allocation.
Volatility, Liquidity, Sentiment.
(1) for a detailed definition and description of Hedge Fund Alpha and Park Ratio
scores see pages 24 and 25.
Page 45
As far as the quantitative criteria for the portfolio construction itself,
we seek to construct highly diversified funds and try to allocate to a
minimum number of managers in our multi-strategy and single
strategy funds of funds; we have limits allocations to managers and
sectors.
Maximum Maximum
Investment Current Number
Allocation Allocation
Programs of Managers
to Any Manager to Any Sector
PARADIGM Master Fund 87 5% 20%*
Page 46
Our portfolio turnover is generally 5%-10%, including test accounts.
Because we view hedge funds as companies and PARADIGM as a
portfolio manager, we agree with Warren Buffet when he says that
successful portfolio management is about identifying outstanding
individuals and investing in them for the long run. PARADIGM does
not trade its managers. We search for and identify talent. When
returns are poor, we examine the manager closely and try to
determine the reason for the drawdown. If our confidence still
remains high, we often add to the allocation to rebalance the
State the average turnover of managers within
portfolio.
the portfolios:
The following are some of the main reasons managers are fired or
excluded from an existing portfolio:
Page 47
In 2002, one of our managers lost 54% within a one-month time
frame. PARADIGM had been invested in this manager for several
years and had always been satisfied with the fund's stable, low-
volatility return. The manager had consistently reported solid
performance numbers up until September 2002, when the fund blew
up. 90 days prior to the manager’s posting the 54% drawdown,
however, PARADIGM sent a partial redemption notice as part of its
portfolio rebalancing process and was able to collect $1 million of the
investment back.
Page 48
What is more important and what we seek to achieve is to identify the
next outstanding manager and allocate to him/her, while the manager
has a small AUM and has enough capacity. We typically try to enter
into relationships with managers at an earlier stage than most large
funds of funds, thus getting a foot in the door before the soft close.
Page 49
20% performance fee. In all probability, this closet mutual fund will
call itself a hedge fund. However, investors in this fund are seriously
disadvantaged. The fund might generate profits during significant
bull markets, but the investors will have paid too much for their long
market exposure because they could have obtained the same
exposure in a mutual fund for 50 to 100 basis points. Over extended
time periods, the outlook for this fund’s investors is bleak. It is well
established that most stock pickers do not outperform the overall
market (even before consideration of fees). Therefore, in all
likelihood, the investors will participate in 80% of market gains, but
suffer 100% of market losses.
Sector/Strategy allocation
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about which managers should perform well in the future. Therefore,
we strive to provide superior, risk-adjusted returns based on
manager skill. We allocate to the managers who exhibit the highest
level of skill relative to their peer group. By selecting the best
available managers, regardless of sector/strategy, our portfolios
become immune to the unpredictable success or failure of any given
sector.
Broad diversification
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RISK MANAGEMENT
Does the company maintain a written risk
Yes.
management policy?
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Jim Hirchak, our risk management and compliance officer, monitors
our portfolios on an intraday, daily and monthly basis, serving as a
secondary opinion, separate from the asset allocation team. He is
also in charge of managing PARADIGM’s use of RiskMetrics and
providing our investors with monthly customized risk reports.
Refco and Cargill Investor Services serve as the FCM, clearing most
of our CTAs’ trades in our Futures portfolio. They monitor the activity
of the CTAs on a real-time basis for any abnormal trading behavior
and excessive positions or losses, all of which would be reported
immediately to PARADIGM.
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Quantitative Risk Management Tools
Spreadsheet for our futures portfolios, providing P/L for
each contract, markets and geographic sectors on an
Intraday P/L aggregate basis and on an individual manager basis.
Monitoring Real time P/L is compared to thresholds, corresponding
and Stress Testing to losses in the case that all the markets move 1, 2 and
3 standard deviations at the same time against our
portfolios.
Daily P/L and
Daily performances of all the managers we are invested
Drawdowns
in. Monitoring focuses on drawdowns.
Monitoring
Reports for each manager detailing performance,
standard deviation, drawdowns, as well as the evolution
Monthly Manager from one month to another of PARADIGM indicators
Monitoring such as Hedge Fund Alpha and Beta, Park Ratio.
Monitoring focuses performance evolution, style drift.
Please see page 28-30.
Monthly Manager
Score below or equal to 1.5 will trigger redemption.
Scoring
Through RiskMetrics we get the following risk reports at
the manager level:
Exposure of NAV to hedge fund strategies
Monthly Portfolios Exposure of NAV to markets/products
Risk Indicators Sensitivities to equity and fixed income markets
Stress testing, parallel shocks
Describe the firm’s quantitative risk
VaR analysis
management tools. Provide examples, where
available:
Diversification Manager and sector/strategy allocation has to stay
Monitoring within limits. Please see description on page 35.
We have a table of red flags that we monitor and would
Red Flags
trigger specific response in case of their occurrence.
Monitoring
See table below.
Quarterly Cluster Contribute in conjunction with other analysis to
Analysis identifying “Style Drift”.
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test procedures, and marked-to-market procedures. PARADIGM
continuously monitors major news feeds, particularly those specific
to the hedge fund industry, to find independent news regarding our
existing allocations. Other sources of information are manager-
reported returns, proprietary analytic models, proprietary indices and
sector sub-indices, and external databases of indices. We also
maintain close contact with third-party service providers, and our
network of business associates provide us with background
information.
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ADMINISTRATION/OPERATIONS
Is the fund administration performed in-
No.
house?
If services are outsourced:
All fund and corporate accounting is provided by Global Fund
• Which tasks are fulfilled by external Services, LLC, an Atlanta-based accounting firm. Offshore fund
service providers (include names of accounting and servicing for our offshore funds is provided by Folio
companies? Administrators, Ltd. The Administrator handles all shareholder
registration and custody issues including subscriptions and
redemptions and computes the net asset value for each fund. The
custodian for all onshore funds is Bank of America, and the custodian
for offshore funds is JP Morgan.
• How long have the relationships with The time frame of our relationships with our service providers are as
those service providers lasted? follows:
Global Fund Services, LLC – 13 years
Folio Administrator, Ltd. – 3 years
• Has the firm ever terminated any
PARADIGM terminated its working relationship with Arthur Anderson,
service providers (including
the auditor, due to their inability to continue providing professional and
auditors)? If so, explain the
timely services.
circumstances:
CLIENT INFORMATION/REPORTING
Client account statements are mailed to clients on a monthly basis
What kinds of reports are sent to investors? and are also available on our website. In addition, clients in all our
Provide sample reports: funds receive quarterly and yearly reports. Please see “Client
Reporting” attachment.
Has the company published or commissioned Yes. PARADIGM has published numerous research reports on the
any research/academic papers? topic of hedge funds and hedge fund investing.
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COMPLIANCE/LEGAL
PARADIGM Global Advisors, LLC is registered with the SEC as an
investment adviser and with the Commodities Futures Trading
Commission as a commodity pool operator and a commodity trading
advisor and is a member of the US National Futures Association.
Is the firm registered with any regulatory
and/or supervisory bodies? PARADIGM Capital Management, LLC, the General Partner for our
domestic products, is registered with the Commodities Futures
Trading Commission as a commodity pool operator and commodity
trading advisor and is a member of the US National Futures
Association.
The NFA performed an audit in 2000, and the SEC audited
When was the last inspection of those PARADIGM Global Advisors in Oct 2003. Both were routine exams.
bodies? Additionally, PARADIGM Global Advisors, LLC and PARADIGM
Capital Management perform an annual self exam for the NFA.
There have been no material, civil, criminal or administrative actions
Are any lawsuits pending against the
against any of the PARADIGM companies, their principals or
company?
employees.
Does the company have a full time compliance
P. James Hirchak, Jr.
officer?
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PARADIGM does not participate in any situation that may be
considered a conflict of interest. It is a common knowledge that some
funds of funds negotiate down fees with underlying hedge funds and
Are there any conflicts of interests the profit from the difference. PARADIGM considers it a conflict of
investor should be aware of? interest and has never participated in this type of activity. As a
result, PARADIGM will not accept any financial or other direct or
indirect compensation from our underlying managers (including
equity participation and soft-dollar arrangements.
Please state the name and title of the officer at your firm who has prepared and reviewed this
questionnaire.
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