Question 1

How Did You Construct The Defense Strategy?

Accepted Answer

The Defense Strategy is intended as a capital efficient way for investors to add a defensive component to their portfolios. It contains an investment into the same ensemble of managers in Mutiny Funds’ Commodity Trend Strategy which is intended to do well in inflationary periods and protracted recessions. It also invested in the same ensemble of managers in Mutiny Funds’ Volatility Strategy which is intended to do well in sharp sell-offs.

Question 2

What Is The Total Exposure Of The Defense Strategy?

Accepted Answer

The portfolio will have a target nominal exposure of 150%. This means that for a $100k investment that the investor will get $150k of nominal exposure to the different return drivers which includes:

75% exposure to Mutiny Funds’ Commodity Trend Strategy
75% exposure to Mutiny Funds’ Volatility Strategy

Question 3

Defense Strategy Managers

Accepted Answer

The Defense Strategy invests in the same ensemble of managers as those contained in the Mutiny Funds’ Commodity Trend Strategy and Mutiny Funds’ Volatility Strategy.

Question 4

How Much Should I Allocate To The Defense Strategy?

Accepted Answer

The question of how much you should invest is, of course, unique to your situation and nothing we say here is a substitute for speaking with a financial advisor or the use of your own judgment. Having said that, we can offer a few ways of how we personally think about it.

We believe that the best combination of offensive assets and defensive assets is approximately equal weight as embodied in our Cockroach Strategy.

In that scenario, the Defense component accounts for approximately 50% of the total exposure of the portfolio. For investors seeking to use it in a similar way then, an allocation along those lines seems appropriate to us. Given the capital efficiency of our structure noted in WHAT IS THE EXPOSURE OF THE DEFENSE STRATEGY, a ~33% allocation to the Defense Strategy would achieve this total exposure.

For investors that have a different view of the role and sizing of trend strategies in a portfolio, they are able to size their investment however they deem appropriate.

Of course, your investment decision and amount is a personal choice and you should consult with your financial advisor and exercise your own good judgment.

Question 5

Where Does The Defense Strategy Struggle?

Accepted Answer

We anticipate the most challenging environments for the Defense Strategy would be low or declining volatility environments without any trends such as 2019 where volatility remained relatively low and there were few pronounced price trends.

Our expectation is that offensive strategies such as equities or income oriented strategies will do well in this environment. Since the Defense Strategy is not intended as a stand alone investment, but rather as a part of a broader portfolio, we would expect that the rest of an investors’ portfolio would be generating the returns in this type of period.

Question 6

What Are The Fees Charged By Mutiny?

Accepted Answer

For the Defense Strategy, the fee structure is a 1% management fee and 10% incentive fee.

We use a "high watermark" meaning investors are only assessed an incentive fee on net new profits. As an example, if you were to invest $100k and the value of your investment goes down to $95k then up to $105k, you would only pay the incentive fee on the $5,000 gain from $100k to $105k.

Question 7

Which Strategy Should I Invest In?

Accepted Answer

The question of what you should invest in is, of course, unique to your situation. Nothing we say here can or should be considered a substitute for speaking with a financial advisor and the use of your own judgment. Having said that, we will offer a few ways of how we personally think about it.

In our opinion, the Cockroach Strategy is the best liquid total portfolio solution for those looking to maximize long-term compound growth while reducing drawdowns.

The way we look at it is that the best portfolio should perform across all major macroeconomics environments: Growth, Deflation, Decline and Inflation.

We believe that this requires roughly equal parts offense and defense.

Offensive assets would be assets such as public equities, angel, private equity, and real estate.

Defensive assets would be assets such as the Volatility Strategy, gold, commodity trend strategies, and cash.

The Cockroach Strategy seeks to provide exposure to a diversified ensemble of offense and defensive assets in a liquid portfolio.

[caption id="attachment_18095" align="alignnone" width="512"] The Firm Uses CME Bitcoin and Ethereum Futures, Not Cash Crypto.[/caption]

In our view, Mutiny Funds’ other offerings including the Defense Strategy, Volatility Strategy, Volatility+Stocks Strategy, and Trend Strategy are best used as tools for investors which want to customize other parts of their portfolios within the Cockroach framework.

For instance, an investor that focuses on stock selection and wants discretion over the stock portion of their portfolio could do so as they see fit and use the Volatility Strategy and Trend Strategy to complement it and provide their defensive exposure.

Similarly, an investor focused on income from Real Estate may want to manage the Income component themselves through their real estate holding and could use the Volatility+Stocks Strategy as well as the Trend Strategy to round out the portfolio.

Of course, you may have differing views on what the appropriate portfolio construction is for your situation and should allocate using your own judgment.

In the Cockroach Strategy, we will automatically rebalance the assets each month. For investors wishing to implement themselves, we believe they must rebalance regularly to achieve the best results. This means adding to the strategies when they are losing money as well as redeeming when they are performing well.

If you are investing through a retirement account, the rebalancing can be difficult to do since sometimes new funds cannot be transferred in when you would like to and so the Volatility+Stocks Strategy or Cockroach Total Portfolio Strategy may be more appropriate as the rebalancing is done “in house.”

Question 8

When Should I Invest?

Accepted Answer

We don’t believe in trying to time our exposures. For instance, Calpers missed a billion dollar payday in March 2020 when they redeemed their tail risk exposure just months before. Our philosophy is that investors should focus on building a balanced portfolio rather than trying to time macroeconomic trends.

Rather than engaging in market timing, we believe it is important to remember that the Volatility Strategy, Trend Strategy or any other component of the Cockroach Portfolio should be seen as part of a broader portfolio and viewed holistically.

There will be periods where Mutiny Funds’ Volatility Strategy or any long volatility strategy underperforms short volatility strategies and/or outright loses money. Similarly, there will be periods where Mutiny Funds’ Commodity Trend Strategy underperforms or suffers losses. However, what matters is how it is performing its role in the portfolio. If a long volatility strategy is struggling while the rest of the portfolio is doing well, that’s nothing to be unhappy about - indeed that is part of its role.

We strongly believe that the combination of long and short volatility strategies will produce the best risk-adjusted returns over the long run of a lifetime, a form of True Diversification.

Question 9

What Counterparty Risks are There?

Accepted Answer

The principal sources of counterparty risk would be our bank, outside funds we are invested in, our futures brokers, and our securities brokers.

Mutiny Funds main bank is CIBC Bank USA, whose parent CIBC is the 11th largest bank in North America.

Funds are also held at StoneX, ADM, and Wedbush, the Futures Clearing Merchants (FCMs) which facilitate futures trading, who in turn hold assets not being posted to the exchanges at top tier banks such as BMO.

The funds held primarily at our FCMs are held as a so-called “performance bond”, effectively margin, against futures and options positions purchased and sold by the fund.

Per regulatory requirements, the money is held in StoneX’s customer segregated account, meaning it is for the benefit of the firms’ customers only, and not commingled with the firm’s capital or rehypothecated as happens in a fractional reserve system. Additionally, StoneX, our primary FCM, has National Futures Association (NFA) reporting requirements and is a publicly traded company that has all the scrutiny which goes along with being public.

The way that the Futures industry works is that only members of exchanges like the CME Group can transact with one another, and only after posting a “Performance Bond” to the exchange. Here’s the Chicago Mercantile Exchange’s explanation:

Performance Bonds, also known as margins, are deposits held at CME Clearing to ensure that clearing members can meet their obligations to their customers and to CME Clearing. Performance bond requirements vary by product and market volatility.

This protects against counterparty risk, with each trade having to be ‘pre-funded’ with the margin amount, and CME Clearing acting as the buyer for every seller and vice versa on every trade. They guarantee the other side of the trade by holding the performance bonds of each party to the trade.

Further, the exchanges have a ‘guaranty fund’ which is in place in case a clearing member loses more in a day than they had on deposit with the exchange and are not able to meet the ‘margin call’ for more money. As of March 31, 2023, The CME’s guaranty fund is $4,804,588,702. They have an additional $13 Billion ($13,212,618,930) in assessment powers where they can require the members (primarily Futures Clearing Merchants such as StoneX) to cover any shortfall in the guaranty fund. (Please see the CME Website for an up to date number)

Additionally, everything is marked to market every day, meaning the clearing members who had positions that lost money that day need to settle with the exchange against those who made money that day, with billions moving back and forth between the clearing members and the exchange each day to ‘clear’ and ‘settle’ these trades, even before the trade is officially closed out.

For instance, if a trader has a position move against them, then they are required to post additional margin if they wish to continue trading so that their counterparty knows they will be paid out in full.

Finally, not everyone who uses futures is a member of the clearing exchanges. The FCM’s solve this issue, with them owning the expensive membership, posting the margin requirements, and taking on the counterparty risk. The end customers, such as the Fund, use the FCM’s membership in exchange for a commission on each trade.

As noted above, when an FCM accepts customer money, that money must be held in a segregated account and only used to post margin to the exchange and settle trades between the FCM’s customers and other FCMs. The FCMs hold the entirety of their customer’s cash in this manner and are regulated so that the money isn’t rehypothecated or levered up. The FCMs also add their own capital to this customer pool, called excess capital, to act as a buffer against any one customer being unable to cover losses in their account.

In 2008 when the equity space saw a large amount of counterparty risk realized with firms such as Lehman going under, the Futures and Options space functioned as designed, without major disruptions to the workings of those markets or counterparties.

We specifically built our funds in the futures space because of the transparency, liquidity, and control present there via the centralized exchange model, in addition to layers of risk monitoring by introducing brokers and FCMs noted above. If you’d like to learn more about how Futures work, we believe this Khan Academy course provides a helpful introduction.

The intention is that the majority of our funds are held at either the bank or FCM as described above. However, we also have some funds at securities brokers for managers that trade securities and we have some 3rd party funds which have different counterparty risks. Our intention is to always limit this exposure, but we believe that, appropriately limited, it offers some additional diversification that improves the overall portfolio.

Additionally, we use 3rd party administrators for all our funds and auditors to try and eliminate any single point of failure.

Question 10

What is the Liability Situation For Each of The Funds?

Accepted Answer

Investors in the Fund(s) are provided all the liability protections of a Delaware Limited Liability Company.

This means a Member cannot be individually subjected to margin calls and cannot lose more than the amount of such Member’s original investment and any profits earned thereon (which have not already been withdrawn).

Question 11

What are the Other Risks and How Do You Think About Them?

Accepted Answer

If you want to move forward with an investment, you will see a full list of risks associated with the fund in the Private Placement Memorandum (PPM). The PPM is available upon request or will be supplied upon submission of our investor information form to proceed with an investment.

In addition to the counterparty risk controls highlighted above, we would note the following two risk control measures:

As much as possible, we use Separately Managed Accounts (SMAs) with most of our sub-advisors. Unlike investing in a fund, theser allow us to see their trading intraday and to put contract size limits that they are not allowed to exceed with the Futures Clearing Merchant (FCM).

Beyond the rebalancing benefits of diversification, we also use it to limit risk to any one manager with appropriate position sizing. Our ensemble approach to sub-advisors, strategies, and market micro structures seeks to mitigate the primary risks associated with any one sub-advisor or trading strategy.

Question 12

What Compliance Policies are in Place?

Accepted Answer

The Co-managers have the following policies and procedures in place:

AML Policy
Additional Risk Disclosures
Material Conflicts of Interest Policy
Customer Complaints Policy
Disaster Recovery Plan
Discretionary Account Procedures
Do Not Call Policy
Electronic Mail Policy
Ethics Training Policy
Information Systems and Cyber Security Policy
NFA Self Examination Policy
Opt Out Notice
Privacy Policy
Promotional Material and Supervisory Procedures
Sales Practice Policy

All policies are available for review upon request.

Question 13

When are the Fees Paid: Monthly? Quarterly?

Accepted Answer

Management fees for all strategies of all funds are 1% of assets under management per year.

The management fee is assessed monthly (1/12 of 1% each month).

Incentive fees crystallize and are paid quarterly and are specific to each strategy.

Question 14

What is the Tax Situation For U.S. Investors?

Accepted Answer

For U.S. based investors, the majority (we estimate ~70%) of our trading for all Strategies is in futures markets and certain option trades which are considered Section 1256 contracts.

Under the U.S. tax code, Section 1256 contracts get special treatment where the total gain is treated as being 60% long-term capital gains and 40% short-term capital gains.

This is regardless of if the holding period is one minute or one year. Since many of our holdings (especially in the Volatility Strategy) are being actively traded with average holding periods of a few hours or days, this is advantageous to us, giving us a blended rate below the short-term capital gains rate.

Depending upon our managers strategies, it is possible that a portion may also take place in equities at the standard equity tax rates for short and long-term capital gains.

One primary difference between Mutiny and a mutual fund, ETF or stock is the 60% long-term capital gains and 40% short-term capital gains treatment as noted above.

The other primary difference is that it is marked-to-market (vs a mutual fund or stock which only has tax triggered at time of sale) so that taxes will be owed each year.

For example, an investor investing $1mm that then sees their investment appreciate to $1.1mm over the course of a year will owe tax on the $100,000 profit. As tax rates vary materially from state to state and based on personal circumstances, we leave it to the investor to do the ultimate calculation.

The Fund does not anticipate that it will make current distributions. Accordingly, each Member should have alternative sources from which to pay its U.S. federal income tax liability or be prepared to withdraw the needed amounts from the Fund.

If you have a self-directed IRA or solo 401k, we are able to take investments through a self-directed IRA custodian. This should have all the tax-deferral benefits of an IRA investment and so may make more sense depending on your individual situation. If you would like help setting up a self-directed IRA, please contact us.

For investors whom it affects, we do not expect to incur any UBTI.

Question 15

When Will US Fund Investors Receive Tax Documents and How Does the Process Work?

Accepted Answer

Investors will receive an audited annual report with financial statements, detailing the activity and financials for the overall Fund in which they are invested.

Investors will also receive a K-1 reporting their share of the prior year’s profits and losses for the Fund in which they invest. Here is an explanation of how K-1s work in a fund structure if you are not familiar.

Because our funds are invested in other funds, we have to wait until we receive final audited financial statements from those funds to compile the audited annual report and K-1. Those outside funds are not required to submit their audited financial statements with the regulators until March 31. We usually receive most of them around that time though it is typical for at least one or two of our managers to file an extension.

Once we have received the audited financial statements and K-1s from the other funds, we will work with our third party administrator, to put together the annual financial statement for Mutiny Funds, and then turn them over to our auditor and tax preparer, Cohen & Co., to perform their certified audit of the financials.

Once the audit has been completed, the annual report will be filed with the National Futures Association (NFA) and you will receive a copy. Typically this will be the end of June.

At the same time, the Cohen & Co. tax department will use the prior year’s financial statements to prepare the fund’s overall tax return and each investor’s individual K-1s. These will be sent out to you as soon as we receive them.

We will do everything in our power to get investors the K-1s promptly, but owing to the fact that we cannot begin our own process until we receive everything from our managers it is unlikely we will be able to send them out before June at the earliest. Based on prior years, investors should expect K-1s in August which would require filing an extension.

As a matter of practice, we will file an extension for Mutiny’s overall tax return, given the need to wait for the third party fund’s K-1s.

Question 16

Do you have an Offshore Vehicle?

Accepted Answer

Yes, we have a Cayman Fund vehicle, the Mutiny Cayman Fund, Ltd. which acts as a feeder fund into our U.S. based funds.

Question 17

What is the Difference Between the Cayman Fund and US Funds?

Accepted Answer

The Cayman Fund is intended exclusively for non-US persons and U.S. Persons which are tax-exempt organizations described in Section 501(c)(3) of United States Internal Revenue Code of 1986, as amended. The primary difference between the Funds is their registrations, tax jurisdictions and allowable investors.

The Cayman Fund is registered with the Cayman Islands Monetary Authority (CIMA) and submitted its offering docs to them prior to launch, versus the US funds which do so with the National Futures Association.

The Cayman Fund is not under US tax jurisdiction and thus does not file a partnership return with the US government as the US Fund does. Finally, the Cayman Fund allows non-US investors to choose which of Mutiny’s investment strategies they wish to invest in, at which point that money is invested by the Cayman Fund into the applicable US Fund: Long Volatility Fund for our Volatility, Volatility + Stocks, and 2.5x strategies and Cockroach Fund for our Cockroach and Commodity Trend strategies.

The Cayman Fund is only available to non-US persons or entities. That means:

You are not a U.S. citizen;
You do not have a U.S. permanent resident visa (“green card” in common parlance);
You do not spend “too many days” in the United States every year; and
You have not made a special election to be taxed as a U.S. resident.

The Cayman fund is also open to U.S. Persons which are tax-exempt organizations described in Section 501(c)(3) of United States Internal Revenue Code of 1986, as amended.

If you are a non-US person or entity, it is our understanding that Cayman fund investors would not be subject to U.S. estate taxes as they are not investing into a US entity whereas individual investors into the US Funds would be subject to the US estate tax. Investors into the Cayman Fund are also not required to fill out a W-8BEN.

In regards to tax jurisdictions, please note that we are not tax advisors and none of this is tax advice and you should consult with a tax expert to determine the most appropriate course of action.

If you’d like to consult with your tax advisor, the info you likely want to pass on is that our US funds are structured as US LLCs (Delaware LLCs), taxed as a partnership and investors will receive a K-1 showing their share of partnership income/expenses each year. The Mutiny Cayman Fund, Ltd. is an exempted company under the Cayman Mutual Fund Act.

Please note that there is a slight increase in the effective fee level on the Cayman Fund since investors in it are paying the same fees as the investors into the U.S. fund plus the operational expenses of the Cayman Fund (e.g. cost of Cayman based audit and directors).

Question 18

Can Offshore Investors Invest in the U.S. Fund?

Accepted Answer

We do accept certain non-US investors into our U.S. Funds, pending a few requirements.

We have non-US investors sign a W-8BEN which is essentially the investor representing that they are under a different non-US tax jurisdiction and will report their profit/loss to their local tax authority.

We also have non-US investors sign a side letter waiving their right to any US based income in the form of FDAP income (dividends or interest) which would trigger a withholding requirement by the fund. The funds are not designed to produce any such income, and as such we believe it will be a de minimis amount, if ever realized. This side letter attempts to prevent non-US investors from needing to file any U.S. tax forms such as the 1042 withholding form for any de minimis income. Interest from T-bills shouldn’t generate FDAP or ECI income for non-US investors.

We are unable to comment on the tax situation with specific countries as it’s outside our scope of expertise. If you’d like to consult with your tax advisor, the info you likely want to pass on is that both funds are structured as US companies (Delaware LLCs) and investors will receive a K-1 showing their share of partnership income/expenses each year.

Non-U.S. residents could also be subject to the U.S. estate tax. This applies only if an investor should pass away while invested in the fund as an individual. Investments via an entity are typically not subject to the estate tax as the entity does not pass away. One option if you are investing as an individual is to get a life insurance policy that would cover any taxes owed which is typically fairly affordable (depending on one’s age).

Non-U.S. investors will also need to sign a form that explains how you found out about us and confirms we did not actively solicit your investment in your home country.

Of course, nothing we say here is or should be considered tax advice.

Addendum: If you are a non-US person but have a Social Security Number or US Tax ID (e.g. if you were a U.S. resident at some point), please notify us of this prior to investing so we can accommodate your situation appropriately.

Question 19

What is the Process for Investing If I Decide to Do So?

Accepted Answer

If you move forward with an investment, the subscription process should take about 15-20 minutes.

The steps are:

Submit your information (est. 10 minutes) - To make the process smoother for you, we can pre-populate your subscription agreement to make the process smoother. In order to put your docs together, we will need you to complete our investor information form. If you prefer to do it yourself, let us know and we can send you the blank subscription agreement for you to fill out.

Filling out the form is not binding. We will not consider your subscription active nor ask you to wire funds until you have received, reviewed and signed off on the offering memorandum.
(For US Investors) Verify your accreditation (est. 5 minutes) - If you list a CPA, Lawyer or Financial Advisor in the investor information form, we will automatically email them on your behalf. If you do not have anyone that can verify your accreditation then we are able to accept accreditation from services Accredd and Parallel Markets. Non-US persons do not need to go through this process.
We Pre-Populate Your Subscription Agreement - Once we've received your investor information form, we will pre-populate your subscription documents and send them to you for electronic signature along with the appropriate tax documents (W9 for U.S. investors or W-8BEN for non-U.S. investors).
Review and Sign the Investment Documents - Review your pre-populated subscription agreement to confirm and sign.
We get 3rd Party Administrator Approval (We do it) - Once you have had time to review the documents and sign them, we will countersign them and send them to our third party administrator for their approval. If necessary, the administrator may contact you directly asking for follow up information or documentation.
Wire in Funds (5 minutes) - Once the administrator has confirmed that everything is in order, you will receive instructions to send either a wire or a check to our account at CIBC Bank for the amount of your subscription.

Question 20

What are the Deadlines for Making a New Investment in a Given Month?

Accepted Answer

In order to make sure all investors receive a smooth onboarding experience, our deadlines for investment are:

Finalized Subscription Documents are due 8 business days prior to the end of the month at 11:59pm ET/8:59pm PT. This includes acknowledgements of receipt of PPM and OA, signed Subscription Agreement, photo identification, tax form, accredited investor letter, and any corporate/entity/trust related documentation (if applicable).

Any completed subscription agreements received later than 8 business days prior to the end of the month will be assigned to the subsequent month. (For example, if we do not receive final docs until June 22nd, the investment will be active as of August 1. If all completed docs are received by June 21st, your investment will go active July 1st assuming the wire also arrives in time).

If you submit our investor information form by the 10th of the month, we anticipate you will have plenty of time to get your accreditation verified (for US investors only) and supply other documents should they be needed. If information is submitted just before the deadline then it is likely that your investment will be assigned to the following month though we will do our best to include it.

Subscription funds (e.g. a wire transfer) must be received no later than 5 business days prior to the end of the month by 4:30pm ET/1:30pm PT in order to be active at the start of the following month.

Question 21

Can I Invest Through My Existing Custodian Or Brokerage (E.G. Schwab, Fidelity, TD Ameritrade, Interactive Brokers, Etc.)?

Accepted Answer

We are able to accommodate clients of Registered Investment Advisors (RIAs) that use Schwab, Fidelity and TD Ameritrade through their RIA platforms.

We would love to be able to facilitate this for all investors. Unfortunately the major custodians and brokers we have spoken with do not enable investments into private funds.

The investment process would just require you to complete our subscription documents and send a wire from one of your existing accounts. Upon redemption, funds would be wired back to your account. You would be able to track the performance of the fund via monthly statements.

Question 22

Are You Able to Accept IRAs?

Accepted Answer

Yes, we are able to accept investments via Individual Retirement Accounts (IRAs), but most commonly those assets will need to be outside of a corporate plan and set up as a self-directed IRA (sometimes called checkbook IRAs). Equity Trust (formerly Midland) is the firm we most frequently work with and they charge a flat annual fee (around $325 at time of writing) for funds under their custody.

Millenium and Kingdom Trust are the other firms we've worked with, though we are able to get set up with any self-directed IRA provider that you prefer.

One important difference between Mutiny and a mutual fund, ETF or stock is that it is marked-to-market (vs a mutual fund or stock which only has tax triggered at time of sale) so that taxes will be owed each year.

For example, an investor investing $1mm that then sees their investment appreciate to $1.1mm over the course of a year will owe tax on the $100,000 profit. Because of this, investments via an IRA account may be more tax advantageous for investors.

Please note that due to transfer times outside our control, it typically takes ten days (and can take up to 3 weeks) from the time you start setting up a self-directed IRA to when you are able to fund your account. Our IRA Onboarding document has more details on the process and timelines of getting set up.

In order to make sure all investors set up a self-directed IRA in time for a following month investment, our recommendations are:

Setting up a self-directed IRA and funding by wire: +/ - 9 days. Process to be initiated by the 15th of the month.
Requesting a Transfer from another IRA (e.g. eTrade, Schwab, Fidelity) with funds available in cash: +/ - 9 days. Process to be initiated by the 15th of the month.
Setting up a self-directed IRA and funding by check: +/ - 14 days. Process to be initiated by the 10th of the month.
Requesting a Transfer, funds are not in an IRA and need to be rolled over from an employer plan. +/ - 21 days Process to be initiated by the 4th of the month.

Question 23

Are You Able to Accept 401ks?

Accepted Answer

We are not able to accept 401k plans provided through a company as it triggers ERISA regulations which we do not operate under.

We can take Solo 401ks if they are self-directed and not an ‘ERISA Plan”. The process would be the same as explained above in “Are you able to accept IRAs?” where you would need to choose a self-directed custodian and move your self-directed 401k account to them.

Question 24

What Are the Liquidity Terms? How Quickly Can I Redeem or Add Funds?

Accepted Answer

In the normal course of business, we are able to offer monthly liquidity. That means that if we get 8 business days' notice before the end of the month, we are able to send the majority of your funds the following month.

Typically, you will receive 90% of your funds back by the 15th of the following month.

For example, any request made before the March cut off (circa March 22nd) the ~90% wire would go out by April 15th. We do reserve the right to hold up to 10% of your investment until the next calendar year to finalize the audit and prevent any unnecessary back and forth, though this is not typical and we aim to finalize the full redemption within 30 days.

As a remnant of the financial crisis and people reading about gates and hedge fund lockups, some people worry about the impact of redemptions on other investors in the Fund.

In general, we are trading highly liquid markets and so do not anticipate any situation in which one investor redeeming would materially affect other investors.

In certain extreme circumstances, such as a delay in payments from 3rd-party funds, liquidity crisis, etc., the Fund may delay payment of redemptions until the Fund has sufficient assets to pay out those redemptions. We have never had an issue with this and do not anticipate this to be an issue.

To see a full list of risks associated with the Funds, please see the Private Placement Memorandum (PPM) which is available upon request or will be supplied upon submission of our investor information form to proceed with an investment.

If you are investing via a self-directed IRA custodian like Midland or Millenium, all redemption requests should be directed to Mutiny instead of an IRA in order to prevent delays.

Question 25

How to Add and Redeem Funds

Accepted Answer

To add or redeem funds, please complete our change form.

In order to accept additional funds or new investments, we need to receive the wires with funding five (5) business days before the month to make sure we are able to deploy the funds to our managers in a timely manner so we ask that you submit the change form no later than eight (8) business days before the end of the month.

Forms received later than eight (8) business days before the end of the month and wires received later than five (5) days before the end of the month will be held for allocation the subsequent month. (e.g. If the wire is received May 29, it will be invested July 1 rather than June 1 as it was not received 5 business days prior to June 1).

If you are redeeming funds, please note there are two parts to the process:

First, your investment will be reduced/end as of the last day of the month the request is made (assuming it is done before the 8 business day cut off date). For example, if you request a redemption on May 15th, your investment will be liquidated by the amount requested on the last trading day of May.

Second, the 3rd party administrator has to calculate the monthly performance and finalize the accounting for that month before we are able to send the full amount of your redemption.

Because we need all of our managers to finalize their accounting before we can finalize ours, this is unlikely to be completed before the 20th of the month and usually happens around the 25th-30th. Given this, our standard practice is to wire out 90% of your estimated capital account amount around the 10th-15th wires of the month. The remaining 10% of funds would go out after accounting is finalized, usually around the end of the month. In our example here of a request made on May 15th, the first wire would go out around June 10th-15th with 90% of the value. The second wire would go out around June 30th with the remaining balance.

Please be advised that this means any redemption request received inside of eight (8) business days prior to the end of the month (say May 29th) would mean your investment would remain active through the end of the following month (June 30), and the withdrawal redemption amount would be wired out the month after that (July in our example).

Question 26

When Will I Receive My Monthly Statement?

Accepted Answer

We anticipate you will typically receive your monthly statement around the 25th of the new month depending on how long it takes our sub-advisors to complete their monthly close process. We will also provide an estimate on the 1st of each month via our email distribution list which investors are automatically added to.

If you are not receiving the monthly estimate or the updated statement, please email invest@mutinyfund.com.

Question 27

What Will My Monthly Statements Looks Like?

Accepted Answer

Each month, investors will receive a statement from our Third Party Administrator similar to the one below. Statements should come out around the 25th of the month. They will typically look similar to the below:

We have annotated the document with the blue text to explain each line item.

To help clarify what each of the line items represents:

Beginning Balance: the balance of your capital account prior to the beginning of the month.
Additions: any additions you made to your account that went into effect that month.
Redemptions: any redemptions from your account that went into effect that month.
Management Fees: This is the 1% management fee/annum that Mutiny charges to manage the assets. The amount taken out is annualized (i.e. 1/12 of 1% is paid monthly).
Performance Fees/Allocation (AKA Mutiny Funds/APA Incentive Fee): This is the incentive fee that Mutiny Funds charges based on our performance. This crystallizes quarterly.
Trading Advisor Management Fee (AKA Sub-Advisors Mgmt Fee): This is the management fee which our sub-advisors (the hedge funds we allocate to) charge. Likewise it is annualized (i.e. 1/12 of the annual amount is paid monthly). The amount varies from sub-advisor to sub-advisor.
Trading Advisor Incentive Fee (Sub-Advisor Incentive Fee): This is the percentage of gains that each sub-advisor takes on trading profits. This also varies manager to manager.
Operating Expenses: This is operating expenses incurred by the fund in the normal course of business. This reflects things like the annual audit, state filing fees and bank fees.
Net Income: The net gain or loss for your account in that month.

Please note that all our funds use a high watermark or benchmark. In the case of a high watermark, investors are only assessed an incentive fee on net new profits. As an example, if you were to invest $100k and the value of your investment goes down to $95k then up to $105k, you would only pay the incentive fee on the $5,000 gain from $100k to $105k.

This means that depending on when someone invests, they will receive different returns than someone who invested at a different time. We try to account for the high watermark in the public number in the Tortuga Times or first of month estimates email but given everyone began investing at a different time, there will likely be discrepancies between the public numbers and your statements. Your statement number is the one you should rely on for tracking your personal investment’s value.

Question 28

Is There a Portal I Can Log In to View My Investment?

Accepted Answer

We can provide access to an online portal. Please note that the fund only strikes a Net Asset Value (NAV) once per month (around the 15th) so this number will not change other than the one day per month when we will also send out your statement via email. That means the portal will not give you any additional information to what you will receive via email, merely let you access it in your browser as opposed to in an email.

If you would like access to the portal as a reference then we are happy to facilitate that. Simply complete the form at the bottom of this page and select the “I want access to the portal with my monthly statements” option from the drop-down menu.

Question 29

Who are Mutiny's Service Providers?

Accepted Answer

Fund Structure - The fund is a Delaware LLC operating as registered commodity pools and regulated by the National Futures Association. It is co-managed by Mutiny Funds [NFA ID: 0523924] and Attain Portfolio Advisors [NFA ID: 0339046].
Fund accountant/controller - NAV Consulting (Best Fund Administrator - 2023 Hedgeweek US Digital Assets Awards)
Auditor - Cohen & Co (Hedgeweek’s Best Audit Provider - U.S. Digital Assets Awards)
Tax preparer - Cohen & Co
Legal counsel - Howard & Howard, Jeffrey Barclay
Bank - CIBC
Compliance Consultant - RCM Alternatives

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Management Fee	1%
Performance Fee	10%
Min Investment	$100,000
Redemptions	Monthly with 10 days notice
IRA Eligible	Yes
Investor Type	Accredited
Investor Eligibility	Global US master fund (for US investors) Cayman Islands feeder fund (for non-US investors)