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TIF FUND MANAGEMENT LLC
(“TIF”)
NFA ID# 0305212
SUMMARY OF DISCLOSURE & FAIR PRACTICE
Updated 1/30/04
TIF refers to TIF Fund
Management LLC, a multi-strategy, alternative investments investment
management company.
TIF’s role is:
development of investment vehicles, supervision of assets under management,
analysis of strategies, allocation of assets to strategies, diversification
among strategies & markets, communications, vigilance, administration, and
reporting.
TIF
1. Is a
licensed Commodity Pool Operator (“CPO”) and Commodity Trading Advisor (“CTA”)
with the Commodity Futures Trading Commission (“CFTC”).
2. Is
regulated by both the CFTC and the National Futures Association (“NFA”).
3. Is a
member in good standing of the NFA.
4. Uses selling
procedures that comply with the rules of the above bodies and also with the
requirements of the Securities and Exchange Commission, the National
Association of Securities Dealers and the applicable Securities Acts of 1933
and 1940.
5. Receives compensation
for operational expenses, management fees and profit sharing agreements.
All or a portion of these revenues may be shared with the trading
strategists to whom assets are allocated.
6.
Neither TIF nor its employees participate in any form of commissions or
other transactional expenses.
7. We
have no “soft dollar arrangements” and receive no “soft dollars” from any
source.
8. No
TIF employees other than James Moore, have access to any investors’ assets.
9. No
TIF strategy managers have access to any assets other than to make trades
via a limited power of attorney.
10. TIF
manages “Alternative Investment” asset pools (funds.)
We are not
brokers, we are not financial planners.
11. TIF
invests in “strategies” and financially backs specific “strategy managers”
with our funds’ assets.
12. TIF
products typically trades in exchange listed Securities, Debt Securities,
Derivatives and related options thereon.
13.
Positions must be capable of being “marked-to-market” at the close of
business each day by at least three or more independent services that are
well known in the industry.
14. Our
privacy policy is strict and is on our website.
15. The
SEC Rules under which our products are sold are clear:
a.
We are not permitted to advertise.
b.
We are required to determine the suitability of our
products for your portfolio.
c.
To determine suitability, you must provide us with an
accurate and up-to-date picture of your financial picture.
16. Investments are made
solely through either of two “Feeder Funds” that feed into the Master Fund.
No assets are retained at the Feeder Fund level. US or non-US citizens
(taxpayers) may invest in the Onshore (US) Feeder Fund. US tax-exempt or
non-US citizens may invest in the Offshore (non-US) Feeder Fund. US
citizens (taxpayers) are not permitted to invest in the Offshore (non-US)
Feeder Fund.
17. The Feeder Funds are
merely “pass through” entities used to gather assets and “feed” them to the
Master. No assets are retained at the Feeder Fund level, other than the
bare minimum required to maintain a bank account at a Financial Institution.
18. TIF
supervises, directs and administrates all of its own funds.
a.
We attempt to maintain a simple structure.
b.
Our outside auditor reviews our monthly statements at
least quarterly, prior to distribution.
c.
Our products have no complicated accounting or expense
calculation.
d.
There are no rents, salaries or complicated
arrangements or reciprocal agreements.
e.
We provide full statements to each investor.
f.
We can administer our funds at a lower cost than
outside administrators.
19. TIF’s funds do not
require the use of a Custodian. All investments are initially deposited
with JP Morgan-Chase Bank, New York.
Checks can only be received in the
name of the fund, not the management company.
20. JP Morgan-Chase has a
copy of each Fund’s Agreement and knows precisely how our fees are
calculated. They are not permitted to transfer greater amounts to TIF.
Only the Managing Member has signing or transfer
capability.
21. In
any investment, the Managing Member could abscond with your money but
controls are in place to reduce this possibility.
POTENTIAL INVESTORS:
TIF’s
products are all “3c1” offerings at this time.
1. To invest in a “3c1”
offerings (less than 100 investors), 1) the product you invest in must be
suitable for your portfolio, and 2) you must meet the specific minimum
financial qualifications of a Qualified Eligible Person. This also requires
you to have specific investment experience and knowledge of the risks
associated with alternative investments. You may find the “QEP” definition
both in our offering literature and on our Website.
TIF
anticipates making a “3c7” offering in the near future.
2. To invest in a “3c7”
offerings (less than 500 investors), the product in which you invest must be
suitable for your portfolio. Furthermore, you must also meet the more
stringent minimum financial qualifications of a Qualified Participant.
Again, you are required to have specific investment experience and knowledge
of the risks associated with alternative investments. You may find the “QP”
definition both in our offering literature and on our Website.
3. The SEC assumes that
if you have significant assets and that you are capable of making this type
of investment or know where to acquire the proper advice and counsel.
4. We request that you read
our “prequalification information” prior to our providing sales literature
or offering literature for any of our products.
OUR OFFERING LITERATURE:
1.
Specifically outlines all fees and expenses. You should fully understand
these costs and the break-even levels that apply to the investment of your
choice.
2. Is
designed to disclose all of the apparent risks associated with alternative
investment products.
3.
Clearly defines the markets we trade in, our services and our general
investment activities.
4. We
do not reveal the identity of our trading strategists or their specific
strategies.
5.
Provides in the Subscription Agreement a plain English contract and
Power-of-Attorney which you must sign to make the investment.
6. The
Managing Member is responsible for maintaining proper financial records
which are available monthly, including:
General Balance Sheet,
Income Statement and specific “Capital Account” information for your
individual investment.
TIF will also demonstrate
its basic financial solvency along with that of the specific product in
which you are invested.
All of this information will
be subject to our Privacy Policy.
7. As
an investor you assign full trading authority (Power of Attorney) to
management.
8.
Management then allocates assets to the respective trading strategists and
assigns a Limited Power of Attorney to each individual strategist.
9.
There are presently 16 strategies.
10.
Multiple strategies provide diversity in markets and methodologies. This
diversity spreads the risk while expanding the opportunities for profit.
11. We
do not want all of our investment capital allocated to one strategy or
market.
12.
Solicitors (agents) of the fund are independent operators and receive their
income via a Form 1099.
13. The
Management Company is a major investor in the Fund.
14.
James S. Moore, the Managing Member has the majority of his liquid assets
invested in TIF products.
MARKETING & COMMUNICATIONS
1.We
try to be consistent:
a.
Our agents may not contradict any information that is
in the Offering Memorandum.
b.
If you have any questions, the Offering Memorandum is
gospel.
c.
Our numbers are accurate.
d.
You will receive an estimate of the present period
performance upon demand.
e.
We will provide full disclosure of risk.
f.
You should like the look, feel, tone, and
quality of our communications.
2. We will communicate
with you on a timely basis. You may call during market hours (Eastern Time)
and we will provide you with an up to date estimate of the respective
products’ return for that period.
3. We
try to focus on both the big picture and the small.
4. We
try to keep our explanations simple.
5. The
focus is on you. It is your money and you are our best representative for
expanding our business.
6. Our integrity is our
greatest asset, but you can never confirm that we have it until we lose your
trust. James Moore has been on Wall Street since 1968 and has a host of
references. While we would never divulge our clients’ names without their
permission, the first thing you can do is to check on us with the National
Futures Association and the National Association of Securities Dealers.
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