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BVI FSC Approved ManagerIBR/AIM/26/2644

Investor Guide

How your capital is held, where every fee sits, and what can go wrong. Twelve chapters, all open, starting with a 60-second check of your own shelf.

CredentialsQlumina Inc.Approved Investment Manager, BVI Financial Services Commission

BVI company number
2201896
Approved Manager certificate
IBR/AIM/26/2644
Legal entity identifier
9845000BG592F5189B91

Registered officeRodus Building, P.O. Box 3093, Road Town, Tortola VG1110, British Virgin Islands.

Chapter 1Shelf check

Take the 60-second check before you read on. It tells you which chapters matter most to you.

  • Six one-tap questionsAbout a minute. Answer with a tap or the number keys.
  • A range forms as you answerWatch your tier narrow with every answer, before the last one.
  • A card you can keepA free self-assessment of your alternatives shelf, from Qlumina.
1 of 6

Alternatives shelf check6 taps. About a minute.

Which best describes you?

Answer six questions about how your clients hold alternatives. A tier range forms as you go.

One tap per question. Press 1 to 4.

Chapter 2Ownership

Switch the structure, then point at a number.

  1. Own the brokerage account and all underlying assets directly.

  2. Holds custody of funds; strictly restricts the LPOA to trading commands.

  3. Trading execution rights only, never the ability to withdraw, transfer, or encumber capital.

  4. Executes strategy; zero withdrawal or asset-transfer capabilities.

Fig. 1Separately managed account. Schematic, not to scale.

Broker-level risk control

A floor the manager cannot move.

Certain prime brokers offer automated risk controls configured at the account infrastructure layer, independent of the investment manager. The example from this guide: $1,000,000, a 10% maximum drawdown tolerance, a floor at $900,000.

  1. The managerTrading signals only

    Executes strategy under a limited power of attorney. No withdrawals, no asset transfers, and no say over the layer below.

  2. Your brokerFloor $900,000

    Below the floor: positions closed10% tolerance

  3. YouStarting equity $1,000,000

    The brokerage account and every asset in it stay in your name.

If equity touches the floor, the broker:

  1. 1Closes all active positions
  2. 2Deactivates Qlumina's trading access
  3. 3Notifies the investor immediately
Fig. 2Example from the guide. The scale is cropped to $800,000 to $1,000,000.

Chapter 3Structures

Pick what matters to you. The structures answer side by side.

SMAMarketplace format

Separately managed account

Individually managed portfolios where the investor retains direct legal and beneficial ownership of all assets in their own segregated brokerage account.

Liquidity

Daily

Positions may be liquidated or the mandate terminated on any business day.

AMC

Actively managed certificate

Securitized investment products tracking a Qlumina strategy with an ISIN, issued through an institutional issuance vehicle or bank.

Liquidity

Weekly

Weekly subscription/redemption; secondary market if exchange-listed.

Hedge fund

Hedge fund vehicle

Pooled investment vehicles structured as limited partnerships or corporate funds, offering scalable access to complex or capacity-constrained strategies.

Liquidity

Monthly (with notice)

Subject to notice (typically 30–90 days), with possible initial lock-ups and gates.

Chapter 4Vs fund

In a fund

Investors pool capital into a single corporate or partnership vehicle that owns the underlying positions.

In a separately managed account

Assets remain segregated with zero commingling, and the investor verifies all activity through their own brokerage statements.

Full comparison Trade-only limited power of attorney managed accounts

Chapter 5SMA

An individually owned investment portfolio managed on behalf of a single investor, with assets held in a segregated brokerage account in the investor's own name.

Qlumina does not hold, control, or withdraw investor funds. It is granted a Limited Power of Attorney permitting only the transmission of trading signals.

  1. YouOwn the account and every asset in it
  2. Your brokerSegregated account, in your own name
  3. QluminaTrading signals only, under the LPOA

Full definition

Chapter 6Fund or SMA

Three answers, five rows. Every line below is a fact from this guide.

Your ticket
How fast you may need cash back
Where your assets sit
Separately managed account3 of 3 answers fit

Clears the $100K minimum per program

Fund0 of 3 answers fit

Below the indicative $250K+ in the offering memorandum

  1. Custody

    Managed account

    A segregated brokerage account in your own name. Qlumina never takes custody; the limited power of attorney covers trading only.

    Fits your answer
    Fund

    The fund holds the assets, through its administrator and prime broker. You hold shares or limited partnership interests.

    Differs from your answer
  2. Liquidity

    Managed account

    Daily. Positions may be liquidated or the mandate ended on any business day.

    Fits your answer
    Fund

    Monthly, with notice of typically 30 to 90 days. Initial lock-ups and gates are possible.

    Differs from your answer
  3. Fees

    Managed account

    Manager fee visible line by line on your own account. No front-end load, back-end load or custody fee.

    Fund

    Management and performance fees sit inside the NAV. Entry and exit charges vary by fund.

  4. Reporting

    Managed account

    Real-time broker access 24/7, plus daily broker statements.

    Fund

    Periodic NAV, monthly or quarterly, verified by an independent administrator.

  5. Exit

    Managed account

    End the mandate when you decide. Nothing is locked.

    Fits your answer
    Fund

    Redeem in a window on the fund's schedule, subject to notice, lock-ups and gates.

    Differs from your answer

Indicative terms. The terms that bind are the ones in your mandate. Not investment advice.

Chapter 7Fees

In your own account, a fee is a line you can read.

  • Your holding

    Managed accountEvery position, in your name

    FundA share of the vehicle

  • Management fee

    Managed accountA visible line on your account

    FundInside the vehicle, in the NAV

  • Performance fee

    Managed accountOn net new profits above the monthly high-water mark

    FundInside the vehicle, in the NAV

  • Entry charge

    Managed accountNone, no front-end load

    FundVaries by fund

  • Exit charge

    Managed accountNone, no back-end load

    FundVaries by fund

What you see. Managed account: every position and every fee line, and no custody fee at the broker. Fund: one NAV per share.

Fig. 3Structure only. No fee levels are shown; the terms that bind are the ones in your mandate.

Fee mechanics

Paid on new highs, not on recoveries.

Management fee
Annual % of AUM, billed monthly pro rata
Performance fee
On net new profits above monthly HWM
Management fee billing
Monthly (1/12 pro rata)
HWM cycle
Monthly
Fee calculation basis
Direct account; investor verifies on statements

The high-water mark ensures a manager only earns performance fees on net new profits — recovering any prior drawdowns before earning further fees — aligning manager incentives with investor outcomes.

High-water markMonthly check, twelve months
Move across the chart
Account valueHigh-water markFee-eligible gain

Chapter 8Evidence

Four independent sources, triangulated before any track record is presented.

01 / 03

Four sources, one record.

Every track record is checked against four independent records before it is shown.

Administrator NAV statementsOfficial reporting packages produced by regulated fund administrators.
Direct prime broker statementsTrade confirmations and daily equity runs sourced directly from institutional clearing brokers.
Timestamped tick-level trade dataEvery individual execution is analyzed for slippage, latency, and fill veracity.
Live pilot capital allocationsDeploying real capital within our proprietary ecosystem to verify execution veracity before public onboarding.
Triangulated recordPresented only after all four reconcile

02 / 03

AI accelerates. People sign off.

AI operates as a powerful accelerant to human judgment. It never replaces human fiduciary oversight.

  1. AI-assisted01 Research & discovery

    Deep data analysis, feature extraction, and automated factor testing across decades of tick-level market data.

  2. AI-assisted02 Manager evaluation

    Algorithmic verification of timestamped fills, detecting overfitting, hidden regime bias, and tail risks.

  3. AI-assisted03 Real-time monitoring

    Live factor drift tracking, automated intraday VaR boundary enforcement, and liquidity regime classification.

  4. Human sign-off04 Human-in-the-loop

    All portfolio allocations, capital adjustments, and risk parameters require veteran human fiduciary sign-off.

03 / 03

Three families of alpha.

Programs fall into three families, each built on a different market behavior.

Systematic trend & macro

Medium-term trend (MFT)

Adaptive multi-horizon trend identification across 45+ liquid CME global futures. Designed for crisis alpha and sustained directional expansion.

Statistical arbitrage

Market-neutral mean reversion

Paired equity trades exploiting temporary statistical pricing dislocations in S&P 500 and Russell indices with strict beta neutrality.

Alpha acceleration

High-conviction equity momentum

Deep-learning regime classification isolating structural capital inflows into liquid US equities with disciplined weekly reconstitution.

How the review works: Investment Philosophy

Chapter 9Risk

Where each risk sits, from the signal to your capital. Nothing here is summarized away.

01 / 03

Risk begins where signals are made.

Models can fail when markets change character. These are the controls against it.

  • Market & factor risk

    Adverse price movements, systemic liquidity dry-ups, and macro shocks.

  • Model & parameter risk

    Algorithmic signal decay during unprecedented market regime shifts.

  • Model validation & anti-overfitting controls

    Quantitative research is guarded by rigorous walk-forward cross-validation, out-of-sample stress testing across disparate market regimes (including the 2008 Global Financial Crisis, 2020 Liquidity Shock, and 2022 Inflationary Cycle), and combinatorial purged cross-validation to prevent data snooping and look-ahead bias.

02 / 03

Then it travels through the plumbing.

Orders, custody and, for certificates, the issuer each add a risk of their own.

  • Execution & slippage

    Latency and spread widening during fast-moving macroeconomic events.

  • Counterparty risk

    Operational or financial distress at prime brokers, custodians, or issuers.

  • Issuer credit risk (AMC)

    Because an AMC is a debt obligation of the issuer, issuer insolvency may result in the partial or total loss of invested capital, regardless of the underlying quantitative strategy's performance. Counterparty creditworthiness must be evaluated prior to allocation.

03 / 03

Every layer ends at your capital.

Whatever goes wrong above lands here.

  • Capital is not guaranteed

    Qlumina does not guarantee any return of capital or specific performance outcome. All quantitative and alternative investments involve substantial risk of loss, including the possible loss of principal.

Reference desk

Every topic, in full.

24 topics across risk, structures, operations and regulation. Search them, or browse by section.

24 of 24 topics

Risk

Capital is not guaranteed

Qlumina does not guarantee any return of capital or specific performance outcome. All quantitative and alternative investments involve substantial risk of loss, including the possible loss of principal.

Chapter 10Glossary

14 terms you will meet in a mandate.

AMCActively managed certificate
A note or certificate issued by a bank or special purpose vehicle that tracks an actively managed strategy. A claim against the issuer.Chapter 3
Approved ManagerBVI FSC category
A category of investment manager authorized by the BVI Financial Services Commission to manage investment funds and accounts.Chapter 9
High-water markPerformance fee threshold
A manager only earns performance fees on net new profits, recovering any prior drawdowns before earning further fees.Chapter 7
IMAInvestment management agreement
The mandate document between you and the manager, executed together with the LPOA.Chapter 12
ISINSecurity identifier
The identifier assigned to an AMC, so it can be held through a standard brokerage account.Chapter 3
KYC / AMLIdentity and source of wealth
Identification, proof of address, source of wealth and eligibility sign-off, under BVI AML/CTF rules.Chapter 12
LEILegal entity identifier
The GLEIF international standard identifier for a legal entity.Chapter 9
Lock-up and gateFund redemption limits
Fund terms that hold capital after subscription or limit redemptions in a window. In SMA format, nothing is locked.Chapter 3
LPOALimited power of attorney
Grants trading execution rights only, never the ability to withdraw, transfer, or encumber investor capital.Chapter 2
MandateYour terms, agreed with you
Risk limits, exposures, exclusions and the broker, agreed with you. It ends when you say it does.Chapter 2
NAVNet asset value
The official valuation of a certificate or fund; for funds, calculated by an independent administrator.Chapter 7
Prime brokerCustody and execution
Holds custody of funds and strictly restricts the LPOA to trading commands.Chapter 2
SIBASecurities and Investment Business Act, 2010
The BVI statute Qlumina operates under, as administered by the BVI FSC.Chapter 9
SMASeparately managed account
An individually owned portfolio managed for a single investor, held in a segregated brokerage account in the investor's own name.Chapter 2

Chapter 11Questions

Straight answers drawn from the chapters above. Search them, or read them all.

8 of 8 questions

  1. What is the difference between an SMA and a hedge fund?

    In a fund, investors pool capital into a single corporate or partnership vehicle that owns the underlying positions. In an SMA, assets remain segregated with zero commingling. This delivers direct transparency into every open position, daily liquidity, the ability to impose personalized restrictions, and, in many jurisdictions, individual tax-loss harvesting advantages. The investor verifies all activity through their own brokerage statements — visibility not possible in pooled offshore structures with monthly or quarterly reporting lags.

  2. Who holds my money in a separately managed account?

    Assets are held in a segregated brokerage account in the investor's own name at an institutional prime broker or custodian. Qlumina never takes custody of funds and is granted a Limited Power of Attorney permitting only the transmission of trading signals, never the ability to withdraw, transfer or encumber capital.

  3. What is an actively managed certificate (AMC)?

    An AMC is a note or certificate issued by a bank or special purpose vehicle that tracks an actively managed strategy. It is a claim against the issuer, so issuer credit risk applies in addition to the strategy's market risk.

  4. How do the fees work?

    In an SMA the management fee is annual % of aum, billed monthly pro rata, and the performance fee is charged on net new profits above monthly hwm. The investor verifies the fee basis on their own account statements. A manager only earns performance fees on net new profits, recovering prior drawdowns before earning further fees.

  5. What are the indicative minimum investments?

    Every SMA program carries the same $100K minimum, set platform-wide. FX & liquid CFDs: High turnover, tight spreads, flexible fractional allocation. US liquid equities: Direct exchange execution across major US equities and ETFs. CME global futures: Futures trade in whole contracts, so a smaller account holds fewer contracts across a multi-asset book. The terms that bind are the ones in your mandate.

  6. Who is eligible to invest?

    Qlumina accepts allocations strictly from Professional Investors, High-Net-Worth Individuals (net worth exceeding US$1,000,000 excluding primary residence), and Institutional Counterparties as defined under the BVI Securities and Investment Business Act, 2010 (SIBA). Retail clients are strictly prohibited.

  7. Is Qlumina regulated, and how can I check?

    Qlumina Inc. is incorporated in the British Virgin Islands as a BVI Business Company (No. 2201896) and approved by the BVI Financial Services Commission as an Approved Investment Manager under the Investment Business (Approved Managers) Regulations, 2012, Certificate No. IBR/AIM/26/2644. Its Legal Entity Identifier is 9845000BG592F5189B91. Approved Manager status is a category of authorization with regulatory conditions, and it is not a guarantee of any investment outcome.

  8. How do I get started?

    Request access to start investor onboarding, or talk to the desk. The sequence is eligibility, KYC and AML checks (identification, proof of address, source of wealth and eligibility sign-off), execution of the investment management agreement and limited power of attorney, account opening at an approved prime broker in your own name, and funding.

Managers: read the due diligence FAQ

Chapter 12Access

Seven steps, from first contact to an account you can watch.

  1. 01Request access

    Start Investor Onboarding, or talk to the desk.

  2. 02Eligibility

    Professional investors, high-net-worth individuals and institutional counterparties under SIBA. No retail clients.

  3. 03KYC / AML

    Compliance review and formal institutional clearance.

    • Identification
    • Proof of address
    • Source of wealth
    • Eligibility sign-off
  4. 04Mandate & LPOA

    Execute the IMA and LPOA granting trading execution rights only.

  5. 05Account setup

    Open an account at an approved prime broker in the investor's legal name.

  6. 06Funding & go-live

    Fund the account directly. Qlumina commences algorithmic strategy execution.

  7. 07Supervise

    Full real-time account access 24/7 plus daily broker statements.

General risk warning

Investing involves substantial risk of loss. The value of investments and the income derived from them can fall as well as rise, and investors may not recover the amount originally invested. Past performance is no guarantee of future returns. Nothing in this document constitutes financial, legal, tax, or investment advice.

Regulatory status

Qlumina Inc. is incorporated in the British Virgin Islands as a BVI Business Company (No. 2201896) and approved by the BVI Financial Services Commission as an Approved Investment Manager under the Investment Business (Approved Managers) Regulations, 2012, Certificate No. IBR/AIM/26/2644.