Form N-CSR Advisors Preferred Trust For: Sep 30

December 8, 2021 10:46 AM EST

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united states
securities and exchange commission
washington, d.c. 20549

form n-csr

certified shareholder report of registered management
investment companies

Investment Company Act file number 811-22756

 

Advisors Preferred Trust

(Exact name of registrant as specified in charter)

 

1445 Research Blvd, Suite 530, Rockville, MD 20850

(Address of principal executive offices) (Zip code)

 

The Corporation Trust Company

1209 Orange Street Wilmington, DE 19801

(Name and address of agent for service)

 

Registrant's telephone number, including area code: 631-470-2734

 

Date of fiscal year end: 9/30

 

Date of reporting period: 9/30/21

 

Item 1. Reports to Stockholders.

 

 

 (LOGO)

 

 

Spectrum Low Volatility Fund

Spectrum Advisors Preferred Fund

Spectrum Unconstrained Fund

 

 

Annual Report 

September 30, 2021

 

 

 

 

 

Investor Information: 1-866-862-9686

 

This report and the financial statements contained herein are submitted for the general information of shareholders and are not authorized for distribution to prospective investors unless preceded or accompanied by an effective prospectus. Nothing herein contained is to be considered an offer of sale or solicitation of an offer to buy shares of the Spectrum Funds. Such offering is made only by prospectus, which includes details as to offering price and other material information.

 

Distributed by Ceros Financial Services, Inc.

Member FINRA 

 

 

November 23, 2021

 

Dear Shareholders:

 

This annual report for the Spectrum Funds covers the period from October 1, 2020 –September 30, 2021. The Spectrum Low Volatility Fund was built to adapt to changing credit markets while seeking to outperform with superior risk-adjusted returns through exposure to all available credit markets. The Fund returned 10.82% for the year; the Fund’s primary benchmark, the S&P/LSTA U.S. Leveraged Loan 100 Total Return Index, returned 6.66% for the same period. The Fund’s secondary benchmark, a customized index composed of a 50% weighting of the Barclays U.S. High Yield Very Liquid Total Return Index and a 50% weighting of the S&P Leveraged Loan 100 Total Return Index, rose by 8.32% for the year.

 

As October 2020 began, economically sensitive bond classes such as high yield, emerging market and convertibles moved higher as investors looked with optimism for another stimulus package. Exposure to credit within the Fund was rapidly increased. In November and December, credit markets continued to move higher to close out a tumultuous year. Market participants remained positioned for potential volatility, utilizing credit assets for yield and as a safe haven from possible equity swings. After this investor enthusiasm for risk-on assets in the final quarter of 2020, January 2021 opened with less fanfare. As interest rate risk began to rise early in the month, exposure to high yield bonds was reduced. Duration was a strong theme throughout the first three months of the year as yield spreads tightened. Positions within longer duration products, such as high yield, were decreased and replaced with shorter duration bonds including senior loans that have a floating rate coupon.

 

April and May were relatively quiet months within fixed income sectors. Shorter duration products continued to outperform their longer duration counterparts as low rates compressed risk premiums across markets. Treasuries even participated in the rise, proving their resiliency in the face of continually strong economic data. Few changes were made in the portfolio until a modest pullback in mid-May within high yield caused the Sub-advisor to lighten exposure in that asset class. Fixed income products saw mostly choppy price action throughout June but ended with a mildly positive bias. Yield spreads remained thin, contributing to a reduction in demand for some bond classes. Preferreds and convertible bonds, however, saw favorable tailwinds supported by the theme of a re-opening economy. Municipals also continued to build on favorable trends. Portfolio changes in the Fund were minor during June and July. Credit remained mostly resilient in the face of equity volatility. Liquidity and volumes in the bond markets remained low as investors awaited the outcome of the Jackson Hole Fed meeting which took place the end of August. Senior loan issues held up better for most of the month as high yield was partially dragged down by declines in energy. After six weeks of declines, high yield began to firm up and the Fund added some exposure to that sector on an opportunistic basis. Credit remained resilient in September given the weakness of equities and the increased market volatility. While the risk of slower growth ultimately bled over to high yield from the equity markets, the rise in Treasury yields pressured fixed income broadly. Continued weakness within municipal bonds led the Sub-advisor to strongly trim exposure within that category early in the month. Small opportunistic trades were made within high yield assets, but ultimately ended the month neutral. The Sub-advisor used total return swaps on mutual funds and credit default swaps to execute a portion of its strategy during the period.

 

The Spectrum Advisors Preferred Fund returned 33.91% for the year ending September 30, 2021. The Fund’s benchmark, the S&P 500 Total Return Index, returned 30.00% for the period. A customized benchmark comprised of a 60% weighting of the NYSE Composite Index and a 40% weighting of the Bloomberg Barclays U.S. Aggregate Bond Index returned 17.57% for the twelve months. The Fund provides investors with opportunistic access to equities and bonds. 

1

 

Equity markets contracted in October 2020. The Fund’s performance was initially strong and only modest defensive measures were taken when market momentum eased. The stock market performed extremely well in November with the S&P 500 Index of large cap stocks having its best monthly return since the sharp rebound in April 2020. Small cap stocks, as measured by the Russell 2000 Index, performed even better than its April return and better than the S&P 500 Index. As the stock market tested its September lows, technical buying support was detected, and the Sub-advisor added positions that allowed the Fund to take advantage of the November rebound. Equity markets rallied in December, led by small caps as measured by the Russell 2000 Index. The Sub-advisor made several tactical adjustments to the Fund’s portfolio, but overall, was in a bullish stance. Large caps, mostly technology, and small caps were primary contributors to performance.

 

Equity markets started the year with strong momentum. On several occasions during January, the Sub-advisor reduced exposure very briefly, followed by rapidly adding positions to take advantage of short-term opportunities. Investors drove equity markets higher early in February, led by small caps. The new 52-week highs by the S&P 500 Index, NASDAQ and small cap Russell 2000 were short-lived. The Fund reduced positions modestly somewhat early in the month as momentum turned less favorable. In March, as optimism for a return to normalcy took hold, the Fund made several sharp exposure adjustments as momentum ebbed and flowed.

 

April began with a broad-based rally in equities, led by technology, consumer discretion and utilities, which were replaced as leading sectors mid-month by industrials, financials, basic materials and healthcare. Against this backdrop, the Sub-advisor made only minor tactical adjustments in the Fund’s portfolio. In May, the S&P 500 and the Russell indices each posted modest gains as the tech- heavy NASDAQ posted a loss. The Sub-advisor made multiple sharp adjustments between defensive and offensive issues as the equity markets pulled back. Favorable equity returns in June were generally focused within large caps as small and mid-caps mostly consolidated in choppy patterns. The Sub-advisor made several minor adjustments to the Fund’s holdings, emphasizing technology stocks. A sudden loss in momentum mid-month in the equity markets caused the Sub-advisor to undertake defensive measures. Equity volumes were low in August, which likely contributed to the choppy price action. The Fund began the month with a bullish stance but without the full use of strategic leverage. The Sub-advisor further reduced positions as momentum faltered mid-month. Most equity sectors lost ground in September with the exception of energy, banking, and transportation stocks. The Fund was active, tactically raising and lowering exposure during the month according to signals. Throughout the year, the Sub-advisor used futures and total return swaps on equities to execute a portion of its strategy.

 

The new Spectrum Unconstrained Fund returned 4.50% from inception on April 16 through September 30, 2021. The Fund’s primary benchmark, the Bloomberg Aggregate Bond Index was up 1.03% for the same period, and the S&P 500 Total Return Index increased by 3.57% during this time. The Fund seeks total return from fixed income and preferred stock investments through the ability to employ considerable leverage in certain market environments. The Fund actively traded ETF bond positions and maintained some core positions in securitized credit funds. Although the Fund was modestly leveraged during most of the period, it never attained full leverage due to market conditions. The Sub-advisor used total return swaps on ETF’s and mutual funds to execute a portion of its strategy during the period.

 

Thank you for your investment in the Funds. Please visit the website www.thespectrumfunds.com at any time for information regarding the Funds.

 

Spectrum Financial, Inc. Advisors Preferred, LLC
   
Sub-advisor to the Funds Advisor to the Funds

2

 

Spectrum Low Volatility Fund 

Portfolio Review (Unaudited) 

September 30, 2021

 

The Fund’s performance figures* for the periods ended September 30, 2021, as compared to its benchmark:

 

    Annualized
  One Year Five Year Since Inception **
Spectrum Low Volatility Fund - Investor Class 10.82% 9.25% 8.06%
S&P/LSTA Leveraged Loan 100 Index*** 6.66% 4.26% 3.58%

 

*The performance data quoted is historical. Past performance is no guarantee of future results. Current performance may be higher or lower than the performance data quoted. The principal value and investment return of an investment will fluctuate so that your shares, when redeemed, may be worth more or less than their original cost. The returns shown do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or on the redemptions of Fund shares. Returns greater than 1 year are annualized. The total gross annual operating expenses as stated in the fee table of the Fund’s prospectus dated February 1, 2021 is 3.02% for the Investor Class. The gross expense ratio shown above does not tie to the financial highlights in the annual report due to acquired funds fees. For performance information current to the most recent month-end, please call 1-866-862-9686.

 

**Inception date is December 16, 2013.

 

***The S&P/LSTA Leveraged Loan 100 Index is designed to reflect the performance of the largest facilities in the leverage loan market.

 

Comparison of the Change in Value of a $10,000 Investment 

Since Inception through September 30, 2021

 (LINE GRAPH)

 

Portfolio Composition as of September 30, 2021 (Unaudited)

 

Holdings by Type of Investment:     % of Net Assets * 
Mutual Funds   50.7%
Short-term Investments   43.4%
Other Assets in Excess of Liabilities   5.9%
    100.0%

 

*The portfolio composition detailed above does not include derivative exposure.

 

Please refer to the Portfolio of Investments and the Shareholder Letter in this report for a detailed listing of the Fund’s holdings. 

3

 

Spectrum Advisors Preferred Fund 

Portfolio Review (Unaudited) 

September 30, 2021

 

The Fund’s performance figures* for the periods ended September 30, 2021, as compared to its benchmark:

 

    Annualized
  One Year Five Years Since Inception **
Spectrum Advisors Preferred Fund - Investor Class 33.91% 15.52% 11.71%
S&P 500 Total Return Index *** 30.00% 16.90% 14.11%

 

*The performance data quoted is historical. Past performance is no guarantee of future results. Current performance may be higher or lower than the performance data quoted. The principal value and investment return of an investment will fluctuate so that your shares, when redeemed, may be worth more or less than their original cost. The returns shown do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or on the redemptions of Fund shares. Spectrum Advisors Preferred Fund’s Investor Class shares are subject to a gross annual operating expense ratio of 2.35%, as per the February 1, 2021 Investor Class prospectus. The gross expense ratio shown above does not tie to the financial highlights in the annual report due to acquired funds fees. For performance information current to the most recent month-end, please call 1-866-862-9686.

 

**Inception date is June 1, 2015.

 

***The S&P 500 Total Return Index is an unmanaged composite of 500 large capitalization companies and includes the reinvestment of dividends. This index is widely used by professional investors as a performance benchmark for large-cap stocks. Investors cannot invest directly in an index.

 

Comparison of the Change in Value of a $10,000 Investment 

Since Inception through September 30, 2021

 

(LINE GRAPH)

 

Portfolio Composition as of September 30, 2021 (Unaudited)

 

Holdings by Type of Investment:     % of Net Assets * 
Short-term Investments   67.7%
Mutual Funds   29.7%
Other Assets in Excess of Liabilities   2.6%
    100.0%

 

*The portfolio composition detailed above does not include derivative exposure.

 

Please refer to the Portfolio of Investments and the Shareholder Letter in this report for a detailed listing of the Fund’s holdings. 

4

 

Spectrum Unconstrained Fund 

Portfolio Review (Unaudited) 

September 30, 2021

 

The Fund’s performance figures* for the period ended September 30, 2021, as compared to its benchmark:

 

  Since Inception **
Spectrum Unconstrained Fund - Investor Class 4.50%
Bloomberg U.S. Aggregate Bond Index *** 1.03%

 

*The performance data quoted is historical. Past performance is no guarantee of future results. Current performance may be higher or lower than the performance data quoted. The principal value and investment return of an investment will fluctuate so that your shares, when redeemed, may be worth more or less than their original cost. The returns shown do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or on the redemptions of Fund shares. Spectrum Unconstrained Fund’s Investor Class shares are subject to a gross annual operating expense ratio of 2.93%, as per the April 13, 2021 Investor Class prospectus. The gross expense ratio shown above does not tie to the financial highlights in the annual report due to acquired funds fees. For performance information current to the most recent month-end, please call 1-866-862-9686.

 

**Inception date is April 16, 2021.

 

**The Bloomberg U.S. Aggregate Bond Index is an unmanaged index comprised of U.S. investment grade, fixed rate bond market securities, including government, government agency, corporate and mortgage-backed securities. Investors cannot invest directly in an index; unlike the Fund’s returns, the index does not reflect any fees or expenses.

 

Comparison of the Change in Value of a $10,000 Investment

Since Inception through September 30, 2021

 

(LINE GRAPH)

 

Portfolio Composition as of September 30, 2021 (Unaudited)

 

Holdings by Type of Investment:     % of Net Assets * 
Short-term Investments   66.7%
Mutual Funds   19.9%
Other Assets in Excess of Liabilities   13.4%
    100.0%

 

*The portfolio composition detailed above does not include derivative exposure.

 

Please refer to the Portfolio of Investments and the Shareholder Letter in this report for a detailed listing of the Fund’s holdings. 

5

 

SPECTRUM LOW VOLATILITY FUND 

PORTFOLIO OF INVESTMENTS 

September 30, 2021

 

Shares      Value 
     MUTUAL FUNDS - 50.7%     
     DEBT FUNDS - 50.7%     
 3,724,556   AlphaCentric Income Opportunities Fund, Class I  $44,880,900 
 2,050,860   Axonic Strategic Income Fund, Class I   20,488,093 
 3,733,681   Braddock Multi-Strategy Income Fund, Institutional Class   27,479,894 
 3,041,036   Cohen & Steers Preferred Securities and Income Class F   43,851,734 
 3,370,339   Columbia Mortgage Opportunities Fund Class I3   35,860,407 
 2,106,247   DoubleLine Flexible Income Fund Class I   20,388,475 
 1,131,433   Holbrook Income Fund Class I   12,095,022 
 2,078,873   Semper MBS Total Return Fund, Institutional Class   20,061,126 
     TOTAL DEBT FUNDS (Cost - $210,212,236)   225,105,651 
           
     MUNICIPAL FUND - 0.0%     
 5,423   Nuveen High Yield Municipal Bond Fund, Class I   99,241 
     TOTAL MUNICIPAL FUND (Cost - $100,361)     
           
     TOTAL MUTUAL FUNDS (Cost - $210,312,597)   225,204,892 
           
     SHORT-TERM INVESTMENTS - 43.4%     
     MONEY MARKET FUNDS - 43.4%     
 192,924,934   Fidelity Government Portfolio, Class I, 0.01% (a)   192,924,934 
     TOTAL SHORT-TERM INVESTMENTS (Cost - $192,924,934)     
           
     TOTAL INVESTMENTS - 94.1% (Cost $403,237,531)  $418,129,826 
     OTHER ASSETS IN EXCESS OF LIABILITIES - 5.9%   26,030,344 
     NET ASSETS - 100.0%  $444,160,170 

 

(a)Rate disclosed is the seven-day effective yield as of September 30, 2021.

 

See accompanying notes to financial statements.

6

 

SPECTRUM LOW VOLATILITY FUND
PORTFOLIO OF INVESTMENTS (Continued)
September 30, 2021

 

TOTAL RETURN SWAPS

 

Number of
Shares
  Reference Entity*  Notional Amount
at September
30, 2021
   Interest Rate Payable (1)  Termination
Date
  Counterparty  Unrealized
Appreciation
(Depreciation)
 
Long Position:                      
1,185.808  AlphaCentric Income Opportunities Fund  $14,288,982   3-Mth USD LIBOR plus 150 bp  7/22/2022  BRC  $ 
2,519,549  AlphaCentric Income Opportunities Fund   30,360,562   3-Mth USD LIBOR plus 185 bp  9/13/2022  CIBC    
5,543,189  Credit Suisse Floating Rate High Income Fund   36,751,344   3-Mth USD LIBOR plus 150 bp  6/30/2022  BRC    
5,083,908  Eaton Vance Floating-Rate Advantaged Fund   53,838,589   3-Mth USD LIBOR plus 150 bp  6/30/2022  BRC    
7,072,540  Invesco Senior Floating Rate Fund   50,215,034   3-Mth USD LIBOR plus 150 bp  6/30/2022  BRC    
54,083  Nuveen High Yield Municipal Bond Fund   990,806   3-Mth USD LIBOR plus 150 bp  7/31/2024  BRC    
1,668,206  Nuveen Preferred Securities and Income Fund   29,844,213   3-Mth USD LIBOR plus 150 bp  7/31/2024  BRC    
3,221,384  Osterweis Strategic Income Fund   37,142,556   3-Mth USD LIBOR plus 150 bp  7/31/2024  BRC    
22,973,976  PIMCO Government Money Market Fund   22,973,976   3-Mth USD LIBOR plus 150 bp  7/31/2024  BRC    
1,988,906  PIMCO Income Fund   23,946,425   3-Mth USD LIBOR plus 150 bp  6/30/2022  BRC    
2,011,341  PIMCO Preferred and Capital Securities Fund   22,909,171   3-Mth USD LIBOR plus 150 bp  7/31/2024  BRC    
2,116,640  PIMCO Preferred and Capital Securities Fund   24,108,526   3-Mth USD LIBOR plus 185 bp  7/26/2022  CIBC    
3,368,022  Principal Spectrum Preferred and Capital Securities Income Fund   35,431,599   3-Mth USD LIBOR plus 185 bp  10/4/2022  CIBC    
                 Total:  $ 

 

BRC - Barclays Capital

 

CIBC - Canadian Imperial Bank of Commerce

 

LIBOR - London Interbank Offered Rate

 

(1)Interest rate is based upon predetermined notional amounts, which may be a multiple of the number of shares plus a specified spread.

 

*Swap contract reset at September 30, 2021.

 

CENTRALLY CLEARED CREDIT DEFAULT SWAP AGREEMENTS - SELL PROTECTION: (1)(2)(3)
Reference
Entity
  Counterparty  Termination
Date
  Interest Rate
Received(4)
  Notional Value at
September 30,
2021
   Fair Value   Upfront
Premiums
Paid
   Unrealized
Appreciation
 
CDX North American High Yield Series 37 v1  CS  12/20/2026  500 bps  $44,800,000   $(4,189,775)  $(4,221,330)  $31,555 

 

CS - Credit Suisse Securities (USA) LLC

 

 

(1)For centrally cleared swaps, when a credit event occurs as defined under the terms of the swap contract, the Fund as a seller of credit protection will either (i) pay a net amount equal to the par value of the defaulted reference entity and receive the reference entity or (ii) pay a net amount equal to the par value of the defaulted reference entity less its recovery value.

 

(2)For centrally cleared swaps, implied credit spread, represented in absolute terms, utilized in determining the market value of the credit default swap contracts as of period will serve as an indicator of the payment/performance risk and represent the likelihood of risk of default for the credit derivative. The implied credit spread of a reference entity reflects the cost of buying/selling protection and may include upfront payments required to be made to enter into the contract Generally, wider credit spreads represent a perceived deterioration of the reference entity’s credit soundness and a greater likelihood or risk of default or other credit event occurring as defined under the terms of the swap contract.

 

(3)For centrally cleared swaps, the notional amounts represents the maximum potential the Fund may pay as a seller of credit protection if a credit event occurs, as defined under the terms of the swap contract, for each security included in the CDX HY S37.

 

(4)Interest rate is based upon predetermined notional amounts, which may be a multiple of the number of shares plus a specified spread

 

See accompanying notes to financial statements.

7

 

SPECTRUM ADVISORS PREFERRED FUND
PORTFOLIO OF INVESTMENTS
September 30, 2021

 

Shares      Value 
     MUTUAL FUNDS - 29.7%     
     DEBT FUNDS - 29.7%     
 210,555   Braddock Multi-Strategy Income Fund, Institutional Class  $1,549,682 
 342,674   Fidelity Capital & Income Fund   3,882,494 
     TOTAL MUTUAL FUNDS (Cost - $5,191,285)   5,432,176 
           
           
     SHORT-TERM INVESTMENTS - 67.7%     
     MONEY MARKET FUNDS - 67.7%     
 6,197,083   Fidelity Government Portfolio, Class I, 0.01%(a)   6,197,083 
 6,197,084   First American Government Obligations Fund, Class Z, 0.02%(a)   6,197,084 
     TOTAL SHORT-TERM INVESTMENTS (Cost $12,394,167)   12,394,167 
           
     TOTAL INVESTMENTS - 97.4% (Cost $17,585,452)  $17,826,343 
     OTHER ASSETS IN EXCESS OF LIABILITIES - 2.6%   474,762 
     NET ASSETS - 100.0%  $18,301,105 

 

(a)Rate disclosed is the seven-day effective yield as of September 30, 2021.

 

OPEN FUTURES CONTRACTS

          Notional Value at     
Number of         September 30,   Unrealized 
Contracts   Open Long Futures Contracts  Expiration  2021   (Depreciation) 
 15   NASDAQ 100 E-Mini Index  Dec-2021  $4,404,750   $(148,610)
 42   Russell 2000 E-Mini Index  Dec-2021   4,621,680    (35,230)
 22   S&P 500 E-Mini Index  Dec-2021   4,727,525    (149,050)
     TOTAL FUTURES CONTRACTS          $(332,890)

 

See accompanying notes to financial statements.

8

 

SPECTRUM ADVISORS PREFERRED FUND
PORTFOLIO OF INVESTMENTS (Continued)
September 30, 2021

 

TOTAL RETURN SWAPS

 

Number of
Shares
  Reference Entity  Notional Amount
at September 30,
2021
   Interest Rate Payable (1)  Termination
Date
  Counterparty  Unrealized
Depreciation
 
Long Position:                      
2,977  Applied Material, Inc.  $383,229   1-Mth USD LIBOR plus 30 bp  10/20/2022  BRC  $(28,204)
419  ASML Holdimngs Co.   312,201   1-Mth USD LIBOR plus 30 bp  10/20/2022  BRC   (51,543)
764  Broadcom, Inc.   370,487   1-Mth USD LIBOR plus 30 bp  10/20/2022  BRC   (10,341)
1,170  KLA, Inc.   391,377   1-Mth USD LIBOR plus 30 bp  10/20/2022  BRC   (36,170)
643  LAM research Corp.   365,963   1-Mth USD LIBOR plus 30 bp  10/20/2022  BRC   (19,128)
6,090  Marvell Techcnology, Inc.   367,288   1-Mth USD LIBOR plus 30 bp  10/20/2022  BRC   (14,875)
2,708  Microchip Techcnology, Inc.   415,651   1-Mth USD LIBOR plus 30 bp  10/20/2022  BRC   (22,069)
5,291  Micron Techcnology, Inc.   375,555   1-Mth USD LIBOR plus 30 bp  10/20/2022  BRC   (17,684)
1,875  NXP Semiconductors NV   367,256   1-Mth USD LIBOR plus 30 bp  10/20/2022  BRC   (30,596)
2,423  Qualcomm, Inc.   312,519   1-Mth USD LIBOR plus 30 bp  10/20/2022  BRC   (10,272)
2,025  Skyworks Solutions, Inc.   333,680   1-Mth USD LIBOR plus 30 bp  10/20/2022  BRC   (16,864)
1,983  Texas Instruments, Inc.   381,152   1-Mth USD LIBOR plus 30 bp  10/20/2022  BRC   (8,148)
                 Total:  $(265,894)

 

BRC - Barclays Capital

 

LIBOR - London Interbank Offered Rate

 

(1)Interest rate is based upon predetermined notional amounts, which may be a multiple of the number of shares plus a specified spread.

 

See accompanying notes to financial statements.

9

 

SPECTRUM UNCONSTRAINED FUND
PORTFOLIO OF INVESTMENTS
September 30, 2021

 

Shares      Value 
     MUTUAL FUNDS — 19.9%     
     DEBT FUNDS - 19.0%     
 102,280   Axonic Strategic Income Fund, Class I  $1,021,775 
 90,872   Easterly Structured Credit Value Fund, Class R6   1,015,948 
     TOTAL DEBT FUNDS (Cost - $2,036,303)   2,037,723 
           
     MUNICIPAL FUND — 0.9%     
 5,423   Nuveen High Yield Municipal Bond Fund, Class I   99,241 
     TOTAL MUNICIPAL FUND (Cost - $99,958)     
           
     TOTAL MUTUAL FUNDS (Cost $2,136,261)   2,136,964 
           
           
     SHORT-TERM INVESTMENTS — 66.7%     
     MONEY MARKET FUNDS - 66.7%     
 3,585,792   Fidelity Government Portfolio, Class I, 0.01%(a)   3,585,792 
 3,585,791   First American Government Obligations Fund, Class Z, 0.02%(a)   3,585,791 
     TOTAL SHORT-TERM INVESTMENTS (Cost $7,171,583)   7,171,583 
           
     TOTAL INVESTMENTS - 86.6% (Cost $9,307,844)  $9,308,547 
     OTHER ASSETS IN EXCESS OF LIABILITIES- 13.4%   1,434,397 
     NET ASSETS - 100.0%  $10,742,944 

 

(a)Rate disclosed is the seven-day effective yield as of September 30, 2021.

 

TOTAL RETURN SWAPS

 

Number of
Shares
  Reference Entity*  Notional Amount
at September
30, 2021
   Interest Rate Payable (1)  Termination
Date
  Counterparty  Unrealized
Appreciation
(Depreciation)
 
Long Position:                      
432,526  AlphaCentric Income Opportunities Fund  $5,211,938   3-Mth USD LIBOR plus 150 bp  6/30/2022  BRC  $ 
468,674  AlphaCentric Income Opportunities Fund   5,647,518   3-Mth USD LIBOR plus 185 bp  9/13/2022  CIBC    
475,285  Eaton Vance Floating-Rate Advantaged Fund   5,033,270   3-Mth USD LIBOR plus 150 bp  6/30/2022  BRC    
                 Total:  $ 

 

BRC - Barclays Capital

 

CIBC - Canadian Imperial Bank of Commerce

 

LIBOR - London Interbank Offered Rate

 

(1)Interest rate is based upon predetermined notional amounts, which may be a multiple of the number of shares plus a specified spread.

 

*Swap contract reset at September 30, 2021.

 

See accompanying notes to financial statements.

10

 

Spectrum Funds
Statements of Assets and Liabilities
September 30, 2021

 

   Spectrum Low   Spectrum Advisors   Spectrum 
   Volatility Fund     Preferred Fund     Unconstrained Fund 
ASSETS               
Investment securities:               
At cost  $403,237,531   $17,585,452   $9,307,844 
At value  $418,129,826   $17,826,343   $9,308,547 
Segregated cash - Collateral for swaps   17,340,000        1,080,000 
Deposit with broker for swaps   11,964,209         
Receivable for swaps   3,707,400        433,837 
Unrealized appreciation on swaps   31,555         
Deposit with broker for futures   292,138    1,073,321     
Receivable for Fund shares sold   282,239         
Dividend and interest receivable   271,903        6,229 
Prepaid expenses   11,611    24,213    5,062 
TOTAL ASSETS   452,030,881    18,923,877    10,833,675 
                
LIABILITIES               
Due to broker - upfront payment on the CDX   4,221,450         
Payable for swaps   2,752,141        68,458 
Investment advisory fees payable   792,788    22,855    19,008 
Payable for Fund shares redeemed   91,604        3,000 
Shareholder servicing fees payable   12,728    894    265 
Unrealized depreciation on swaps       265,894     
Unrealized depreciation on futures       332,890     
Interest Payable       239     
TOTAL LIABILITIES   7,870,711    622,772    90,731 
NET ASSETS  $444,160,170   $18,301,105   $10,742,944 
                
NET ASSET VALUE               
Net Assets  $444,160,170   $18,301,105   $10,742,944 
Shares of beneficial interest outstanding   17,083,129    593,941    519,261 
Net Asset Value, Offering and Redemption Price Per Share (Net Assets ÷ Shares Outstanding)  $26.00   $30.81   $20.69 
                
NET ASSETS CONSIST OF:               
Paid in capital ($0 par value, unlimited shares authorized)  $414,103,257   $13,890,960   $10,386,804 
Distributable earnings   30,056,913    4,410,145    356,140 
NET ASSETS  $444,160,170   $18,301,105   $10,742,944 

 

See accompanying notes to financial statements.

11

 

Spectrum Funds
Statements of Operations
For the Year or Period Ended September 30, 2021

 

   Spectrum Low   Spectrum Advisors   Spectrum 
   Volatility Fund     Preferred Fund     Unconstrained Fund (a) 
INVESTMENT INCOME               
Dividends  $10,277,319   $246,632   $52,100 
Interest   11,381    623    509 
TOTAL INVESTMENT INCOME   10,288,700    247,255    52,609 
                
EXPENSES               
Investment advisory fees   8,277,994    270,984    100,777 
Administration expenses (Note 5)   718,627    32,749    6,944 
Shareholder servicing fees   115,507    5,420    1,406 
Miscellaneous expenses   15,944    10,767    289 
TOTAL EXPENSES   9,128,072    319,920    109,416 
                
NET INVESTMENT INCOME/(LOSS)   1,160,628    (72,665)   (56,807)
                
REALIZED AND UNREALIZED GAIN (LOSS) ON INVESTMENTS               
Net realized gain (loss) from:               
Investments   4,099,083    (11,190)   2,449 
Swaps   18,474,392    1,757,243    515,452 
Futures   (892,737)   4,132,693     
Distributions received from underlying investment companies   40,029         
TOTAL NET REALIZED GAIN   21,720,767    5,878,746    517,901 
                
Net change in unrealized appreciation (depreciation) on:               
Investments   10,143,003    63,990    703 
Swaps   633,589    (505,507)    
Futures       (568,108)    
TOTAL NET CHANGE IN UNREALIZED APPRECIATION (DEPRECIATION)   10,776,592    (1,009,625)   703 
                
NET REALIZED AND UNREALIZED GAIN ON INVESTMENTS   32,497,359    4,869,121    518,604 
                
NET INCREASE IN NET ASSETS FROM OPERATIONS  $33,657,987   $4,796,456   $461,797 

 

(a)The Fund commenced operations on April 16, 2021.

 

See accompanying notes to financial statements. 

12

 

Spectrum Low Volatility Fund
Statements of Changes in Net Assets

 

   For the   For the 
   Year Ended   Year Ended 
   September 30, 2021     September 30, 2020 
INCREASE (DECREASE) IN NET ASSETS          
FROM OPERATIONS          
Net investment income  $1,160,628   $159,372 
Net realized gain from security transactions, swaps, and futures contracts   21,720,767    13,764,132 
Net change in unrealized appreciation of investments, swaps and futures contracts   10,776,592    4,114,324 
Net increase in net assets resulting from operations   33,657,987    18,037,828 
           
DISTRIBUTIONS TO SHAREHOLDERS          
Total distributions paid   (16,564,167)   (3,280,545)
Net decrease in net assets from distributions to shareholders   (16,564,167)   (3,280,545)
           
FROM SHARES OF BENEFICIAL INTEREST          
Proceeds from shares sold   281,994,640    174,401,309 
Net asset value of shares issued in reinvestment of distributions   15,110,995    3,038,916 
Payments for shares redeemed   (109,431,976)   (35,000,238)
Net increase in net assets from shares of beneficial interest   187,673,659    142,439,987 
           
TOTAL INCREASE IN NET ASSETS   204,767,479    157,197,270 
           
NET ASSETS          
Beginning of Year   239,392,691    82,195,421 
End of Year  $444,160,170   $239,392,691 
           
SHARE ACTIVITY          
Shares Sold   11,085,376    7,239,131 
Shares Reinvested   605,559    143,571 
Shares Redeemed   (4,265,622)   (1,508,837)
Net increase in shares of beneficial interest outstanding   7,425,313    5,873,865 

 

See accompanying notes to financial statements.

13

 

Spectrum Advisors Preferred Fund
Statements of Changes in Net Assets

 

   For the   For the 
   Year Ended   Year Ended 
   September 30, 2021     September 30, 2020 
INCREASE (DECREASE) IN NET ASSETS          
FROM OPERATIONS          
Net investment (loss)  $(72,665)  $(47,568)
Net realized gain from security transactions, swaps and futures contracts   5,878,746    2,624,659 
Distibutions from underlying investment companies       97,201 
Net change in unrealized (depreciation) of investments, swaps and futures contracts   (1,009,625)   (812,054)
Net increase in net assets resulting from operations   4,796,456    1,862,238 
           
DISTRIBUTIONS TO SHAREHOLDERS          
Total distributions paid   (2,572,366)   (83,676)
Net decrease in net assets from distributions to shareholders   (2,572,366)   (83,676)
           
FROM SHARES OF BENEFICIAL INTEREST          
Proceeds from shares sold   4,435,031    2,331,410 
Net asset value of shares issued in reinvestment of distributions   2,565,863    83,624 
Payments for shares redeemed   (4,261,689)   (3,537,769)
Net increase (decrease) in net assets from shares of beneficial interest   2,739,205    (1,122,735)
           
TOTAL INCREASE IN NET ASSETS   4,963,295    655,827 
           
NET ASSETS          
Beginning of Year   13,337,810    12,681,983 
End of Year  $18,301,105   $13,337,810 
           
SHARE ACTIVITY          
Shares Sold   145,182    93,280 
Shares Reinvested   99,068    3,591 
Shares Redeemed   (138,317)   (145,399)
Net increase (decrease) in shares of beneficial interest outstanding   105,933    (48,528)

 

See accompanying notes to financial statements. 

14

 

Spectrum Unconstrained Fund
Statement of Changes in Net Assets

 

   For the 
   Period Ended 
   September 30, 2021 (a) 
INCREASE (DECREASE) IN NET ASSETS     
FROM OPERATIONS     
Net investment (loss)  $(56,807)
Net realized gain from security transactions and swaps contracts   517,901 
Net change in unrealized appreciation of investments and swaps contracts   703 
Net increase in net assets resulting from operations   461,797 
      
DISTRIBUTIONS TO SHAREHOLDERS     
Total distributions paid   (106,366)
Net decrease in net assets from distributions to shareholders   (106,366)
      
FROM SHARES OF BENEFICIAL INTEREST     
Proceeds from shares sold   10,750,257 
Net asset value of shares issued in reinvestment of distributions   106,366 
Payments for shares redeemed   (469,110)
Net increase in net assets from shares of beneficial interest   10,387,513 
      
TOTAL INCREASE IN NET ASSETS   10,742,944 
      
NET ASSETS     
Beginning of Period    
End of Period  $10,742,944 
      
SHARE ACTIVITY     
Shares Sold   537,412 
Shares Reinvested   5,219 
Shares Redeemed   (23,370)
Net increase in shares of beneficial interest outstanding   519,261 

 

(a)The Fund commenced operations on April 16, 2021.

 

See accompanying notes to financial statements.

15

 

Spectrum Low Volatility Fund
Financial Highlights

 

Per Share Data and Ratios for a Share of Beneficial Interest Outstanding Throughout Each Year Presented

 

   For the   For the   For the   For the   For the 
   Year Ended   Year Ended   Year Ended   Year Ended   Year Ended 
   September 30, 2021   September 30, 2020   September 30, 2019   September 30, 2018   September 30, 2017 
                     
Net asset value, beginning of year  $24.79   $21.72   $21.35   $22.58   $22.16 
                          
Activity from investment operations:                         
Net investment income (loss) (1)   0.08    0.03    0.02    0.02    (0.04)
Net realized and unrealized gain on investments, swaps and futures contracts   2.53    3.89    1.04    0.21    2.35 
Total from investment operations   2.61    3.92    1.06    0.23    2.31 
Less distributions from:                         
Net investment income   (0.45)   (0.52)   (0.69)   (1.01)   (1.39)
Net realized gains   (0.95)   (0.33)       (0.45)   (0.50)
Total distributions   (1.40)   (0.85)   (0.69)   (1.46)   (1.89)
                          
Net asset value, end of year  $26.00   $24.79   $21.72   $21.35   $22.58 
                          
Total return (2)   10.82%   18.76%   5.12%   1.06%   11.32%
                          
Net assets, end of year (000s)  $444,160   $239,393   $82,195   $66,725   $65,313 
                          
Ratio of expenses to average net assets,   2.37%   2.51%   2.53%   2.53%   2.54%
                          
Ratio of net investment income (loss) to average net assets (3,4)   0.30%   0.14%   0.08%   0.10%   (0.20)%
                          
Portfolio Turnover Rate   131%   389%   675%   438%   319%

 

 
(1)Per share amounts calculated using the average shares method, which more appropriately presents the per share data for the year.

 

(2)Assumes reinvestment of all dividends and distributions if any.

 

(3)The ratios of expenses to average net assets and net investment income (loss) to average net assets do not reflect the expenses of the underlying investment companies in which the Fund invests.

 

(4)Recognition of net investment income (loss) by the Fund is affected by the timing and declaration of dividends by the underlying investment companies in which the Fund invests.

 

See accompanying notes to financial statements. 

16

 

Spectrum Advisors Preferred Fund
Financial Highlights

 

Per Share Data and Ratios for a Share of Beneficial Interest Outstanding Throughout Each Year Presented

 

   For the   For the   For the   For the   For the 
   Year Ended   Year Ended   Year Ended   Year Ended   Year Ended 
   September 30, 2021   September 30, 2020   September 30, 2019   September 30, 2018   September 30, 2017 
                     
Net asset value, beginning of year  $27.33   $23.64   $23.83   $21.95   $19.46 
                          
Activity from investment operations:                         
Net investment income (loss) (1)   (0.12)   (0.09)   0.02    (0.15)   0.09 
Net realized and unrealized gain (loss) on investments, swaps and future contracts   8.46    3.95    0.60    2.93    2.51 
Total from investment operations   8.34    3.86    0.62    2.78    2.60 
Less distributions from:                         
Net investment income   (0.25)   (0.17)   (0.18)   (0.29)   (0.11)
Net realized gains   (4.61)       (0.45)   (0.61)    
Return of capital           (0.18)        
Total distributions   (4.86)   (0.17)   (0.81)   (0.90)   (0.11)
                          
Net asset value, end of year  $30.81   $27.33   $23.64   $23.83   $21.95 
                          
Total return (2)   33.91%   16.46%   2.89%   13.07%   13.39%
                          
Net assets, end of year (000s)  $18,301   $13,338   $12,682   $11,427   $7,350 
                          
Ratio of expenses to average net assets (3)   1.77%   1.89%   1.83%   1.81%   1.86%
                          
Ratio of net investment income (loss) to average net assets (3,4)   (0.40)%   (0.36)%   0.08%   (0.65)%   0.45%
Portfolio Turnover Rate   1294%   831%   360%   269%   260%

 

 
(1)Per share amounts calculated using the average shares method, which more appropriately presents the per share data for the year.

 

(2)Assumes reinvestment of all dividends and distributions if any.

 

(3)The ratios of expenses to average net assets and net investment income (loss) to average net assets do not reflect the expenses of the underlying investment companies in which the Fund invests.

 

(4)Recognition of net investment income (loss) by the Fund is affected by the timing and declaration of dividends by the underlying investment companies in which the Fund invests.

 

See accompanying notes to financial statements.

17

 

Spectrum Unconstrained Fund
Financial Highlights

 

Per Share Data and Ratios for a Share of Beneficial Interest Outstanding Throughout the Period Presented

 

   For the 
   Period Ended 
   September 30, 2021 (a) 
     
Net asset value, beginning of period  $20.00 
      
Activity from investment operations:     
Net investment (loss) (1)   (0.11)
Net realized and unrealized gain (loss) on investments, swaps   1.01 
Total from investment operations   0.90 
Less distributions from:     
Net investment income   (0.21)
Total distributions   (0.21)
      
Net asset value, end of period  $20.69 
      
Total return (2)   4.50% (5) 
      
Net assets, end of period (000s)  $10,743 
      
Ratio of expenses to average net assets (3)   2.33% (6)
      
Ratio of net investment (loss) to average net assets (3,4)   (1.21)% (6)
      
Portfolio Turnover Rate   75% (5)

 

 

(a)The Fund commenced operations on April 16, 2021.

 

(1)Per share amounts calculated using the average shares method, which more appropriately presents the per share data for the period.

 

(2)Assumes reinvestment of all dividends and distributions if any.

 

(3)The ratios of expenses to average net assets and net investment income (loss) to average net assets do not reflect the expenses of the underlying investment companies in which the Fund invests.

 

(4)Recognition of net investment (loss) by the Fund is affected by the timing and declaration of dividends by the underlying investment companies in which the Fund invests.

 

(5)Not annualized.

 

(6)Annualized.

 

See accompanying notes to financial statements.

18

 

Spectrum Funds

Notes to Financial Statements

September 30, 2021

 

1.ORGANIZATION

 

The Spectrum Low Volatility Fund (the “Low Volatility Fund”), Spectrum Advisors Preferred Fund (the “Advisors Preferred Fund”) and Spectrum Unconstrained Fund (the “Unconstrained Fund”) (collectively, the “Funds”) are each a diversified series of Advisors Preferred Trust (the “Trust”), a statutory trust organized under the laws of the State of Delaware on August 15, 2012 and registered under the Investment Company Act of 1940, as amended (the “1940 Act”), as an open-end management investment company. The Low Volatility Fund’s investment objective is total return with lower downside volatility and risk compared to major stock market indices while the Advisors Preferred Fund seeks long term capital appreciation. The Unconstrained Fund’s investment objective is total return. Each Fund currently offers one class of shares, Investor Class shares, which is offered at net asset value. The Low Volatility Fund also offers Advisor Class shares, but as of the date of this report none have been issued. The Low Volatility Fund commenced operations on December 16, 2013, the Advisors Preferred Fund commenced operations on June 1, 2015 and the Unconstrained Fund commenced operations on April 16, 2021. The Trust’s Agreement and Declaration of Trust permits the Trust’s Board of Trustees (“Board”) to authorize and issue an unlimited number of shares of beneficial interest of separate series without par value. The investment adviser to each Fund is Advisors Preferred LLC (the “Adviser”). The investment sub-adviser to each Fund is Spectrum Financial, Inc. (the “Sub-Adviser”).

 

2.SIGNIFICANT ACCOUNTING POLICIES

 

The following is a summary of significant accounting policies followed by the Funds in preparation of their financial statements. These policies are in conformity with accounting principles generally accepted in the United States of America (“GAAP”). The preparation of the financial statements in conformity with GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of increases and decreases in net assets from operations during the reporting period. Actual results could differ from those estimates. The Funds are each an investment company and accordingly follow the investment company accounting and reporting guidance of the Financial Accounting Standards Board (FASB) Accounting Standard Codification Topic 946 Financial Services – Investment Companies.

 

Securities Valuation – Securities listed on an exchange are valued at the last reported sale price at the close of the regular trading session of the exchange on the business day the value is being determined, or in the case of securities listed on NASDAQ at the NASDAQ Official Closing Price (“NOCP”). If the NOCP is not available, such securities shall be valued at the last bid on the day of valuation. Financial futures, which are traded on an exchange, are valued at the last quoted sales price determined by the exchange. Investments in open-end investment companies are valued at net asset value. Total return swaps on exchange-listed securities shall be valued at the last quoted sales price or, in the absence of a sale, at the mean between the current bid and ask prices. Exchange listed swaps shall be valued at the last quoted sales price or, in the absence of a sale, at the mean between the current bid and ask prices. Credit default swaps are valued by a pricing agent covering the specific type of swap. Certain credit default swaps (“CDS”) and credit indices are valued independently by Markit; or if no valuation is available from a pricing agent, at the price received from the broker-dealer/counterparty that issued the swap. Investments valued in currencies other than the U.S. dollar are converted to U.S. dollars using exchange rates obtained from pricing services. Short-term debt obligations, excluding U.S. Treasury Bills, having 60 days or less remaining until maturity, at time of purchase, may be valued at amortized cost.

 

The Funds may hold securities, such as private placements, interests in commodity pools, other non-traded securities or temporarily illiquid securities, for which market quotations are not readily available or are determined to be unreliable. These securities will be valued using the “fair value” procedures approved by the Board. The Board has delegated execution of these procedures to a fair value committee composed of one or more representatives from each of the (i) Trust, (ii) administrator, and (iii) advisor and/or sub-advisor. The committee may also enlist third party consultants such as a valuation specialist at a public accounting firm, valuation consultant or financial officer of a security issuer on an as-needed basis to assist in determining a security-specific fair value. The Board reviews and ratifies the execution of this process and the resultant fair value prices at least quarterly to assure the process produces reliable results.

19

 

Spectrum Funds

Notes to Financial Statements (Continued)

September 30, 2021

 

Fair Valuation Process – As noted above, the fair value committee is composed of one or more representatives from each of the (i) Trust, (ii) administrator, and (iii) Adviser and/or Sub-Adviser. The applicable investments are valued collectively via inputs from each of these groups. For example, fair value determinations are required for the following securities: (i) securities for which market quotations are insufficient or not readily available on a particular business day (including securities for which there is a short and temporary lapse in the provision of a price by the regular pricing source), (ii) securities for which, in the judgment of the Adviser or Sub-Adviser, the prices or values available do not represent the fair value of the instrument. Factors which may cause the Adviser or Sub-Adviser to make such a judgment include, but are not limited to, the following: only a bid price or an asked price is available; the spread between bid and asked prices is substantial; the frequency of sales; the thinness of the market; the size of reported trades; and actions of the securities markets, such as the suspension or limitation of trading; (iii) securities determined to be illiquid; (iv) securities with respect to which an event that will affect the value thereof has occurred (a “significant event”) since the closing prices were established on the principal exchange on which they are traded, but prior to a Fund’s calculation of its net asset value. Specifically, interests in commodity pools or managed futures pools are valued on a daily basis by reference to the closing market prices of each futures contract or other asset held by a pool, as adjusted for pool expenses. Restricted or illiquid securities, such as private investments or non-traded securities are valued via inputs from the Adviser or Sub-Adviser based upon the current bid for the security from two or more independent dealers or other parties reasonably familiar with the facts and circumstances of the security (who should take into consideration all relevant factors as may be appropriate under the circumstances). If the Adviser or Sub-Adviser is unable to obtain a current bid from such independent dealers or other independent parties, the fair value committee shall determine the fair value of such security using the following factors: (i) the type of security; (ii) the cost at date of purchase; (iii) the size and nature of a Fund’s holdings; (iv) the discount from market value of unrestricted securities of the same class at the time of purchase and subsequent thereto; (v) information as to any transactions or offers with respect to the security; (vi) the nature and duration of restrictions on disposition of the security and the existence of any registration rights; (vii) how the yield of the security compares to similar securities of companies of similar or equal creditworthiness; (viii) the level of recent trades of similar or comparable securities; (ix) the liquidity characteristics of the security; (x) current market conditions; and (xi) the market value of any securities into which the security is convertible or exchangeable.

 

Valuation of Investment in Funds – The Funds may invest in open-end or closed-end investment companies (the “Underlying Funds”). The Underlying Funds value securities in their funds for which market quotations are readily available at their market values (generally the last reported sale price) and all other securities and assets at their fair value to the methods established by the board of directors of the Underlying Funds.

 

Open-end investment companies are valued at their respective net asset values as reported by such investment companies. The shares of many closed-end investment companies, after their initial public offering, frequently trade at a price per share, which is different than the net asset value per share. The difference represents a market premium or market discount of such shares. There can be no assurances that the market discount or market premium on shares of any closed-end investment company purchased by the Funds will not change.

 

The Funds utilize various methods to measure the fair value of all of their investments on a recurring basis. GAAP establishes a hierarchy that prioritizes inputs to valuation methods. The three levels of input are:

 

Level 1 – Unadjusted quoted prices in active markets for identical assets and liabilities that the Funds have the ability to access.

 

Level 2 – Observable inputs other than quoted prices included in Level 1 that are observable for the asset or liability, either directly or indirectly. These inputs may include quoted prices for the identical instrument on an inactive market, prices for similar instruments, interest rates, prepayment speeds, credit risk, yield curves, default rates and similar data.

 

Level 3 – Unobservable inputs for the asset or liability, to the extent relevant observable inputs are not available, representing the Funds’ own assumptions about the assumptions a market participant would use in valuing the asset or liability, and would be based on the best information available.

 

The availability of observable inputs can vary from security to security and is affected by a wide variety of factors,

20

 

Spectrum Funds

Notes to Financial Statements (Continued)

September 30, 2021

 

including, for example, the type of security, whether the security is new and not yet established in the marketplace, the liquidity of markets, and other characteristics particular to the security. To the extent that valuation is based on models or inputs that are less observable or unobservable in the market, the determination of fair value requires more judgment. Accordingly, the degree of judgment exercised in determining fair value is greatest for instruments categorized in Level 3.

 

The inputs used to measure fair value may fall into different levels of the fair value hierarchy. In such cases, for disclosure purposes, the level in the fair value hierarchy within which the fair value measurement falls in its entirety, is determined based on the lowest level input that is significant to the fair value measurement in its entirety.

 

The inputs or methodology used for valuing securities are not necessarily an indication of the risk associated with investing in those securities. The following table summarizes the inputs used as of September 30, 2021 for each Fund’s investments measured at fair value:

 

Spectrum Low Volatility Fund

 

Assets *  Level 1   Level 2   Level 3   Total 
Mutual Funds  $225,204,892   $   $   $225,204,892 
Short-term Investments   192,924,934            192,924,934 
Derivatives                    
Swaps       31,555        31,555 
Total Assets   $418,129,826   $31,555   $   $418,161,381 

 

Spectrum Advisors Preferred Fund

 

Assets *  Level 1   Level 2   Level 3   Total 
Mutual Funds  $5,432,176   $   $   $5,432,176 
Short-term Investments   12,394,167            12,394,167 
Total Assets   $17,826,343   $   $   $17,826,343 
Liabilities*                    
Derivatives                    
Futures Contracts  $(332,890)  $   $   $(332,890)
Swaps       (265,894)       (265,894)
Total Liabilities   $(332,890)  $(265,894)  $   $(598,784)

 

Spectrum Unconstrained Fund

 

Assets *  Level 1   Level 2   Level 3   Total 
Mutual Fund  $2,136,964   $   $   $2,136,964 
Short-term Investments   7,171,583            7,171,583 
Total Assets   $9,308,547   $   $   $9,308,547 

 

*Refer to the Portfolios of Investments for sector classifications.

 

The Funds did not hold any Level 3 securities during the current period.

 

Exchange Traded Funds – The Funds may invest in exchange traded funds (“ETFs”). ETFs are typically a type of fund bought and sold on a securities exchange. An ETF trades like common stock and represents a portfolio of securities that may be designed to track the performance and dividend yield of a particular domestic or foreign market index. The Funds may purchase an ETF to temporarily gain exposure to a portion of the U.S. or a foreign market while awaiting purchase of underlying securities. The risks of owning an ETF generally reflect the risks of owning the underlying securities they are designed to track, although the lack of liquidity on an ETF could result in it being more volatile. Additionally, ETFs have fees and expenses which reduce their value.

 

Futures Contracts – The Funds are subject to interest rate risk, equity risk and forward currency exchange rate risk in the normal course of pursuing their respective investment objectives. The Funds have purchased or sold

21

 

Spectrum Funds

Notes to Financial Statements (Continued)

September 30, 2021

 

futures contracts to gain exposure to, or hedge against, changes in the value of equities and interest rates. Initial margin deposits required upon entering into futures contracts are satisfied by the segregation of specific securities or cash as collateral for the account of the broker (the Funds’ agent in acquiring the futures position). During the period the futures contracts are open, changes in the value of the contracts are recognized as unrealized gains or losses by “marking to market” on a daily basis to reflect the market value of the contracts at the end of each day’s trading. Variation margin payments are received or made depending upon whether unrealized gains or losses are incurred. When the contracts are closed, the Funds recognize a realized gain or loss equal to the difference between the proceeds from, or cost of, the closing transaction and the Funds’ basis in the contract. If the Funds were unable to liquidate a futures contract and/or enter into an offsetting closing transaction, the Funds would continue to be subject to market risk with respect to the value of the contracts and continue to be required to maintain the margin deposits on the futures contracts. The Funds segregate cash having a value at least equal to the amount of the current obligation under any open futures contract. Risks may exceed amounts recognized in the Statements of Assets and Liabilities. With futures, there is minimal counterparty credit risk to the Funds since futures are exchange traded and the exchange’s clearinghouse, as counterparty to all exchange traded futures, guarantees the futures against default.

 

Swap Contracts – Each Fund is subject to equity price, credit risk, and interest rate risk in the normal course of pursuing its investment objective. The Funds have entered into various swap transactions for investment purposes or to manage interest rate, equity, or credit risk. These would typically be two-party contracts entered into primarily to exchange the returns (or differentials in rates of returns) typically earned or realized on particular pre-determined investments or instruments.

 

Standard equity swap contracts are between two parties that agree to exchange the returns (or differentials in rates of return) earned or realized on particular predetermined investments or instruments. The gross amount to be exchanged is calculated with respect to a “notional amount” (i.e. the return on or increase in value of a particular dollar amount invested in a “basket” of securities representing a particular index or industry sector). Most equity swap agreements entered into by a Fund calculate the obligations of the parties on a “net basis”. Consequently, a Fund’s current obligations under a swap agreement generally will be equal to the net amount to be paid or received under the agreement based on the relative value of the positions held by each party. A Fund’s obligations are accrued daily (offset by any amounts owed to a Fund).

 

The Funds may enter into swap contracts that provide the opposite return of the particular benchmark or security (“short” the index or security). The operations are similar to that of the swaps disclosed above except that the counterparty pays interest to the Fund on the notional amount outstanding and the dividends on the underlying securities reduce the return of the swap. However, in certain instances, market factors such as the interest rate environment and the demand to borrow the securities underlying the swap agreement can cause a scenario in which a Fund pays the counterparty interest. These amounts are netted with any unrealized appreciation or depreciation to determine the value of the swap. The Funds will typically enter into equity swap agreements in instances where the Adviser or Sub-Adviser believes that it may be more cost effective or practical than buying a security or the securities represented by a particular index.

 

The Funds may enter into credit default swaps (“CDS”). CDS are typically two-party (bilateral) financial contracts that transfer credit exposure between the two parties. One party to a CDS (referred to as the credit protection “buyer”) receives credit protection or sheds credit risk, whereas the other party to a CDS (referred to as the credit protection “seller”) is selling credit protection or taking on credit risk. The seller typically receives pre-determined periodic payments from the other party. These payments are in consideration for agreeing to make compensating specific payments to the buyer should a negative credit event occur, such as (1) bankruptcy or (2) failure to pay interest or principal on a reference debt instrument, with respect to a specified issuer or one of the reference issuers in a CDS portfolio. In general, CDS may be used by the Funds to obtain credit risk exposure similar to that of a direct investment in high yield bonds. Higher swap spreads generally imply a higher risk of default.

 

The amounts to be exchanged or “swapped” between parties are calculated with respect to the notional amount. Changes in the value of swap agreements are recognized as unrealized gains or losses in the Statements of Operations by “marking to market” on a daily basis to reflect the value of the swap agreement at the end of each

22

 

Spectrum Funds

Notes to Financial Statements (Continued)

September 30, 2021

 

trading day. Payments received or paid at the beginning of the agreement are reflected as such on the Statements of Assets and Liabilities and may be referred to as upfront payments. A liquidation payment received or made at the termination of the swap agreement is recorded as a realized gain or loss on the Statements of Operations. The maximum pay-outs for these contracts are limited to the notional amount of each swap. CDS may involve greater risks than if the Funds had invested in the referenced obligation directly and are subject to general market risk, liquidity risk, counterparty risk and credit risk.

 

By contrast, certain swap transactions are subject to mandatory central clearing. These swaps are executed through a derivatives clearing member (“DCM”), acting in an agency capacity, and submitted to a central counterparty (“CCP”) (“centrally cleared swaps”), in which case all payments are settled with the CCP through the DCM. Swaps are marked-to-market daily using pricing vendor quotations, counterparty or clearinghouse prices or model prices, and the change in value, if any, is recorded as an unrealized gain or loss. Upon entering into a swap contract, a Fund is required to satisfy an initial margin requirement by delivering cash or securities to the counterparty (or in some cases, segregated in a triparty account on behalf of the counterparty), which can be adjusted by any mark-to-market gains or losses pursuant to bilateral or centrally cleared arrangements. For centrally cleared swaps the daily change in valuation, if any, is recorded as a receivable or payable for variation margin.

 

The Funds collateralize swap agreements with cash and certain securities as indicated on the Portfolios of Investments and Statements of Assets and Liabilities of the Funds, respectively. Such collateral is held for the benefit of the counterparty in a segregated account at the Custodian to protect the counterparty against non-payment by the Funds. The Funds do not net collateral. In the event of a default by the counterparty, the Funds will seek return of this collateral and may incur certain costs exercising their rights with respect to the collateral. Amounts expected to be owed by the Funds are regularly collateralized either directly with the Funds or in a segregated account at the Custodian.

 

A Fund bears the risk of loss of the amount expected to be received under a swap agreement in the event of the default or bankruptcy of a swap agreement counterparty to the extent that posted collateral, if any, is insufficient. The Funds will enter into swap agreements only with large, well-capitalized and established financial institutions. The creditworthiness of each of the firms that is counterparty to a swap agreement is monitored by the Adviser. The financial statements of these counterparties may be available by accessing the SEC’s website, at www.sec.gov.

 

International Swaps and Derivatives Association, Inc. Master Agreements (“ISDA Master Agreements”) govern OTC financial derivative transactions entered into by the Funds and those counterparties. The ISDA Master Agreements maintain provisions for general obligations, representations, agreements, collateral and events of default or termination. Events of termination include conditions that may entitle counterparties to elect to terminate early and cause settlement of all outstanding transactions under the applicable ISDA Master Agreements. Any election to early terminate could be material to the financial statements.

 

During the normal course of business, the Funds purchase and sell various financial instruments, which may result in market, credit and liquidity risks, the amount of which is not apparent from the financial statements.

 

Security Transactions and Related Income – Security transactions are accounted for on trade date. Interest income is recognized on an accrual basis. Discounts are accreted and premiums are amortized on securities purchased over the lives of the respective securities using the effective yield method. Dividend income is recorded on the ex-dividend date. Realized gains or losses from sales of securities are determined by comparing the identified cost of the security lot sold with the net sales proceeds. Foreign withholding tax is recorded as incurred or known, in accordance with the Funds’ understanding of the applicable country’s tax rules and rates.

 

Dividends and Distributions to Shareholders – Dividends from net investment income, if any, are declared and paid quarterly. Distributable net realized capital gains, if any, are declared and distributed annually in December. Dividends from net investment income and distributions from net realized gains are recorded on ex-dividend date and are determined in accordance with federal income tax regulations, which may differ from GAAP. These “book/tax” differences are considered either temporary (i.e., deferred losses, capital loss carryforwards) or

23

 

Spectrum Funds

Notes to Financial Statements (Continued)

September 30, 2021

 

permanent in nature. To the extent these differences are permanent in nature, such amounts are reclassified within the composition of net assets based on their federal tax-basis treatment; temporary differences do not require reclassification. These reclassifications have no effect on net assets, results from operations or net asset value per share of the Funds.

 

Federal Income Tax – It is each Fund’s policy to continue to qualify as a regulated investment company by complying with the provisions of Subchapter M of the Internal Revenue Code that are applicable to regulated investment companies and to distribute substantially all of its taxable income and net realized gains to shareholders. Therefore, no federal income tax provision is required.

 

The Funds recognize the tax benefits of uncertain tax positions only where the position is “more likely than not” to be sustained assuming examination by tax authorities. Management has analyzed each Fund’s tax positions and has concluded that no liability for unrecognized tax benefits should be recorded related to uncertain tax positions expected to be taken on returns filed for the open tax years 2018 – 2020 or expected to be taken in the Funds’ 2021 tax returns. The Funds identify their major tax jurisdictions as U.S. Federal and foreign jurisdictions where the Funds make significant investments; however, the Funds are not aware of any tax positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will change materially in the next twelve months.

 

The Funds recognize interest and penalties, if any, related to unrecognized tax benefits as income tax expense in the Statements of Operations. During the period, the Funds did not incur any interest or penalties.

 

Expenses – Expenses of the Trust that are directly identifiable to a specific Fund are charged to that Fund. Expenses which are not readily identifiable to a specific fund are allocated in such a manner as deemed equitable, taking into consideration the nature and type of expense and the relative sizes of the funds in the Trust.

 

Indemnification – The Trust indemnifies its officers and trustees for certain liabilities that may arise from the performance of their duties to the Trust. Additionally, in the normal course of business, the Funds enter into contracts that contain a variety of representations and warranties and which provide general indemnities. Each Fund’s maximum exposure under these arrangements is unknown, as this would involve future claims that may be made against the Funds that have not yet occurred. However, based on experience, the risk of loss due to these warranties and indemnities appears to be remote.

 

3.INVESTMENT TRANSACTIONS

 

For the year or period ended September 30, 2021, cost of purchases and proceeds from sales of portfolio securities, other than short-term investments and derivatives amounted to $390,842,468 and $301,145,247 for the Low Volatility Fund, $91,643,850 and $90,806,956 for the Advisors Preferred Fund and $4,049,983 and $1,916,567 for the Unconstrained Fund.

 

4.OFFSETTING OF FINANCIAL AND DERIVATIVE ASSETS AND LIABILITIES

 

The Funds’ policy is to recognize a gross asset or liability equal to the unrealized gain/(loss) for futures and gross asset or liability equal to unrealized gain/(loss) for futures and swap contracts. During the year or period ended September 30, 2021, the Funds were subject to a master netting arrangement for the swap contracts. The following table shows additional information regarding the offsetting of assets and liabilities at September 30, 2021.

24

 

Spectrum Funds

Notes to Financial Statements (Continued)

September 30, 2021

 

Spectrum Low Volatility Fund

 

Assets:

 

               Gross Amounts Not Offset in the     
               Statements of Assets &     
               Liabilities     
   Gross Amount   Gross Amounts   Net Amounts of             
   Recognized in the   Offset in the   Assets Presented       Cash     
   Statements of   Statements of   in the Statements of   Financial   Collateral     
Description  Assets & Liabilities   Assets & Liabilities   Assets & Liabilities   Instruments   Received   Net Amount 
Swaps Contracts - OTC  $31,555   $   $31,555   $   $   $31,555 

 

Spectrum Advisors Preferred Fund                      

 

Liabilities:

                                                                   

               Gross Amounts Not Offset in the     
               Statements of Assets & Liabilities     
   Gross Amount                     
   Recognized in   Gross Amounts   Net Amounts of             
   the Statements   Offset in the   Assets Presented in             
   of Assets &   Statements of   the Statements of   Financial   Cash Collateral     
Description  Liabilities   Assets & Liabilities   Assets & Liabilities   Instruments   Pledged (1)   Net Amount 
Futures Contracts  $(332,890)  $   $(332,890)  $   $332,890   $ 
Swaps Contracts - OTC   (265,894)       (265,894)           (265,894)
Total  $(598,784)  $   $(598,784)  $   $332,890   $(265,894)

 

(1)The amount is limited to the derivative liability balance and accordingly does not include excess collateral pledged.

 

Impact of Derivatives on the Statements of Assets and Liabilities and Statements of Operations

 

The following is a summary of the location of derivative investments on the Funds’ Statements of Assets and Liabilities as of September 30, 2021:

 

Derivative Investment Type Location on the Statement of Assets and Liabilities
Swap Contracts (Low Volatility Fund, Advisors Preferred Fund) Unrealized appreciation/depreciation on swaps
Futures Contracts (Advisors Preferred Fund) Unrealized depreciation on futures

 

The following table sets forth the fair value of the Funds’ derivative contracts as of September 30, 2021:

 

Spectrum Low Volatility Fund

 

Asset (Liability) Derivatives Investment Value 
   Multiple Risks (Credit and   Total as of 
Derivative Investment Type  Interest)   September 30, 2021 
Credit Default Swaps   31,555    31,555 
Total  $31,555   $31,555 

 

Spectrum Advisors Preferred Fund

 

Asset (Liability) Derivatives Investment Value
       Total as of 
Derivative Investment Type  Equity Risk   September 30, 2021 
Total Return Swaps  $(265,894)  $(265,894)
Futures Contracts *   (332,890)   (332,890)
Total  $(598,784)  $(598,784)

 

*Represents cumulative (depreciation) on futures contracts as reported in the Portfolios of Investments.

25

 

Spectrum Funds

Notes to Financial Statements (Continued)

September 30, 2021

 

The following is a summary of the location of derivative investments on the Funds’ Statements of Operations for the year or period ended September 30, 2021:

 

Derivative Investment Type Location of Gain/Loss on Derivative
Swaps/Futures

Net realized gain from Swaps

Net realized gain (loss) from Futures

Net change in unrealized appreciation (depreciation) on Swaps

Net change in unrealized (depreciation) on Futures

 

The following is a summary of the Funds’ realized gain/(loss) on derivative investments recognized in the Statements of Operations categorized by primary risk exposure for the year or period ended September 30, 2021:

 

    Spectrum Low Volatility Fund

 

Realized gain (loss) on derivatives recognized in the Statements of Operations 

   Interest Rate       Total for the Year Ended 
Derivative Investment Type  Risk   Credit Risk   September 30, 2021 
Swaps  $17,583,074   $891,318   $18,474,392 
Futures   (892,737)       (892,737)
Total  $16,690,337   $891,318   $17,581,655 

 

Changes in unrealized depreciation on derivatives recognized in the Statements of Operations

   Multiple Risks     
   (Credit, Equity,     
   Interest, and   Total for the Year Ended 
Derivative Investment Type  Currency)   September 30, 2021 
Swaps  $633,589   $633,589 
Total  $633,589   $633,589 

 

    Spectrum Advisors Preferred Fund

 

Realized gain on derivatives recognized in the Statements of Operations

       Total for the Year Ended 
Derivative Investment Type  Equity Risk   September 30, 2021 
Swaps  $1,757,243   $1,757,243 
Futures   4,132,693    4,132,693 
Total  $5,889,936   $5,889,936 

 

Changes in unrealized appreciation/(depreciation) on derivatives recognized in the Statements of Operations

       Total for the Year Ended 
Derivative Investment Type  Equity Risk   September 30, 2021 
Swaps  $(505,507)  $(505,507)
Futures   (568,108)   (568,108)
Total  $(1,073,615)  $(1,073,615)

 

    Spectrum Unconstrained Fund

 

Realized gain on derivatives recognized in the Statements of Operations 

   Multiple Risks (Credit and   Total for the Period Ended 
Derivative Investment Type  Interest)   September 30, 2021 
Swaps  $515,452   $515,452 
Total  $515,452   $515,452 

26

 

Spectrum Funds

Notes to Financial Statements (Continued)

September 30, 2021

 

The notional value of the derivative instruments outstanding as of September 30, 2021 as disclosed in the Portfolios of Investments and the amounts realized and changes in unrealized gains and losses on derivative instruments during the year or period as disclosed above and within the Statements of Operations serve as indicators of the volume of derivative activity for the Funds.

 

Market Risk: Market risk is the risk that changes in interest rates, foreign exchange rates or equity prices will affect the positions held by the Funds. The Funds are exposed to market risk on financial instruments that are valued at market prices as disclosed in the Portfolios of Investments. The prices of derivative instruments, including swaps and futures prices, can be highly volatile. Price movements of derivative contracts in which the Funds’ assets may be invested are influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. The Funds are exposed to market risk on derivative contracts in that the Funds may not be able to readily dispose of its holdings when it chooses and also that the price obtained on disposal is below that at which the investment is included in Funds’ financial statements. All financial instruments are recognized at fair value, and all changes in market conditions directly affect net income. A Fund’s investments in derivative instruments are exposed to market risk and are disclosed in the portfolio of investments.

 

Unexpected local, regional or global events, such as war; acts of terrorism; financial, political or social disruptions; natural, environmental or man-made disasters; the spread of infectious illnesses or other public health issues; and recessions and depressions could have a significant impact on the Funds and their investments and may impair market liquidity. Such events can cause investor fear, which can adversely affect the economies of nations, regions and the market in general, in ways that cannot necessarily be foreseen. An outbreak of infectious respiratory illness known as COVID-19, which is caused by a novel coronavirus (SARS-CoV-2), was first detected in China in December 2019 and subsequently spread globally. This coronavirus has resulted in, among other things, travel restrictions, closed international borders, enhanced health screenings at ports of entry and elsewhere, disruption of and delays in healthcare service preparation and delivery, prolonged quarantines, significant disruptions to business operations, market closures, cancellations and restrictions, supply chain disruptions, lower consumer demand, and significant volatility and declines in global financial markets, as well as general concern and uncertainty. The impact of COVID-19 has adversely affected, and other infectious illness outbreaks that may arise in the future could adversely affect, the economies of many nations and the entire global economy, individual issuers and capital markets in ways that cannot necessarily be foreseen. Public health crises caused by the COVID-19 outbreak may exacerbate other pre-existing political, social and economic risks in certain countries or globally. The duration of the COVID-19 outbreak and its effects cannot be determined with certainty.

 

Counterparty Risk: The Funds invest in derivative instruments (the “Product”) issued for the Funds by Credit Suisse Securities (Europe) Limited, Credit Suisse Securities (USA) LLC (“Credit Suisse”), Barclays Capital, Inc. (“Barclays”) and Canadian Imperial Bank of Commerce (“CIBC”) (collectively, “Counterparties”). If Counterparties become insolvent, each may not be able to make any payments under the Product and a Fund may lose their capital invested in the Product. A decline in Counterparties’ financial standing is likely to reduce the market value of the Product and therefore the price a Fund may receive for the Product if sold it in the market.

 

Liquidity Risk: Liquidity risk is the risk that a Fund will encounter difficulty in raising funds to meet commitments. Liquidity risk may result in an inability to sell investments quickly at close to fair value. The Funds’ financial instruments include investments in securities which are not traded on organized public exchanges and which generally may be illiquid. As a result, the Funds may not be able to quickly liquidate its investments in these instruments at an amount close to its fair value in order to meet its liquidity requirements. The Funds do not anticipate any material losses as a result of liquidity risk.

 

5.INVESTMENT ADVISORY AGREEMENT AND TRANSACTIONS WITH RELATED PARTIES

 

The business activities of the Funds are overseen by the Board, which is responsible for the overall management of the Funds. Advisors Preferred, LLC, serves as investment adviser to the Funds. The Adviser has engaged 

27

 

Spectrum Funds

Notes to Financial Statements (Continued)

September 30, 2021

 

Spectrum Financial, Inc. to serve as the sub-adviser to the Funds. These expenses are the responsibility of the Adviser.

 

Pursuant to an advisory agreement with the Funds, the Adviser, under the oversight of the Board, directs the daily operations of the Funds and supervises the performance of administrative and professional services provided by others. As compensation for its services and the related expenses borne by the Adviser, the Funds pay the Adviser computed and accrued daily and paid monthly at an annual rate of 2.15% of the average daily net assets for both Spectrum Low Volatility Fund and Spectrum Unconstrained Fund and 1.50% of the average daily net assets for the Spectrum Advisors Preferred Fund. The Adviser, not the Fund, pays the Sub-Adviser. Pursuant to the advisory agreement, the Advisor earned $8,277,994, $270,984, and $100,777 for Spectrum Low Volatility Fund, Spectrum Advisors Preferred Fund and Spectrum Unconstrained Fund, respectively, in advisory fees for the year or period ended September 30, 2021.

 

Pursuant to a liquidity program administrator agreement with the Funds, the Adviser, provides a liquidity program administrator who, directs the operations of the Funds’ liquidity risk management program. As compensation for its services and the related expenses borne by the Adviser, the Funds pay the Adviser out of pocket expenses and an annual fee of $9,000 per Fund. The liquidity program administrator agreement became effective June 1, 2021. Pursuant to the liquidity program administrator agreement, the Adviser earned (net of voluntary waivers) $3,000, $0 and $0 for Spectrum Low Volatility Fund, Spectrum Advisors Preferred Fund and Spectrum Unconstrained Fund, respectively, in fees for the period ended September 30, 2021.

 

Ultimus Fund Solutions, LLC (“UFS”), provides administration, fund accounting, and transfer agent services to the Trust. Pursuant to a separate servicing agreement with UFS, the Funds pay UFS customary fees for providing administration, fund accounting and transfer agency services to the Funds. Under the terms of the Funds’ agreement with UFS, UFS pays for certain operating expenses of the Funds. Certain officers of the Trust are also officers of UFS and are not paid any fees directly by the Funds for serving in such capacities.

 

In addition, certain affiliates of UFS provide ancillary services to the Funds as follows:

 

Blu Giant, LLC (“Blu Giant”) Blu Giant, an affiliate of UFS, provides EDGAR conversion and filing services as well as print management services for the Funds on an ad-hoc basis. These expenses are the responsibility of UFS.

 

The Funds pay Ceros Financial Services Inc. (the “Distributor”) to provide compensation for ongoing servicing related activities or services and/or maintenance of the Investor Class accounts, not otherwise required to be provided by the Adviser. For the year or period ended September 30, 2021, the Funds paid $130, $5,420 and $1,406 for Spectrum Low Volatility Fund, Spectrum Advisors Preferred Fund and Spectrum Unconstrained Fund, respectively, which was paid out to brokers and dealers.

 

During the year or period ended September 30, 2021, Ceros Financial Services, Inc. (“Ceros”), a registered broker/dealer and an affiliate of the Adviser, executed trades on behalf of the Funds. Spectrum Low Volatility Fund, Spectrum Advisor Preferred Fund and Spectrum Unconstrained Fund paid trade commissions of $130 $19,164, and $0 to Ceros, respectively. Any 12b-1 fees received by Ceros related to a Fund’s investment in another Fund are returned to the respective Fund.

 

Each Trustee who is not an “interested person” of the Trust or Advisor is compensated at a rate of $50,000 per year plus $2,500 per meeting for certain special meetings as well as for reimbursement for any reasonable expenses incurred attending the meetings, paid quarterly. The Advisor pays these fees. The “interested persons” who serve as Trustees of the Trust receive no compensation for their services as Trustees. None of the executive officers receive compensation from the Trust. Interested trustees of the Trust are also officers or employees of the Advisor and its affiliates.

28

 

Spectrum Funds

Notes to Financial Statements (Continued)

September 30, 2021

 

6.AGGREGATE UNREALIZED APPRECIATION AND DEPRECIATION – TAX BASIS

 

The identified cost of investments in securities owned by each Fund for federal income tax purposes excluding futures and swaps, and its respective gross unrealized appreciation and depreciation at September 30, 2021, were as follows:

 

   Cost for           Tax Net 
   Federal Tax   Unrealized   Unrealized   Unrealized 
Fund  purposes   Appreciation   Depreciation   App/Dep 
Spectrum Low Volatility Fund  $399,016,563   $14,894,168   $(2,235)  $14,891,933 
Spectrum Advisors Preferred Fund   17,585,452    268,238    (27,347)   240,891 
Spectrum Unconstrained Fund   9,307,844    5,010    (4,307)   703 

 

7.DISTRIBUTION TO SHAREHOLDERS AND TAX COMPONENTS OF CAPITAL

 

The tax character of fund distributions paid for the periods ended September 30, 2021 and September 30, 2020 were as follows:

 

For the period ended September 30, 2021:
   Ordinary   Long-Term   Return   Tax-exempt     
Portfolio  Income   Capital Gains   of Capital   Income   Total 
Spectrum Low Volatility Fund  $15,323,448   $   $   $1,240,719   $16,564,167 
Spectrum Advisors Preferred Fund   950,251    1,622,115            2,572,366 
Spectrum Unconstrained Fund   106,366                106,366 

 

For the period ended September 30, 2020:
   Ordinary   Long-Term   Return     
Portfolio  Income   Capital Gains   of Capital   Total 
Spectrum Low Volatility Fund  $3,981,333   $989,623   $   $4,970,956 
Spectrum Advisors Preferred Fund   83,676    234,581        318,257 

 

As of September 30, 2021, the components of distributable earnings/(accumulated deficit) on a tax basis were as follows:

 

   Undistributed   Undistributed   Post October Loss   Capital Loss   Other   Unrealized   Total 
   Ordinary   Long-Term   and   Carry   Book/Tax   Appreciation/   Distributable Earning/ 
Portfolio  Income   Capital Gains   Late Year Loss   Forwards   Differences   (Depreciation)   (Accumulated Deficit) 
Spectrum Low Volatility Fund  $15,164,980   $   $   $   $    14,891,933   $30,056,913 
Spectrum Advisors Preferred Fund   2,585,534    1,583,720                240,891    4,410,145 
Spectrum Unconstrained Fund   483,148            (127,711)       703    356,140 

 

The difference between book basis and tax basis undistributed net investment income/(loss), accumulated net realized gain/(loss), and unrealized appreciation/(depreciation) from investments is primarily attributable to the tax deferral of losses on wash sales, and mark-to-market on open swap contracts and open Section 1256 contracts.

 

At September 30, 2021, the Funds had capital loss carry forwards for federal income tax purposes available to offset future capital gains and utilized capital loss carryforwards as follows: 

 

Fund  Short-Term   Long-Term   Total   CLCF Utilized 
Spectrum Low Volatility Fund  $   $   $   $ 
Spectrum Advisors Preferred Fund                
Spectrum Unconstrained Fund   127,711        127,711     

29

 

Spectrum Funds

Notes to Financial Statements (Continued)

September 30, 2021

 

During the fiscal period ended September 30, 2021, the Funds utilized tax equalization which is the use of earnings and profits distributions to shareholders on redemption of shares as part of the dividends paid deduction for income tax purposes. Permanent book and tax differences, primarily attributable to book/tax treatment of non-deductible expenses, and tax adjustment for equalization credits, resulted in reclassification for the year ended September 30, 2021 as follows:

 

       Accumulated 
       Earnings 
Fund  Paid in Capital   (Losses) 
Spectrum Low Volatility Fund  $2,423,779   $(2,423,779)
Spectrum Advisors Preferred Fund   555,026    (555,026)
Spectrum Unconstrained Fund   (709)   709 

 

8.CONTROL OWNERSHIP

 

The beneficial ownership, either directly or indirectly, of more than 25% of the voting securities of a fund creates presumption of control of the fund pursuant to Section 2(a)(9) of the 1940 Act. As of September 30, 2021, National Financial Services LLC held approximately 31%, Charles Schwab held approximately 29%, and TD Ameritrade held approximately 28% of the Spectrum Low Volatility Fund, National Financial Services LLC held approximately 92% of the Spectrum Advisors Preferred Fund and National Financial Services LLC held approximately 100% of the Spectrum Unconstrained Fund.

 

9.UNDERLYING INVESTMENT IN OTHER INVESTMENT COMPANIES

 

The Funds currently invests a portion of its assets in Fidelity Government Portfolio (“Fidelity”) and First American Government Obligations Fund (“First American”). The Advisors Preferred Fund may redeem its investment at any time if the Adviser or Sub-Adviser determines that it is in the best interest of the Advisors Preferred Fund and its shareholders to do so.

 

The performance of the Funds will be directly affected by the performance of Fidelity and First American. The financial statements of Fidelity and First American, including the portfolio of investments, can be found at the Securities and Exchange Commission’s website www.sec.gov and should be read in conjunction with the Advisors Preferred Fund’s financial statements. As of September 30, 2021, the percentage of the Low Volatility Fund’s net assets invested in Fidelity was 43.4%, Advisors Preferred Fund’s net assets invested in Fidelity and First American was 33.8% and 33.9% and Unconstrained Fund’s net assets invested in Fidelity and First American was 33.4% and 33.3%respectively.

 

10.NEW ACCOUNTING PRONOUNCEMENTS

 

In March 2020, FASB issued ASU 2020-04, Reference Rate Reform (Topic 848): Facilitation of the Effects of Reference Rate Reform on Financial Reporting (’‘ASU 2020-04’’). The amendments in ASU 2020-04 provide optional temporary financial reporting relief from the effect of certain types of contract modifications due to the planned discontinuation of LIBOR and other interbank-offered based reference rates as of the end of 2021. ASU 2020-04 is effective for certain reference rate-related contract modifications that occur during the period March 12, 2020 through December 31, 2022. Management is currently evaluating the impact, if any of applying this ASU.

 

In October 2020, the Securities and Exchange Commission (“SEC”) adopted new regulations governing the use of derivative by registered investment companies (“Rule 18f-4”). Rule 18f-4 will impose limits on the amount of derivatives a Fund can enter into, eliminate the asset segregation framework currently used by funds to comply with Section 18 of the 1940 Act, and require funds whose use of derivatives is greater than a limited specified amount to establish and maintain a comprehensive derivatives risk management program and appoint a derivatives risk manager. Funds will be required to comply with Rule 18f-4 by August 19, 2022. It is not currently 

30

 

Spectrum Funds

Notes to Financial Statements (Continued)

September 30, 2021

 

clear what impact, if any, Rule 18f-4 will have on the availability, liquidity or performance of derivatives. Management is currently evaluating the potential impact of Rule 18f-4 on the Funds. When fully implemented, Rule 18f-4 may require changes in how a Fund uses derivatives, adversely affect the Fund’s performance and increase costs related to the Funds’ use of derivatives.

 

11.SUBSEQUENT EVENTS

 

Subsequent events after the date of the Statements of Assets and Liabilities have been evaluated through the date the financial statements were issued. Management has determined that no events or transactions occurred requiring adjustment or disclosure in the financial statements other than the following.

 

On November 15, 2021, the Funds paid the following distributions to shareholders of record on November 12, 2021: 

 

       Short-   Long- 
       Term   Term 
   Income   Capital   Capital 
Fund  Dividend   Gains   Gains 
Spectrum Low Volatility Fund  $0.9441   $0.0360   $ 
Spectrum Advisors Preferred Fund  $   $4.3550   $2.6676 
Spectrum Unconstrained Fund  $0.8536   $   $ 

31

 

(COHEN&CO)

 

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

 

To the Shareholders of Spectrum Low Volatility Fund, Spectrum Advisors Preferred Fund, and Spectrum Unconstrained Fund and Board of Trustees of Advisors Preferred Trust

 

Opinion on the Financial Statements

 

We have audited the accompanying statements of assets and liabilities, including the portfolios of investments, of Spectrum Funds, each a series of Advisors Preferred Trust, comprising the funds listed below (the “Funds”) as of September 30, 2021, the related statements of operations, the statements of changes in net assets, the related notes, and the financial highlights for each of the periods indicated below (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the financial position of each of the Funds as of September 30, 2021, the results of their operations, the changes in net assets, and the financial highlights for each of the periods indicated below in conformity with accounting principles generally accepted in the United States of America.

 

    Statements of  
  Statements of Changes in Net  
Fund Name Operations Assets Financial Highlights
Spectrum Low Volatility Fund For the year ended For the years For the years ended
Spectrum Advisors Preferred Fund September 30, ended September 30,
  2021 September 30, 2021, 2020, 2019,
    2021 and 2020 2018 and 2017
Spectrum Unconstrained Fund For the period from April 16, 2021 (commencement of operations) through September 30, 2021

 

Basis for Opinion

 

These financial statements are the responsibility of the Funds’ management. Our responsibility is to express an opinion on the Funds’ financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (“PCAOB”) and are required to be independent with respect to the Funds in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

 

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement whether due to error or fraud.

 

COHEN & COMPANY, LTD.

800.229.1099 | 866.818.4538 fax | cohencpa.com

 

Registered with the Public Company Accounting Oversight Board

32

 

Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our procedures included confirmation of securities owned as of September 30, 2021, by correspondence with the custodian and brokers. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audits provide a reasonable basis for our opinion.

 

We have served as the auditor of one or more investment companies advised by Advisors Preferred, LLC since 2012.

 

(COHAN&CO)

 

COHEN & COMPANY, LTD.

Chicago, Illinois

November 24, 2021 

33

 

Spectrum Funds

Expense Example (Unaudited)

September 30, 2021

 

As a shareholder of Spectrum Funds, you incur ongoing costs, including management fees; service fees; and other Fund expenses. This example is intended to help you understand your ongoing costs (in dollars) of investing in the Funds and to compare these costs with the ongoing costs of investing in other mutual funds.

 

The example is based on an investment of $1,000 invested at the beginning of the period and held for the entire period from April 1, 2021 through September 30, 2021.

 

Table 1. Actual Expenses

 

The “Actual Expenses” line in the table below provides information about actual account values and actual expenses. You may use the information below; together with the amount you invested, to estimate the expenses that you paid over the period. Simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply the result by the number in the table under the heading entitled “Expenses Paid During Period” to estimate the expenses you paid on your account during this period.

 

Table 2. Hypothetical Example for Comparison Purposes

 

The “Hypothetical” line in the table below provides information about hypothetical account values and hypothetical expenses based on the Funds’ actual expense ratio and an assumed rate of return of 5% per year before expenses, which is not the Funds’ actual return. The hypothetical account values and expenses may not be used to estimate the actual ending account balances or expenses you paid for the period. You may use this information to compare this 5% hypothetical example with the 5% hypothetical examples that appear in the shareholder reports of other funds.

 

Please note that the expenses shown in the table are meant to highlight your ongoing costs. Therefore, the table is useful in comparing ongoing costs only, and will not help you determine the relative total costs of owning different funds. In addition, if these transactional costs were included, your costs would have been higher.

 

             
   Annualized  Beginning  Ending  Expenses Paid During
Actual  Expense  Account  Account  Period
Expenses  Ratio  4/1/2021  9/30/2021  4/1/2021-9/30/2021
Spectrum Low Volatility Fund *  2.33%  $1,000.00  $1,028.90  $11.85
Spectrum Advisors Preferred Fund *  1.71%  $1,000.00  $1,039.80  $8.74
Spectrum Unconstrained Fund **  2.33%  $1,000.00  $1,044.00  $10.63
             
   Annualized  Beginning  Ending  Expenses Paid During
Hypothetical  Expense  Account  Account  Period
(5% return before expenses)  Ratio  4/1/2021  9/30/2021  4/1/2021-9/30/2021
Spectrum Low Volatility Fund *  2.33%  $1,000.00  $1,013.39  $11.76
Spectrum Advisors Preferred Fund *  1.71%  $1,000.00  $1,016.50  $8.64
Spectrum Unconstrained Fund **  2.33%  $1,000.00  $1,011.92  $10.47

 

*Expenses are equal to the average account value over the period, multiplied by the Fund’s annualized expense ratio, multiplied by the number of days in the period (183) divided by the numbers of days in the fiscal year (365).

 

**Expenses are equal to the average account value over the period, multiplied by the Fund’s annualized expense ratio, multiplied by the number of days in the period (163) divided by the numbers of days in the fiscal year (365).

34

 

Spectrum Funds

SUPPLEMENTAL INFORMATION (Unaudited)

September 30, 2021

 

Approval of the Renewal of the Advisory and Sub-Advisory Agreements – Spectrum Low Volatility Fund & Spectrum Advisors Preferred Fund

 

At a meeting held on May 25, 2021 (the “Meeting”), held in accordance with relief granted by the U.S. Securities and Exchange Commission (the “SEC”) to ease certain governance obligations required under the Investment Company Act of 1940, as amended (the “1940 Act”) in light of travel concerns related to the COVID-19 pandemic (the “SEC Relief Order”)the Board of Trustees (the “Board”) of Advisors Preferred Trust (the “Trust”), including a majority of Trustees who are not “interested persons” (the “Independent Trustees”), as such term is defined under Section 2(a)(19) of 1940 Act, considered the renewal of the investment advisory agreement (the “Advisory Agreement’) between Advisors Preferred, LLC (the “Adviser”) and the Trust, on behalf of the Spectrum Low Volatility Fund and the Spectrum Advisors Preferred Fund (each a “Fund” and together the “Funds”) and the renewal of the sub-advisory agreement (the “Sub-Advisory Agreement”) between the Adviser and Spectrum Financial, Inc. (the “Sub-Adviser”).

 

In connection with the Board’s consideration of the Advisory Agreement and Sub-Advisory Agreements, (together the “Advisory Agreements”) the Adviser and Sub-Adviser provided the Board in advance of the Meeting with written materials, which included information regarding: (a) a description of the investment management personnel of the Adviser and Sub-Adviser; (b) the Adviser’s and Sub-Adviser’s operations and the Adviser’s financial condition; (c) the Adviser’s proposed brokerage practices (including any soft dollar arrangements); (d) the level of the advisory fees proposed to be charged compared with the fees charged to comparable mutual funds or accounts; (e) each Fund’s anticipated level of profitability from the Adviser’s and Sub-Adviser’s fund-related operations; (g) the Adviser’s and Sub-Adviser’s compliance policies and procedures; and (h) information regarding the performance of the New Fund as compared to their respective benchmarks and Morningstar categories.

 

Moreover, each Trustee may have afforded different weight to the various factors in reaching conclusions with respect to the Agreements. The Trustees reviewed the quality of work and abilities of the Adviser and its relationship with the respective Sub-Advisers and the performance of the Funds. In light of each Fund’s performance and the compliance/review relationship with the respective Sub-Adviser, the Trustees concluded that the Adviser had sufficient quality and depth of personnel, resources, investment methods and compliance policies and procedures essential to performing its duties to the Funds. The Trustees conducted some of their deliberations on a joint basis for the Adviser and the Sub-Adviser given the close working relationship of the Adviser and Sub-Adviser and conducted their deliberations on a consolidated basis for the Funds that have a subsidiary.

 

Nature, Extent and Quality of Services. With respect to the nature, extent and quality of services provided, the Trustees reviewed the Adviser’s Form ADV, and each Sub-Adviser’s Form ADV, a description of the manner in which investment decisions will be made for each Fund by the respective Sub-Adviser, a description of the services provided by the Adviser and those services provided by the respective Sub-Adviser and those executed by the Adviser. The Board reviewed the experience of professional personnel from both the Adviser and Sub-Advisers performing services for the Funds, including the team of individuals that primarily monitor and execute the investment and administration process, and the respective portfolio managers. Further reviewed by the Board was a certification from each of the Adviser and Sub-Advisers certifying that each has adopted a Code of Ethics containing provisions reasonably necessary to prevent Access Persons, as that term is defined

35

 

Spectrum Funds

SUPPLEMENTAL INFORMATION (Unaudited)

September 30, 2021

 

in Rule 17j-1 under the 1940 Act, from engaging in conduct prohibited by Rule 17j-1(b) and that each the of the Adviser and Sub-Advisers have adopted procedures reasonably necessary to prevent Access Persons from violating such Code of Ethics. The Trustees also noted the financial resources of the Adviser and each Sub-Adviser appeared adequate.

 

The Board also discussed the Adviser’s compliance program with the CCO of the Trust. The Board noted that the Adviser continues to have in place procedures which are currently working to prevent violations of applicable securities laws. The CCO of the Trust noted she works closely with the Adviser’s CCO. The Board concluded that the Adviser has qualified professionals, resources, and compliance policies essential to performing its duties under the Advisory Agreement.

 

Regarding the compliance programs of each Sub-Adviser, the Trust’s CCO noted that she works with the CCO of the Sub-Adviser and had reviewed the policies and procedures manual of the Sub-Adviser, including latest revisions and business continuity plans. The Board determined that the Sub-Adviser has a compliance program in place that prevents violations of the applicable securities law.

 

Performance. The Board considered that the Adviser delegates day-to-day investment decisions to each Sub-Adviser and, therefore, would not directly control the performance of the Funds. The Board considered the Adviser’s other responsibilities under the Advisory Agreement, including with respect to trade oversight, reviewing daily positions and balance reports for the Funds, obtaining derivative agreements and reporting to the Board, and concluded that the Adviser appears to be adequately monitoring the Sub-Adviser’s adherence to the respective Fund’s investment objectives and appears to be carrying out its functions appropriately.

 

With respect to the performance results from the Sub-Adviser’s daily management and investment strategies, the Board considered the updated performance of each of the Funds compared to their primary benchmark and Morningstar category for various periods provided by the Adviser. The Trustees also reviewed the Sub-Adviser’s strategy and each Fund’s performance for various periods with explanations for over/under performance.

 

The Board then reviewed and discussed the written materials that were provided in advance of the Meeting and deliberated on the renewal of the Advisory Agreements with respect to Spectrum Low Volatility Fund and Spectrum Advisers Preferred Fund (together the “Spectrum Funds”) The Board members relied upon the advice of independent legal counsel and their own business judgment in determining the material factors to be considered in evaluating the Agreements with respect to the Spectrum Funds.

 

Spectrum Low Volatility Fund

 

The Board considered the Fund’s performance as compared to various benchmark indices and the Fund’s Morningstar category, Nontraditional Bond. The Board reviewed one-three-and five-year periods and since inception (December 16, 2013) through April 30, 2021. They noted the Fund outperformed its primary benchmark, the S&P/LSTA Leveraged Loan Index, and the Morningstar Nontraditional Bond category for all periods. The Trustees recognized that this Fund seeks risk adjusted returns, and therefore lagged the S&P 500 Total Return Index, as it is not expected to necessarily be highly correlated to the returns of an equity index. Specifically, the Board noted that with respect to major stock market indices, such as the S&P 500 Total Return

36

 

Spectrum Funds

SUPPLEMENTAL INFORMATION (Unaudited)

September 30, 2021

 

Index, that the Fund’s investment objective was total return with lower downside volatility and risk compared to major stock market indices. The Board concluded that performance was satisfactory, and that with Adviser oversight, Spectrum Financial was expected to continue to obtain an acceptable level of investment returns for shareholders over the long term.

 

Spectrum Advisers Preferred Fund

 

With respect to Advisers Preferred, the Board recognized the Fund’s favorable performance. The Board reviewed the Fund’s performance as compared to its benchmark index, the S&P 500 Total Return Index, Morningstar Tactical Allocation and Morningstar Macro Trading categories. It was noted the Fund outperformed for the one- three- and five-year periods through April 30, 2021 (expect for the five-year period as compared to the S&P 500). The Board noted that because its investment objective had a long-term element, and the Fund did not employ an index-tracking strategy, and the principal strategy included non-equity instruments, it was not expected to outperform the S&P 500 Index in all environments. Mr. Bridgeport stated that the Morningstar Macro Trading category was a newer category under Morningstar, and in certain ways better suited the Fund’s investment strategy. With its favorable performance, the Fund had outperformed the S&P 500 Index for both the one- and three periods ended April 30, 2021. The Board then concluded that the performance and strategy implementation by Spectrum Financial was satisfactory, and that with Adviser oversight, the Fund was expected to continue to obtain an acceptable level of investment returns for shareholders over the long term.

 

Fees and Expenses. As to the costs of the services to be provided to each Fund by the Adviser and Sub-Adviser, respectively, the Board reviewed and discussed the advisory fee and total operating expenses of each Fund compared to its peer group and Morningstar category as presented in the Meeting Materials.

 

Spectrum Low Volatility Fund

 

The Board noted that advisory fee of 2.15% for Low Volatility was above the above range for the Morningstar Nontraditional Bond, and the Morningstar Tactical Allocation Categories, but below the maximum and within range for the Multialternative Category. The Trustees note that the Fund does not easily fit within a single category because of its strategy. The Trustees discussed that the net expenses of 3.02% for Investor Class was slightly above the maximum net expense for the Morningstar Nontraditional Bond Institutional, but below the maximum net expense for Morningstar Tactical Allocation Institutional and for the Morningstar Multialternative Institutional Class. With regards to Low Volatility Advisory Class, the Board noted the net expense ratio of 3.27% was slightly above range for the Nontraditional Bond A within range of the net expense ratio for the Morningstar Tactical Allocation A and Morningstar Multialternative A categories. The Board concluded that the advisory fee and net expenses for Low Volatility were not unreasonable.

 

Spectrum Advisers Preferred Fund

 

The Board noted that advisory fee of 1.50% for Advisers Preferred was above the above range for the Morningstar Tactical Allocation category, and within range for the Morningstar Multialternative Category. The Trustees note that the Fund does not easily fit within a single category because of its strategy. The Trustees discussed that the net expenses of 2.35% for Investor Class was within range for both the Tactical Allocation Institutional and Multialternative 

37

 

Spectrum Funds

SUPPLEMENTAL INFORMATION (Unaudited)

September 30, 2021

 

Institutional Morningstar categories. The Board concluded that the advisory fee and net expenses for Advisers Preferred were not unreasonable.

 

Profitability of Adviser. The Board reviewed the levels of profits to the Adviser for the two most recent fiscal years or partial fiscal periods from each Fund with respect to advisory fees and from the total relationship with each Fund. They considered whether profits from each Fund were reasonable in light of services provided, including the assets levels and payments to the respective Sub-Adviser, and any breakpoints in fee structures for respective fund.

 

Spectrum Low Volatility and Advisers Preferred

 

In discussion and review of the profitability statement from the Adviser with respect to the Spectrum Funds, the Board considered the split between the Adviser and Sub-Adviser. The Board noted that the Adviser made a small 3% profit from Low Volatility and 4% from Advisers Preferred when considering the amounts paid to the Sub-Adviser and slightly less profitable when viewed from a totality of the relationship perspective with each Fund. The Trustees discussed the commission earned on Fund portfolio transactions by the Adviser’s affiliate as part of the total relationship. The Board concluded that the Adviser had realized minimal profits from its services to the Funds and therefore excessive profits were not of concern at this time.

 

Profitability Sub-Advisers: The Board reviewed the levels of profits to the Sub-Advisers for the two most recent fiscal years or partial fiscal periods from each Fund with respect to sub-advisory fees and from the total relationship with each Fund. With regards to the Funds, the Board noted that the Sub-Adviser usually charges higher fees from separately managed accounts with similar investment strategies, if any. They further concluded that the Sub-Adviser’s profits were not excessive, and they would monitor as each Fund’s assets continue to grow.

 

The Board reviewed the profitability reports submitted by Spectrum Financial, and noted that with respect to sub-advisory fees, they receive of 1.80% and 1.15%, respectively from Low Volatility and Advisers Preferred. They considered that Spectrum Financial charges 1.90% to 2.50% for separately managed accounts following similar investment strategies. The Board noted that Spectrum Financial made a 41% profit from Low Volatility and 22% from Advisers Preferred when considering the amounts paid to the Sub-Adviser for managing each Fund’s portfolio. The Trustees discussed the profits for Low Volatility were lower when considering the marketing expenses incurred by the Sub-Adviser and not different for Advisers Preferred. The Board concluded that Spectrum Financial’s profits from each of Low Volatility and Advisers Preferred were reasonable for services provided. They further concluded that the Sub-Adviser’s profits were not excessive, and they would monitor as each Fund’s assets continue to grow.

 

Economies of Scale. As to the extent to which the Funds will realize economies of scale, the Adviser reported an estimate of $500 million per Fund to be the minimum asset level required to reach such economies of scale and that some Funds may not achieve economies of scale as they may face capacity issues. The Board discussed the Adviser’s expectations for the growth of each Fund and concluded that any material economies of scale were not a concern at present assets levels. The Trustees agreed to revisit economies of scale as assets of the Funds continue to grow. 

38

 

Spectrum Funds

SUPPLEMENTAL INFORMATION (Unaudited)

September 30, 2021

 

Conclusion. Counsel assisted the Board throughout the Advisory Agreements review process. The Board members relied upon the advice of counsel, and their own business judgment in determining the material factors to be considered in evaluating each of the Advisory Agreement and Sub-Advisory Agreements where appropriate. In considering the approval Board noted that each Trustee may have afforded different weight to the various factors in reaching his conclusions and determined that approval of each of the Advisory Agreement and Sub-Advisory Agreements was in the best interests of each of the Spectrum Funds and its respective shareholders.

39

 

Spectrum Funds

SUPPLEMENTAL INFORMATION (Unaudited)

September 30, 2021

 

Approval of Advisory and Sub-Advisory Agreement – Spectrum Unconstrained Fund

 

At a meeting held on February 23, 2021 (the “Meeting”), held in accordance with relief granted by the U.S. Securities and Exchange Commission (the “SEC”) to ease certain governance obligations required under the Investment Company Act of 1940, as amended (the “1940 Act”) in light of travel concerns related to the COVID-19 pandemic (the “SEC Relief Order”)the Board of Trustees (the “Board”) of Advisors Preferred Trust (the “Trust”), including a majority of Trustees who are not “interested persons” (the “Independent Trustees”), as such term is defined under Section 2(a)(19) of 1940 Act, considered the approval of the investment advisory agreement (the “Advisory Agreement’) between Advisors Preferred, LLC (the “Adviser”) and the Trust, on behalf of the Spectrum Unconstrained Fund (the “New Spectrum Fund” or (“Spectrum Unconstrained”) and the approval of the sub-advisory agreement (the “Sub-Advisory Agreement”) between the Adviser and Spectrum Financial, Inc. (the “Sub-Adviser”).

 

In connection with the Board’s consideration of the Advisory Agreement and Sub-Advisory Agreements, (together the “Advisory Agreements”) the Adviser and Sub-Adviser provided the Board in advance of the Meeting with written materials, which included information regarding: (a) a description of the investment management personnel of the Adviser and Sub-Adviser; (b) the Adviser’s and Sub-Adviser’s operations and the Adviser’s financial condition; (c) the Adviser’s proposed brokerage practices (including any soft dollar arrangements); (d) the level of the advisory fees proposed to be charged compared with the fees charged to comparable mutual funds or accounts; (e) each Fund’s anticipated level of profitability from the Adviser’s and Sub-Adviser’s fund-related operations; (g) the Adviser’s and Sub-Adviser’s compliance policies and procedures; and (h) information regarding the performance of the New Fund as compared to their respective benchmarks and Morningstar categories.

 

The Board then reviewed and discussed the written materials that were provided by the Adviser and Sub-Adviser in advance of the Meeting and deliberated on the approval of the proposed Advisory Agreements with respect to Spectrum Unconstrained. The Board members relied upon the advice of independent legal counsel and their own business judgment in determining the material factors to be considered in evaluating the Advisory Agreements with respect to Spectrum Unconstrained and the weight to be given to each such factor. The conclusions reached by the Board were based on a comprehensive evaluation of all the information provided, both in written and verbal form, and were not the result of any one factor. Moreover, each Trustee may have afforded different weight to the various factors in reaching his conclusions with respect to the Advisory Agreements. The Trustees reviewed the quality of work and abilities of the Adviser and its relationship with Spectrum Financial and Spectrum Advisors Preferred Fund and Spectrum Low Volatility Fund (together the “Existing Spectrum Funds”). The Board further noted that Hundredfold Advisors, LLC is affiliated to the Sub-Adviser, as Mr. Doudera services of portfolio manager of the that adviser and of Hundredfold Select Alternative Fund. The Trustees concluded that in light of the performance history of the Existing Spectrum Funds and the compliance/review relationship with Spectrum Financial, the Adviser had sufficient quality and depth of personnel, resources, overview experience, investment methods and compliance policies and procedures essential to performing its duties to the Spectrum Unconstrained. The Trustees conducted some of their deliberations on a joint Adviser and Sub-Adviser basis given the close working relationship of the Adviser and Sub-Adviser.

40

 

Spectrum Funds

SUPPLEMENTAL INFORMATION (Unaudited)

September 30, 2021

 

Nature, Extent and Quality of Services. With respect to the nature, extent and quality of services provided, the Trustees reviewed the Adviser’s and the Sub-Adviser’s Form ADV, a description of the manner in which investment decisions will be made for Spectrum Unconstrained by the Sub-Adviser, a description of the services provided by the Adviser and those services provided by the Sub-Adviser and those executed by the Adviser, a review of the experience of professional personnel performing services for the Spectrum Unconstrained, including the team of individuals that primarily monitor and execute the investment and administration process, and a certification from each of the Adviser and Sub-Adviser certifying that each has adopted a Code of Ethics containing provisions reasonably necessary to prevent Access Persons, as that term is defined in Rule 17j-1 under the 1940 Act, from engaging in conduct prohibited by Rule 17j-1(b) and that each the of the Adviser and Sub-Adviser has adopted procedures reasonably necessary to prevent Access Persons from violating such Code of Ethics. The Trustees also noted the financial resources of the Adviser appeared adequate.

 

The Board also discussed the Adviser’s compliance program with the CCO of the Trust. The Board noted that the Adviser continues to have in place procedures which are currently working to prevent violations of applicable securities laws. The CCO noted she works closing with the CCO of the Adviser. The Board concluded that the Adviser has qualified professionals, resources, and compliance policies essential to performing its duties under the Advisory Agreement.

 

With respect to the Sub-Adviser, the Trustees considered that the Sub-Adviser will be primarily responsible for the New Spectrum Fund’s investment management. The Board considered the Sub-Adviser’s skills and experience relating to management of the Existing Spectrum Funds and its portfolio management and research techniques. The Trustees also noted the financial resources of the Sub-Adviser appeared adequate. The Board also noted the Trust’s CCO considers the Sub-Adviser’s compliance policies and procedures excellent. The Board concluded that the Sub-Adviser had sufficient quality and depth of personnel, resources, investment methods and compliance policies and procedures essential to performing its duties under the amended Sub-Advisory Agreement and that the nature, overall quality and extent of the management services to be provided by the Sub-Adviser to Spectrum Unconstrained will be satisfactory and reliable.

 

Performance. The Board considered that the Adviser generally delegates its day-to-day investment decisions to the Sub-Adviser and, therefore, would not directly control the performance of Spectrum Unconstrained. The Trustees reviewed the performance for the Existing Spectrum Funds managed by the Sub-Adviser, acknowledging the five-star Morningstar rating of Spectrum Low Volatility Fund. The Board noted that based on the experience of the portfolio managers, the Adviser and Sub-Adviser should be able to provide satisfactory performance for Spectrum Unstrained and its shareholders.

 

Fees and Expenses. As to the costs of the services to be provided to Spectrum Unconstrained by the Adviser and Sub-Adviser the Board reviewed and discussed the advisory fee and total operating expenses of Spectrum Unconstrained compared to its peer group and Morningstar category as presented in the Meeting Materials.

 

The Trustees noted that the proposed advisory fee of 2.15% was slightly above the range of management fees of the Nontraditional Bond, Long Short Credit and Multi-Alternative Morningstar categories when viewed together, but was nonetheless reasonable in light of the highly 

41

 

Spectrum Funds

SUPPLEMENTAL INFORMATION (Unaudited)

September 30, 2021

 

sophisticated derivative strategy element to be employed for the Fund. The Board acknowledged the sub-advisory fee paid to Spectrum Financial will be 1.80% and noted that the Sub-Adviser charges separately managed clients 1.90% to 2.50% for similar services The Board then reviewed the projected expense ratio of 2.93% for the Investor Class and found it to be within range of the expenses of the Morningstar categories when viewed together. The Board concluded that the advisory fee to be charged by the Adviser and projected expenses for the Fund were not unreasonable and the split between the Adviser and Sub-Advisor was acceptable.

 

Profitability. The Board reviewed the levels of projected profits to the Adviser from Spectrum Unconstrained and noted that with expected assets of $25 million for the first year, the Adviser projects a profit of approximately 8% from the advisory agreement and 7% profitability when considering the totality of the relationship with the Fund. For year two, with assets of $35 million, the Adviser expects profits from Spectrum Unconstrained to be 7% form advisory services and 7% when considering the totality of the relationship with the Fund. After review and discussion, the Board concluded that, based on the services to be provided by the Adviser the anticipated level of profit from the Adviser’s relationship with Spectrum Unconstrained was not excessive.

 

With respect to the Sub-Adviser’s profitability, the Trustees reviewed the projected profitability of Spectrum Financial, and noted that with less optimistic, yet reasonable, expected assets of $10 million for the first year, the Sub-Adviser anticipates to achieve a profit of 53% from sub-advisory services and 3% when considering the totality of the relationship with the Fund. The Board noted that for year two, with projected assets consistent, the expected overall profits for the Sub-Adviser would be 58% from sub-advisory services and 33% when considering the totality of the relationship with the Fund. After further discussion, the Board concluded that, based on the services to be provided by the Sub-Adviser, the anticipated level of profit from the Sub-Adviser’s relationship with Spectrum Unconstrained represented a fair entrepreneurial profit and was not excessive.

 

Economies of Scale. As to the extent to which Spectrum Unconstrained will realize economies of scale, the Adviser reported $500 million to be the minimum asset level to reach such economies of scale. The Board discussed the Adviser’s expectations for growth of Spectrum Unconstrained and concluded that any material economies of scale would not be achieved in the near term, and the Trustees agreed to revisit economies of scale as assets of Spectrum Unconstrained grow

 

Conclusion. Counsel assisted the Board throughout the Advisory Agreements review process. The Board members relied upon the advice of independent counsel, and their own business judgment in determining the material factors to be considered in evaluating each of the Advisory Agreements and the weight to be given to each such factor. In considering the approval of each of the Advisory Agreements, the Board did not identify any one factor as all important, but rather considered these factors collectively and determined that approval of each of the Advisory Agreements was in the best interests of Spectrum Unconstrained and its respective shareholders. Moreover, the Board noted that each Trustee may have afforded different weight to the various factors in reaching his conclusions and determined that approval of each of the Advisory Agreements was in the best interests of each of the Spectrum Unconstrained Fund and its respective shareholders. 

42

 

Spectrum Funds

SUPPLEMENTAL INFORMATION (Unaudited)

September 30, 2021

 

Independent Trustees

 

The following table provides information regarding each Trustee who is not an “interested person” of the Trust, as defined in the 1940 Act. 

 

Name, Address 1 and
Year of Birth
Position(s)
Held with
the Trust
Term of
Office/Length
of Time Served
Principal Occupation(s) During Past
5 Years
Number of
Portfolios in
Fund Complex
Overseen by
Trustee 2
Other
Directorships
Held by Trustee
During Past 5
Years
Charles R. Ranson Born: 1947 Trustee Indefinite, since November 2012 Principal, Ranson & Associates (business consultancy) (since 2003) 23 Northern Lights Fund Trust IV (27 series) (since 2015)
Felix Rivera Born: 1963 Trustee Indefinite, since November 2012 Managing Partner, Independent Channel Advisors, LLC (investment advisory consultancy), (since January 2011). 23 Centerstone Investors Trust (2 series) (since March 2016); BlueArc Multi- Strategy Fund (2014-2017)
David Feldman Born: 1963 Trustee Indefinite, since September 2017 Independent Consultant (since January 2015). Head of Intermediary Sales, Baron Capital Inc. (February 2010 to December 2014) 23 None

 

AP 9/30/21 v1

43

 

Spectrum Funds

SUPPLEMENTAL INFORMATION (Unaudited)

September 30, 2021

 

Interested Trustees and Officers

 

The following table provides information regarding each Trustee who is an “interested person” of the Trust, as defined in the 1940 Act, and each officer of the Trust. 

 

Name, Address 1
and Year of Birth
Position(s)
Held with
the Fund
Term of Office/
Length of Time
Served
Principal Occupation(s) During Past 5
Years
Number of
Portfolios in
Fund
Complex
Overseen by
Trustee 2
Other
Directorships
Held by
Trustee
Catherine Ayers-
Rigsby 3
Born: 1948
Trustee,
Chairperson,
President
Indefinite; since
November 2012
CEO, Advisors Preferred, LLC (since April  2011); President, Ceros Financial Services,  Inc.), (since August 2009); President Atcap  Partners, LLC (investment adviser) (since  July 2011). 23 None
Brian S. Humphrey 4 Born: 1972 Trustee Indefinite; since November 2012 Managing Director, Ceros Financial Services, Inc. (since January 2011). 23 None
Christine Casares
Born: 1975
Treasurer Indefinite; since
May 2019
Vice President, Tax Administration, Ultimus  Fund Solutions, LLC (since February 2016);  Assistant Vice President, Tax Administration  (January 2014 – January 2016). N/A N/A
Angela Holland
Born: 1970
Chief
Compliance
Officer
Indefinite; since
July 1, 2020
Chief Compliance Officer, Ceros Financial  Services, Inc. (since January 2016), Sales  Supervisor/AML Compliance Officer, Ceros  Financial Services, Inc. (April 2012 –  January 2016); Compliance Manager,  Advisors Preferred, LLC (April 2012 to  Present); Compliance Manager, AtCap  Partners, LLC (investment adviser) (Since  April 2012). N/A N/A
Richard Malinowski Born: 1983 Secretary Indefinite; since November 2012 Senior Vice President and Senior Managing Counsel, Ultimus Fund Solutions, LLC; (since February 2020); Senior Vice President (February 2017- February 2020); Vice President Legal Administration and Counsel (April 2016 – 2017) and AVP and Staff Attorney (September 2012 – March 2016). N/A N/A

 

1Unless otherwise specified, the address of each Trustee and officer is c/o Advisors Preferred Trust, 1445 Research Blvd., Suite 530, Rockville, MD 20850.

 

2The “Fund Complex” consists of the series of the Trust.

 

3Ms. Ayers-Rigsby is an interested person Trustee because she is an officer of the Trust, an officer of the Trust’s investment adviser, and an officer of the Trust’s principal underwriter.

 

4Mr. Humphrey is an interested person Trustee because he is an officer of the Trust’s principal underwriter.

 

The Funds’ Statement of Additional Information includes additional information about the Trustees and is available free of charge by calling toll- free 1-866-862-9686.

 

AP 9/30/21 v1

44

 

PRIVACY NOTICE 

 

Rev. May 2014

 

FACTS WHAT DOES ADVISORS PREFERRED TRUST DO WITH YOUR PERSONAL INFORMATION?
   
Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
   
What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:
   
    Social Security number Purchase History
         
  Assets Account Balances
         
  Retirement Assets Account Transactions
         
  Transaction History Wire Transfer Instructions
         
  Checking Account Information    
   
  When you are no longer our customer, we continue to share your information as described in this notice.
   
How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Advisors Preferred Trust chooses to share; and whether you can limit this sharing.

  

Reasons we can share your personal information Does Advisors
Preferred Trust
share?
Can you limit this
sharing?

For our everyday business purposes –

such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes No

For our marketing purposes –

to offer our products and services to you

No We don’t share
For joint marketing with other financial companies No We don’t share

For our affiliates’ everyday business purposes –

information about your transactions and experiences

No We don’t share

For our affiliates’ everyday business purposes –

information about your creditworthiness

No We don’t share
For nonaffiliates to market to you No We don’t share

 

Questions?   Call 1-866-862-9686

45

 

Who we are

Who is providing this notice?

 

Advisors Preferred Trust

What we do
How does Advisors Preferred Trust protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

 

Our service providers are held accountable for adhering to strict policies and procedures to prevent any misuse of your nonpublic personal information.

How does Advisors Preferred Trust collect my personal information?

We collect your personal information, for example, when you

 

■    Open an account

 

■    Provide account information

 

■    Give us your contact information

 

■    Make deposits or withdrawals from your account

 

■    Make a wire transfer

 

■    Tell us where to send the money

 

■    Tells us who receives the money

 

■    Show your government-issued ID

 

■    Show your driver’s license

 

We also collect your personal information from other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only  

■    Sharing for affiliates’ everyday business purposes – information about your creditworthiness

■    Affiliates from using your information to market to you

 

■    Sharing for nonaffiliates to market to you

 

State laws and individual companies may give you additional rights to limit sharing.

Definitions
Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

 

■    Advisors Preferred Trust does not share with our affiliates.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.  

   Advisors Preferred Trust does not share with nonaffiliates so they can market to you.

Joint marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

 

   Advisors Preferred Trust doesn’t jointly market.

46

 

PROXY VOTING POLICY

 

Information regarding how the Funds voted proxies relating to portfolio securities for the most recent twelve month period ended June 30 as well as a description of the policies and procedures that the Fund use to determine how to vote proxies will be available without charge, upon request, by calling 1-866-862-9686 or by referring to the Securities and Exchange Commission’s (“SEC”) website at http://www.sec.gov.

 

PORTFOLIO HOLDINGS

 

The Fund files its complete schedule of portfolio holdings with the SEC for the first and third quarters of each fiscal year as an exhibit to its reports on Form N-PORT, within sixty days after the end of the period. Form N-PORT reports are available on the SEC’s website at http://www.sec.gov. The information on Form N-PORT is available without charge, upon request, by calling 1-866-862-9686.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

INVESTMENT ADVISOR

Advisors Preferred LLC

1445 Research Blvd., Suite 530

Rockville, Maryland 20850

 

INVESTMENT SUB-ADVISOR

Spectrum Financial, Inc.

272 Bendix Road Suite 600

Virginia Beach, VA 23452

 

ADMINISTRATOR

Ultimus Fund Solutions, LLC

225 Pictoria Drive, Suite 450

Cincinnati, Ohio 45246

 

SPECTRUM-AR21

 

 

Item 2. Code of Ethics.

 

(a)       As of the end of the period covered by this report, the registrant has adopted a code of ethics that applies to the registrant's principal Principal Executive Officer, principal Principal Financial Officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party.

 

(b)        For purposes of this item, “code of ethics” means written standards that are reasonably designed to deter wrongdoing and to promote:

 

(1)Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
(2)Full, fair, accurate, timely, and understandable disclosure in reports and documents that a registrant files with, or submits to, the Commission and in other public communications made by the registrant;

(3)        Compliance with applicable governmental laws, rules, and regulations;

(4)The prompt internal reporting of violations of the code to an appropriate person or persons identified in the code; and

(5)        Accountability for adherence to the code.

 

(c)        Amendments: During the period covered by the report, there have not been any amendments to the provisions of the code of ethics.

 

(d)        Waivers: During the period covered by the report, the registrant has not granted any express or implicit waivers from the provisions of the code of ethics.

 

(e) The Code of Ethics is not posted on Registrant’ website.

 

(f) A copy of the Code of Ethics is attached as an exhibit.

 

Item 3. Audit Committee Financial Expert.

 

(a)The Registrant’s board of trustees has determined that Felix Rivera is an audit committee financial expert, as defined in Item 3 of Form N-CSR.  Mr. Rivera is independent for purposes of this Item 3.

 

Item 4. Principal Accountant Fees and Services.

 

(a)Audit Fees

2021 - $39,000

2020 - $29,400

 

(b)Audit-Related Fees

2021 - $0

2020 - $0

 

(c)Tax Fees

2021 - $9,000

2020 - $6,300

 

Preparation of Federal & State income tax returns, assistance with calculation of required income, capital gain and excise distributions and preparation of Federal excise tax returns.

 

(d)All Other Fees

2021 - None

2020 - None

 

(e)(1) Audit Committee’s Pre-Approval Policies

 

The registrant’s Audit Committee is required to pre-approve all audit services and, when appropriate, any non-audit services (including audit-related, tax and all other services) to the registrant. The registrant’s Audit Committee also is required to pre-approve, when appropriate, any non-audit services (including audit-related, tax and all other services) to its adviser, or any entity controlling, controlled by or under common control with the adviser that provides ongoing services to the registrant, to the extent that the services may be determined to have an impact on the operations or financial reporting of the registrant. Services are reviewed on an engagement by engagement basis by the Audit Committee.

 

(2)Percentages of Services Approved by the Audit Committee
   2021  2020
Audit-Related Fees:   100%   100%
Tax Fees:   100%   100%
All Other Fees:   100%   100%

 

(f)During the audit of registrant's financial statements for the most recent fiscal year, less than 50 percent of the hours expended on the principal accountant's engagement were attributed to work performed by persons other than the principal accountant's full-time, permanent employees.

 

(g)The aggregate non-audit fees billed by the registrant's accountant for services rendered to the registrant, and rendered to the registrant's investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the registrant:

 

2021 - $9,000

2020 - $6,300

 

(h)        The registrant's audit committee has considered whether the provision of non-audit services to the registrant's investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the investment adviser that provides ongoing services to the registrant, that were not pre-approved pursuant to paragraph (c)(7)(ii) of Rule 2-01 of Regulation S-X, is compatible with maintaining the principal accountant's independence.

 

Item 5. Audit Committee of Listed Companies. Not applicable to open-end investment companies.

 

Item 6. Schedule of Investments. Schedule of investments in securities of unaffiliated issuers is included under Item 1.

 

Item 7. Disclosure of Proxy Voting Policies and Procedures for Closed-End Funds. Not applicable to open-end investment companies.

 

Item 8. Portfolio Managers of Closed-End Management Investment Companies. Not applicable to open-end investment companies.

 

Item 9. Purchases of Equity Securities by Closed-End Funds. Not applicable to open-end investment companies.

 

Item 10. Submission of Matters to a Vote of Security Holders. Vote of security holders is included under item 1.

 

Item 11. Controls and Procedures.

 

(a)       Based on an evaluation of the Registrant’s disclosure controls and procedures as of a date within 90 days of filing date of this Form N-CSR, the principal Principal Executive Officer and principal Principal Financial Officer of the Registrant have concluded that the disclosure controls and procedures of the Registrant are reasonably designed to ensure that the information required in filings on Form N-CSR is recorded, processed, summarized, and reported by the filing date, including that information required to be disclosed is accumulated and communicated to the Registrant’s management, including the Registrant’s principal Principal Executive Officer and principal Principal Financial Officer, as appropriate to allow timely decisions regarding required disclosure.

 

(b)       There were no significant changes in the Registrant’s internal control over financial reporting that occurred during the Registrant’s last fiscal half-year that have materially affected, or are reasonably likely to materially affect, the Registrant’s internal control over financial reporting.

 

Item 12. Disclosure of Securities Lending Activities for Closed-End Management Investment Companies. Not applicable.

 

Item 13. Exhibits.

 

(a)(1) Code of Ethics filed herewith.

 

(a)(2) Certifications required by Section 302 of the Sarbanes-Oxley Act of 2002 (and Item 11(a)(2) of Form N-CSR) are filed herewith.

 

(a)(3) Not applicable for open-end investment companies.

 

(b)       Certifications required by Section 906 of the Sarbanes-Oxley Act of 2002 (and Item 11(b) of Form N-CSR) are filed herewith.

 

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

 

(Registrant) Advisors Preferred Trust

 

By (Signature and Title)

/s/ Catherine Ayer-Rigsby

Catherine Ayer-Rigsby, Principal Executive Officer

 

Date 12/7/21

 

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

 

By (Signature and Title)

/s/ Catherine Ayer-Rigsby

Catherine Ayers-Rigsby, Principal Executive Officer

 

Date 12/7/21

 

 

By (Signature and Title)

/s/Christine Casares

Christine Casares, Principal Financial Officer

 

Date 12/7/21

CERTIFICATIONS

 

I, Catherine Ayers-Rigsby, certify that:

 

1.       I have reviewed this report on Form N-CSR of the Spectrum Funds (series of Advisors Preferred Trust);

 

2.       Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

 

3.       Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

 

4.       The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

 

a)       designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

b)       designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

c)       evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and

d)       disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the second fiscal quarter of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

 

5.       The registrant's other certifying officer(s) and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of directors (or persons performing the equivalent functions):

 

a)       all significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and

b)       any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting.

 

 

Date: 12/7/21                                              /s/Catherine Ayers-Rigsby

Catherine Ayers-Rigsby, Principal Executive Officer

I, Christine Casares, certify that:

 

I have reviewed this report on Form N-CSR of Spectrum Funds (series of Advisors Preferred Trust);

 

2.       Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

 

3.       Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

 

4.       The registrant's other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

 

a)       designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

b)       designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

c)       evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and

d)       disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent fiscal half-year (the registrant’s second fiscal half-year in the case of an annual report) that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

 

5.       The registrant's other certifying officer(s) and I have disclosed to the registrant's auditors and the audit committee of the registrant's board of directors (or persons performing the equivalent functions):

 

a)       all significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant's ability to record, process, summarize, and report financial information; and

b)       any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant's internal control over financial reporting.

 

 

Date: 12/7/21                                                                  /s/Christine Casares

Christine Casares

Principal Financial Officer

certification

Catherine Ayers-Rigsby, Principal Executive Officer, and Christine Casares, Principal Financial Officer of Advisors Preferred Trust (the “Registrant”), each certify to the best of his knowledge that:

1.       The Registrant’s periodic report on Form N-CSR for the period ended September 30, 2021 (the “Form N-CSR”) fully complies with the requirements of Sections 15(d) of the Securities Exchange Act of 1934, as amended; and

2.       The information contained in the Form N-CSR fairly presents, in all material respects, the financial condition and results of operations of the Registrant.

Principal Executive Officer  Principal Financial Officer
Advisors Preferred Trust  Advisors Preferred Trust
    
    
/s/Catherine Ayers-Rigsby  /s/Christine Casares
Catherine Ayers Rigsby  Christine Casares
Date: 12/7/21  Date: 12/7/21

 

 

A signed original of this written statement required by Section 906 of the Sarbanes-Oxley Act of 2002 has been provided to Advisors Preferred Trust and will be retained by Advisors Preferred Trust and furnished to the Securities and Exchange Commission (the “Commission”) or its staff upon request.

 

This certification is being furnished to the Commission solely pursuant to 18 U.S.C. § 1350 and is not being filed as part of the Form N-CSR filed with the Commission.

 

Advisors Preferred Trust

CODE OF ETHICS

November 27, 2012

 

 

The Advisors Preferred Trust (the “Trust”) and each series thereof (the “Funds”) has adopted this Code of Ethics (the “Code”) in order to set forth guidelines and procedures that promote ethical practices and conduct by all of its Access Persons and to ensure that all Access Persons comply with the federal securities laws. Although this Code contains a number of specific standards and policies, there are four key principles embodied throughout the Code.

 

The interests of the Funds must always be paramount

 

Access Persons have a legal, fiduciary duty to place the interests of the Funds ahead of their own. In any decision relating to their personal investments, Access Persons must scrupulously avoid serving their own interests ahead of those of Trust.

 

Access Persons may not take advantage of their relationship with the Funds

 

Access Persons should avoid any situation (unusual investment opportunities, perquisites and accepting gifts of more than token value from persons seeking to do business with the Funds) that might compromise, or call into question, the exercise of their fully independent judgment in the interests of the Funds.

 

All Personal Securities Transactions should avoid any actual, potential, or apparent conflicts of interest

 

Although all Personal Securities Transactions by Access Persons must be conducted in a manner consistent with this Code, the Code itself is based on the premise that Access Persons owe a fiduciary duty to the Funds, and should avoid any activity that creates an actual, potential, or apparent conflict of interest. This includes executing transactions through or for the benefit of a third party when the transaction is not in keeping with the general principles of this Code.

 

Access Persons must adhere to these general principles as well as comply with the specific provisions of this Code. Technical compliance with the Code and its procedures will not automatically prevent scrutiny of trades that show a pattern of abuse of an individual’s fiduciary duty to the Funds.

 

Access Persons must comply with all applicable laws

In both work-related and personal activities, Access Persons must comply with all applicable laws, including the federal securities laws.

 

Any violations of this Code should be reported promptly to the Chief Compliance Officer or his designee. Failure to do so will be deemed a violation of the Code.

 
 

DEFINITIONS

 

“Access Person” shall have the same meaning as set forth in Rule 17j-1 under the Investment Company Act of 1940, as amended (the “1940 Act”) and shall include:

1.all officers and trustees (or persons occupying a similar status or performing a similar function) of the Funds;
2.all officers and trustees (or persons occupying a similar status or performing a similar function) of an Adviser with respect to its corresponding series of the Trust
3.any employee of the Trust or the Advisers (or of any company controlling or controlled by or under common control with the Trust or the Advisers) who, in connection with his or her regular functions or duties, makes, participates in, or obtains information regarding the purchase or sale of Covered Securities by the Funds, or whose functions relate to the making of any recommendations with respect to the purchase or sale; and
4.any other natural person controlling, controlled by or under common control with the Trust or the Advisers who obtains information concerning recommendations made to the Funds with regard to the purchase or sale of Covered Securities by the Funds.

 

“Beneficial Ownership” means in general and subject to the specific provisions of Rule 16a-1(a)(2) under the Securities Exchange Act of 1934, as amended, having or sharing, directly or indirectly, through any contract arrangement, understanding, relationship, or otherwise, a direct or indirect “pecuniary interest” in the security.

 

“Chief Compliance Officer” means the Code of Ethics Compliance Officer of the Trust with respect to Trustees and officers of the Trust, or the CCO of the Advisers with respect to Advisers personnel.

 

“Code” means this Code of Ethics.

 

“Covered Security” means any Security, except (i) direct obligations of the U.S. Government, (ii) bankers’ acceptances, bank certificates of deposit, commercial paper and high quality short-term debt instruments, including repurchase agreements, and (iii) shares issued by open-end mutual Funds.

 

Decision Making Access Person” means any Access Person who, in connection with his or her regular functions or duties, makes or participates in or obtains information regarding recommendations on the purchase or sale of a security by the Funds, or whose functions relate to the making of any recommendations with respect to such purchases or sales. Decision Makers typically are Adviser personnel.

 

“Funds” means series of the Trust.

 

“Immediate family” means an individual’s spouse, child, stepchild, grandchild, parent, stepparent, grandparent, siblings, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law and should include adoptive relationships. For purposes of determining whether an Access Person has an “indirect pecuniary interest” in securities, only ownership by “immediate family” members sharing the same household as the Access Person will be presumed to be an “indirect pecuniary interest” of the Access Person, absent special circumstances.

 

“Independent Trustees” means those Trustees of the Trust that would not be deemed an “interested person” of the Trust, as defined in Section 2(a)(19)(A) of the 1940 Act.

 

“Indirect Pecuniary Interest” includes, but is not limited to: (a) securities held by members of the person’s Immediate Family sharing the same household (which ownership interest may be rebutted); (b) a

 
 

general partner’s proportionate interest in Fund securities held by a general or limited partnership; (c) a person’s right to dividends that is separated or separable from the underlying securities (otherwise, a right to dividends alone will not constitute a pecuniary interest in securities); (d) a person’s interest in securities held by a Trust; (e) a person’s right to acquire securities through the exercise or conversion of any derivative security, whether or not presently exercisable; and (f) a performance-related fee, other than an asset based fee, received by any broker, dealer, bank, insurance company, investment company, investment manager, Trustee, or person or entity performing a similar function, with certain exceptions.

 

“Pecuniary Interest” means the opportunity, directly or indirectly, to profit or share in any profit derived from a transaction in securities.

 

“Personal Securities Transaction” means any transaction in a Covered Security in which an Access Person has a direct or indirect Pecuniary Interest.

 

“Purchase or Sale of a Security” includes the writing of an option to purchase or sell a Security. A Security shall be deemed “being considered for Purchase or Sale” for the Trust when a recommendation to purchase or sell has been made and communicated by a Decision Making Access Person, and, with respect to the person making the recommendation, when such person seriously considers making such a recommendation. These recommendations are placed on the “Restricted List” until they are no longer being considered for Purchase or Sale, or until the Security has been purchased or sold.

 

“Restricted List” means the list of securities maintained by the Chief Compliance Officer in which trading by Access Persons is generally prohibited.

 

“Security” means any note, stock, treasury stock, bond, debenture, evidence of indebtedness, certificate of interest or participation in any profit-sharing agreement, collateral-trust certificate, pre-organization certificate or subscription, transferable share, investment contract, voting-trust certificate, certificate of deposit for a security, fractional undivided interest in oil, gas, or other mineral rights, or, in general, an interest or instrument commonly known as “security”, or any certificate or interest or participation in temporary or interim certificate for, receipt for, guarantee of, or warrant or right to subscribe to or purchase (including options) any of the foregoing.

 

“Advisers” mean the Advisers to the Trust.

 

“Trust” mean the Advisors Preferred Trust.

 

 

PROHIBITED ACTIONS AND ACTIVITIES

 

  1. No Access Person shall purchase or sell directly or indirectly, any Covered Security in which he or she has, or by reason of such transaction acquires, any direct or indirect beneficial ownership and which he or she knows or should have known at the time of such purchase or sale;

 

(1)is being considered for purchase or sale by a Fund, or

 

(2)is being purchased or sold by a Fund.

 

  1. Decision-Making Access Persons may not participate in any initial public offering of Covered Securities in any account over which they exercise Beneficial Ownership. All Access Persons must obtain prior written authorization from the Chief Compliance Officer or his designee prior to such participation;
 
 

 

  1. No Access Person may purchase a Covered Security in which by reason of such transaction they acquire Beneficial Ownership in a private placement of a Security, without prior written authorization of the acquisition by the Chief Compliance Officer or his designee;

 

  1. Access Persons may not accept any fee, commission, gift, or services, other than de minimus gifts, from any single person or entity that does business with or on behalf of the Trust;

 

  1. Decision-Making Access Persons may not serve on the board of directors of a publicly traded company without prior authorization from the Chief Compliance Officer or his designee based upon a determination that such service would be consistent with the interests of the Trust. If such service is authorized, procedures will then be put in place to isolate such Decision-Making Access Persons serving as directors of outside entities from those making investment decisions on behalf of the Trust.

 

Advanced notice should be given so that the Trust or Advisers may take such action concerning the conflict as deemed appropriate by the Chief Compliance Officer or his designee.

 

  1. Decision-Making Access Persons may execute a Personal Securities Transaction involving a Covered Security without pre-authorization of the Chief Compliance Officer or such persons who may be designated by the Chief Compliance Officer from time to time, provided it is permitted by the Adviser’s Code of Ethics. The Chief Compliance Officer or his designee may restrict purchases of Covered Securities pursuant to the Adviser’s Code of Ethics.

 

  1. It shall be a violation of this Code for any Access Person, in connection with the purchase or sale, directly or indirectly, of any Covered Security held or to be acquired by a Fund:
    1. to employ any device, scheme or artifice to defraud the Trust;
    2. to make to the Trust any untrue statement of a material fact or to omit to state to the Trust a material fact necessary in order to make the statements made, in light of the circumstances under which they are made, not misleading;
    3. to engage in any act, practice or course of business that operates or would operate as a fraud or deceit upon the Trust; or
    4. to engage in any manipulative practice with respect to the Trust.

 

 

EXEMPTED TRANSACTIONS

 

The provisions described above under the heading Prohibited Actions and Activities and the preclearance procedures under the heading Preclearance of Personal Securities Transactions do not apply to:

 

·Purchases or Sales of Securities effected in any account in which an Access Person has no Beneficial Ownership;

 

·Purchases or Sales of Securities which are non-volitional on the part the Access Person (for example, the receipt of stock dividends);

 

·Purchase of Securities made as part of automatic dividend reinvestment plans;

 

·Purchases of Securities made as part of an employee benefit plan involving the periodic purchase of company stock or mutual Funds; and
 
 

 

·Purchases of Securities effected upon the exercise of rights issued by an issuer pro rata to all holders of a class of its Securities, to the extent such rights were acquired from such issuer, and sale of such rights so acquired.

 

 

 

PRECLEARANCE OF PERSONAL SECURITIES TRANSACTIONS

 

All Decision-Making Access Persons wishing to engage in a Personal Securities Transaction involving, as defined in the Securities Act of 1933, an Initial Public Offering (IPO) or a Limited Offering, must obtain prior authorization of any such Personal Securities Transaction from the Chief Compliance Officer or such person or persons that the Chief Compliance Officer may from time to time designate to make such authorizations. Personal Securities Transactions by the Chief Compliance Officer involving an IPO or Limited Offering, shall require prior authorization from the President or Chief Executive Officer of the Trust (unless such person is also the Chief Compliance Officer) or their designee, who shall perform the review and approval functions relating to reports and trading by the Chief Compliance Officer. The Trust shall adopt the appropriate forms and procedures for implementing this Code of Ethics.

 

Any authorization so provided is effective until the close of business on the fifth trading day after the authorization is granted. In the event that an order for the Personal Securities Transaction involving an IPO or Limited Offering, is not placed within that time period, a new authorization must be obtained. If the order for the transaction is placed but not executed within that time period, no new authorization is required unless the person placing the order originally amends the order in any manner. Authorization for “good until canceled” orders is effective unless the order conflicts with a Trust order.

 

If a Decision-Making Access Person wishing to effect a Personal Securities Transaction learns, while the order is pending, that the same Security is being considered for Purchase or Sale by a Fund, he or she should consult with the Chief Compliance Officer or his or her designee.

 

 

REPORTING AND MONITORING

 

The Chief Compliance Officer or such person or persons that the Chief Compliance Officer may from time to time designate shall monitor all personal trading activity of all Access Persons pursuant to the procedures established under this Code.

 

Disclosure of Personal Brokerage Accounts

 

Within 10 days of the commencement of employment or at the commencement of a relationship with the Trust, all Access Persons, except Independent Trustees, are required to submit to the Chief Compliance Officer or his designee a report stating the names and account numbers of all of their personal brokerage accounts, brokerage accounts of members of their Immediate Family, and any brokerage accounts which they control or in which they or an Immediate Family member has Beneficial Ownership. Such report must contain the date on which it is submitted and the information in the report must be current as of a date no more than 45 days prior to that date. In addition, if a new brokerage account is opened during the course of the year, the Chief Compliance Officer or his designee must be notified immediately.

 

 
 

The information required by the above paragraph must be provided to the Chief Compliance Officer or his designee on an annual basis, and the report of such should be submitted with the annual holdings reports described below.

 

Each of these accounts is required to furnish duplicate confirmations and statements to the Chief Compliance Officer or his designee. These statements and confirms for each series of the Trust may be sent to the Advisers.

 

Initial Holdings Report

Within ten days of becoming an Access Person (and with information that is current as of a date no more than 45 days prior to the date that the report was submitted), each Access Person, except Independent Trustees must submit a holdings report that must contain, at a minimum, the title and type of Security, and as applicable, the exchange ticker symbol or CUSIP number, number of shares, and principal amount of each Covered Security in which the Access Person has any direct or indirect Beneficial Ownership. This report must state the date on which it is submitted.

 

Annual Holdings Reports

 

All Access Persons, except Independent Trustees, must supply the information that is required in the initial holdings report on an annual basis, and such information must be current as of a date no more than 45 days prior to the date that the report was submitted. Such reports must state the date on which they are submitted.

 

QUARTERLY TRANSACTION REPORTS

 

All Access Persons shall report to the Chief Compliance Officer or his designee the following information with respect to transactions in a Covered Security in which such person has, or by reason of such transaction acquires, any direct or indirect Beneficial Ownership in the Covered Security:

 

·The date of the transaction, the title, and as applicable the exchange ticker symbol or CUSIP number, interest rate and maturity date, number of shares, and the principal amount of each Covered Security;
·The nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition);
·The price of the Covered Security at which the transaction was effected; and
·The name of the broker, dealer, or bank with or through whom the transaction was effected.
·The date the Access Person Submits the Report.

 

Reports pursuant to this section of this Code shall be made no later than 30 days after the end of the calendar quarter in which the transaction to which the report relates was effected, and shall include a certification that the reporting person has reported all Personal Securities Transactions required to be disclosed or reported pursuant to the requirements of this Code. Confirmations and Brokerage Statements sent directly to each Adviser’s address noted above is an acceptable form of a quarterly transaction report.

 

An Independent Trustee need only make a quarterly transaction report if he or she, at the time of the transaction, knew, or in the ordinary course of fulfilling his or her official duties as a Trustee, should have known that during the 15-day period immediately preceding or following the date of the transaction by the Independent Trustee, the Covered Security was purchased or sold by a Fund or was considered for purchase or sale by a Fund.

 

 
 

 

ENFORCEMENTS AND PENALTIES

 

The Chief Compliance Officer or his designee shall review the transaction information supplied by Access Persons. If a transaction appears to be a violation of this Code, the transaction will be reported to the Board of Trustees.

 

Upon being informed of a violation of this Code, the Board of Trustees may impose sanctions as it deems appropriate, including but not limited to, a letter of censure or suspension, termination of the employment of the violator, or a request for disgorgement of any profits received from a securities transaction effected in violation of this Code. The Trust shall impose sanctions in accordance with the principle that no Access Person may profit at the expense of its clients. Any losses are the responsibility of the violator. Any profits realized on personal securities transactions in violation of the Code must be disgorged in a manner directed by the Board of Trustees.

 

Annually, the Chief Compliance Officer at each regular meeting of the Board shall issue a report on Personal Securities Transactions by Access Person. The report submitted to the board shall:

 

·Summarize existing procedures concerning Personal Securities investing and any changes in the procedures made during the prior year;
·Identify any violations of this Code and any significant remedial action taken during the prior year; and;
·Identify any recommended changes in existing restrictions or procedures based upon the experience under the Code, evolving industry practices or developments in applicable laws and regulations.

 

 

Acknowledgment

 

The Trust must provide all Access Persons with a copy of this Code. Upon receipt of this Code, all Access Persons must do the following:

 

All new Access Persons must read the Code, complete all relevant forms supplied by the Chief Compliance Officer or his designee (including a written acknowledgement of their receipt of the Code), and schedule a meeting with the Chief Compliance Officer or his designee to discuss the provisions herein within two calendar weeks of employment.

 

Existing Access Persons who did not receive this Code upon hire, for whatever reason, must read the Code, complete all relevant forms supplied by the Chief Compliance Officer or his designee (including a written acknowledgement of their receipt of the Code), and schedule a meeting with the Chief Compliance Officer or his designee to discuss the provisions herein at the earliest possible time, but no later than the end of the current quarter.

 

All Access Persons must certify on an annual basis that they have read and understood the Code.

 

 



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