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BVI FSC Approved Investment ManagerIBR/AIM/26/2644

Investor GuideField edition

The allocator’s field guide.

How your capital is held, where every fee sits, and what can go wrong. Eight plates you can touch.

CredentialsQlumina Inc.Approved Investment Manager, BVI Financial Services Commission

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

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

Plate 01Ownership

Trading authority. Never custody.

Switch the structure, then point at a number.

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

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

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

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

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

Broker-level risk control

A floor the manager cannot move.

Configured at the broker, independent of the investment manager. The example from this guide: $1,000,000, a 10% maximum drawdown tolerance, a floor at $900,000.

Account risk controlLiquidate all positions if equity touches the floor
Armed
Starting equity$1,000,000
Max drawdown10%
Floor$900,000
  1. Closes all active positions
  2. Deactivates Qlumina's trading access
  3. Notifies the investor immediately
Example from the guideScroll to run the example

Plate 02Structures

Three ways to hold a strategy.

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

SMAMarketplace format

Separately managed account

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

Liquidity

Daily

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

AMC

Actively managed certificate

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

Liquidity

Weekly

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

Hedge fund

Hedge fund vehicle

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

Liquidity

Monthly (with notice)

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

Plate 03Fees

Where every fee sits.

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

Account statementSeparately managed account, in your name
Line by line
  • PositionsHeld in your nameYours
  • Manager feeOn your accountVisible line by line
  • Front-end loadOn entryNone
  • Back-end loadOn exitNone
  • Custody feeAt the brokerNone
  • What you seeEvery position and every fee line

A manager fee on your account, visible line by line. No front-end load, no back-end load, no custody fee.

NAV statementPooled fund, shares of the vehicle
Netted
  • Entry chargeOn subscriptionVaries by fund
  • Management feeInside the vehicleIn the NAV
  • Performance feeInside the vehicleIn the NAV
  • Exit chargeOn redemptionVaries by fund
  • Your holdingShares of the vehicleA share
  • What you seeOne NAV per share

Management and performance fees charged inside the vehicle, alongside entry and exit charges that vary by fund.

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

Fee mechanics

Paid on new highs, not on recoveries.

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

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

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

Plate 04Evidence

Evidence before allocation.

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

Medium-term trend (MFT)

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

Track record verificationExample program under review
Reconciling
  • 01Administrator NAV statementsOfficial NAV packagesQueued
  • 02Direct prime broker statementsClearing-broker confirmationsQueued
  • 03Timestamped tick-level trade dataEvery execution, timestampedQueued
  • 04Live pilot capital allocationsReal capital, observed liveQueued
Sources reconciled 0 of 4

AI across the process

Investment Philosophy
  1. AI-assisted01 Research & discovery

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

  2. AI-assisted02 Manager evaluation

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

  3. AI-assisted03 Real-time monitoring

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

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

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

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

Plate 05Risk

Every risk, in plain sight.

Search or filter the reference. Nothing here is summarized away.

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

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

  • Algorithmic signal decay during unprecedented market regime shifts.

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

  • Latency and spread widening during fast-moving macroeconomic events.

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

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

  • An individually owned investment portfolio managed on behalf of a single investor. Assets are held in a segregated brokerage account in the investor's own name. Qlumina does not hold, control, or withdraw investor funds — it is granted a Limited Power of Attorney permitting only the transmission of trading signals. The investor retains full legal and beneficial ownership at all times.

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

  • A securitized investment product — typically a note or certificate — issued by a third-party issuer (a bank or special purpose vehicle) that tracks a strategy actively managed by Qlumina. The investor purchases the certificate; its value rises or falls with the underlying strategy, net of fees. AMCs combine discretionary management flexibility with the accessibility and transferability of a listed or OTC security.

  • Unlike ETFs and mutual funds, Actively Managed Certificates (AMCs) are structured debt instruments issued by an institutional issuer (such as a Swiss or European bank or special purpose vehicle), exposing the investor to issuer credit risk in addition to strategy market risk. They do not hold segregated assets in the investor's name — the investor holds a transferable claim against the issuer. However, AMCs can be launched with greater agility, carry lower structural overheads, and provide access to dynamic quantitative strategies through standard brokerage accounts via an assigned ISIN.

  • Pooled investment vehicles structured as limited partnerships or corporate funds domiciled in the BVI or another appropriate jurisdiction. Each fund has constitutional documents, an offering memorandum, and subscription documents. Hedge funds offer access to more complex or capacity-constrained strategies and achieve economies of scale, netting, and institutional prime-broker infrastructure.

    Qlumina's hedge funds are structured as limited partnerships or corporate fund vehicles domiciled in the British Virgin Islands or other premier fund jurisdictions. Each fund operates under constitutional documents, an institutional offering memorandum, and formal subscription agreements.

    • Infrastructure-intensive strategies: high-frequency quantitative strategies requiring ultra-low-latency co-location and specialized hardware feeds that are economically viable only when shared across pooled capital.
    • Economies of scale: pooled vehicles achieve institutional prime brokerage clearing rates, reduced financing spreads, and tighter execution than individual account sizes can command.
    • Netting & margin efficiency: cross-strategy position netting inside a single fund vehicle significantly reduces aggregate collateral requirements compared to multiple separate accounts.
    • Institutional governance: independent third-party fund administration, independent annual audit, and fiduciary director oversight built into the fund constitutional structure.
  • Certain prime brokers offer automated risk controls configured directly at the account infrastructure layer, independent of the investment manager. For example, an investor with $1,000,000 and a specified maximum drawdown tolerance of 10% can instruct the broker to automatically liquidate all open positions if account equity touches $900,000. On breach, the broker closes all active positions, deactivates Qlumina's trading access, and notifies the investor immediately.

  • Investors maintain online access to their account 24/7 via the prime broker's portal, with live visibility into open orders, margin utilization, P&L, and cash balances, complemented by automated daily broker statements.

  • Assets are held at institutional prime brokers or custodians selected in consultation with the investor. Qlumina never takes custody of funds.

  • Every fund vehicle utilizes an independent fund administrator responsible for calculating official NAV, reconciling broker records, and managing subscriptions and redemptions, alongside independent annual audits conducted by recognized accounting firms under IFRS or US GAAP.

  • Qlumina (pronounced Q-Lumina, from quantitative science and computational illumination) is an AI-native asset management firm that designs, evaluates, and manages investment programs across multiple structures — Separately Managed Accounts (SMAs), Actively Managed Certificates (AMCs), and hedge funds. We combine systematic, technology-driven research with rigorous human oversight to source, validate, and allocate to investment strategies across global markets.

    Our philosophy is built on the conviction that artificial intelligence and systematic data analysis can meaningfully improve the sourcing, evaluation, and risk management of investment strategies — while final investment decisions and fiduciary oversight require experienced human judgment. We identify high-quality portfolio managers and strategies through technology-enhanced due diligence and offer access through the structure best suited to investor needs.

  • An Approved Manager is a category of investment manager authorized by the British Virgin Islands Financial Services Commission to manage investment funds and accounts, subject to regulatory conditions including limits on the number of investors and/or assets under management, ongoing compliance obligations, and adherence to anti-money laundering (AML) and counter-terrorist financing (CTF) requirements. The regime is designed for professional and institutional investor-facing managers and provides a proportionate regulatory framework while maintaining internationally recognized standards of conduct and investor protection. Qlumina operates under the Securities and Investment Business Act, 2010 (SIBA), as administered by the BVI FSC.

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

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

    • Identification: government ID and corporate constitutional documentation.
    • Proof of address: official verification of registered address and tax residency.
    • Source of wealth: declarations compliant with BVI AML/CTF statutory regulations.
    • Eligibility sign-off: compliance review and formal institutional clearance.
  • Investing involves substantial risk of loss. The value of investments and the income derived from them can fall as well as rise, and investors may not recover the amount originally invested. Past performance is no guarantee of future returns. Nothing in this document constitutes financial, legal, tax, or investment advice.

  • A separately managed account is a delivery format, not a strategy or a guarantee: performance, risk and the suitability of any program depend on the mandate you agree. Lock-up, redemption, minimum and fee terms shown on this page are indicative; the terms that bind are the ones in your mandate.

Plate 06Glossary

The words, defined once.

Fourteen terms you will meet in a mandate.

LPOA

Limited power of attorney

Grants trading execution rights only, never the ability to withdraw, transfer, or encumber investor capital.

See Plate 01: Who holds what

Plate 07Questions

Common questions, answered plainly.

Straight answers drawn from the plates above.

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

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

Who holds my money in a separately managed account?

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

What is an actively managed certificate (AMC)?

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

How do the fees work?

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

What are the indicative minimum investments?

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

Who is eligible to invest?

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

Is Qlumina regulated, and how can I check?

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

How do I get started?

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

Managers: read the due diligence FAQ

Plate 08Access

After you request access.

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

  1. 01Request access

    Start Investor Onboarding, or talk to the desk.

  2. 02Eligibility

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

  3. 03KYC / AML

    Compliance review and formal institutional clearance.

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

    Execute the IMA and LPOA granting trading execution rights only.

  5. 05Account setup

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

  6. 06Funding & go-live

    Fund the account directly. Qlumina commences algorithmic strategy execution.

  7. 07Supervise

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

General risk warning

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

Regulatory status

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