Clear Disclosures
Straightforward Terms
This page summarizes important information about Sirius Trading Partners, including advisory services, fees, brokerage arrangements, material risks, and other regulatory disclosures. It is intended as a plain-English overview for prospective and current clients.
Regulatory status
Sirius Trading Partners LLC is a registered investment adviser. Registration does not imply a certain level of skill or training. The information presented on this website is provided for general informational purposes and should not be considered a recommendation or solicitation to buy or sell any security.
Investing involves risk, including the potential loss of principal. No investment strategy, risk management technique, or allocation framework can guarantee profits or eliminate the possibility of loss.
Additional information about Sirius Trading Partners is available in the firm’s Form ADV Part 2A (Firm Brochure) and Form ADV Part 2B (Advisor Biography). These documents are provided to clients during the advisory process and are available upon request.
Advisory services
Sirius Trading Partners provides discretionary investment management for individual client accounts. The firm uses a structured, rules-based investment process that evaluates market behavior through quantitative models and generally implements portfolios through exchange-traded funds across multiple asset classes.
Discretionary Management
Client accounts are managed on a discretionary basis, which means Sirius may place trades and adjust allocations in accordance with the agreed investment program and the authority granted by the client.
Rules-Based Framework
The firm operates within a systematic process designed to support consistency across time and across client accounts. While quantitative models help guide decisions, all strategies remain subject to market volatility, drawdowns, and periods of underperformance.
ETF Implementation
Portfolios are generally implemented using liquid ETFs that may provide exposure to broad equity markets, sectors, commodities, currencies, and related instruments within the strategy framework.
Shared Core Process
Because the firm operates within a structured framework, the same core process can generally be applied across client accounts, subject to account size, client-specific constraints, and custodial mechanics.
Fees and account terms
Sirius Trading Partners generally charges an annual advisory fee of 2.00% of assets under management, billed quarterly in arrears. The firm generally requires a $100,000 minimum relationship size, although exceptions may be made at the firm’s discretion.
Advisory Fee
The standard advisory fee is 2.00% annually, typically calculated and charged at the end of each calendar quarter based on account value as described in the client agreement and Form ADV.
Other Costs
Clients may also incur custodial fees, brokerage-related expenses, and the internal operating expenses of exchange-traded funds. These costs are separate from and in addition to the advisory fee charged by Sirius Trading Partners.
Billing and Review
If authorized by the client, Sirius may deduct advisory fees directly from the client’s brokerage account. Clients should review both custodian statements and any fee information provided by the firm.
Minimums and Termination
The firm generally requires a $100,000 minimum account relationship, though exceptions may be made. Advisory relationships may generally be terminated by either party in accordance with the client advisory agreement.
Brokerage and custody
Client assets are held at an independent qualified custodian. Sirius currently requires client accounts to be maintained at Fidelity in order to support operational consistency, reliable execution, and implementation of the firm’s investment process across accounts.
Clients establish and maintain their brokerage accounts directly with the custodian. Sirius Trading Partners does not take physical custody of client funds or securities.
Clients receive account statements directly from the custodian and are encouraged to review those statements carefully. While Sirius has a fiduciary duty to seek best execution, clients may not always receive the lowest possible commission or transaction cost available through other brokerage firms.
Investment risks
All investing involves risk, and clients should be prepared to experience fluctuations in account value. Risks associated with the firm’s strategies may include market risk, model risk, trading risk, liquidity risk, and ETF-related risks.
General Strategy Risks
- Market risk and economic risk
- Model or strategy risk
- Trading and timing risk
- Liquidity and execution risk
- ETF structure and tracking risk
Leveraged and Inverse ETF Risk
Certain strategies may utilize leveraged or inverse ETFs. These instruments can be more volatile than traditional ETFs and may behave differently than expected over longer holding periods due to compounding effects, rebalancing mechanics, trading costs, and changing market conditions.
Near-Close and Extended-Hours Risk
Because Sirius may place trades near the market close and, in limited cases, during extended-hours sessions, clients should understand that lower liquidity, wider spreads, increased volatility, and unfilled orders may occur.
Volatility Tolerance
Sirius generally believes its advisory services are most appropriate for clients who understand market volatility, understand the risks associated with leveraged instruments when used, and are able to tolerate fluctuations in account value.
Conflicts and firm conduct
Sirius Trading Partners is compensated through advisory fees paid by clients and does not receive commissions from the sale of securities, insurance products, or other financial instruments.
Separate Commercial Work
The firm’s principal may engage in professional activities outside the investment advisory business, including work related to industrial materials and commodities. These activities involve physical goods and commercial markets and are separate from advisory services provided to clients.
Code of Ethics
Sirius has adopted a Code of Ethics designed to support fiduciary conduct, professional standards, compliance with applicable securities laws, personal trading oversight, and the protection of confidential client information.
Personal Trading
The principal may invest in the same securities used in client accounts. Because the firm’s strategies are systematic and model-driven, trades for client accounts and the adviser’s personal account may occur at or near the same time based on the same signals.
Disciplinary History
Sirius Trading Partners LLC and its management personnel have no disciplinary events to disclose that would be material to a client’s evaluation of the firm or its management.
Questions about the details?
Sirius Trading Partners believes clients should understand both the structure of the investment program and the terms of the advisory relationship. Full disclosure documents, including Form ADV Part 2A and Part 2B, are available upon request.