EFTA00583288.pdf
dataset_9 pdf 320.5 KB • Feb 3, 2026 • 6 pages
303 Capital Partners Questionnaire
for Due Diligence Review
EFTA00583288
303 Capital Partners Questionnaire for Due Diligence Review
To navigate this document please use the tab-key or point mouse to the beginning of the input field. The size of
the field will automatically adjust to the length of your input. Please complete to the best of your ability and
return as soon as possible (some questions may not apply to your strategy).
MANAGER INFORMATION
Manager Entity/Team Name:
Manager Name:
Address:
Telephone:
E-mail:
Name of Primary Contact: Same as above
Title of Primary Contact: Same as above
Telephone of Primary Contact: Same as above
E-mail of Primary Contact: Same as above
PREVIOUS FIRM
Firm Name: Tower Research Capital
Position: Quantitative Trader
Period of Employment: 2009-2011
Accomplishments: Developed and ran high frequency Spot FX Strategy,
Created Alpha Models for FX, Futures and Equities
P&L Return on capital (Please explain all capital Approximately 100K/Day. Average unleveraged return
usage and leverage assumptions): approximately 10 bps. Leverage varies by product type.
Track record owned? (If no, then provide ways Track record as part of group, covered by non-disclosure
to verify): agreement. Personal references are available (Dave
Dugan received them).
Reason for leaving: Resigned to run own book
STRATEGY
Strategy category: Statistical Arbitrage, Data Driven.
Hedging Techniques: Broad, Portfolio Sharpe maximizing diversification. Low
sector, industry concentration.
Market Exposure: Low percentage exposure per name. Average Beta 20%.
Highly liquid names (Average ADV 175MM, min ADV
30MM)
Asset classes / markets traded: US Equities: NASDAQ and other venues.
Geographical focus: Currently US. Can be extended to European and Asian
equities.
Instruments used by percentage: 200-300 highly liquid Tape A and B securities — under 5%
EFTA00583289
exposure per name.
Describe the strategy in simple terms:
Uses combination of mean reversion and momentum
signals. Mean reversion with respect to set of statistical
indices resembling multiple RSIs.
Systematic/Discretionary Fully systematic, nondiscretionary
Who developed the strategy: Self
Automated/Manual execution: Automated
Avg/min/max holding period: 12 hrs/<lhr/20hrs
Daily/monthly trading volumes: Approximate max book size 500MM with 50% daily
turnover
Have you encountered position limit problems? Max position is based on 3% of traded volume over
signal duration (5 hr average)
EDGE
Specific Edge: Sophisticated and robust statistical analysis for broad
security universe. Multi-horizon forecasting. Horizons
chosen to eliminate adverse selection, maximize
capacity while keeping reasonably high turnover.
Background/evolution of edge: Ideas developed since early 2009 gradually increasing
robustness and variation in time scale while retaining
model parsimony.
Factors/experience allowing manager to access Extensive background in various mathematical statistics
edge: methods, statistical machine learning and econometrics.
Development of successful alpha models for other
product types. Development of optimal portfolio
execution algorithms, market impact analysis from work
on the agency side.
Discuss the persistence of edge: Edge exists over hundreds of securities and in timespan
of at least 10 years irrespectively of time of the day or
other calendar effects. Breadth of trading universe
provides resistance to fluke moves in individual
securities.
Method for monitoring ongoing effectiveness of Consistency of Sharpe ratio and it's confidence intervals;
edge: mean and median returns; number of trades; overall
market volumes; return auto-correlation profile —
appearance of streaks; return empirical PDF skewness
and excess kurtosis.
When is the strategy most/least effective: Most effective during higher market volumes, fewer
number of rapid market regime changes. Least effective
when volumes are very low and there are frequent
market regime changes.
EFTA00583290
RISK
Discuss overall risk management approach: Proactively, main idea is to reduce return adjusted
portfolio risk, while maintaining capacity. Also keeping
low single name and industry/sector exposure.
Reactively, maintain stop losses and analyze model
performance on ongoing basis.
Proactive risk management: Broad, Portfolio Sharpe maximizing diversification
balances risk-return tradeoff. Low sector, industry
concentration further reduces exposure to risk factors.
Low percentage exposure per name reduces sensitivity
to major moves in a given name. Highly liquid names
(Average ADV 175MM, min ADV 30MM) allows to
quickly enter and exit positions.
Reactive risk management: Uses stop losses by name and by portfolio on a given
day. On a multi-day horizon, strategy edge monitoring
identifies systemic situations when model performance
worsens.
Discuss maximum capital risk per trade, per day, Maximum seen drawdown is -4% on a peak-to-trough
per month: basis, lowest daily draw down is -1.65%, lowest monthly
return seen is -3.6%.
Trade level risk management methodology: Stop losses, model predictive ability monitoring
Portfolio level risk management methodology: Portfolio Sharpe maximization, portfolio stop loss
Potential regulatory risks: None presently. If Congress decides to impose a 50bp
transaction fee, that would be an issue.
Liquidity risks: Flash crash type short term liquidity squeeze.
How can risk management methodologies fail?: 1. In the event of large shocks even uncorrelated
securities become concordant so covariance
matrix based risk management will not be
adequate. Stop losses will kick in.
2. Stop losses may fail if there is a line or hardware
failure. Backups should be in place.
CAPITAL USAGE
Discuss actual capital requirements of strategy: Once pipes are tested, real trading can start with as low as 2M
in capital, trading all instruments to maximize Sharpe. Odd lots
can be traded without penalties as long as they are executed on
INET. Over the course of 6-8 months the aim will be to reach
100MM in trading capital use. From that point strategy is
further scalable to about 500MM in trading capital in US. Later
on using Europe and Asia it may be possible to reach 18 in
trading capital use.
Address leverage usage, cross-margining, Initial leverage factor should be kept artificially lower in 3-4
gearing associated with strategy: range as it scales and builds up P&L, leverage may reach 8-10
range. When exposure exceeds 100MM leverage may be scaled
down again.
What is the capacity of the current strategy: 500MM
EFTA00583291
Can additional strategies be added to increase Adapting to European and Asian markets may do that.
capacity:
EXECUTION
Specific prime broker/clearer requirements Commission under S mills is preferred. Rapid ability to borrow
for short sales is a big plus.
Specific trading platform and connectivity Co-location and fast risk checks are preferred. Access to dark
requirements pools and all lit venues will be important for scaling up.
Exchange membership requirements: none
Leverage/margining requirements: Access to leverage in 6-10 range is preferred.
INVESTMENT RESEARCH
Describe your overall R&D Process 1. Data collection, cleaning, structuring for optimal
access
2. Security universe selection
3. Model implementation in R — this takes advantage of
cutting edge R packages.
i. Data preprocessing, identifying data
idiosyncrasies and transformations.
ii. Hypothesizing about temporal relationships
and formulating a model.
iii. Model refinements, stability analysis,
identifying key model metrics
iv. Identifying execution logic for given model.
v. Back tests using rolling training window on
chosen data subset, finding optimal
execution parameters.
vi. Confirming resulting execution logic with it's
parameters on a separate (left out) data set.
4. Model implementation in C++.
i. Developing the equivalent of the required R
numerical methods in C++
ii. Matching execution logic and position
management between R and C++. This serves
as bug proofing for both R and C++
implementation.
iii. Developing tick level simulator in C++
iv. Implementing API agnostic trading interface
"black box". This way simulation and
production strategy internals are the same.
v. Matching C++ and R simulation results. Fixing
discrepancies based on finding aggregated
differences, subdividing that to find lower
level differences and etc until a clear test case
exhibiting difference emerges and fixing it.
What are you R&D goals for the next 6, 12, and 1. Reduce execution costs on lit venues using known
EFTA00583292
24 months: pattern of actual trades and selecting optimal
execution logic for those times.
2. Incorporate dark venues and develop their heat maps
3. Apply model to European and Asian markets, including
model tweaks incorporating different cost structures
and exchange rules.
Describe the flow of an investment idea from Reading research papers in statistics and econometrics — they
inception to trading: highlight some of the market phenomena and methods to
identify them. Discussing things that work with other quants on
a general and mutually beneficial basis. Synthesizing new ideas
and thinking of ways to improve based on those inputs. Testing
resulting ideas in It Also described above under "R&D process"
Describe your back testing of investments: Described above under "R&D process": using sliding window
model generation and testing, cross validation.
Have you published or commissioned any Yes: my early research area was in multivariate complex
research/academic papers? function theory. Lately I focus on combinatorial optimization
methods.
PERFORMANCE
Annual P8d. Realized: 19M (first year projectedt) based on average trading
capital of 50M (due to initial scaling).
Annual realized return on capital: 38%t (unleveraged)
Realized Sharpe ratio: 5.15t
Maximum capital drawdown: 4% t
How can performance be verified:
How do you expect this performance to differ 2013 volumes appear to be improving along with retail
going forward: investor sentiment which is positive for the strategy
'Mote: Realized P&L numbers based on live strategies at Tower are based on a different trade horizon
and therefore not relevant for the current strategy. Presented numbers are based on extensive back
test, while the model itself is proven in live trading — on a different time horizon.
EFTA00583293
Entities
0 total entities mentioned
No entities found in this document
Document Metadata
- Document ID
- 3fd2cb7f-50de-4ace-89ad-24aa0815ed07
- Storage Key
- dataset_9/EFTA00583288.pdf
- Content Hash
- 95dd205ef4bc90cfd83ba22ff37f70fa
- Created
- Feb 3, 2026