CMT Asset Management LLC is a Delaware limited liability company that became registered with
the SEC as an investment adviser on December 14, 2017. Our principal place of business is 156
N. Jefferson Street, Suite 102, Chicago, Illinois 60661.
We were formed in September 2017 as part of a trading and investments complex founded in 1997
by Scott A. Casto and Jan-Dirk Lueders (the “Principals”). We are wholly owned by our managing
member, CMT Digital Holdings LLC, a Delaware limited liability company (“CMT DH”). CMT
DH is, in turn, wholly owned by GTO LLC, a Delaware limited liability company. The principal
owners of GTO LLC are the Principals. In connection with managing assets for our clients, we use
the investment personnel, infrastructure, and support provided by our affiliates (collectively, the
“CMT Group” and together with CMT Asset Management LLC, “CMT”).
CMTAM is an investment management firm that provides advisory services to privately offered
pooled investment vehicles (“Funds”). CMTAM also provides advisory services to high net worth
individuals and institutional investors (together with Funds, “Clients”) through separately
managed accounts (“Accounts”). We generally have broad and flexible investment discretion with
respect to the investment decisions we make for our Clients.
We provide investment management services to each Client based on the particular investment
objectives and strategies of that Client. The investment objectives and strategies of a Fund are
described in the Fund’s organizational and offering documents (collectively, “Offering
Documents”). The investment objectives and strategies of an Account are set forth
in an investment
management or similar agreement (“Account Agreement”) between us and the relevant Client.
Please see Item 8 for additional details.
As a general matter, CMTAM neither tailors its advisory services to the individual needs of
underlying investors in a Fund (“Investors”), nor accepts Investor-imposed investment restrictions.
When deemed appropriate, CMTAM has in the past and may in the future establish one or more
customized investment funds or Accounts, which (i) tailor their investment objectives and/or (ii)
are subject to different terms (including fees and liquidity) than those of the Funds. Such
investment objectives and terms will be individually negotiated, and it should be noted that any
such future separately managed account relationships would generally be expected to be subject
to significant account minimums.
CMTAM does not participate in wrap fee programs.
As of December 31, 2023, our regulatory assets under management were approximately
$397,115,287. This represents the amount of client assets that we manage on a discretionary basis,
calculated in accordance with the method for calculating regulatory assets under management set
forth in the instructions to Part 1A of SEC Form ADV. For a description of the manner in which
we characterize accounts as “discretionary,” see Item 16 below. We do not currently manage any
client assets on a non-discretionary basis. For the avoidance of doubt, we do not include the
proprietary assets of our affiliates in the calculation of our regulatory assets under management
pursuant to previous guidance we received from the SEC’s staff.