SCM is a Delaware limited partnership that was formed in April 2002 by Matthew S.
Tewksbury. Mr. Tewksbury serves as SCM’s Chief Executive Officer. SCM is registered as an
investment adviser with the SEC under the Investment Advisers Act of 1940 (the “Advisers
Act”); such registration does not imply a certain level of skill or training. SCM is registered as a
commodity pool operator since January 2009 and a commodity trading advisor since June 2003
with the U.S. Commodity Futures Trading Commission (the “CFTC”) and is a member of the
National Futures Association (the “NFA”), a U.S. self-regulatory organization supervised by the
CFTC. SCM currently employs 64 professional and administrative staff in its office located at
201 King of Prussia Road, Suite 400, Radnor, Pennsylvania, 19087.
SCM is the investment, portfolio and administrative manager for four clients: Tewksbury
Investment Fund ("TIF"); Hamilton Fund Ltd. (“HFL”), a Bermuda company that invests all of
its capital into TIF; Tewksbury Futures Fund Ltd. ("TFF"); and Tewksbury Futures Fund, LP
("TFFLP"), a Delaware limited partnership that invests all of its capital into TFF. HFL does not
hold any portfolio investments other than the shares of TIF. TFFLP does not hold any portfolio
investments other than the shares of TFF (TIF and TFF may be referred to individually as a
“Fund” and collectively as the "Funds". HFL and TFFLP may be referred to individually as a
“Feeder Fund” and collectively as the "Feeder Funds". TIF, HFL, TFF and TFFLP may be
referred to collectively as the “Clients”.).
TIF is an open-ended Bermuda company that trades and invests in a wide and substantially
unrestricted variety of financial markets and instruments. TFF is an open-ended Bermuda
company that pursues substantially similar trading strategies to those employed by SCM on
behalf of TIF in global futures and commodities markets as well as in a number of common
stocks and exchange-traded products traded as part of TIF's futures trading strategies (“F-Desk
Strategies”). In managing the trading for the Funds' portfolios, SCM will employ proprietary
investment strategies, based on quantitative analysis as well as fundamental research, taking both
long and short positions,
combined with proprietary risk management and trade execution
methodologies and strategies. In addition, SCM allocates significant assets to external
investment advisers and commodity trading advisors. SCM has committed, on behalf of the
Funds, a substantial portion of the Funds' assets to “outside” investment managers unaffiliated
with TIF, TFF or SCM through its Outside Traders Investment Program (“OTIP”), a department
within SCM that selects outside investment managers.
SCM is the principal adviser and trader for the Funds and has overall responsibility for all of the
Funds' trading activities. SCM delegates investment discretion to a number of internal traders
and in the case of OTIP, to external traders as well. SCM has a sub-advisory and contractual
services agreement with Waterfront International Ltd. (“Waterfront”), a company based in
Toronto, Canada, as further described under Item 8 and Item 10. SCM’s staff includes technical
support personnel and a team of financial analysts to support its investment advisory and trading
activities. SCM is also responsible for certain aspects of the administrative operations for the
Clients, which broadly include: (1) administrative, legal and regulatory compliance; and (2)
development and implementation of accounting systems, procedures and policies. Other than
serving as the investment, portfolio and administrative manager of the Clients (and certain of
their respective subsidiaries), SCM currently does not offer any other financial or advisory
services.
The general partner of SCM is Adams Holdings LLC (“Adams”), a company owned by Matthew
Tewksbury and his family. Mr. Tewksbury is the Managing Member of Adams. SCM's limited
partners are Mr. Tewksbury and Adams. SCM has full discretion in investment decisions made
on behalf of the Funds, including the decision as to which external managers to allocate capital to
as part of OTIP. Investment advice is provided directly to the Funds according to their particular
investment objectives and not individually to the Funds’ shareholders As of December 31, 2023,
SCM manages, on a discretionary basis, U.S. $2,496,405,124 in Client assets. SCM does not
manage any client assets on a non-discretionary basis.