Overview
ADVISORY BUSINESS
A. Description of the Advisory Firm
Christmas Corporation (hereinafter “Christmas”) is a Corporation organized in the State of Delaware
and a investment adviser registered with the Securities and Exchange Commission (“SEC”).
The firm was formed in June 2015 and registration was approved by the SEC in January 2016.
Principal owners are Eduardus Christmas, Ivana Arinahapsari, Ivan Indrapermana, CFA, and Erenst
Anip.
B. Types of Advisory Services
Portfolio Management Services
Christmas ongoing portfolio management services include, but are not limited to, the following:
Christmas will request discretionary authority from clients in order to select securities and execute
transactions without permission from the client prior to each transaction.
Christmas seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of Christmas’ economic, investment or other
financial interests. To meet its fiduciary obligations, Christmas attempts to avoid, among other things,
investment or trading practices that systematically advantage or disadvantage certain client portfolios,
and accordingly, Christmas’s policy is to seek fair and equitable
allocation of investment opportunities/
transactions among its clients to avoid favoring one client over another over time. It is Christmas’
policy to allocate investment opportunities and transactions it identifies as being appropriate and
prudent among its clients on a fair and equitable basis over time.
C. Client Tailored Services and Imposed Restrictions
Christmas offers the same suite of services to all of its clients. However, specific client investment
strategies and their implementation may be delivered subject to minimum investment amount that is
determined by Christmas from time to time.
Clients may not impose restrictions in investing in certain securities or types of securities in
accordance with their values or beliefs.
D. Wrap Fee Program
A wrap fee program is an investment program where the investor pays one stated fee that includes
management fees, transaction costs, fund expenses, and other administrative fees. Christmas does
not participate in any wrap fee programs.
•Investment strategy• Equity analysis and selection
•Asset allocation• Regular portfolio monitoring
•Risk tolerance
E. Regulatory Assets Under Management
Christmas has the following assets under management: