STF Management, LP (herein referred to as “STF Management”, “Firm,” “Adviser,” “we,” “our,”
“us”) is an investment adviser registered with the U.S. Securities and Exchange Commission
(“SEC”). Our registration as an investment adviser does not imply any level of skill or training.
The oral and written communications we provide you, including this Brochure, is information you
can use to evaluate us and other advisers, which are factors in your decision to hire us or to continue
to maintain a mutually beneficial relationship. This Brochure provides information about our
qualifications and business practices. When we use the words “you”, “your” and “client” we are
referring to you as our client or our prospective client. We use the term “supervised person” when
referring to our officers, employees, and all individuals providing investment advice on behalf of
STF Management.
Ownership
STF Management was formed as a limited liability company in August 2014. A Certificate of
Conversion was filed with the State of Texas Secretary of State in February 2022 to convert its
form of organization from a Texas limited liability company to a Texas limited partnership. STF
GP, LLC is the general partner of STF Management, and Seventh Floor Inc. and TREN
Management, Inc. are the limited partners of STF Management.
Services Offered
STF Management offers the following advisory services:
• Exchange Traded Fund management
• Market timing services
• Selection of other advisers
• Educational Seminars and Workshops
Exchange Traded Fund Management
STF Management has entered into an agreement with Listed Funds Trust to provide
investment management services to actively managed exchange traded funds (each an “ETF” or
“Fund” and collectively “ETFs” or “Funds”) and provide the Funds with investment research, and
advice, and to continuously furnish an investment program for the Funds, consistent with the
respective investment objectives and policies of each Fund and subject to the supervision of its
trustees. Each of the Funds is a registered investment company under the Investment Company
Act of 1940. Each Fund has different investment objectives, policies and restrictions that are set
forth in the Fund’s registration statement. STF Management shall determine, from time to time,
what securities or other assets shall be purchased for the Funds, what securities or other assets shall
be held or sold by the Funds and what portion of the Funds’ assets shall be held un-invested in
cash.
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Tactical Unconstrained Growth & Income ETF
The Tactical Unconstrained Growth & Income ETF will invest in shares of the securities in the
Nasdaq-100 Index in addition to potentially allocating to US Treasury bonds, The Fund will
purchase equities in full replication of the underlying benchmark index when the proprietary
model indicates a signal that the index is anticipated to show strength and divest when market
weakness in that segment is anticipated. In evaluating a segment’s relative strength, the Fund will
measure the performance of that segment’s securities against the performance of all other
securities in the Fund’s investing universe, which will typically encompass all U.S. equity and
fixed income securities, but, depending on market conditions, the Fund may, from time to time,
utilize short-term government bonds and or money market or cash positions in seeking to meet
its investment objective, but at no time will more than 20% of the Fund’s portfolio be invested in
cash. The Fund will rotate assets into, and out of, positions on a periodic basis, and the Fund’s
portfolio may therefore be traded frequently. During certain market conditions, notably those
which the Fund deems to be relatively unattractive for equities (based on certain proprietary
quantitative indicators), the Fund may take positions in fixed-income securities or cash
equivalents as an alternative to equities in an attempt to preserve capital. This may, at times, result
in the Fund holding positions across both equities and fixed-income securities simultaneously.
The Fund may indirectly invest in equity securities of all capitalization ranges and in fixed-
income securities of all credit qualities.
The Fund seeks to generate high current income monthly from a combination of the dividends
received from the Fund’s equity holdings and the premiums earned from trading of call options.
The Fund’s Adviser generally utilizes a proprietary, systematic model to manage the Fund’s
options positions in an objective, rules-based manner, although the Adviser may actively manage
the call options prior to expiration to potentially capture gains and minimize liabilities due to
market movements. Strike selection and position management, includes opening and closing of
positions, is fully data driven and systematic in nature.
The Fund’s options spread strategy typically consists of two components: (i) selling call options
on the Nasdaq-100 Index representing U.S. equity securities on up to 100% of the value of the
equity securities held by the Fund to generate premium from such options, while (ii)
simultaneously reinvesting a portion of such premium to buy call options on the same reference
asset(s).
Short Call Options. A written (sold) call option gives the seller the obligation to sell shares of the
reference asset at a specified price (“strike price”) until a specified date (“expiration date”). The
writer (seller) of the call option receives an amount (premium) for writing (selling) the option. In
the event the reference asset appreciates above the strike price and the holder exercises the call
option, the Fund will have to pay the difference between the value of the reference asset and the
strike price or deliver the reference asset (which loss is offset by the premium initially received),
and in the event the reference asset declines in value, the call option may end up worthless and the
Fund retains the premium. The call options written by the Fund will be collateralized by the Fund’s
equity holdings at the time the Fund sells the options.
Long Call Options. When the Fund purchases a call option, the Fund pays an amount (premium) to
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acquire the right to buy shares of a reference asset at a strike price until the expiration date. In the
event the reference asset appreciates in value above the strike price and the Fund exercises its call
option, the Fund will be entitled to receive the difference between the value of the reference asset
and the strike price (which gain is offset by the premium originally paid by the Fund), and in the
event the reference asset closes below the strike price as of the expiration date, the call option may
end up worthless and the Fund’s loss is limited to the amount of premium it paid.
The options purchased or sold by the Fund will typically have an expiration date approximately
one-month from the time
of purchase or sale. The Fund expects the total value of the call options
and the total value of the call options to each be up to 100% of the Fund’s net assets. The Fund
will use a portion of the premium received from writing call options to purchase call options. Call
options written by the Fund will typically have a strike price that is at, near, or higher than the
current price of the reference asset, and call options purchased by the Fund will typically have a
strike price that is higher (in some cases, significantly higher) than the current price of the reference
asset. In addition, both call options will be traded on a national securities exchange and be settled
in cash.
Tactical Unconstrained Growth ETF
The Tactical Unconstrained Growth ETF will invest in shares of the securities in the
Nasdaq-100 Index in addition to potentially allocations to US Treasury bonds, the Fund will
purchase equities in full replication of the underlying benchmark index when the proprietary model
indicates a signal that the index is anticipated to show strength and divest when market weakness
in that segment is anticipated. In evaluating a segment’s relative strength, the Fund will measure
the performance of that segment’s securities against the performance of all other securities in the
Fund’s investing universe, which will typically encompass all U.S. equity and fixed income
securities, but, depending on market conditions, The Fund may, from time to time, utilize short-
term government bonds and or money market or cash positions in seeking to meet its investment
objective, but at no time will more than 20% of the Fund’s portfolio be invested in cash. The Fund
will rotate assets into, and out of, positions on a periodic basis, and the Fund’s portfolio may
therefore be traded frequently. During certain market conditions, notably those which the Fund
deems to be relatively unattractive for equities (based on certain proprietary quantitative
indicators), the Fund may take positions in fixed-income securities or cash equivalents as an
alternative to equities in an attempt to preserve capital. This may, at times, result in the Fund holding
positions across both equities and fixed-income securities simultaneously. The Fund may indirectly
invest in equity securities of all capitalization ranges and in fixed-income securities of all credit
qualities.
Market Timing Services
STF Management is no longer accepting any new clients for its Self-adjusting Trend
Following Market Timing Services. Clients with active agreements will remain in effect until
terminated by either party.
Thomas Campbell develops technical methodology for trading and investment programs. These
trading systems are proprietary and the first is called the Self-adjusting Trend Following (“STF”).
This market timing strategy follows easily identifiable trends in the market that seek to generate
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gains, with rule sets that seek to take advantage of both up and down trends. Since investments are
based solely on the price action of the NASDAQ 100, our strategy strives to outperform the index
long-term with less downside risk. Our strategy uses the relationships among NASDAQ 100
Moving Averages, rate of change of Moving Average, and the daily closing prices to generate
signals.
The second trading system is called TUG. It provides the opportunity for third parties to take
advantage of both bull and bear markets through the use of strategic long (including leveraged)
and short equity positions in addition to long/short treasury and money market positions. Looking
to capitalize upon the non-correlation between equities and bonds, the program will assess which
asset class provides the best opportunity in light of prevailing market conditions. When the equity
markets become indecisive, TUG seeks to both protect and benefit from the periodic reversals in
equities by allocating into treasury positions and/or money markets. Over the long-term TUG is
designed to maintain a low correlation to equity markets.
Our market timing services are not personal investment advice and are not suitable for all
investor’s needs.
Referrals to Third-Party Money Managers
We may refer clients to an outside, unaffiliated, third-party money manager (“TPMM”) that
are registered or exempt from registration as investment advisors. TPMMs are responsible for
continuously monitoring client accounts and making trades client accounts when necessary. Prior
to referring any clients to third-party advisors, we will make sure that they are properly registered,
or notice filed with the applicable state(s). We do not have any trading authority with respect to
the designated accounts managed by a TPMM nor do we act as a sub- advisor to the designated
accounts managed by a TPMM. Each referral arrangement is performed pursuant to a written
solicitation agreement and complies with applicable securities rules and regulations.
Clients who are referred to a TPMM will receive full disclosure, including services rendered and
fee schedules at the time of the referral by delivery of a copy of the relevant TPMM’s brochure or
equivalent disclosure document and privacy policy, prior to placing the assets with the Manager.
The TPMM may impose a minimum dollar amount for initial client assets for the investment
advisory services. These minimums may be waived at the TPMM’s discretion.
Educational Seminars and Workshops
We assist with the promotion of the STF and TUG (“Tactical Unconstrained Growth”)
methodologies by participating in seminars, trade shows, presentations, and webcasts sponsored
by unaffiliated third-party money managers. We assist in the preparation of communications to
clients and prospective clients of either methodology. Topics may include a focus on the
NASDAQ 100, the positions the strategies can take, environments in which the strategy is going
to struggle, and how the strategy can fail to produce expected results. All educational seminars are
conducted under the approval of the third-party money manager's compliance department, and in
the presence of the sponsoring third-party money manager’s representative. All materials are
approved for use with the public and is owned material of either the third-party money manager
and/or the third- party money manager’s representative. Information about STF Management, or
their associated persons, are not a part of the presentation.
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Assets Under Management
As of February 29, 2024, STF Management’s assets under management for which it has investment
discretion are $227,392,883 and it has no assets under management for which it does not have
investment discretion.
Wrap Programs
STF Management does not sponsor or participate in any wrap fee programs. While we do not
participate in any wrap fee programs, we may refer suitable clients to a third-party advisor that
may offer a wrap fee program.