Graham Capital Goes Dark on Two Registered Macro Funds With Fewer Than 200 Holders Each
The withdrawal closes one of the few public windows into a major macro manager’s sector-level trading results that an advisor could read without holding private offering documents.
August 12, 2026
Graham Capital Management has moved to end Exchange Act reporting for both of its registered alternative investment funds, filing certifications on August 11 that terminate the registration of Graham Alternative Investment Fund I LLC and Graham Alternative Investment Fund II LLC and suspend their obligation to file periodic reports.
The two Delaware funds, which carry commission file numbers 0-53965 and 0-53967, each reported a holder base well under the 300-record-holder ceiling that makes deregistration available: 178 holders for Fund I and 177 for Fund II. Both certifications cover Core Macro Portfolio units of interests and rely on the same two provisions — one terminating Section 12(g) registration, the other suspending the separate reporting duty that attaches under Section 15(d). Jason Slutsky, chief operating officer and general counsel, signed on behalf of Graham Capital as manager of both funds.
The Disclosure Window Closes Now
The practical effect is immediate. The duty to file periodic reports lapses on submission rather than on the later date when deregistration formally takes hold, which means neither fund is expected to produce another quarterly or annual report.
That window was unusually wide. Graham Capital manages a macro franchise whose trading detail is otherwise visible only to investors holding private offering documents, and the registered feeders published it. The most recent annual report for Fund II’s Core Macro Portfolio disclosed:
- trading contribution and detraction broken out by sector;
- margin utilization and the absence of illiquidity periods;
- advisory, sponsor, and professional fees itemized against returns;
- the target split between the firm’s discretionary program and its systematic K4D program;
- the master funds through which capital was deployed;
- the firm’s first substantive account of its internal use of artificial intelligence.
None of that has a private-market equivalent an advisor can pull on demand.
Vehicles That Had Been Contracting
The holder counts also mark how far these funds had shrunk. Fund II closed 2025 with roughly $30.7 million in members’ capital, down from about $35.5 million a year earlier, as redemptions of roughly $7.1 million outpaced some $2 million of new subscriptions — a pattern that continued into 2026. At that scale, the cost of audited financials, counsel, and periodic reporting is difficult to justify against the assets bearing it.
Deregistration does not wind up a fund. Both entities can continue trading for existing members under their operating agreements, and nothing in the certifications addresses redemption terms, portfolio strategy, or the funds’ futures. What ends is the public record.
Turnover at the Manager
The step also lands during a period of change in Graham Capital’s senior ranks. Slutsky took on the operating chief role earlier this year following the retirement of longtime chief executive Brian Douglas, while Jens Foehrenbach consolidated investment leadership as president and chief investment officer after the departure of co-chief investment officer Pablo Calderini.
