Attached files

file filename
EX-32.2 - EXHIBIT 32.02 - CAMPBELL STRATEGIC ALLOCATION FUND LPbrhc10024276_ex32-02.htm
EX-32.1 - EXHIBIT 32.01 - CAMPBELL STRATEGIC ALLOCATION FUND LPbrhc10024276_ex32-01.htm
EX-31.2 - EXHIBIT 31.02 - CAMPBELL STRATEGIC ALLOCATION FUND LPbrhc10024276_ex31-02.htm
EX-31.1 - EXHIBIT 31.01 - CAMPBELL STRATEGIC ALLOCATION FUND LPbrhc10024276_ex31-01.htm

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

FORM 10-Q

Quarterly Report Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934
For the quarterly period ended March 31, 2021
or

Transition Report Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934
For the transition period from ________ to ________

Commission File number: 000-22260

CAMPBELL STRATEGIC ALLOCATION FUND, L.P.

(Exact name of Registrant as specified in charter)

Delaware
 
52-1823554
  (State or other jurisdiction of incorporation or organization)
 
  (IRS Employer Identification Number)

 
 2850 Quarry Lake Drive
 
 
 Baltimore, Maryland 21209
 
 
 (Address of principal executive offices, including zip code)
 

 
 (410) 413-2600
 
 
 (Registrant’s telephone number, including area code)
 

Securities registered pursuant to Section 12(b) of the Act:

Title of each class
Trading Symbol(s)
Name of each exchange on which registered
Not applicable.
Not applicable.
Not applicable.

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.  Yes ☑ No ☐

Indicate by check mark whether the registrant has submitted electronically and posted on its corporate Web site, if any, every Interactive data File required to be submitted and posted pursuant to Rule 405 of regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).  Yes ☑ No ☐

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company or an emerging growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company” and “emerging growth company” in Rule 12b-2 of the Exchange Act.

 Large accelerated filer ☐
Accelerated filer ☐
Non-accelerated filer ☑
Smaller reporting company ☐
Emerging growth company ☐

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Securities Act. ☐

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act).  Yes ☐ No ☑

The Registrant has no voting stock. As of March 31, 2021, there were 60,760.146 Units of General and Limited Partnership Interest issued and outstanding.



TABLE OF CONTENTS

 
Page
PART I — FINANCIAL INFORMATION
 
       
 
Item 1.
Financial Statements.
 
       
   
1-6
       
    7
       
    8
       
    9
       
    10
       
    11
       
   
12-25
       
 
Item 2.
26-30
       
 
Item 3.
31-34
       
 
Item 4.
35
       
PART II — OTHER INFORMATION
 
       
 
Item 1.
36
       
 
Item 1A.
36
       
 
Item 2.
36
       
 
Item 3.
36
       
 
Item 4.
36
       
 
Item 5.
36
       
 
Item 6.
37-38
       
39

CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
CONDENSED SCHEDULE OF INVESTMENTS
MARCH 31, 2021 (Unaudited)

FIXED INCOME SECURITIES

Maturity
Face Value
 
Description
 
Fair
Value ($)
   
% of Net
Asset Value
 

   
Asset Backed Securities
           
     
United States
           
     
Auto Loans
 
$
6,358,696
     
4.63
%
     
Credit Cards
   
545,399
     
0.40
%
     
Equipment Loans
   
670,809
     
0.49
%
     
Total Asset Backed Securities (cost $7,572,505)
   
7,574,904
     
5.52
%
     
 
               
     
Bank Deposits
               
     
Australia
               
     
Financials (cost $799,895)
   
799,842
     
0.58
%
     
United States
               
     
Financials (cost $875,043)
   
875,195
     
0.64
%
     
Total Bank Deposits (cost $1,674,938)
   
1,675,037
     
1.22
%
     
 
               
     
Commercial Paper
               
     
United Kingdom
               
     
Financials (cost $3,709,265)
   
3,709,151
     
2.70
%
     
United States
               
     
Communications
   
998,850
     
0.73
%
     
Consumer Discretionary
   
4,354,183
     
3.17
%
     
Financials
   
5,576,256
     
4.06
%
     
Industrials
     639,368       0.47
%
     
Materials
   
3,214,098
     
2.34
%
     
Real Estate
   
2,274,585
     
1.66
%
     
Technology
    804,938       0.59 %
     
Utilities
   
11,698,467
     
8.53
%
     
Total United States (cost $29,562,189)
   
29,560,745
     
21.55
%
     
Total Commercial Paper (cost $33,271,454)
 
$
33,269,896
     
24.24
%

CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
CONDENSED SCHEDULE OF INVESTMENTS
MARCH 31, 2021 (Unaudited)

FIXED INCOME SECURITIES

Maturity
Face Value
 
Description
 
Fair
Value ($)
   
% of Net
Asset Value
 

   
Corporate Bonds
           
     
Australia
           
     
Financials (cost $1,910,000)
 
$
1,919,361
     
1.40
%
     
Canada
               
     
Energy
   
240,711
     
0.18%
 
     
Financials
   
2,448,345
     
1.78
%
     
Total Canada (cost $2,683,790)
   
2,689,056
     
1.96
%
     
Germany
               
     
Consumer Discretionary (cost $2,144,796)
   
2,159,284
     
1.57
%
     
Japan
               
     
Financials (cost $401,767)
   
401,676
     
0.29
%
     
Switzerland
               
     
Financials (cost $1,819,804)
   
1,830,890
     
1.33
%
     
United Kingdom
               
     
Financials (cost $1,880,000)
   
1,881,258
     
1.37
%
     
United States
               
     
Communications
   
545,522
     
0.40
%
     
Consumer Discretionary
   
5,108,442
     
3.72
%
     
Consumer Staples
   
2,282,484
     
1.66
%
     
Energy
   
2,521,013
     
1.84
%
     
Financials
   
5,891,749
     
4.29
%
     
Health Care
   
1,178,293
     
0.86
%
     
Industrials
   
2,677,694
     
1.95
%
     
Technology
   
649,266
     
0.47
%
     
Utilities
   
1,173,138
     
0.85
%
     
Total United States (cost $21,951,209)
   
22,027,601
     
16.04
%
     
Total Corporate Bonds (cost $32,791,366)
   
32,909,126
     
23.96
%
     
 
               
     
Government and Agency Obligations
               
     
United States
               
     
U.S. Treasury Bills
               
$
2,135,000
 
U.S. Treasury Bills Due 04/15/2021 (1)
   
2,134,987
     
1.56
%
$
8,175,000
 
U.S. Treasury Bills Due 05/13/2021 (1)
   
8,174,787
     
5.96
%
$
10,000,000
 
U.S. Treasury Bills Due 06/10/2021 (1)
   
9,999,680
     
7.29
%
     
Total Government and Agency Obligations (cost $20,309,045)
    20,309,454       14.81 %
     
Total Fixed Income Securities (cost $95,619,307) (2)
  $ 95,738,417       69.75 %



(1)
Pledged as collateral for the trading of future positions.
(2)
Included in fixed income securities are U.S. Treasury Bills with a fair value of $20,309,454 deposited with the futures brokers.

CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
CONDENSED SCHEDULE OF INVESTMENTS
MARCH 31, 2021 (Unaudited)
 
SHORT TERM INVESTMENTS

Description
 
Fair
Value ($)
   
% of Net
Asset Value
 
Money Market Funds
           
United States
           
Money Market Funds (cost $2,223,437)
 
$
2,223,437
     
1.62
%
Total Short Term Investments (cost $2,223,437)
 
$
2,223,437
     
1.62
%

LONG FUTURES CONTRACTS

Description
 
Fair
Value ($)
   
% of Net
Asset Value
 
Agriculture
 
$
720,966
     
0.52
%
Energy
   
(171,636
)
   
(0.13
)%
Metals
   
(747,318
)
   
(0.54
)%
Stock indices
   
1,236,007
     
0.90
%
Short-term interest rates
   
(276,473
)
   
(0.20
)%
Long-term interest rates
   
(325,780
)
   
(0.24
)%
Net unrealized gain (loss) on long futures contracts
   
435,766
     
0.31
%

SHORT FUTURES CONTRACTS

Description
 
Fair
Value ($)
   
% of Net
Asset Value
 
Agriculture
   
212,651
     
0.15
%
Energy
   
(40,694
)
   
(0.03
)%
Metals
   
617,151
     
0.45
%
Stock indices
   
(54,110
)
   
(0.04
)%
Short-term interest rates
   
(53,700
)
   
(0.04
)%
Long-term interest rates
   
(66,937
)
   
(0.05
)%
Net unrealized gain (loss) on short futures contracts
   
614,361
     
0.44
%
Net unrealized gain (loss) on open futures contracts
 
$
1,050,127
     
0.75
%

FORWARD CURRENCY CONTRACTS

Description
 
Fair
Value ($)
   
% of Net
Asset Value
 
Various long forward currency contracts
 
$
(2,694,204
)
   
(1.96
)%
Various short forward currency contracts
   
8,254,242
     
6.02
%
Net unrealized gain (loss) on open forward currency contracts
 
$
5,560,038
     
4.06
%

CREDIT DEFAULT INDEX SWAPS

Description
 
Fair
Value ($)
   
% of Net
Asset Value
 
Centrally cleared credit default index swaps - Sell protection (net cost $1,411,638) (3)
 
$
1,486,107
     
1.08
%

INTEREST RATE SWAPS

Description
 
Fair
Value ($)
   
% of Net
Asset Value
 
Centrally cleared interest rate swaps - Receive fixed (net cost $57,622) (4)
 
$
35,374
     
0.03
%
 


(3)
Includes $1,408,245 of cumulative appreciation/(depreciation) of swaps contracts that is considered variation margin receivable. Variation margin amount is included within cash at swaps broker in the statement of financial condition.
(4)
Excludes $14,510 of cumulative appreciation/(depreciation) of swaps contracts that is considered variation margin receivable. Variation margin amount is  included within cash at swaps broker in the statement of financial condition.

CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
CONDENSED SCHEDULE OF INVESTMENTS
DECEMBER 31, 2020 (Unaudited)

FIXED INCOME SECURITIES

Maturity
Face Value
 
Description
 
Fair
Value ($)
   
% of Net
Asset Value
 

   
Asset Backed Securities
           
     
United States
           
     
Auto Loans
 
$
5,362,418
     
3.97
%
     
Credit Cards
   
548,406
     
0.41
%
     
Equipment Loans
   
610,982
     
0.45
%
     
Total Asset Backed Securities (cost $6,496,521)
   
6,521,806
     
4.83
%
     
 
               
     
Bank Deposits
               
     
United States
               
     
Financials
   
874,999
     
0.65
%
     
Total Bank Deposits (cost $875,109)
   
874,999
     
0.65
%
     
 
               
     
Commercial Paper
               
     
Switzerland
               
     
Financials (cost $1,063,200)
   
1,064,733
     
0.79
%
     
United Kingdom
               
     
Financials (cost $729,469)
   
729,374
     
0.55
%
     
United States
               
     
Consumer Discretionary
   
2,394,214
     
1.78
%
     
Consumer Staples
   
1,464,908
     
1.08
%
     
Energy
   
1,364,790
     
1.01
%
     
Financials
   
8,276,221
     
6.12
%
     
Industrials
   
2,434,867
     
1.80
%
     
Utilities
   
9,903,470
     
7.33
%
     
Total United States (cost $25,835,969)
   
25,838,470
     
19.12
%
     
Total Commercial Paper (cost $27,628,638)
  $
27,632,577
     
20.45
%

CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
CONDENSED SCHEDULE OF INVESTMENTS
DECEMBER 31, 2020 (Unaudited)

FIXED INCOME SECURITIES

Maturity
Face Value
 
Description
 
Fair
Value ($)
   
% of Net
Asset Value
 

   
Corporate Bonds
           
     
Australia
           
     
Financials (cost $1,910,000)
  $
1,918,395
     
1.42
%
     
Canada
               
     
Financials (cost $3,752,648)
   
3,759,657
     
2.78
%
     
Germany
               
     
Consumer Discretionary (cost $2,144,696)
   
2,158,878
     
1.60
%
     
Switzerland
               
     
Financials (cost $1,304,759)
   
1,322,027
     
0.98
%
     
United Kingdom
               
     
Financials (cost $1,880,000)
   
1,883,519
     
1.38
%
     
United States
               
     
Communications
   
545,680
     
0.40
%
     
Consumer Discretionary
   
6,017,125
     
4.46
%
     
Consumer Staples
   
909,534
     
0.67
%
     
Energy
   
2,551,362
     
1.89
%
     
Financials
   
10,134,257
     
7.50
%
     
Industrials
   
2,475,189
     
1.83
%
     
Technology
   
3,041,520
     
2.25
%
     
Total United States (cost $25,556,403)
   
25,674,667
     
19.00
%
     
Total Corporate Bonds (cost $36,548,506)
   
36,717,143
     
27.16
%
                       
     
Government and Agency Obligations
               
     
United States
               
     
U.S. Treasury Bills
               
$
2,135,000
 
U.S. Treasury Bills Due 01/14/2021 (1)
   
2,134,972
     
1.58
%
$
7,675,000
 
U.S. Treasury Bills Due 02/11/2021 (1)
   
7,674,517
     
5.68
%
$
12,085,000
 
U.S. Treasury Bills Due 03/11/2021 (1)
   
12,083,332
     
8.94
%
     
Total Government and Agency Obligations (cost $21,892,544)
   
21,892,821
     
16.20
%
     
Total Fixed Income Securities (cost $93,441,318) (2)
  $
93,639,346        69.29 %



(1)
Pledged as collateral for the trading of future positions.
(2)
Included in fixed income securities are U.S. Treasury Bills with a fair value of $21,892,821 deposited with the futures brokers.
 
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
CONDENSED SCHEDULE OF INVESTMENTS
DECEMBER 31, 2020 (Unaudited)

SHORT TERM INVESTMENTS

 
Description
 
Fair
Value ($)
   
% of Net
Asset Value
 
Money Market Funds
           
United States
           
Money Market Funds (cost $8,053,123)
 
$
8,053,123
     
5.96
%
Total Short Term Investments (cost $8,053,123)
 
$
8,053,123
     
5.96
%

LONG FUTURES CONTRACTS

Description
 
Fair
Value ($)
   
% of Net
Asset Value
 
Agriculture
 
$
1,420,040
     
1.05
%
Energy
   
233,562
     
0.17
%
Metals
   
2,030,713
     
1.50
%
Stock indices
   
946,270
     
0.70
%
Short-term interest rates
   
163,439
     
0.12
%
Long-term interest rates
   
971,543
     
0.72
%
Net unrealized gain (loss) on long futures contracts
   
5,765,567
     
4.26
%

SHORT FUTURES CONTRACTS

Description
 
Fair
Value ($)
   
% of Net
Asset Value
 
Agriculture
   
(132,206
)
   
(0.10
)%
Energy
   
53,644
     
0.04
%
Metals
   
(860,760
)
   
(0.64
)%
Stock indices
   
9,072
     
0.01
%
Short-term interest rates
   
33,161
     
0.02
%
Long-term interest rates
   
(107,424
)
   
(0.08
)%
Net unrealized gain (loss) on short futures contracts
   
(1,004,513
)
   
(0.75
)%
Net unrealized gain (loss) on open futures contracts
 
$
4,761,054
     
3.51
%

FORWARD CURRENCY CONTRACTS

Description
 
Fair
Value ($)
   
% of Net
Asset Value
 
Various long forward currency contracts
 
$
4,948,421
     
3.66
%
Various short forward currency contracts
   
(3,823,010
)
   
(2.83
)%
Net unrealized gain (loss) on open forward currency contracts
 
$
1,125,411
     
0.83
%

CREDIT DEFAULT INDEX SWAPS

Description
 
Fair
Value ($)
   
% of Net
Asset Value
 
Centrally cleared credit default index swaps - Sell protection (net cost $817,091) (3)
 
$
1,265,353
     
0.94
%

INTEREST RATE SWAPS

Description
 
Fair
Value ($)
   
% of Net
Asset Value
 
Centrally cleared interest rate swaps - Receive fixed (net cost $111,176) (4)
 
$
392,904
     
0.29
%
 


(3)
Includes $1,261,433 of cumulative appreciation/(depreciation) of swaps contracts that is considered variation margin receivable. Variation margin amount is included within cash at swaps broker in the statement of financial condition.
(4)
Includes $465,134 of cumulative appreciation/(depreciation) of swaps contracts that is considered variation margin receivable. Variation margin amount is included within cash at swaps broker in the statement of financial condition.

CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
STATEMENTS OF FINANCIAL CONDITION
MARCH 31, 2021 AND DECEMBER 31, 2020 (Unaudited)
 
   
March 31, 2021
   
December 31, 2020
 
ASSETS
           
Equity in futures brokers trading accounts
           
Cash
 
$
13,893,621
   
$
7,921,729
 
Fixed income securities (cost $20,309,044 and $21,892,544, respectively)
   
20,309,454
     
21,892,821
 
Net unrealized gain (loss) on open futures contracts
   
1,050,127
     
4,761,054
 
Total equity in futures brokers trading accounts
   
35,253,202
     
34,575,604
 
                 
Cash and cash equivalents
   
2,799,082
     
530,925
 
Cash at interbank market maker
   
6,080,662
     
6,016,235
 
Restricted cash at interbank market makers
   
7,587,664
     
9,501,426
 
Short term investments (cost $2,223,437 and $8,053,123, respectively)
   
2,223,437
     
8,053,123
 
Cash at swaps broker
   
4,152,847
     
3,252,089
 
Restricted cash at swaps broker
   
593,406
     
4,035,982
 
Fixed income securities (cost $75,310,263 and $71,548,774, respectively)
   
75,428,963
     
71,746,525
 
Credit default index swaps
   
77,862
     
3,920
 
Interest rate swaps
   
49,884
     
0
 
Due from swaps broker
   
22,012
     
22,431
 
Net unrealized gain on open forward currency contracts
   
5,560,038
     
1,125,411
 
Interest receivable
   
108,628
     
109,689
 
Total assets
 
$
139,937,687
   
$
138,973,360
 
                 
LIABILITIES
               
Accounts payable
 
$
165,921
   
$
143,714
 
Brokerage fee payable
   
814,862
     
808,965
 
Interest rate swaps
   
0
     
72,230
 
Accrued commissions and other trading fees on open contracts
   
28,540
     
32,264
 
Offering costs payable
   
52,607
     
45,477
 
Redemptions payable
   
1,651,068
     
2,725,737
 
Total liabilities
   
2,712,998
     
3,828,387
 
PARTNERS’ CAPITAL (Net Asset Value)
               
General Partner - 0.000 and 0.000 redeemable units outstanding at March 31, 2021 and December 31, 2020
   
0
     
0
 
Limited Partners - 60,760.146 and 63,149.651 redeemable units outstanding at March 31, 2021 and December 31, 2020
   
137,224,689
     
135,144,973
 
Total partners’ capital (Net Asset Value)
   
137,224,689
     
135,144,973
 
Total liabilities and partners’ capital (Net Asset Value)
 
$
139,937,687
   
$
138,973,360
 
 
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
STATEMENTS OF OPERATIONS
FOR THE THREE MONTHS ENDED MARCH 31, 2021 AND 2020 (Unaudited)
 
   
Three Months Ended March 31,
 
   
2021
    2020  
TRADING GAINS (LOSSES)
 
   

 
Futures trading gains (losses)
           
Realized
 
$
8,939,450
   
$
(8,732,159
)
Change in unrealized
   
(3,710,927
)
   
7,005,019
 
Brokerage commissions
   
(280,266
)
   
(306,106
)
Net gain (loss) from futures trading
   
4,948,257
     
(2,033,246
)
                 
Forward currency trading gains (losses)
               
Realized
   
2,878,870
     
2,723,787
 
Change in unrealized
   
4,434,627
     
10,427,590
 
Brokerage commissions
   
(28,342
)
   
(25,841
)
Net gain (loss) from forward currency trading
   
7,285,155
     
13,125,536
 
                 
Swap trading gains (losses)
               
Realized
   
(1,775,371
)
   
0
 
Change in unrealized
   
(677,769
)
   
0
 
Net gain (loss) from swap trading
   
(2,453,140
)
   
0
 
Total net trading gain (loss)
   
9,780,272
     
11,092,290
 
                 
NET INVESTMENT INCOME (LOSS)
               
Investment income
               
Interest income
   
127,968
     
754,381
 
Realized gain (loss) on fixed income securities
   
(3,755
)
   
10,991
 
Change in unrealized gain (loss) on fixed income securities
   
(78,918
)
   
(996,484
)
Total investment income
   
45,295
     
(231,112
)
                 
Expenses
               
Brokerage fee
   
2,351,405
     
3,016,225
 
Operating expenses
   
127,612
     
166,094
 
Total expenses
   
2,479,017
     
3,182,319
 
Net investment income (loss)
   
(2,433,722
)
   
(3,413,431
)
NET INCOME (LOSS)
 
$
7,346,550
   
$
7,678,859
 
                 
NET INCOME (LOSS) PER GENERAL AND LIMITED PARTNER UNIT
               
(based on weighted average number of units outstanding during the period)
 
$
117.97
   
$
103.72
 
                 
INCREASE (DECREASE) IN NET ASSET VALUE PER GENERAL AND LIMITED PARTNER UNIT
 
$
118.40
   
$
99.33
 
                 
WEIGHTED AVERAGE NUMBER OF UNITS OUTSTANDING DURING THE PERIOD
   
62,277.082
     
74,037.033
 

CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
STATEMENTS OF CASH FLOWS
FOR THE THREE MONTHS ENDED MARCH 31, 2021 AND 2020 (Unaudited)
 
   
Three Months Ended March 31,
 
   
2021
   
2020
 
Cash flows from (for) operating activities
           
Net income (loss)
 
$
7,346,550
   
$
7,678,859
 
Adjustments to reconcile net income (loss) to net cash from (for) operating activities
               
Net change in unrealized on futures, forwards, swaps and investments
   
32,987
     
(16,436,125
)
(Increase) decrease in interest receivable
   
1,061
     
62,221
 
(Increase) decrease in due from swaps broker
   
419
     
0
 
Increase (decrease) in accounts payable and accrued expenses
   
24,380
     
(29,192
)
Payments for swap contracts
   
(873,825
)
   
0
 
Purchases of investments
   
(389,773,120
)
   
(415,593,097
)
Sales/maturities of investments
   
393,424,817
     
435,547,966
 
Net cash from (for) operating activities
   
10,183,269
     
11,230,632
 
                 
Cash flows from (for) financing activities
               
Redemption of units
   
(6,184,737
)
   
(5,158,505
)
Offering costs paid
   
(149,636
)
   
(214,587
)
Net cash from (for) financing activities
   
(6,334,373
)
   
(5,373,092
)
                 
Net increase (decrease) in cash, cash equivalents and restricted cash
   
3,848,896
     
5,857,540
 
                 
Cash, cash equivalents and restricted cash at beginning of period
   
31,258,386
     
24,870,425
 

               
Cash, cash equivalents and restricted cash at end of period
 
$
35,107,282
   
$
30,727,965
 

The following table provides a reconciliation of cash, cash equivalents and restricted cash reported within the Statements of Financial Condition that sum to the total of the same such amounts shown in the Statements of Cash Flows.

   
March 31, 2021
   
December 31, 2020
 
Cash, cash equivalents and restricted cash at end of period consists of:
               
Equity in futures brokers trading accounts:
               
Cash
 
$
13,893,621
   
$
7,921,729
 
Cash and cash equivalents
   
2,799,082
     
530,925
 
Cash at interbank market maker
   
6,080,662
     
6,016,235
 
Restricted cash at interbank market makers
   
7,587,664
     
9,501,426
 
Cash at swaps broker
   
4,152,847
     
3,252,089
 
Restricted cash at swaps broker
   
593,406
     
4,035,982
 
Total cash, cash equivalents and restricted cash at end of period
 
$
35,107,282
   
$
31,258,386
 

CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
STATEMENTS OF CHANGES IN PARTNERS’ CAPITAL (NET ASSET VALUE)
FOR THE THREE MONTHS ENDED MARCH 31, 2021 AND 2020 (Unaudited)
 
   
Partners’ Capital
 
   
General Partner
   
Limited Partners
   
Total
 
   
Units
   
Amount
   
Units
   
Amount
   
Units
   
Amount
 
Three Months Ended March 31, 2021
                                   
                                     
Balances at December 31, 2020
   
0.000
   
$
0
     
63,149.651
   
$
135,144,973
     
63,149.651
   
$
135,144,973
 
Net income (loss) for the three months ended March 31, 2021
           
0
             
7,346,550
             
7,346,550
 
Redemptions
   
0.000
     
0
     
(2,389.505
)
   
(5,110,068
)
   
(2,389.505
)
   
(5,110,068
)
Offering costs
           
0
             
(156,766
)
           
(156,766
)
Balances at March 31, 2021
   
0.000
   
$
0
     
60,760.146
   
$
137,224,689
     
60,760.146
   
$
137,224,689
 
                                                 
Three Months Ended March 31, 2020
                                               
                                                 
Balances at December 31, 2019
   
0.000
   
$
0
     
74,725.829
   
$
163,853,523
     
74,725.829
   
$
163,853,523
 
Net income (loss) for the three months ended March 31, 2020
           
0
             
7,678,859
           
$
7,678,859
 
Redemptions
   
0.000
     
0
     
(2,063.891
)
   
(4,780,012
)
   
(2,063.891
)
   
(4,780,012
)
Offering costs
           
0
             
(206,947
)
           
(206,947
)
Balances at March 31, 2020
   
0.000
   
$
0
     
72,661.938
   
$
166,545,423
     
72,661.938
   
$
166,545,423
 

Net Asset Value per General and Limited Partner Unit

March 31, 2021
   
December 31, 2020
   
March 31, 2020
   
December 31, 2019
 
$
2,258.47
   
$
2,140.07
   
$
2,292.06
   
$
2,192.73
 

CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
FINANCIAL HIGHLIGHTS
FOR THE THREE MONTHS ENDED MARCH 31, 2021 AND 2020 (Unaudited)

The following information presents per unit operating performance data and other supplemental financial data for the three months ended March 31, 2021 and 2020. This information has been derived from information presented in the financial statements.
 
   
Three Months Ended March 31,
 
   
2021
   
2020
 
Per Unit Performance
           
(for a unit outstanding throughout the entire period)
           
Net asset value per unit at beginning of period
 
$
2,140.07
   
$
2,192.73
 
                 
Income (loss) from operations:
               
Total net trading gains (losses) (1)
   
160.00
     
148.23
 
Net investment income (loss) (1)
   
(39.08
)
   
(46.10
)
Total net income (loss) from operations
   
120.92
     
102.13
 
Offering costs (1)
   
(2.52
)
   
(2.80
)
Net asset value per unit at end of period
 
$
2,258.47
   
$
2,292.06
 
Total Return (4)
   
5.53
%
   
4.53
%
                 
Supplemental Data
               
Ratios to average net asset value:
               
Expenses prior to performance fee (3)
   
7.44
%
   
7.55
%
Performance fee (4)
   
0.00
%
   
0.00
%
Total expenses
   
7.44
%
   
7.55
%
Net investment income (loss) (2) (3)
   
(7.32
)%
   
(8.10
)%
 
Total returns are calculated based on the change in value of a unit during the period. An individual partner’s total returns and ratios may vary from the above total returns and ratios based on the timing of transfers and redemptions.
 


(1)
Net investment income (loss) per unit and offering costs per unit are calculated by dividing the net investment income (loss) and offering costs by the average number of units outstanding during the period. Total net trading gains (losses) is a balancing amount necessary to reconcile the change in net asset value per unit with the other per unit information.
(2)
Excludes performance fee.
(3)
Annualized
(4)
Not Annualized

11

Table of Contents
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
NOTES TO FINANCIAL STATEMENTS
MARCH 31, 2021 (Unaudited)
Note 1.  ORGANIZATION AND SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

A.  General Description of the Fund

Campbell Strategic Allocation Fund, L.P. (the “Fund”) is a Delaware limited partnership which operates as a commodity investment pool. The Fund engages in the speculative trading of futures contracts, forward currency contracts, and centrally cleared swap contracts.

Effective January 6, 2012, Units in the Fund were no longer offered for sale. For existing investors in the Fund, business has been and will be conducted as usual. There was no change in trading, operations, or monthly statements, etc., and redemptions will continue to be offered on a monthly basis.

B.  Regulation

As a registrant with the Securities and Exchange Commission (the “SEC”), the Fund is subject to the regulatory requirements under the Securities Exchange Act of 1934. Prior to January 6, 2012, the Fund was also subject to the regulatory requirements under the Securities Act of 1933. As a commodity investment pool, the Fund is subject to the regulations of the Commodity Futures Trading Commission, an agency of the United States (U.S.) government which regulates most aspects of the commodity futures industry; rules of the National Futures Association, an industry self-regulatory organization; and the requirements of the various commodity exchanges where the Fund executes transactions. Additionally, the Fund is subject to the requirements of the futures commission merchants (“futures brokers”), interbank market makers, and centrally cleared swaps broker through which the Fund trades.

C.  Method of Reporting

The Fund’s financial statements are presented in accordance with accounting principles generally accepted in the United States of America, which may require the use of certain estimates made by the Fund’s management. Actual results may differ from these estimates.

The Fund meets the definition of an investment company according to the provisions of Financial Accounting Standards Board (“FASB”) Accounting Standards Codification (“ASC”) 946-10, Financial Services – Investment Companies.

Investment transactions, including futures, forwards and fixed income securities are accounted for on the trade date. Gains or losses are realized when contracts are liquidated. Realized gains or losses on spot trades associated with forward currency contract trading are included in realized gains or losses from forward currency trading. Unrealized gains and losses on open contracts (the difference between contract trade value and fair value) are reported in the Statements of Financial Condition as a net gain or loss, as there exists a right of offset of unrealized gains or losses in accordance with ASC 210-20, Offsetting - Balance Sheet. The fair value of futures (exchange-traded) contracts is based on various futures exchanges, and reflects the settlement price for each contract as of the close on the last business day of the reporting period. The fair value of forward currency (non-exchange traded) contracts was extrapolated on a forward basis from the spot prices quoted as of 3:00 P.M. (E.T.) on the last business day of the reporting period.

The daily exchange of variation margin associated with a Central Counterparty Clearing House derivative instrument is legally characterized as the daily settlement of the derivative instrument itself. Accordingly, the Fund accounts for the daily receipt or payment of variation margin associated with its centrally cleared swaps and futures as a direct reduction to the carrying value of the centrally cleared swaps and futures derivative asset or liability, respectively. The carrying amount of centrally cleared swaps and futures reflected in the Fund’s Statements of Financial Condition is equal to the unsettled fair value of such instruments, which generally represents the change in fair value that occurred on the last day of the reporting period.

12

Table of Contents
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
NOTES TO FINANCIAL STATEMENTS
MARCH 31, 2021 (Unaudited)
Centrally cleared credit default index swaps and interest rate swap transactions are recorded on the trade date. Realized gains or losses are determined using the identified cost method. The fair value of centrally cleared swap contracts is determined by using current market quotations provided by an independent external pricing source. Valuation using an external pricing source involves the use of observable inputs in accordance with the fair value hierarchy. Any change in net unrealized gain or loss from the prior period is reported in Swap trading gains (losses) - Change in unrealized in the Statements of Operations. Period payments received or paid on swap contracts, commissions and fees associated with trading the swap contracts and cash payments received or made due to the underlying obligation in the event of a credit event are recorded as part of “Swap trading gains (losses) – Realized” in the Statements of Operations.

The fixed income investments are marked to market on the last business day of the reporting period using a third party vendor hierarchy of pricing providers who specialize in such markets. The prices furnished by the providers consider the yield or price of bonds of comparable quality, coupon, maturity, and type, as well as prices quoted by dealers who make markets in such securities. Premiums and discounts on fixed income securities are amortized and accreted for financial reporting purposes.

The short term investments represent cash held at the custodian and invested overnight in a money market fund.

For purposes of both financial reporting and calculation of redemption value, Net Asset Value per unit is calculated by dividing Net Asset Value by the number of outstanding units.

D. Fair Value

The Fund follows the provisions of ASC 820, Fair Value Measurements and Disclosures (“ASC 820”). ASC 820 provides guidance for determining fair value and requires increased disclosure regarding the inputs to valuation techniques used to measure fair value. ASC 820 defines fair value as the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date.

ASC 820 establishes a fair value hierarchy which prioritizes the inputs to valuation techniques used to measure fair value into three broad levels. The fair value hierarchy gives the highest priority to quoted prices (unadjusted) in active markets for identical assets or liabilities (Level 1) and the lowest priority to unobservable inputs (Level 3).

Level 1 inputs are quoted prices (unadjusted) in active markets for identical assets or liabilities that the Fund has the ability to access at the measurement date. An active market for the asset or liability is a market in which transactions for the asset or liability occur with sufficient frequency and volume to provide pricing information on an ongoing basis. The value of the Fund’s exchange-traded futures contracts and short term investments fall into this category.

Level 2 inputs are inputs other than quoted prices included in Level 1 that are observable for the asset or liability, either directly or indirectly. This category includes forward currency contracts that the Fund values using models or other valuation methodologies derived from observable market data. For centrally cleared swap contracts, the Fund uses current market quotations provided by an independent external pricing source to determine fair value. This category also includes fixed income investments.

Level 3 inputs are unobservable inputs for an asset or liability (including the Fund’s own assumptions used in determining the fair value of investments). Unobservable inputs shall be used to measure fair value to the extent that observable inputs are not available, thereby allowing for situations in which there is little, if any, market activity for the asset or liability at the measurement date. As of March 31, 2021 and December 31, 2020, and for the periods ended March 31, 2021 and 2020, the Fund did not have any Level 3 assets or liabilities.

13

Table of Contents
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
NOTES TO FINANCIAL STATEMENTS
MARCH 31, 2021 (Unaudited)
The following tables set forth by level within the fair value hierarchy the Fund’s investments accounted for at fair value on a recurring basis as of March 31, 2021 and December 31, 2020.
 
   
Fair Value at March 31, 2021
 
Description
 
Level 1
   
Level 2
   
Level 3
   
Total
 
Investments
                       
Short term investments
 
$
2,223,437
   
$
0
   
$
0
   
$
2,223,437
 
Fixed income securities
   
0
     
95,738,417
     
0
     
95,738,417
 
                                 
Other Financial Instruments
                               
Exchange-traded futures contracts
   
1,050,127
     
0
     
0
     
1,050,127
 
Forward currency contracts
   
0
     
5,560,038
     
0
     
5,560,038
 
Credit default index swap contracts
   
0
     
1,486,107
     
0
     
1,486,107
 
Interest rate swap contracts
   
0
     
35,374
     
0
     
35,374
 
Total
 
$
3,273,564
   
$
102,819,936
   
$
0
   
$
106,093,500
 
 
   
Fair Value at December 31, 2020
 
Description
 
Level 1
   
Level 2
   
Level 3
   
Total
 
Investments
                       
Short term investments
 
$
8,053,123
   
$
0
   
$
0
   
$
8,053,123
 
Fixed income securities
   
0
     
93,639,346
     
0
     
93,639,346
 
                                 
Other Financial Instruments
                               
Exchange-traded futures contracts
   
4,761,054
     
0
     
0
     
4,761,054
 
Forward currency contracts
   
0
     
1,125,411
     
0
     
1,125,411
 
Credit default index swap contracts
   
0
     
1,265,353
     
0
     
1,265,353
 
Interest rate swap contracts
   
0
     
392,904
     
0
     
392,904
 
Total
 
$
12,814,177
   
$
96,423,014
   
$
0
   
$
109,237,191
 

The gross presentation of the fair value of the Fund’s derivatives by instrument type is shown in Note 11. See Condensed Schedules of Investments for additional detail categorization.

E.  Cash and Cash Equivalents

Cash and cash equivalents includes cash and overnight money market investments at financial institutions.

F.  Income Taxes

The Fund prepares calendar year U.S. federal and applicable state tax returns and reports to the partners their allocable shares of the Fund’s income, expenses and trading gains or losses. No provision for income taxes has been made in the accompanying financial statements as each partner is individually responsible for reporting income or loss based on such partner’s respective share of the Fund’s income and expenses as reported for income tax purposes.

Management has continued to evaluate the application of ASC 740, Income Taxes, to the Fund, and has determined that no reserves for uncertain tax positions were required. There are no tax positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will significantly increase or decrease within twelve months. The Fund files federal and state tax returns. The 2017 through 2020 tax years generally remain subject to examination by the U.S. federal and most state tax authorities.

14

Table of Contents
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
NOTES TO FINANCIAL STATEMENTS
MARCH 31, 2021 (Unaudited)
G.  Offering Costs

Campbell & Company, LP (“Campbell & Company”) has incurred all costs in connection with the initial and continuous offering of units of the Fund (“offering costs”). In addition, Campbell & Company continues to compensate wholesalers for services rendered to Limited Partners. The Fund’s liability for offering costs is limited to the maximum of total offering costs incurred by Campbell & Company, not to exceed 2.5% of the aggregate subscriptions accepted during the initial and continuous offerings. As of March 31, 2021 and December 31, 2020, the Fund has the potential remaining reimbursement amount of approximately $34.1 million and $34.2 million, respectively. If the Fund terminates prior to completion of payment of the calculated amounts to Campbell & Company, Campbell & Company will not be entitled to any additional payments, and the Fund will have no further obligation to Campbell & Company.

The Fund is only liable for payment of offering costs on a monthly basis as calculated based on the limitations stated above. At March 31, 2021 and December 31, 2020, the amount of unreimbursed offering costs incurred by Campbell & Company and reflected as a liability in the Statements of Financial Condition for offering costs payable to Campbell & Company is $52,607 and $45,477, respectively. The amount of monthly reimbursement due to Campbell & Company is charged directly to partners’ capital.

H.  Foreign Currency Transactions

The Fund’s functional currency is the U.S. dollar; however, it transacts business in currencies other than the U.S. dollar. Assets and liabilities denominated in currencies other than the U.S. dollar are translated into U.S. dollars at the rates in effect at the date of the Statements of Financial Condition. Income and expense items denominated in currencies other than the U.S. dollar are translated into U.S. dollars at the rates in effect during the period. Gains and losses resulting from the translation to U.S. dollars are reported in income.

I.  Recently Issued Accounting Pronouncements

In April 2020, the FASB issued ASU-2020-04, the FASB issued ASU 2020-04, Reference Rate Reform (Topic 848): Facilitation of the Effects of Reference Rate Reform on Financial Reporting to provide optional guidance for a limited period of time to ease the potential burden in accounting for (or recognizing the effects of) reference rate reform on financial reporting. In July 2017, the head of the United Kingdom Financial Conduct Authority announced the desire to phase out the use of the London Interbank Offered Rate (“LIBOR”) and other Interbank offered rates (IBORs). In November 2020, United States and United Kingdom regulators made announcements planning to cease publication of overnight, one-month, three-month, six-month and one-year LIBOR and IBOR tenors after June 2023. If LIBOR and IBORs prematurely cease to exist, the Fund may need to renegotiate outstanding swaps to replace affected rates with the identified replacement rates. There is currently no definitive information regarding the future discontinuance of LIBORs or IBORs prior to 2023. As such, the potential effect of any such event on our cost of capital and net investment income cannot yet be determined.

15

Table of Contents
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
NOTES TO FINANCIAL STATEMENTS
MARCH 31, 2021 (Unaudited)
Note 2.  GENERAL PARTNER AND COMMODITY TRADING ADVISOR

The general partner of the Fund is Campbell & Company, which conducts and manages the business of the Fund. Campbell & Company is also the commodity trading advisor of the Fund. The Amended Agreement of Limited Partnership provides that Campbell & Company may make withdrawals of its units, provided that such withdrawals do not reduce Campbell & Company’s aggregate percentage interest in the Fund to less than 1% of the net aggregate contributions.

Campbell & Company is required by the Amended Agreement of Limited Partnership to maintain a net worth equal to at least 5% of the capital contributed by all the limited partnerships for which it acts as general partner, including the Fund. The minimum net worth shall in no case be less than $50,000 nor shall net worth in excess of $1,000,000 be required.

The Fund pays a monthly brokerage fee equal to 1/12 of 7% (7% annualized) of month-end net assets to Campbell & Company and approximately $4 per round turn to the futures brokers for execution and clearing costs. From the 7% fee, a portion (4%) is used to compensate selling agents for ongoing services rendered and a portion (3%) is retained by Campbell & Company for trading and management services rendered. The amount paid to the futures brokers, interbank market makers and swaps broker for execution and clearing costs is limited to 1/12 of 1% (1% annualized) of month-end net assets.

Campbell & Company is also paid a quarterly performance fee of 20% of the Fund’s aggregate cumulative appreciation in the Net Asset Value per unit, exclusive of appreciation attributable to interest income. More specifically, the performance fee is paid on the cumulative increase, if any, in the Net Asset Value per Unit over the highest previous cumulative Net Asset Value per Unit (commonly referred to as a High Water Mark) adjusting for investment income. In determining the brokerage and performance fees (the “fees”), adjustments shall be made for capital additions and withdrawals and Net Assets shall not be reduced by the fees being calculated for such current period. The performance fee is not subject to any clawback provisions. The fees are typically paid in the month following the month in which they are earned. The fees are paid from the available cash at the Fund’s bank, futures brokers or cash management accounts.

Note 3.  ADMINISTRATOR AND TRANSFER AGENT

Effective January 1, 2020, NAV Consulting, Inc. became the Administrator of the Fund. The Administrator receives fees at rates agreed upon between the Fund and the Administrator and is entitled to reimbursement of certain actual out-of-pocket expenses incurred while performing its duties. The Administrator’s primary responsibilities are portfolio accounting and fund accounting services. Prior to January 1, 2020, Northern Trust Hedge Fund Services LLC served as the Administrator of the Fund.

NAV Consulting, Inc. serves as the Transfer Agent of the Fund. The Transfer Agent receives fees at rates agreed upon between the Fund and the Transfer Agent and is entitled to reimbursement of certain actual out-of-pocket expenses incurred while performing its duties.

Note 4.  CASH MANAGER AND CUSTODIAN

PNC Capital Advisors, LLC serves as the cash manager under the Investment Advisory Agreement to manage and control the liquid assets of the Fund. PNC Capital Advisors, LLC is registered as an investment adviser with the SEC of the United States under the Investment Advisers Act of 1940.

The Fund opened a custodial account at the Northern Trust Company (the “custodian”) and has granted the cash manager authority to make certain investments on behalf of the Fund provided such investments are consistent with the investment guidelines created by the general partner. All securities purchased by the cash manager on behalf of the Fund will be held in the Fund’s custody account at the custodian. The cash manager will have no beneficial or other interest in the securities and cash in such custody account.

16

Table of Contents
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
NOTES TO FINANCIAL STATEMENTS
MARCH 31, 2021 (Unaudited)
Note 5.  DEPOSITS WITH FUTURES BROKERS

The Fund deposits assets with UBS Securities LLC and Goldman, Sachs & Co. subject to Commodity Futures Trading Commission regulations and various exchange and futures broker requirements. Margin requirements are satisfied by the deposit of U.S. Treasury Bills and cash with such futures brokers. The Fund typically earns interest income on its assets deposited with the futures brokers.

Note 6.  DEPOSITS WITH INTERBANK MARKET MAKERS

The Fund’s counterparties with regard to its forward currency transactions are NatWest Markets Plc (“NatWest”) and UBS AG (“UBS”). The Fund has entered into an International Swap and Derivatives Association, Inc. agreement (“ISDA Agreement”) with NatWest and UBS which governs these transactions. The credit ratings reported by the three major rating agencies for NatWest and UBS were considered investment grade as of March 31, 2021 and December 31, 2020. Margin requirements are satisfied by the deposit of U.S. Treasury Bills and cash with NatWest and UBS. The Fund typically earns interest income on its assets deposited with NatWest and UBS.

Note 7.  DEPOSITS WITH SWAPS BROKER

The Fund deposits cash with Goldman, Sachs & Co. to act as swaps broker for its centrally cleared swap contracts, subject to Commodity Futures Trading Commission regulations and central counterparty and broker requirements. Margin requirements are satisfied by the deposit of cash with such swaps broker. Accordingly, assets used to meet margin and other broker or regulatory requirements are partially restricted. The Fund typically earns interest on its credit balances and pays interest on debit balances with the swaps broker.

The Fund pays commissions to the swaps broker on a transaction basis at rates agreed upon between the Fund and the swaps broker.

Note 8.  OPERATING EXPENSES

Operating expenses of the Fund are limited by the Amended Agreement of Limited Partnership to 0.5% per year of the average month-end Net Asset Value of the Fund. Actual operating expenses were less than 0.5% (annualized) of average month-end Net Asset Value for the three months ended March 31, 2021 and 2020.

Note 9.  SUBSCRIPTIONS, DISTRIBUTIONS AND REDEMPTIONS

Investments in the Fund were made by subscription agreement, subject to acceptance by Campbell & Company.

The Fund is not required to make distributions, but may do so at the sole discretion of Campbell & Company. A limited partner may request and receive redemption of units owned, subject to restrictions in the Amended Agreement of Limited Partnership. Units are transferable, but no market exists for their sale and none is expected to develop. Monthly redemptions are permitted upon ten (10) business days advance written notice to Campbell & Company.

17

Table of Contents
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
NOTES TO FINANCIAL STATEMENTS
MARCH 31, 2021 (Unaudited)
Note 10.  CREDIT DERIVATIVES AND CREDIT-RELATED CONTINGENCY FEATURES

Credit derivatives generally require the seller to make a payment to the buyer in the event the underlying referenced security or index to the contract defaults or another triggering event, as defined in the applicable derivative contract, occurs. The Fund sells credit derivative contracts for speculative investment purposes. The following table summarizes the notional amounts of credit derivative contracts sold by the Fund by their maturity for contracts which are outstanding at March 31, 2021 and December 31, 2020. Notional amounts are disclosed as they represent the maximum potential payout. At March 31, 2021 and December 31, 2020, the carrying value of such credit derivative contracts sold was $1,486,107 and $1,265,353, respectively.

   
March 31, 2021
   
December 31, 2020
 
Credit Default Index Swaps
 
Maturity Date:
June 2026
   
Maturity Date:
December 2025
 
Investment grade
 
$
18,816,698
   
$
19,273,236
 
Non-investment grade
   
14,673,385
     
16,235,572
 
Total
 
$
33,490,083
   
$
35,508,808
 

The Fund does not monitor its exposure to credit derivatives based on the notional amounts because that measure does not take into consideration the probability of a credit default event, the legal right to offset assets and liabilities by a counterparty, or collateral posted. However, the notional value of these credit derivative contracts has been included to provide information about the magnitude of involvement with these types of contracts.

Note 11.  TRADING ACTIVITIES AND RELATED RISKS

The Fund engages in the speculative trading of U.S. and foreign futures contracts, forward currency contracts and centrally cleared swap contracts (collectively, “derivatives”). Specifically, the Fund trades a portfolio focused on futures, forward, credit default index swap and interest rate swap contracts, which are instruments designed to hedge changes in interest rates, currency exchange rates, stock index values, metals, energy, agriculture values, and credit risks. The Fund is exposed to both market risk, the risk arising from changes in the fair value of the contracts, and credit risk, the risk of failure by another party to perform according to the terms of a contract.

In February 2020, the Fund transferred all futures contracts held with UBS Securities LLC to Goldman, Sachs & Co., and all forward currency contracts held with UBS to NatWest. Goldman, Sachs and Co. and NatWest serve as the sole futures broker and interbank market maker, respectively, for the Fund’s ongoing trading. In July 2020, the Fund began trading centrally cleared swap contracts.

Market Risk

For derivatives, risks arise from changes in the fair value of the contracts. Market movements result in frequent changes in the fair value of the Fund’s open positions and, consequently, in its earnings and cash flow. The Fund’s market risk is influenced by a wide variety of factors, including the level and volatility of exchange rates, interest rates, equity price levels, the fair value of financial instruments and contracts, the diversification effects among the Fund’s open positions and the liquidity of the markets in which it trades. Theoretically, the Fund is exposed to a market risk equal to the notional contract value of futures and forward currency contracts purchased and unlimited liability on such contracts sold short. The value of an interest rate swap will change as market interest rates rise and fall in conjunction with whether the contract is to receive or pay a fixed interest rate. As a purchaser of credit default index swaps, the Fund’s risk of loss is limited to any cash payments required under the swap contracts. Written credit default contracts (i.e., sell protection) expose the Fund to a market risk equal to the notional value of such swap contracts and any cash payments required under the swap contracts. See Note 1.C. for an explanation of how the Fund determines its valuation for derivatives as well as the netting of derivatives.

The Fund adopted the provisions of ASC 815, Derivatives and Hedging, (“ASC 815”). ASC 815 provides enhanced disclosures about how and why an entity uses derivative instruments, how derivative instruments are accounted for, and how derivative instruments affect an entity’s financial position, financial performance and cash flows.

18

Table of Contents
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
NOTES TO FINANCIAL STATEMENTS
MARCH 31, 2021 (Unaudited)
The following tables summarize quantitative information required by ASC 815.  The fair value of the Fund’s derivatives by instrument type, as well as the location of those instruments on the Statements of Financial Condition, as of March 31, 2021 and December 31, 2020 is as follows:

Type of Instrument *
 
Statements of Financial Condition Location
 
Asset
Derivatives at
March 31, 2021
Fair Value
   
Liability
Derivatives at
March 31, 2021
Fair Value
   
Net
 
Agriculture Contracts
 
Net unrealized gain (loss) on open futures contracts
 
$
1,580,648
   
$
(647,031
)
 
$
933,617
 
Energy Contracts
 
Net unrealized gain (loss) on open futures contracts
   
60,504
     
(272,834
)
   
(212,330
)
Metal Contracts
 
Net unrealized gain (loss) on open futures contracts
   
2,041,531
     
(2,171,698
)
   
(130,167
)
Stock Indices Contracts
 
Net unrealized gain (loss) on open futures contracts
   
1,403,602
     
(221,705
)
   
1,181,897
 
Short-Term Interest Rate Contracts
 
Net unrealized gain (loss) on open futures contracts
   
22,795
     
(352,968
)
   
(330,173
)
Long-Term Interest Rate Contracts
 
Net unrealized gain (loss) on open futures contracts
   
215,054
     
(607,771
)
   
(392,717
)
Forward Currency Contracts
 
Net unrealized gain (loss) on open forward currency contracts
   
10,702,264
     
(5,142,226
)
   
5,560,038
 
Credit Default Index Swap Contracts**
 
Credit default index swaps
   
1,622,357
     
(136,250
)
   
1,486,107
 
Interest Rate Swap Contracts**
 
Interest rate swaps
   
72,659
     
(37,285
)
   
35,374
 
Total
 
 
 
$
17,721,414
   
$
(9,589,768
)
 
$
8,131,646
 
 
*
Derivatives not designated as hedging instruments under ASC 815
**
Amount of centrally cleared swap contracts is not reconciled with the statements of financial condition due to variation margin amount included within cash at swaps broker in the statements of financial condition.
 
Type of Instrument *
 
Statements of Financial Condition Location
 
Asset
Derivatives at
December 31, 2020
Fair Value
   
Liability
Derivatives at
December 31, 2020
Fair Value
   
Net
 
Agriculture Contracts
 
Net unrealized gain (loss) on open futures contracts
 
$
1,448,359
   
$
(160,525
)
 
$
1,287,834
 
Energy Contracts
 
Net unrealized gain (loss) on open futures contracts
   
476,936
     
(189,730
)
   
287,206
 
Metal Contracts
 
Net unrealized gain (loss) on open futures contracts
   
2,607,512
     
(1,437,559
)
   
1,169,953
 
Stock Indices Contracts
 
Net unrealized gain (loss) on open futures contracts
   
1,286,506
     
(331,164
)
   
955,342
 
Short-Term Interest Rate Contracts
 
Net unrealized gain (loss) on open futures contracts
   
196,631
     
(31
)
   
196,600
 
Long-Term Interest Rate Contracts
 
Net unrealized gain (loss) on open futures contracts
   
1,048,732
     
(184,613
)
   
864,119
 
Forward Currency Contracts
 
Net unrealized gain (loss) on open forward currency contracts
   
5,879,307
     
(4,753,896
)
   
1,125,411
 
Credit Default Index Swap Contracts**
 
Credit default index swaps
   
1,427,593
     
(162,240
)
   
1,265,353
 
Interest Rate Swap Contracts**
 
Interest rate swaps
   
552,793
     
(159,889
)
   
392,904
 
Total
 
 
 
$
14,924,369
   
$
(7,379,647
)
 
$
7,544,722
 
 
*
Derivatives not designated as hedging instruments under ASC 815
**
Amount of centrally cleared swap contracts is not reconciled with the statements of financial condition due to variation margin amount included within cash at swaps broker in the statements of financial condition.

19

Table of Contents
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
NOTES TO FINANCIAL STATEMENTS
MARCH 31, 2021 (Unaudited)
The trading gains and losses of the Fund’s derivatives by instrument type, as well as the location of those gains and losses on the Statements of Operations, for the three months ended March 31, 2021 and 2020 is as follows:

Type of Instrument
 
Trading Gains/(Losses) for
the Three Months Ended
March 31, 2021
   
Trading Gains/(Losses) for
the Three Months Ended
March 31, 2020
 
Agriculture Contracts
 
$
2,568,907
   
$
1,923,105
 
Energy Contracts
   
2,453,676
     
5,226,283
 
Metal Contracts
   
(313,410
)
   
4,486,773
 
Stock Indices Contracts
   
5,312,135
     
(23,567,212
)
Short-Term Interest Rate Contracts
   
(1,336,157
)
   
8,009,183
 
Long-Term Interest Rate Contracts
   
(3,456,628
)
   
2,194,728
 
Forward Currency Contracts
   
7,313,497
     
13,151,377
 
Credit Default Index Swap Contracts
   
3,965
     
0
 
Interest Rate Swap Contracts
   
(2,457,105
)
   
0
 
Total
 
$
10,088,880
   
$
11,424,237
 
 
Line Item in the Statements of Operations
 
Trading Gains/(Losses) for
the Three Months Ended
March 31, 2021
   
Trading Gains/(Losses) for
the Three Months Ended
March 31, 2020
 
Futures trading gains (losses):
           
Realized**
 
$
8,939,450
   
$
(8,732,159
)
Change in unrealized
   
(3,710,927
)
   
7,005,019
 
Forward currency trading gains (losses):
               
Realized**
   
2,878,870
     
2,723,787
 
Change in unrealized
   
4,434,627
     
10,427,590
 
Swap trading gains (losses):
               
Realized
   
(1,775,371
)
   
0
 
Change in unrealized
   
(677,769
)
   
0
 
Total
 
$
10,088,880
   
$
11,424,237
 

**
For the three months ended March 31, 2021 and 2020, the amounts above include gains/(losses) on foreign currency cash balances at the futures brokers of $31,789 and $46,054 respectively, and gains/(losses) on spot trades in connection with forward currency trading at the interbank market makers of $(336,205) and $(884,299), respectively.

For the three months ended March 31, 2021 and 2020, the monthly average of futures contracts bought and sold was approximately 27,700,and 31,100, respectively, the monthly average of notional value of centrally cleared swap contracts was approximately $1,645,300,000, and $0 respectively, and the monthly average of notional value of forward currency contracts was $1,213,300,000, and $2,292,300,000,  respectively.

Open contracts generally mature within three months; as of March 31, 2021, the latest maturity date for open futures contracts is June 2022 and the latest maturity date for open forward currency contracts is June 2021. However, the Fund intends to close all futures and offset all forward currency contracts prior to maturity. The latest termination date for centrally cleared swap contracts is June 2026.

20

Table of Contents
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
NOTES TO FINANCIAL STATEMENTS
MARCH 31, 2021 (Unaudited)
Credit Risk

The Fund trades futures contracts on exchanges that require margin deposits with the futures brokers and centrally cleared swap contracts that require margin deposits with the swaps broker. Additional deposits may be necessary for any loss on contract value. The Commodity Exchange Act requires a futures broker or swaps broker to segregate all customer transactions and assets from such future s broker’s or swaps broker’s proprietary activities. A customer’s cash and other property (for example, U.S. Treasury Bills) deposited with a futures broker or swaps broker are considered commingled with all other customer funds subject to the futures broker’s or swaps broker’s segregation requirements. In the event of a futures broker’s or swaps broker’s insolvency, recovery may be limited to a pro rata share of segregated funds available. It is possible that the recovered amount could be less than total cash and other property deposited.

The Fund trades forward currency contracts in unregulated markets between principals and assumes the risk of loss from counterparty nonperformance. Accordingly, the risks associated with forward currency contracts are generally greater than those associated with exchange traded contracts because of the greater risk of counterparty default. Additionally, the trading of forward currency contracts typically involves delayed cash settlement.

The Fund has a portion of its assets on deposit with PNC Bank. In the event of a financial institution’s insolvency, recovery of the Fund’s assets on deposit may be limited to account insurance or other protection afforded such deposits.

The Fund has entered into ISDA Agreements with UBS AG and NatWest. Under the terms of each ISDA Agreement, upon the designation of an Event of Default, as defined in each ISDA Agreement, the non-defaulting party may set-off any sum or obligation owed by the defaulting party to the non-defaulting party against any sum or obligation owed by the non-defaulting party to the defaulting party. If any sum or obligation is unascertained, the non-defaulting party may in good faith estimate that sum or obligation and set-off in respect to that estimate, accounting to the other party when such sum or obligation is ascertained.

Under the terms of each master netting agreement with UBS Securities LLC and Goldman, Sachs & Co., upon occurrence of a default by the Fund, as defined in respective account documents, UBS Securities LLC and Goldman, Sachs & Co. have the right to close out any or all open contracts held in the Fund’s account; sell any or all of the securities held; and borrow or buy any securities, contracts or other property for the Fund’s account. The Fund would be liable for any deficiency in its account resulting from such transactions.

The amount of required margin and good faith deposits with the futures brokers and interbank market makers usually range from 10% to 30% of Net Asset Value. The fair value of securities held to satisfy such requirements at March 31, 2021 and December 31, 2020 was $20,309,454 and $21,892,821, respectively, which equals approximately 15% and 16% of Net Asset Value, respectively. Included in cash deposits with the futures brokers, swaps broker and interbank market makers at March 31, 2021 and December 31, 2020 was restricted cash for margin requirements of $8,181,070 and $13,537,408, respectively, which equals approximately 6% and 10% of Net Asset Value, respectively. There were no cash deposits held at UBS Securities LLC or UBS AG, a futures broker and interbank market maker, respectively, at March 31, 2021 and December 31, 2020.

21

Table of Contents
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
NOTES TO FINANCIAL STATEMENTS
MARCH 31, 2021 (Unaudited)
Set forth below are tables which disclose both gross information and net information about instruments and transactions eligible for offset in the Statements of Financial Condition and instruments and transactions that are subject to a master netting agreement as well as amounts related to financial collateral (including U.S. Treasury Bills and cash collateral) held at clearing brokers and counterparties. Margin reflected in the collateral tables is limited to the net amount of unrealized loss at each counterparty. Actual margin amounts required at each counterparty are based on the notional amounts or the number of contracts outstanding and may exceed the margin presented in the collateral tables.

Offsetting of Derivative Assets by Counterparty
As of March 31, 2021
Type of Instrument
 
 Counterparty
 
Gross
Amounts of
Recognized
Assets
   
Gross
Amounts
Offset in the
Statements of
Financial Condition
   
Net Amounts of
Unrealized Gain
Presented in the
Statements of
Financial Condition
 
Futures contracts
 
Goldman, Sachs & Co.
 
$
5,324,134
   
$
(4,274,007
)
 
$
1,050,127
 
Forward currency contracts
 
NatWest Markets Plc
   
10,702,264
     
(5,142,226
)
   
5,560,038
 
Centrally cleared swap contracts*
 
Centrally Cleared
   
1,695,016
     
(173,535
)
   
1,521,481
 
Total derivatives
 
 
$
17,721,414
   
$
(9,589,768
)
 
$
8,131,646
 

*
Amount of centrally cleared swap contracts is not reconciled with the statements of financial condition due to variation margin amount included within cash at swaps broker in the statements of financial condition.

Derivative Assets and Collateral Received by Counterparty
As of March 31, 2021
   
Net Amounts of
Unrealized Gain
Presented in the
   
Gross Amounts Not Offset in the
Statements of Financial Condition
       
Counterparty
 
Statements of
Financial Condition
   
Financial
Instruments
   
Cash Collateral
Received
   
Net Amount
 
Goldman, Sachs & Co.
 
$
1,050,127
   
$
0
   
$
0
   
$
1,050,127
 
NatWest Markets Plc
   
5,560,038
     
0
     
0
     
5,560,038
 
Centrally Cleared
   
1,521,481
     
0
     
0
     
1,521,481
 
Total
 
$
8,131,646
   
$
0
   
$
0
   
$
8,131,646
 
 
Offsetting of Derivative Liabilities by Counterparty
As of March 31, 2021
Type of Instrument
 
 Counterparty
 
Gross
Amounts of
Recognized
Liabilities
   
Gross
Amounts
Offset in the
Statements of
Financial Condition
   
Net Amounts of
Unrealized Loss
Presented in the
Statements of
Financial Condition
 
Futures contracts
 
Goldman, Sachs & Co.
 
$
4,274,007
   
$
(4,274,007
)
 
$
0
 
Forward currency contracts
 
NatWest Markets Plc
   
5,142,226
     
(5,142,226
)
   
0
 
Centrally cleared swap contracts
 
Centrally Cleared
   
173,535
     
(173,535
)
   
0
 
Total derivatives
 
 
 
$
9,589,768
   
$
(9,589,768
)
 
$
0
 

22

Table of Contents
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
NOTES TO FINANCIAL STATEMENTS
MARCH 31, 2021 (Unaudited)
Derivative Liabilities and Collateral Pledged by Counterparty
As of March 31, 2021
   
Net Amounts of
Unrealized Loss
Presented in the
   
Gross Amounts Not Offset in the
Statements of Financial Condition
       
Counterparty
 
Statements of
Financial Condition
   
Financial
Instruments
   
Cash Collateral
Pledged
   
Net Amount
 
Goldman, Sachs & Co.
 
$
0
   
$
0
   
$
0
   
$
0
 
NatWest Markets Plc
   
0
     
0
     
0
     
0
 
Centrally Cleared
   
0
     
0
     
0
     
0
 
Total
 
$
0
   
$
0
   
$
0
   
$
0
 
 
Offsetting of Derivative Assets by Counterparty
As of December 31, 2020
Type of Instrument
 
 Counterparty
 
Gross
Amounts of
Recognized
Assets
   
Gross
Amounts
Offset in the
Statements of
Financial Condition
   
Net Amounts of
Unrealized Gain
Presented in the
Statements of
Financial Condition
 
Futures contracts
 
Goldman, Sachs & Co.
 
$
7,064,676
   
$
(2,303,622
)
 
$
4,761,054
 
Forward currency contracts
 
NatWest Markets Plc
   
5,879,307
     
(4,753,896
)
   
1,125,411
 
Centrally cleared swap contracts*
 
Centrally Cleared
   
1,980,386
     
(322,129
)
   
1,658,257
 
Total derivatives
 
 
 
$
14,924,369
   
$
(7,379,647
)
 
$
7,544,722
 

*
Amount of centrally cleared swap contracts is not reconciled with the statements of financial condition due to variation margin amount included within cash at swaps broker in the statements of financial condition.

Derivative Assets and Collateral Received by Counterparty
As of December 31, 2020
   
Net Amounts of
Unrealized Gain
Presented in the
   
Gross Amounts Not Offset in the
Statements of Financial Condition
       
Counterparty
 
Statements of
Financial Condition
   
Financial
Instruments
   
Cash Collateral
Received
   
Net Amount
 
Goldman, Sachs & Co.
 
$
4,761,054
   
$
0
   
$
0
   
$
4,761,054
 
NatWest Markets Plc
   
1,125,411
     
0
     
0
     
1,125,411
 
Centrally Cleared
   
1,658,257
     
0
     
0
     
1,658,257
 
Total
 
$
7,544,722
   
$
0
   
$
0
   
$
7,544,722
 

23

Table of Contents
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
NOTES TO FINANCIAL STATEMENTS
MARCH 31, 2021 (Unaudited)
Offsetting of Derivative Liabilities by Counterparty
As of December 31, 2020
Type of Instrument
 
Counterparty
 
Gross Amounts
of Recognized
Liabilities
   
Gross
Amounts
Offset in the
Statements of
Financial Condition
   
Net Amounts of
Unrealized Loss
Presented in the
Statements of
Financial Condition
 
Futures contracts
 
Goldman, Sachs & Co.
 
$
2,303,622
   
$
(2,303,622
)
 
$
0
 
Forward currency contracts
 
NatWest Markets Plc
   
4,753,896
     
(4,753,896
)
   
0
 
Centrally cleared swap contracts
 
Centrally Cleared
   
322,129
     
(322,129
)
   
0
 
Total derivatives
 
 
 
$
7,379,647
   
$
(7,379,647
)
 
$
0
 

Derivative Liabilities and Collateral Pledged by Counterparty
As of December 31, 2020
   
Net Amounts of
Unrealized Loss
Presented in the
   
Gross Amounts Not Offset in the
Statements of Financial Condition
       
Counterparty
 
Statements of
Financial Condition
   
Financial
Instruments
   
Cash Collateral
Pledged
   
Net Amount
 
Goldman, Sachs & Co.
 
$
0
   
$
0
   
$
0
   
$
0
 
NatWest Markets Plc
   
0
     
0
     
0
     
0
 
Centrally Cleared
   
0
     
0
     
0
     
0
 
Total
 
$
0
   
$
0
   
$
0
   
$
0
 

Campbell & Company has established procedures to actively monitor market risk and minimize credit risk, although there can be no assurance that it will, in fact, succeed in doing so. Campbell & Company’s basic market risk control procedures consist of continuously monitoring open positions, diversification of the portfolio and maintenance of a margin-to-equity ratio that rarely exceeds 30%. Campbell & Company’s attempt to manage the risk of the Fund’s open positions is essentially the same in all market categories traded. Campbell & Company applies risk management policies to its trading which generally limit the total exposure that may be taken per “risk unit” of assets under management. In addition, Campbell & Company follows diversification guidelines (often formulated in terms of the balanced volatility between markets and correlated groups), as well as reducing position sizes dynamically in response to trading losses. Campbell & Company controls the risk of the Fund’s non-trading fixed income instruments by limiting the duration of such instruments and requiring a minimum credit quality of the issuers of those instruments.

Campbell & Company seeks to minimize credit risk primarily by depositing and maintaining the Fund’s assets at financial institutions and brokers which Campbell & Company believes to be credit worthy. The limited partners bear the risk of loss only to the extent of the market value of their respective investments and, in certain specific circumstances, distributions and redemptions received.

24

Table of Contents
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
NOTES TO FINANCIAL STATEMENTS
MARCH 31, 2021 (Unaudited)
Note 12. INDEMNIFICATIONS

In the normal course of business, the Fund enters into contracts and agreements that contain a variety of representations and warranties which provide general indemnifications. The Fund’s maximum exposure under these arrangements is unknown, as this would involve future claims that may be made against the Fund that have not yet occurred. The Fund expects the risk of any future obligation under these indemnifications to be remote.

Note 13. INTERIM FINANCIAL STATEMENTS

The Statements of Financial Condition, including the Condensed Schedules of Investments, as of March 31, 2021 and December 31, 2020, the Statements of Operations and Financial Highlights for the three months ended March 31, 2021 and 2020, and the Statements of Cash Flows and Changes in Partners’ Capital (Net Asset Value) for the three months ended March 31, 2021 and 2020 are unaudited. In the opinion of management, such financial statements reflect all adjustments, which were of a normal and recurring nature, necessary for a fair presentation of financial position as of March 31, 2021 and December 31, 2020, the results of operations and financial highlights for the three months ended March 31, 2021 and 2020, and cash flows and changes in partners’ capital (Net Asset Value) for the three months ended March 31, 2021 and 2020.

Note 14. SUBSEQUENT EVENTS

Management of the Fund has evaluated subsequent events through the date the financial statements were filed. There are no subsequent events to disclose or record.

Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations.

Introduction

The offering of its Units of Limited Partnership Interest commenced on January 12, 1994. The initial offering terminated on April 15, 1994 and the Fund commenced operations on April 18, 1994. The continuing offering period commenced at the termination of the initial offering period and terminated on January 6, 2012.

Critical Accounting Policies

The preparation of financial statements in conformity with accounting principles generally accepted in the United States of America requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosures of contingent assets and liabilities at the date of the financial statements and the reported amounts of income and expense during the reporting period. Management believes that the estimates utilized in preparing the financial statements are reasonable and prudent; however, actual results could differ from those estimates. The Fund’s significant accounting policies are described in detail in Note 1 of the Financial Statements.

The Fund records all investments at fair value in its financial statements, with changes in fair value reported as a component of realized and change in unrealized trading gains (losses) in the Statements of Operations. Generally, fair values are based on market prices; however, in certain circumstances, estimates are involved in determining fair value in the absence of an active market closing price (i.e., forward contracts which are traded in the interbank market).

Capital Resources

Effective January 6, 2012, units in the Fund were no longer offered for sale. For existing investors in the Fund, business has been and will be conducted as usual. There will be no change in trading, operations or monthly statements, etc., and redemptions will continue to be offered on a monthly basis.

The Fund does not intend to raise any capital through borrowing. Due to the nature of the Fund’s business, it will make no capital expenditures and will have no capital assets, which are not operating capital or assets.

The Fund generally maintains 60 to 75% of its net asset value in cash, cash equivalents or other liquid positions in its cash management program over and above that needed to post as collateral for trading. These funds are available to meet redemptions each month. After redemptions are taken into account each month, the trade level of the Fund is adjusted and positions in the instruments the Fund trades are liquidated, if necessary, on a pro-rata basis to meet those increases or decreases in trade levels.

Liquidity

Most United States commodity exchanges limit fluctuations in the prices of futures contracts during a single day by regulations referred to as “daily price fluctuation limits” or “daily limits.” During a single trading day, no trades may be executed at prices beyond the daily limit. Once the price of a futures contract has reached the daily limit for that day, positions in that contract can neither be taken nor liquidated. Futures prices have occasionally moved to the daily limit for several consecutive days with little or no trading. Similar occurrences could prevent the Fund from promptly liquidating unfavorable positions and subject the Fund to substantial losses which could exceed the margin initially committed to such trades. In addition, even if futures prices have not moved the daily limit, the Fund may not be able to execute futures trades at favorable prices, if little trading in such contracts is taking place. Other than these limitations on liquidity, which are inherent in the Fund’s futures trading operations, the Fund’s assets are expected to be highly liquid.

The entire offering proceeds, without deductions, were credited to the Fund’s bank, custodial and/or cash management accounts. The Fund meets margin requirements for its trading activities by depositing cash or U.S. government securities with the futures brokers and the over-the-counter counterparties. This does not reduce the risk of loss from trading futures, forward and swap contracts. The Fund receives all interest earned on its assets. No other person shall receive any interest or other economic benefits from the deposit of Fund assets.

Approximately 10% to 30% of the Fund’s assets normally are committed as required margin for futures contracts and held by the futures brokers, although the amount committed may vary significantly. Such assets are maintained in the form of cash or U.S. Treasury bills in segregated accounts with the futures brokers pursuant to the Commodity Exchange Act and regulations thereunder. Approximately 5% to 15% of the Fund’s assets are deposited with over-the-counter counterparties or centrally cleared in order to initiate and maintain forward or contracts. Such assets are not held in segregation or otherwise regulated under the Commodity Exchange Act, unless such over-the-counter counterparty is registered as a futures commission merchant. These assets are held either in U.S. government securities or short-term time deposits with U.S.-regulated bank affiliates of the over-the-counter counterparties.

The general partner deposits the majority of those assets of the Fund that are not required to be deposited as margin with the futures brokers and over-the-counter counterparties in a custodial account with Northern Trust Company. The assets deposited in the custodial account with Northern Trust Company are segregated. Such custodial account constitutes approximately 60% to 75% of the Fund’s assets and are invested directly by PNC Capital Advisors, LLC (“PNC”). PNC is registered with the SEC as an investment adviser under the Investment Advisers Act of 1940. PNC does not guarantee any interest or profits will accrue on the Fund’s assets in the custodial account. PNC invests the assets according to agreed upon investment guidelines that first preserve capital, second allow for sufficient liquidity, and third provide a yield beyond the risk-free rate. Investments can include, but are not limited to, (i) U.S. government, agency, or municipal securities; (ii) banker acceptances or certificates of deposits; (iii) commercial paper or money market securities; (iv) short-term, investment-grade corporate debt securities; or (v) investment-grade, asset backed securities.

The Fund occasionally receives margin calls (requests to post more collateral) from its futures brokers or over-the-counter counterparties, which are met by moving the required portion of the assets held in the custody accounts at Northern Trust Company to the margin accounts. In the past three years, the Fund has not needed to liquidate any position as a result of a margin call.

The Fund’s assets are not and will not be, directly or indirectly, commingled with the property of any other person in violation of law or invested in or loaned to Campbell & Company or any affiliated entities.

Off-Balance Sheet Risk

The term “off-balance sheet risk” refers to an unrecorded potential liability that, even though it does not appear on the balance sheet, may result in future obligation or loss. The Fund trades in futures, forward and swap contracts and is therefore a party to financial instruments with elements of off-balance sheet market and credit risk. In entering into these contracts there exists a risk to the Fund, market risk, that such contracts may be significantly influenced by market conditions, such as interest rate volatility, resulting in such contracts being less valuable. If the markets should move against all of the futures interests positions of the Fund at the same time, and if the Fund’s trading advisor was unable to offset futures interest positions of the Fund, the Fund could lose all of its assets and the Limited Partners would realize a 100% loss. Campbell & Company, the general partner (who also acts as trading advisor), minimizes market risk through real-time monitoring of open positions, diversification of the portfolio and maintenance of a margin-to-equity ratio that rarely exceeds 30% however, these precautions may not be effective in limiting the risk of loss.

In addition to market risk, in entering into futures, forward and swap contracts there is a credit risk that a counterparty will not be able to meet its obligations to the Fund. The counterparty for futures contracts and centrally cleared swap contracts traded in the United States and on most foreign exchanges is the clearinghouse associated with such exchange. In general, clearinghouses are backed by the corporate members of the clearinghouse who are required to share any financial burden resulting from the non-performance by one of their members and, as such, should significantly reduce this credit risk. In cases where the clearinghouse is not backed by the clearing members, like some foreign exchanges, it is normally backed by a consortium of banks or other financial institutions.

In the case of forward contracts, which are traded on the interbank market rather than on exchanges, the counterparty is generally a single bank or other financial institution, rather than a group of financial institutions; thus there may be a greater counterparty credit risk. Campbell & Company trades for the Fund only with those counterparties which it believes to be creditworthy. All positions of the Fund are valued each day at fair value. There can be no assurance that any clearing member, clearinghouse or other counterparty will be able to meet its obligations to the Fund.

Disclosures About Certain Trading Activities that Include Non-Exchange Traded Contracts Accounted for at Fair Value

The Fund invests in futures, forward currency, and centrally cleared swap contracts. The fair value of futures (exchange-traded) contracts is determined by the various futures exchanges, and reflects the settlement price for each contract as of the close of the last business day of the reporting period. The fair value of forward (non-exchange traded) contracts is extrapolated on a forward basis from the spot prices quoted as of 3:00 P.M. (E.T.) of the last business day of the reporting period. The fair value of centrally cleared swap contracts is determined by using currency market quotations provided by an independent external pricing source.

Results of Operations

The returns for the three months ended March 31, 2021 and 2020 were 5.53% and 4.53%, respectively. During the three months ended March 31, 2021 and 2020, the Fund accrued brokerage fees in the amount of $2,351,405 and $3,016,225, respectively, and paid brokerage fees in the amount of $2.345.508 and $3,002,651, respectively. No performance fees were accrued or paid during these periods.

2021 (For the Three Months Ended March 31)

Of the 5.53% year to date return, approximately 7.48% was due to trading gains (before commissions) and approximately 0.03% due to investment income, offset by approximately (1.98)% due to brokerage fees, operating expenses and offering costs borne by the Fund. An analysis of the 7.48% trading gains by sector is as follows:

Sector
 
% Gain (Loss)
 
Credit
   
(2.04
)%
Commodities
   
3.52
%
Foreign Exchange
   
5.53
%
Interest Rates
   
(3.48
)%
Equity Indices
   
3.95
%
     
7.48
%

The Fund showed a decline in January with losses coming from interest rate, foreign exchange (FX), stock index, and credit positions, while commodity holdings produced some partially offsetting gains. Interest rate positions produced the largest losses during the month with declines most pronounced in long-dated instruments.  Long positions on US rate markets suffered as the Democrats took control of the Senate which sent yields higher (prices lower) amid increased expectations for a large scale fiscal stimulus package being passed.  Long positioning on Australian and Canadian rates also generated losses when prices fell (yields rose).  Australian inflation was higher than expected and the Bank of Canada indicated the country would not need as much quantitative easing as initially expected. Foreign exchange trading contributed additional losses during January.  The largest FX losses came from long emerging market positions (against the USD), specifically in the Colombian peso and Brazilian real. The Latin American currencies were the top underperformers during the month, sinking on regional spreading of the COVID-19 virus and slow vaccine rollouts in the region. Global stock index trading also added losses to the Fund during the month.  Long positioning on many global stock indexes saw gains early in the month, however late month risk aversion erased those gains and ultimately generated losses.  Concerns about liquidity induced asset bubbles, retail driven stock volatility in companies with high levels of short interest, and limited vaccine availability and distribution hurdles all contributed to the risk-off sentiment late in the month. In credit trading, short protection positions generated losses as European and US credit spreads widened amid risk-off sentiment, especially within Europe. Commodities generated some partially offsetting gains for the Fund.  Long positions on the grain complex profited as strong Chinese demand linked with supply concerns pushed prices to multi-year highs during the month.  A long holding on gasoline also added to gains as prices rose driven by fiscal stimulus payments to consumers and hopes for economic reopening on the back of mass COVID-19 vaccinations.

In February, the Fund showed a gain with profits coming from commodity, stock index, foreign exchange, and credit positions, while interest rate holdings produced some partially offsetting losses. Commodities trading produced the largest Fund gains during February.  Long holdings on the petroleum complex, specifically on gasoline, Brent, and WTI, generated gains on declining COVID infection trends and a deep freeze in Texas that negatively impacted production.  Long positioning on the grains, softs, and industrial metals also proved profitable amid US dollar weakness and strong expected demand from healing world economies. Global stock indexes generated additional profits during the month.  Long positioning on many global stock indexes profited as most major equity indexes advanced during the month.  Declining COVID infection rates, improving COVID vaccine distribution trends, and expectations for the passage of President Biden’s large US fiscal stimulus package all served as major tailwinds for global stock markets. Foreign exchange trading in the developed markets produced gains for the Fund.  A long British pound holding (against short USD) was among the best performers as the GBP benefited from an efficient vaccine roll-out and optimism about the economic recovery in the United Kingdom.  Mixed positioning in the FX markets proved beneficial as a short holding on the Japanese yen (versus long the greenback) benefited from the strength in the US markets relative to those in Japan. Interest rate positions produced the largest offsetting losses during the month with declines most pronounced in long-dated instruments.  Long positioning on long-dated rate instruments in Australia and Canada led sector losses as note prices in those countries fell sharply (yields rose) during February.  Growing global concerns about mounting inflationary pressures sparked by pent-up demand from COVID lockdowns linked with massive monetary and fiscal stimulus sent most global yields sharply higher, depressing bond prices and generating losses for the Fund.

March saw all the Fund’s asset classes produce gains with profits coming from foreign exchange, stock index, commodity, interest rate, and credit positions. Foreign exchange trading in both the developed and emerging markets produced the largest Fund gains during March. A short Japanese yen holding (against long USD) was the best performing FX position as the JPY sank to its lowest level in a year. The move was primarily driven by the stronger greenback as the COVID-19 vaccine rollout and stimulus efforts in the US caused the dollar to strengthen. Short positioning on the Australian and New Zealand dollars (against long USD) was also profitable after the Reserve Bank of Australia (RBA) continued its bond purchase program and following the New Zealand government’s efforts to curb property speculation. Global stock indexes generated additional profits for the Fund. Long positioning on many global stock indexes profited as most major equity indexes advanced during the month. Positive progress with the COVID-19 vaccine rollout along with fiscal and monetary stimulus support continued to underpin the rally in most global equities. Commodity holdings also produced gains during March. The Fund’s nimble short-term suite of models profitably traded the intra-month volatility within the petroleum complex. A short natural gas position benefited from warmer domestic weather forecasts which led to additional energy sub-sector gains. Long grain positions also produced profits for the Fund as the grain complex advanced sharply into month-end after a USDA report showed planting estimates below market expectations. Interest rate positions contributed small additional profits during the month with gains most notable in long-dated instruments. Long positioning on Australian 3- and 10-year notes produced profits after the RBA doubled down on bond purchases and policymakers expressed concern over the speed of the nation’s economic recovery. Credit trading was also profitable during March as short protection positions generated gains as most US and European credit spreads narrowed amid the risk-on environment.

2020 (For the Three Months Ended March 31)

Of the 4.53% year to date return, approximately 6.88% was due to trading gains (before commissions), offset by approximately (0.14)% due to investment loss and approximately (2.21)% due to brokerage fees, operating expenses and offering costs borne by the Fund. An analysis of the 6.88% trading gains by sector is as follows:

Sector
 
% Gain (Loss)
 
Commodities
   
6.66
%
Foreign Exchange
   
8.05
%
Interest Rates
   
5.92
%
Equity Indices
   
(13.75
)%
     
6.88
%

The Fund had a strong start to 2020 with gains coming from interest rate, commodity, and foreign exchange positions, while stock index holdings provided some partially offsetting losses. Long positioning in Australia, Europe, and the United States benefited as prices advanced on a flight to safety bid sparked by the worsening Wuhan coronavirus outbreak. A short position on the Canadian 10-year note created some partially offsetting losses, which were accelerated by downward pressure on yields prompted by a dovish shift by Bank of Canada policymakers. Commodity holdings produced additional profits for the Fund in January, with the energy sub-sector realizing the best results. Short positioning on natural gas proved profitable as milder weather across the US weighed on demand prospects. Additional gains were generated from short industrial metal holdings. The base metal complex traded weaker as the coronavirus epidemic raised investor concerns about its negative impact on the Chinese economy. Downward price pressure was further intensified by a strong dollar as well as technical selling. In the foreign exchange sector, positive returns were generated in the developed market currencies. Short positions on the Norwegian krone and Australian dollar (against long the US dollar) provided some of the best profits. The commodity-linked currencies came under pressure as commodity prices sold-off on concerns that the worsening coronavirus outbreak would pare Chinese demand for raw materials. A long Brazilian real holding produced some partially offsetting losses after risk fell out of favor and investors sold emerging market currencies. Global stock index trading produced losses for the Fund during January. Long positioning across most global stock indexes profited early in the month amid the ratification of the “phase one” US-China trade deal, renewed central bank balance sheet expansion, Brexit clarity, and some better than expected US earnings releases. However, profits were relinquished in the second-half of the month as stocks traded lower following risk-off trading as the coronavirus outbreak intensified.

Gains from interest rate, foreign exchange, and commodity positions led to a profitable February for the Fund, while stock index holdings produced some partially offsetting losses. Long positioning in Australia and the United States continued to benefit as prices advanced on flight to safety buying sparked by the worsening COVID-19 coronavirus epidemic. Investors aggressively sought the safety of fixed income instruments, sending global yields tumbling and expectations for further central bank stimulus soaring. In the foreign exchange sector, positive returns were generated in the developed and emerging market currencies. Short positions on the Australian dollar and Norwegian krone (against long the US dollar) provided some of the best profits for the sector. These commodity-linked currencies came under renewed selling pressure during February. The widening spread of COVID-19 to countries outside of China, such as Japan, South Korea, and Italy, sparked new concerns that global economic growth would slow materially, thus blunting the demand for raw materials. Short positioning on the industrial metal, energy, and meat complexes profited from a decline in prices. The expanding COVID-19 outbreak is widely expected to negatively impact demand for base metal, petroleum, and beef products. Downward price pressure was further intensified by a strong US dollar as well as technical selling. Global stock index trading produced losses for the Fund during February with the greatest declines seen in Australia, Japan, and the United States. Long positioning across most global stock indexes generally profited during the first two-thirds of the month. However, late in February global stock indexes experienced steep sell-offs sparked by the coronavirus’s quick spread to countries outside of China where it initially began. World economic growth fears and supply chain disruption concerns spread rapidly, sending most global stock indexes sharply lower.

The Fund had an unprofitable March, with losses coming from stock index and interest rate holdings, while foreign exchange and commodity positions contributed some partially offsetting gains during the month. Global stock index trading produced the largest losses for the Fund, with the greatest declines seen in the United States, Australia, and Canada. Long positioning across most global stock indexes suffered severely as equity indexes experienced very sharp sell-offs during the month. The COVID-19 virus spread quickly throughout Europe and North America prompting containment measures in the form of “stay at home” directives, closures, and shutdowns that sharply curtailed economic activity. Global central banks and governments took unprecedented steps in an effort to soften the financial impact from the virus, but fear over the length and depth of the growth slowdown sent risky assets sharply lower. Interest rate positions from long-dated instruments contributed small additional losses during the month. Short positioning on US 10-year notes and US long bonds suffered amid the flight-to-safety scramble that ensued due to the severe economic upheaval wrought by the COVID-19 virus. Long positioning across global short-dated instruments helped to partially offset losses within the sector. Profits were dominated by short positions on the commodity currencies (versus long the USD), specifically in the Norwegian krone. The US dollar was sharply higher during the month amid the extreme flight-to-quality moves. Adding further downward pressure on oil-linked currencies, the petroleum markets sold off severely when tensions escalated between OPEC and Russia, and Saudi Arabia made the decision to ramp up production. Commodity holdings produced additional profits for the Fund during the month. Short positioning on the industrial metal, energy, and meat complexes profited from a decline in prices. The expanding COVID-19 pandemic is widely expected to negatively impact demand for base metal, petroleum, and beef products. Downward price pressure was further intensified by a strong US dollar as well as technical selling.

Item 3. Quantitative and Qualitative Disclosures About Market Risk.

Introduction

Past Results Not Necessarily Indicative of Future Performance

The Fund is a speculative commodity pool. The market sensitive instruments held by it are acquired for speculative trading purposes, and all or a substantial amount of the Fund’s assets are subject to the risk of trading loss. Unlike an operating company, the risk of market sensitive instruments is integral, not incidental, to the Fund’s main line of business.

Market movements result in frequent changes in the fair value of the Fund’s open positions and, consequently, in its earnings and cash flow. The Fund’s market risk is influenced by a wide variety of factors, including the level and volatility of exchange rates, interest rates, equity price levels, the market value of financial instruments and contracts, the diversification effects among the Fund’s open positions and the liquidity of the markets in which it trades.

The Fund rapidly acquires and liquidates both long and short positions in a wide range of different markets. Consequently, it is not possible to predict how a particular future market scenario will affect performance, and the Fund’s past performance is not necessarily indicative of its future results.

Standard of Materiality

Materiality as used in this section, “Quantitative and Qualitative Disclosures About Market Risk,” is based on an assessment of reasonably possible market movements and the potential losses caused by such movements, taking into account the leverage and multiplier features of the Fund’s market sensitive instruments.

Quantifying the Fund’s Trading Value at Risk

Quantitative Forward-Looking Statements

The following quantitative disclosures regarding the Fund’s market risk exposures contain “forward-looking statements” within the meaning of the safe harbor from civil liability provided for such statements by the Private Securities Litigation Reform Act of 1995 (set forth in Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934). All quantitative disclosures in this section are deemed to be forward-looking statements for purposes of the safe harbor, except for statements of historical fact (such as the dollar amount of maintenance margin required for market risk sensitive instruments held at the end of the reporting period).

The Fund’s risk exposure in the various market sectors traded is estimated in terms of Value at Risk (VaR). The Fund estimates VaR using a model based upon historical simulation (with a confidence level of 97.5%) which involves constructing a distribution of hypothetical daily changes in the value of a trading portfolio. The VaR model takes into account linear exposures to risks, including equity and commodity prices, interest rates, foreign exchange rates, credit, and correlation among these variables. The hypothetical changes in portfolio value are based on daily percentage changes observed in key market indices or other market factors to which the portfolio is sensitive. The Fund’s VaR at a one day 97.5% confidence level corresponds to the negative change in portfolio value that, based on observed market risk factors, would have been exceeded once in 40 trading days or one day in 40. VaR typically does not represent the worst case outcome.

The Fund uses approximately one quarter of daily market data and revalues its portfolio for each of the historical market moves that occurred over this time period. This generates a probability distribution of daily “simulated profit and loss” outcomes. The VaR is the 2.5 percentile of this distribution.

The VaR for a sector represents the 2.5 percentile of outcomes for the aggregate exposures associated with that sector alone. The current methodology used to calculate the aggregate VaR represents the VaR of the Fund’s open positions across all market sectors, and is less than the sum of the VaRs for all such market sectors due to the diversification benefit across asset classes.

The Fund’s VaR computations are based on the risk representation of the underlying benchmark for each instrument or contract and does not distinguish between exchange and non-exchange dealer-based instruments. It is also not based on exchange and/or dealer-based maintenance margin requirements.

VaR models, including the Fund’s, are continually evolving as trading portfolios become more diverse and modeling techniques and systems capabilities improve. Please note that the VaR model is used to numerically quantify market risk for historic reporting purposes only and is not utilized by the Fund in its daily risk management activities. Please further note that VaR as described above may not be comparable to similarly titled measures used by other entities.

Because the business of the Fund is the speculative trading of futures, forwards, and swaps, the composition of the Fund’s trading portfolio can change significantly over any given time period, or even within a single trading day, which could positively or negatively materially impact market risk as measured by VaR.

The Fund’s Trading Value at Risk in Different Market Sectors

The following tables indicate the trading Value at Risk associated with the Fund’s open positions by market category as of March 31, 2021 and December 31, 2020 and the trading gains/losses by market category for the three months ended March 31, 2020 and the year ended December 31, 2020.

   
March 31, 2021
 
Market Sector
 
Value
at Risk*
   
Trading
Gain/(Loss)**
 
Credit
   
0.08
%
   
(2.04)
%
Commodities
   
0.53
%
   
3.52
%
Foreign Exchange
   
0.63
%
   
5.53
%
Interest Rates
   
0.69
%
   
(3.48)
%
Equity Indices
   
0.91
%
   
3.95
%
Aggregate/Total
   
1.69
%
   
7.48
%

*
The VaR for a sector represents the 2.5 percentile of outcomes for the aggregate exposures associated with that sector alone. The aggregate VaR represents the VaR of the Fund’s open positions across all market sectors, and is less than the sum of the VaRs for all such market sectors due to the diversification benefit across asset classes.

**
Of the 5.53% year to date return, approximately 7.48% was due to trading gains (before commissions) and approximately 0.03% due to investment income, offset by approximately (1.98)% due to brokerage fees, operating expenses and offering costs borne by the Fund.

   
December 31, 2020
 
Market Sector
 
Value
at Risk*
   
Trading
Gain/(Loss)**
 
Credit
   
0.11
%
   
0.08
%
Commodities
   
0.71
%
   
10.47
%
Foreign Exchange
   
0.51
%
   
4.34
%
Interest Rates
   
0.87
%
   
2.73
%
Equity Indices
   
0.63
%
   
(12.41
)%
Aggregate/Total
   
1.43
%
   
5.21
%

*
The VaR for a sector represents the 2.5 percentile of outcomes for the aggregate exposures associated with that sector alone. The aggregate VaR represents the VaR of the Fund’s open positions across all market sectors, and is less than the sum of the VaRs for all such market sectors due to the diversification benefit across asset classes.

**
Of the (2.40)% year to date return, approximately 5.21% was due to trading gains (before commissions) and approximately 1.13% due to investment income, offset by approximately (8.74)% due to brokerage fees, operating expenses and offering costs borne by the Fund.

Material Limitations of Value at Risk as an Assessment of Market Risk

The following limitations of VaR as an assessment of market risk should be noted:

1)
Past changes in market risk factors will not always result in accurate predictions of the distributions and correlations of future market movements;

2)
Changes in portfolio value caused by market movements may differ from those of the VaR model;

3)
VaR results reflect past trading positions while future risk depends on future positions;

4)
VaR using a one day time horizon does not fully capture the market risk of positions that cannot be liquidated or hedged within one day; and

5)
The historical market risk factor data for VaR estimation may provide only limited insight into losses that could be incurred under certain unusual market movements.

VaR is not necessarily representative of historic risk nor should it be used to predict the Fund’s future financial performance or its ability to manage and monitor risk. There can be no assurance that the Fund’s actual losses on a particular day will not exceed the VaR amounts indicated or that such losses will not occur more than once in 40 trading days.

Non-Trading Risk

The Fund has non-trading market risk on its foreign cash balances not needed for margin. However, these balances (as well as the market risk they represent) are immaterial. The Fund also has non-trading market risk as a result of investing a portion of its available assets in U.S. Treasury Bills held at the broker and over-the-counter counterparty. The market risk represented by these investments is minimal. Finally, the Fund has non-trading market risk on fixed income securities held as part of its cash management program. The cash manager will use its best endeavors in the management of the assets of the Fund but provide no guarantee that any profit or interest will accrue to the Fund as a result of such management.

Qualitative Disclosures Regarding Primary Trading Risk Exposures

The following qualitative disclosures regarding the Fund’s market risk exposures — except for (i) those disclosures that are statements of historical fact and (ii) the descriptions of how the Fund manages its primary market risk exposures — constitute forward-looking statements within the meaning of Section 27A of the Securities Act and Section 21E of the Securities Exchange Act. The Fund’s primary market risk exposures as well as the strategies used and to be used by Campbell & Company for managing such exposures are subject to numerous uncertainties, contingencies and risks, any one of which could cause the actual results of the Fund’s risk controls to differ materially from the objectives of such strategies. Government interventions, defaults and expropriations, illiquid markets, the emergence of dominant fundamental factors, political upheavals, changes in historical price relationships, an influx of new market participants, increased regulation and many other factors could result in material losses as well as in material changes to the risk exposures and the risk management strategies of the Fund. There can be no assurance that the Fund’s current market exposure and/or risk management strategies will not change materially or that any such strategies will be effective in either the short- or long-term. Investors must be prepared to lose all or substantially all of their investment in the Fund.

The following were the primary trading risk exposures of the Fund as of December 31, 2020, by market sector.

Foreign Exchange

The Fund’s currency exposure is to foreign exchange rate fluctuations, primarily fluctuations which disrupt the historical pricing relationships between different currencies and currency pairs. These fluctuations are influenced by interest rate changes as well as political and general economic conditions. The Fund trades in a large number of currencies, including cross-rates — i.e., positions between two currencies other than the U.S. Dollar. Campbell & Company does not anticipate that the risk profile of the Fund’s currency sector will change significantly in the future.

Interest Rates

Interest rate movements directly affect the price of the sovereign bond positions and interest rate swap contracts held by the Fund and indirectly the value of its stock index and currency positions. Interest rate movements in one country as well as relative interest rate movements between countries materially impact the Fund’s profitability. Campbell & Company does not anticipate that the risk profile of the Fund’s interest rate sector will change significantly in the future.

Equity Indices

The Fund’s primary equity exposure is to equity price risk in the G-7 countries as well as Australia, Hong Kong, Singapore, Spain, Taiwan, Netherlands, India, South Africa and Sweden. The stock index futures traded by the Fund are by law limited to futures on broadly based indices. The Fund is primarily exposed to the risk of adverse price trends or static markets in the major U.S., European and Japanese indices. Markets that trade in a narrow range could result in the Fund’s positions being “whipsawed” into numerous small losses.

Credit

The Fund’s primary credit exposure is through fluctuations in the credit worthiness of a particular reference entity, basket of reference entities, or an index.

Energy

The Fund’s primary energy market exposure is to natural gas, crude oil and derivative product price movements, often resulting from international political developments and ongoing conflicts in the Middle East and the perceived outcome. Oil and gas prices can be volatile and substantial profits and losses have been and are expected to continue to be experienced in this market.

Metals

The Fund’s metals market exposure is to fluctuations in the price of aluminum, copper, gold, lead, nickel, palladium, platinum, silver and zinc.

Agricultural

The Fund’s agricultural exposure is to the fluctuations of the price of cattle, cocoa, coffee, corn, cotton, hogs, soy, sugar, and wheat.

Qualitative Disclosures Regarding Non-Trading Risk Exposure

The following were the non-trading risk exposures of the Fund as of March 31, 2021.

Foreign Currency Balances

The Fund’s primary foreign currency balances are in Australian Dollar, British Pound, Canadian Dollar, Euros, Hong Kong Dollar, Japanese Yen, Singapore Dollar, South African Rand and Swedish Krona. The Fund controls the non-trading risk of these balances by regularly converting these balances back into dollars (no less frequently than twice a month, and more frequently if a particular foreign currency balance becomes unusually large).

Fixed Income Securities and Short Term Investments

The Fund’s primary market exposure in instruments (other than treasury positions described in the subsequent section) held other than for trading is in its fixed income portfolio. The cash manager, PNC, has authority to make certain investments on behalf of the Fund. All securities purchased by the cash manager on behalf of the Fund will be held in the Fund’s custody account at the custodian. The cash manager will use its best endeavors in the management of the assets of the Fund but provide no guarantee that any profit or interest will accrue to the Fund as a result of such management.

U.S. Treasury Bill Positions for Margin Purposes

The Fund also has market exposure in its U.S. Treasury Bill portfolio. The Fund holds U.S. Treasury Bills with maturities no longer than six months. Violent fluctuations in prevailing interest rates could cause minimal mark-to-market losses on the Fund’s U.S. Treasury Bills, although substantially all of these short-term investments are held to maturity.

Qualitative Disclosures Regarding Means of Managing Risk Exposure

The means by which the Fund and Campbell & Company, severally, attempt to manage the risk of the Fund’s open positions is essentially the same in all market categories traded. Campbell & Company applies risk management policies to its trading which generally limit the total exposure that may be taken per “risk unit” of assets under management. In addition, Campbell & Company follows diversification guidelines (often formulated in terms of the balanced volatility between markets and correlated groups), as well as reducing position sizes dynamically in response to trading losses.

General

The Fund is unaware of any (i) anticipated known demands, commitments or capital expenditures; (ii) material trends, favorable or unfavorable, in its capital resources; or (iii) trends or uncertainties that will have a material effect on operations. From time to time, certain regulatory agencies have proposed increased margin requirements on futures contracts. Because the Fund generally will use a small percentage of assets as margin, the Fund does not believe that any increase in margin requirements, as proposed, will have a material effect on the Fund’s operations.

The Fund has continued to operate as normal during the COVID-19 pandemic.  The Fund had access to and the ability to trade in approved markets.  There were no disruptions in the Fund’s accounting processes, transfer agent processes or cash processes, including the ability to pay redemptions and meet margin requirements.

The future impact of COVID-19 on the financial performance of the Fund’s investments will depend on future developments, including the effectiveness of vaccines and the public’s willingness to get vaccinated as new strains of the virus emerge, along with any related advisories and restrictions. These developments and the lasting impact of COVID-19 on the financial markets and the overall economy are highly uncertain and cannot be predicted.  If the financial markets and/or the overall economy are impacted for an extended period, the Fund’s ability to trade and investment results may be materially affected.

Item 4.  Controls and Procedures.

Campbell & Company, the general partner of the Fund, with the participation of the general partner’s chief executive officer and chief operating officer, has evaluated the effectiveness of the design and operation of its disclosure controls and procedures (as defined in the Securities Exchange Act of 1934 Rules 13a-15(e) or 15d-15(e)) with respect to the Fund as of the end of the period covered by this annual report. Based on their evaluation, the chief executive officer and chief operating officer have concluded that these disclosure controls and procedures are effective. There were no changes in the general partner’s internal control over financial reporting applicable to the Fund identified in connection with the evaluation required by paragraph (d) of Exchange Act Rules 13a-15 or 15d-15 that occurred during the last fiscal quarter that have materially affected, or is reasonably likely to materially affect, internal control over financial reporting applicable to the Fund.

PART II-OTHER INFORMATION

Item 1.  Legal Proceedings.

None

Item 1A.  Risk Factors.

There are no material changes from the risk factors as previously disclosed in Form 10-K, filed March 26, 2021.

Item 2.  Unregistered Sales of Equity Securities and Use of Proceeds.

None

Item 3.  Defaults Upon Senior Securities.

Not applicable.

Item 4.  Mine Safety Disclosures.

Not applicable.

Item 5.  Other Information.

None

Item 6. Exhibits.

Exhibit Number
 
Description of Document
     
3.01
 
     
3.02
 
     
4.01
 
     
10.01
 
     
10.02
 
     
10.03
 
     
 
Certification of G. William Andrews, Chief Executive Officer, pursuant to Rules 13a-14 and 15d-14 of the Securities Exchange Act of 1934.
     
 
Certification of Gabriel A. Morris, Chief Operating Officer, pursuant to Rules 13a-14 and 15d-14 of the Securities Exchange Act of 1934.
     
 
Certification of G. William Andrews, Chief Executive Officer, pursuant to 18 U.S.C. Section 1350, as enacted by Section 906 of The Sarbanes-Oxley Act of 2002.
     
 
Certification of Gabriel A. Morris, Chief Operating Officer, pursuant to 18 U.S.C. Section 1350, as enacted by Section 906 of The Sarbanes-Oxley Act of 2002.
     
101.01
 
Interactive data file pursuant to Rule 405 of Regulation S-T: (i) Condensed Schedules of Investments as of March 31, 2021 and December 31, 2020, (ii) Statements of Financial Condition as of March 31, 2020 and December 31, 2020, (iii) Statements of Operations For the Three Months Ended March 31, 2021 and 2020, (iv) Statements of Cash Flows For the Three Months Ended March 31, 2021 and 2020, (v) Statements of Changes in Partners’ Capital (Net Asset Value) For the Three Months Ended March 31, 2021 and 2020, (vi) Financial Highlights For the Three Months Ended March 31, 2021 and 2020, (vii) Notes to Financial Statements.

(1)
Incorporated by reference to the respective exhibit to the Registrant’s Registration Statement on Form S-1 on April 27, 2010.
(2)
Incorporated by reference to the respective exhibit to Post-Effective Amendment No. 2 to the Registration Statement on Form S-1 on April 7, 2011.
(3)
Incorporated by reference to the respective exhibit to the Quarterly Report on Form 10-Q on November 14, 2017.
(4)
Incorporated by reference to the respective exhibit to the Quarterly Report on Form 10-Q on May 15, 2014.

EXHIBIT INDEX

Certification of G. William Andrews, Chief Executive Officer, pursuant to Rules 13a-14 and 15d-14 of the Securities Exchange Act of 1934.
   
Certification of Gabriel A. Morris, Chief Operating Officer, pursuant to Rules 13a-14 and 15d-14 of the Securities Exchange Act of 1934.
   
Certification of G. William Andrews, Chief Executive Officer, pursuant to 18 U.S.C. Section 1350, as enacted by Section 906 of The Sarbanes-Oxley Act of 2002.
   
Certification of Gabriel A. Morris, Chief Operating Officer, pursuant to 18 U.S.C. Section 1350, as enacted by Section 906 of The Sarbanes-Oxley Act of 2002.
   
101.01
Interactive data file pursuant to Rule 405 of Regulation S-T: (i) Condensed Schedules of Investments as of March 31, 2021 and December 31, 2020, (ii) Statements of Financial Condition as of March 31, 2021 and December 31, 2020, (iii) Statements of Operations For the Three Months Ended March 31, 2021 and 2020, (iv) Statements of Cash Flows For the Three Months Ended March 31, 2021 and 2020, (v) Statements of Changes in Partners’ Capital (Net Asset Value) For the Three Months Ended March 31, 2021 and 2020, (vi) Financial Highlights For the Three Months Ended March 31, 2021 and 2020, (vii) Notes to Financial Statements.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned thereunto duly authorized.

 
CAMPBELL STRATEGIC ALLOCATION FUND, L.P.
(Registrant)
       
 
By:
Campbell & Company, LP
 
   
General Partner
 
     
Date: May 14, 2021
By:
/s/ G. William Andrews
 
   
G. William Andrews
 
   
Chief Executive Officer
 


39