10-Q

10-Q 1 d168322d10q.htm 10-Q 10-Q

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

Form 10-Q

(Mark One)

x	QUARTERLY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the quarterly period ended March 31, 2016

¨	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 001-34879

Nuveen Diversified Commodity Fund

(Exact name of registrant as specified in its charter)


Delaware		27-2048014
(State or other jurisdiction of incorporation or organization)		(I.R.S. Employer Identification No.)

333 West Wacker Drive Chicago Illinois		60606
(Address of principal executive offices)		(Zip Code)

(877) 827-5920

(Registrant’s telephone number, including area code)

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 x No ¨

Indicate by check mark whether the registrant has submitted electronically and posted on its corporate Website, if any, every Interactive Data File required to be submitted and posted pursuant to Rule 405 of Regulation S-T (§229.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit and post such files). Yes x No ¨

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


Large accelerated filer	¨		Accelerated filer	x

Non-accelerated filer	¨	(Do not check if smaller reporting company)	Smaller reporting company	¨

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

As of May 5, 2016, the registrant had 9,047,040 shares outstanding.

NUVEEN DIVERSIFIED COMMODITY FUND

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 10-Q

TABLE OF CONTENTS


		Page No.
PART I. FINANCIAL INFORMATION

Item 1.	Financial Statements:		3

	Schedule of Investments at March 31, 2016 (Unaudited)		3

	Statements of Financial Condition at March 31, 2016 (Unaudited) and December 31, 2015		9

	Statements of Operations (Unaudited) for the three months ended March 31, 2016 and March 31, 2015		10

	Statements of Changes in Shareholders’ Capital for the three months ended March 31, 2016 (Unaudited) and the year ended December 31, 2015		11

	Statements of Cash Flows (Unaudited) for the three months ended March 31, 2016 and March 31, 2015		12

	Notes to Financial Statements (Unaudited)		13

Item 2.	Management’s Discussion and Analysis of Financial Condition and Results of Operations		26

Item 3.	Quantitative and Qualitative Disclosures About Market Risk		38

Item 4.	Controls and Procedures		41

PART II. OTHER INFORMATION

Item 1.	Legal Proceedings		43

Item 1A.	Risk Factors		43

Item 2.	Unregistered Sales of Equity Securities and Use of Proceeds		43

Item 3.	Defaults Upon Senior Securities		43

Item 4.	Mine Safety Disclosures		43

Item 5.	Other Information		43

Item 6.	Exhibits		44

Signatures			45

PART 1. FINANCIAL INFORMATION

Item 1.

Financial Statements

NUVEEN DIVERSIFIED COMMODITY FUND

SCHEDULE OF INVESTMENTS (Unaudited)

March 31, 2016

Investments


Principal Amount (000)		Description	Coupon			Maturity		Ratings⁽¹⁾		Value
		Short-Term Investments
		U.S. Government and Agency Obligations
	$14,000	U.S. Treasury Bills		0.000	%		4/28/16		Aaa	$	13,998,208
	15,620	U.S. Treasury Bills		0.000	%		5/26/16		Aaa		15,615,923
	5,000	U.S. Treasury Bills		0.000	%		6/23/16		Aaa		4,997,525
	7,000	U.S. Treasury Bills		0.000	%		7/21/16		Aaa		6,994,183
	8,000	U.S. Treasury Bills		0.000	%		9/15/16		Aaa		7,987,576
	3,500	U.S. Treasury Bills		0.000	%		11/10/16		Aaa		3,493,871
	500	U.S. Treasury Bills		0.000	%		12/08/16		Aaa		498,813
	2,000	U.S. Treasury Bills		0.000	%		1/05/17		Aaa		1,992,608
	2,500	U.S. Treasury Bills		0.000	%		2/02/17		Aaa		2,488,843
	5,300	U.S. Treasury Bills		0.000	%		3/02/17		Aaa		5,272,790
	8,000	U.S. Treasury Bills		0.000	%		3/30/17		Aaa		7,952,992

	$71,420	Total U.S. Government and Agency Obligations (cost $71,279,650)									71,293,332

		Repurchase Agreements
	$10,770	Repurchase Agreement with State Street Bank, dated 3/31/16, repurchase price $10,769,895, collateralized by $10,900,000 U.S. Treasury Notes, 1.000%, due 5/15/18, value $10,987,865		0.010	%		4/01/16		N/A	$	10,769,892

		Total Repurchase Agreements (cost $10,769,892)									10,769,892

		Total Short-Term Investments (cost $82,049,542)								$	82,063,224

Investments in Derivatives

Futures Contracts outstanding:


Commodity Group	Contract	Contract Position⁽²⁾		Contract Expiration		Number of Contracts⁽³⁾		Notional Amount at Value⁽³⁾		Unrealized Appreciation (Depreciation)⁽⁴⁾
Energy	Crude Oil
	ICE Brent Crude Oil Futures Contract		Long		June 2016		146	$	5,888,180	$	(134,264	)
	ICE Brent Crude Oil Futures Contract		Long		July 2016		109		4,443,930		218,160
	NYMEX Crude Oil Futures Contract		Long		May 2016		107		4,102,380		(229,070	)
	NYMEX Crude Oil Futures Contract		Long		July 2016		48		1,953,120		(35,434	)

	Total Crude Oil										(180,608	)

	Heating Oil
	ICE Low Sulphur Gasoil Futures Contract		Long		May 2016		70		2,509,500		29,000
	NYMEX NY Harbor ULSD Futures Contract		Long		May 2016		51		2,539,341		39,627

	Total Heating Oil										68,627

	Natural Gas
	NYMEX Natural Gas Futures Contract		Long		May 2016		170		3,330,300		66,029
	NYMEX Natural Gas Futures Contract		Long		July 2016		62		1,334,860		(30,760	)

	Total Natural Gas										35,269

	Unleaded Gas
	NYMEX Gasoline RBOB Futures Contract		Long		May 2016		49		2,977,309		115,643

	Total Energy										38,931

NUVEEN DIVERSIFIED COMMODITY FUND

SCHEDULE OF INVESTMENTS (Continued) (Unaudited)

March 31, 2016

Investments in Derivatives (Continued)

Futures Contracts outstanding (Continued):


Commodity Group	Contract	Contract Position⁽²⁾		Contract Expiration		Number of Contracts⁽³⁾		Notional Amount at Value⁽³⁾			Unrealized Appreciation (Depreciation)⁽⁴⁾
Industrial Metals	Copper
	COMEX Copper Futures Contract		Long		May 2016		21	$	1,146,075		$	72,837
	LME Copper Futures Contract		Long		April 2016		35		4,263,438			255,938
	LME Copper Futures Contract		Short		April 2016		3		(365,438	)		8,588
	LME Copper Futures Contract		Long		May 2016		16		1,943,400			79,300

	Total Copper											416,663

	Aluminum
	LME Primary Aluminum Futures Contract		Long		April 2016		120		4,526,250			18,750

	Zinc
	LME Zinc Futures Contract		Long		April 2016		36		1,629,675			117,675
	LME Zinc Futures Contract		Short		April 2016		3		(135,806	)		1,444

	Total Zinc											119,119

	Nickel
	LME Nickel Futures Contract		Long		April 2016		28		1,420,776			1,932

	Lead
	LME Lead Futures Contract		Long		April 2016		18		764,437			(33,763	)
	LME Lead Futures Contract		Short		April 2016		2		(84,938	)		5,388

	Total Lead											(28,375	)

	Total Industrial Metals											528,089

Agriculturals	Soybean
	CBOT Soybean Futures Contract		Long		May 2016		96		4,371,600			186,400

	Corn
	CBOT Corn Futures Contract		Long		May 2016		138		2,425,350			(128,100	)
	CBOT Corn Futures Contract		Long		July 2016		40		711,500			(36,000	)

	Total Corn											(164,100	)

	Wheat
	CBOT Wheat Futures Contract		Long		May 2016		66		1,562,550			13,462
	KCBT Wheat Futures Contract		Long		May 2016		66		1,571,625			67,187

	Total Wheat											80,649

	Soybean Meal
	CBOT Soybean Meal Futures Contract		Long		May 2016		74		2,000,220			39,090

	Soybean Oil
	CBOT Soybean Oil Futures Contract		Long		May 2016		51		1,047,132			81,654

	Total Agriculturals											223,693

Precious Metals	Gold
	CEC Gold Futures Contract		Long		June 2016		61		7,537,160			83,920

	Silver
	CEC Silver Futures Contract		Long		May 2016		27		2,087,640			30,425

NUVEEN DIVERSIFIED COMMODITY FUND

SCHEDULE OF INVESTMENTS (Continued) (Unaudited)

March 31, 2016

Investments in Derivatives (Continued)

Futures Contracts outstanding (Continued):


Commodity Group	Contract	Contract Position⁽²⁾		Contract Expiration		Number of Contracts⁽³⁾		Notional Amount at Value⁽³⁾		Unrealized Appreciation (Depreciation)⁽⁴⁾
Precious Metals	Platinum
(continued)	NYMEX Platinum Futures Contract		Long		July 2016		12	$	586,500	$	(1,815	)

	Palladium
	NYMEX Palladium Futures Contract		Long		June 2016		8		451,200		38,240

	Total Precious Metals										150,770

Livestock	Live Cattle
	CME Live Cattle Futures Contract		Long		April 2016		70		3,721,900		(17,960	)
	CME Live Cattle Futures Contract		Long		June 2016		40		1,984,400		(26,620	)

	Total Live Cattle										(44,580	)

	Lean Hogs
	CME Lean Hog Futures Contract		Long		April 2016		46		1,257,640		(19,213	)
	CME Lean Hog Futures Contract		Long		June 2016		27		873,180		(9,090	)

	Total Lean Hogs										(28,303	)

	Feeder Cattle
	CME Feeder Cattle Futures Contract		Long		May 2016		16		1,242,000		(32,245	)
	CME Feeder Cattle Futures Contract		Long		August 2016		6		465,225		(19,125	)

	Total Feeder Cattle										(51,370	)

	Total Livestock										(124,253	)

Foods and Fibers	Sugar
	ICE Sugar Futures Contract		Long		May 2016		113		1,942,696		294,179
	ICE White Sugar Futures Contract		Long		May 2016		5		111,175		11,495
	ICE White Sugar Futures Contract		Long		August 2016		3		66,030		(2,070	)

	Total Sugar										303,604

	Coffee
	ICE Coffee C Futures Contract		Long		May 2016		33		1,577,194		116,400
	LIFFE Coffee Robusta Futures Contract		Long		May 2016		17		255,170		15,300

	Total Coffee										131,700

	Cotton
	ICE Cotton Futures Contract		Long		May 2016		36		1,051,920		(20,182	)
	ICE Cotton Futures Contract		Long		July 2016		5		145,775		850

	Total Cotton										(19,332	)

	Cocoa
	ICE Cocoa Futures Contract		Long		May 2016		14		413,000		18,340
	ICE Cocoa Futures Contract		Long		July 2016		13		384,670		(8,320	)

	Total Cocoa										10,020

	Total Foods and Fibers										425,992

	Total Futures Contracts outstanding						2,161	$	84,031,241	$	1,243,222

NUVEEN DIVERSIFIED COMMODITY FUND

SCHEDULE OF INVESTMENTS (Continued) (Unaudited)

March 31, 2016

Investments in Derivatives (Continued)

Call Options Written outstanding:


Commodity Group	Contract	Contract Expiration		Number of Contracts			Strike Price		Value

Energy	Crude Oil
	ICE Brent Crude Oil Futures Options		June 2016		(127	)	$	45.00	$	(41,910	)
	NYMEX Crude Oil Futures Options		April 2016		(77	)		43.00		(10,010	)

	Total Crude Oil									(51,920	)

	Heating Oil
	NYMEX NY Harbor ULSD Futures Options		April 2016		(51	)		130.00		(22,919	)

	Natural Gas
	NYMEX Natural Gas Futures Options		April 2016		(116	)		2.10		(48,720	)

	Unleaded Gas
	NYMEX Gasoline RBOB Futures Options		April 2016		(25	)		164.00		(9,030	)

	Total Energy									(132,589	)

Industrial Metals	Copper
	LME Copper Futures Options⁽⁵⁾		April 2016		(29	)		4,800.00		(73,841	)

	Aluminum
	LME Primary Aluminum Futures Options⁽⁵⁾		April 2016		(60	)		1,600.00		(105	)

	Zinc
	LME Zinc Futures Options⁽⁵⁾		April 2016		(16	)		1,800.00		(12,264	)

	Nickel
	LME Nickel Futures Options⁽⁵⁾		April 2016		(14	)		9,200.00		(301	)

	Lead
	LME Lead Futures Options⁽⁵⁾		April 2016		(8	)		1,900.00		(2	)

	Total Industrial Metals									(86,513	)

Agriculturals	Soybean
	CBOT Soybean Futures Options		April 2016		(48	)		930.00		(10,500	)

	Corn
	CBOT Corn Futures Options		April 2016		(89	)		395.00		(1,113	)

	Wheat
	CBOT Wheat Futures Options		April 2016		(33	)		495.00		(8,044	)
	CBOT Wheat Futures Options		April 2016		(33	)		500.00		(5,981	)

	Total Wheat									(14,025	)

	Soybean Meal
	CBOT Soybean Meal Futures Options		April 2016		(37	)		290.00		(2,220	)

	Soybean Oil
	CBOT Soybean Oil Futures Options		April 2016		(25	)		34.00		(11,550	)

	Total Agriculturals									(39,408	)

Precious Metals	Gold
	COMEX Gold Futures Options		May 2016		(30	)		1,320.00		(25,500	)

	Silver
	CEC Silver Futures Options		April 2016		(13	)		16.75		(4,875	)

	Total Precious Metals									(30,375	)

NUVEEN DIVERSIFIED COMMODITY FUND

SCHEDULE OF INVESTMENTS (Continued) (Unaudited)

March 31, 2016

Investments in Derivatives (Continued)

Call Options Written outstanding (Continued):


Commodity Group	Contract	Contract Expiration		Number of Contracts			Strike Price		Value

Livestock	Live Cattle
	CME Live Cattle Futures Options		April 2016		(69	)	$	142.00	$	(690	)

	Lean Hogs
	CME Lean Hogs Futures Options		April 2016		(37	)		74.00		(370	)

	Total Livestock									(1,060	)

Foods and Fibers	Sugar
	ICE Sugar Futures Options		April 2016		(61	)		14.50		(66,271	)

	Coffee
	ICE Coffee C Futures Options		April 2016		(19	)		130.00		(9,191	)

	Cotton
	ICE Cotton Futures Options		April 2016		(20	)		64.00		(600	)

	Cocoa
	ICE Cocoa Futures Options		June 2016		(13	)		3,250.00		(3,510	)

	Total Foods and Fibers									(79,572	)

	Total Call Options Written outstanding
	(premiums received $560,095)				(1,050	)			$	(369,517	)

NUVEEN DIVERSIFIED COMMODITY FUND

SCHEDULE OF INVESTMENTS (Continued) (Unaudited)

March 31, 2016


⁽¹⁾		Ratings: Using the highest of Standard & Poor’s Group, Moody’s Investors Service, Inc. or Fitch, Inc. rating.
⁽²⁾		The Fund expects to invest only in long futures contracts. Some short futures positions arise in futures contracts traded on the London Metal Exchange (“LME”) solely as the result of closing existing long LME futures positions. For every short LME futures contract outstanding, the Fund had previously entered into a long LME futures contract. The London Clearing House is the counterparty for both the long and short position.
⁽³⁾		Total number of contracts and notional amount at value include the net effect of LME short futures positions, when applicable.
⁽⁴⁾		The gross unrealized appreciation (depreciation) on futures contracts is $2,027,253 and $(784,031), respectively.
⁽⁵⁾		For fair value measurement disclosure purposes, these Call Options Written are classified as Level 2. See Notes to Financial Statements, Note 2—Summary of Significant Accounting Policies, Investment Valuation and Fair Value Measurements for more information.
N/A		Not applicable.
CBOT		Chicago Board of Trade
CEC		Commodities Exchange Center
CME		Chicago Mercantile Exchange
COMEX		Commodities Exchange, Inc.
ICE		Intercontinental Exchange
KCBT		Kansas City Board of Trade
LIFFE		London International Financial Futures Exchange
LME		London Metal Exchange
NY Harbor ULSD		New York Harbor Ultra-Low Sulfur Diesel
NYMEX		New York Mercantile Exchange
RBOB		Reformulated Gasoline Blendstock for Oxygen Blending

See accompanying notes to financial statements.

NUVEEN DIVERSIFIED COMMODITY FUND

STATEMENTS OF FINANCIAL CONDITION

At March 31, 2016 (Unaudited) and December 31, 2015


	March 31, 2016			December 31, 2015
ASSETS
Short-term investments, at value: U.S. government and agency obligations (cost $71,279,650 and $70,029,645 respectively)	$	71,293,332		$	70,000,297
Repurchase agreement (cost approximates value)		10,769,892			1,088,249
Deposits with brokers		10,224,703			16,182,840
Unrealized appreciation on futures contracts		2,027,253			1,629,675

Total assets	$	94,315,180		$	88,901,061


LIABILITIES
Call options written, at value (premiums received $560,095 and $633,387, respectively)	$	369,517		$	439,772
Unrealized depreciation on futures contracts		784,031			2,259,165
Payable for:
Distributions		524,724			—
Investments purchased		7,953,496			—
Accrued expenses:
Conversion		54,759			74,106
Management fees		89,572			91,477
Independent Committee fees		10,022			10,926
Professional fees		262,567			309,773
Other		122,355			84,301

Total liabilities		10,171,043			3,269,520


SHAREHOLDERS’ CAPITAL
Paid-in capital, unlimited number of shares authorized, 9,047,040 shares issued and outstanding at March 31, 2016 and December 31, 2015		217,646,428			217,646,428
Accumulated undistributed earnings (deficit)		(133,502,291	)		(132,014,887	)

Total shareholders’ capital (Net assets)		84,144,137			85,631,541

Total liabilities and shareholders’ capital	$	94,315,180		$	88,901,061


Net assets	$	84,144,137		$	85,631,541

Shares outstanding		9,047,040			9,047,040

Net asset value per share outstanding (net assets divided by shares outstanding)	$	9.30		$	9.47

Market value per share outstanding	$	8.91		$	9.02

See accompanying notes to financial statements.

NUVEEN DIVERSIFIED COMMODITY FUND

STATEMENTS OF OPERATIONS (Unaudited)

For the Three Months Ended March 31, 2016 and March 31, 2015


	Three Months Ended March 31,
	2016			2015
Investment Income:
Interest	$	57,750		$	25,959

Total investment income		57,750			25,959

Expenses:
Management fees		255,978			363,800
Brokerage commissions		27,861			33,568
Custodian fees and expenses		19,671			26,640
Independent Committee fees and expenses		9,118			11,455
Professional fees		111,969			123,017
Shareholder reporting expenses		28,899			34,551
Other expenses		6,983			6,078

Total expenses		460,479			599,109

Net investment income (loss)		(402,729	)		(573,150	)

Net realized gain (loss) from:
Short-term investments		101			1,145
Futures contracts		(2,621,452	)		(15,565,740	)
Call options written		1,198,143			1,834,913
Change in net unrealized appreciation (depreciation) of:
Short-term investments		43,030			4,555
Futures contracts		1,872,712			8,176,470
Call options written		(3,037	)		(178,288	)

Net realized gain (loss) and change in net unrealized appreciation (depreciation)		489,497			(5,726,945	)

Net income (loss)	$	86,768		$	(6,300,095	)


Net income (loss) per weighted-average share	$	0.01		$	(0.70	)
Weighted-average shares outstanding		9,047,040			9,047,040

See accompanying notes to financial statements.

NUVEEN DIVERSIFIED COMMODITY FUND

STATEMENTS OF CHANGES IN SHAREHOLDERS’ CAPITAL

For the Three Months Ended March 31, 2016 (Unaudited) and the Year Ended December 31, 2015


	Three Months Ended March 31, 2016			Year Ended December 31, 2015
Shareholders’ capital—beginning of period	$	85,631,541		$	123,198,004
Repurchase of shares		—			—

Net increase (decrease) in shareholders’ capital resulting from operations:
Net investment income (loss)		(402,729	)		(2,382,074	)
Net realized gain (loss) from:
Short-term investments		101			79
Futures contracts		(2,621,452	)		(40,931,647	)
Call options written		1,198,143			5,739,221
Change in net unrealized appreciation (depreciation) of:
Short-term investments		43,030			(30,540	)
Futures contracts		1,872,712			10,208,143
Call options written		(3,037	)		(462,171	)

Net income (loss)		86,768			(27,858,989	)

Distributions to shareholders		(1,574,172	)		(9,707,474	)

Shareholders’ capital—end of period	$	84,144,137		$	85,631,541

Shares—beginning of period		9,047,040			9,047,040
Repurchase of shares		—			—

Shares—end of period		9,047,040			9,047,040

See accompanying notes to financial statements.

NUVEEN DIVERSIFIED COMMODITY FUND

STATEMENTS OF CASH FLOWS (Unaudited)

For the Three Months Ended March 31, 2016 and March 31, 2015


	Three Months Ended March 31,
	2016			2015
Cash flows from operating activities:
Net income (loss)	$	86,768		$	(6,300,095	)
Adjustments to reconcile net income (loss) to net cash provided by (used in) operating activities:
Purchases of U.S. government and agency obligations		(17,697,035	)		(5,986,236	)
Proceeds from sales and maturities of U.S. government and agency obligations		16,498,823			23,999,877
Proceeds from (purchases of) repurchase agreements, net		(9,681,643	)		(420,347	)
Premiums received for call options written		1,267,141			1,774,828
Cash paid for call options written		(142,290	)		(182,986	)
Amortization (accretion) of short-term investments		(51,692	)		(25,959	)
(Increase) decrease in:
Deposits with brokers		5,958,137			(768,388	)
Other assets		—			(11,301	)
Increase (decrease) in:
Payable for investments purchased		7,953,496			—
Accrued conversion expenses		(19,347	)		—
Accrued management fees		(1,905	)		(15,153	)
Accrued Independent Committee fees		(904	)		(824	)
Accrued professional fees		(47,206	)		—
Other accrued expenses		38,054			(116,661	)
Net realized (gain) loss from:
Short-term investments		(101	)		(1,145	)
Call options written		(1,198,143	)		(1,834,913	)
Change in net unrealized (appreciation) depreciation of:
Short-term investments		(43,030	)		(4,555	)
Futures contracts		(1,872,712	)		(8,176,470	)
Call options written		3,037			178,288

Net cash provided by (used in) operating activities		1,049,448			2,107,960

Cash flows from financing activities:
Cash distributions paid to shareholders		(1,049,448	)		(2,107,960	)

Net cash provided by (used in) financing activities		(1,049,448	)		(2,107,960	)

Net increase (decrease) in cash		—			—
Cash—beginning of period		—			—

Cash—end of period	$	—		$	—

See accompanying notes to financial statements.

NUVEEN DIVERSIFIED COMMODITY FUND

NOTES TO FINANCIAL STATEMENTS (Unaudited)

March 31, 2016

1. Organization

Fund Information

The Nuveen Diversified Commodity Fund (the “Fund”) was organized as a Delaware statutory trust on December 7, 2005, to operate as a commodity pool. Nuveen Commodities Asset Management, LLC, the Fund’s manager (“NCAM” or the “Manager”), is a Delaware limited liability company registered as a commodity pool operator with the Commodity Futures Trading Commission (the “CFTC”) and is a member of the National Futures Association (the “NFA”). The Fund commenced operations on September 27, 2010, with its initial public offering. The Fund operates pursuant to a Second Amended and Restated Trust Agreement dated as of March 30, 2012 (the “Trust Agreement”). The Fund’s shares represent units of fractional undivided beneficial interest in, and ownership of, the Fund. The Fund’s shares trade on the NYSE MKT under the ticker symbol “CFD.” The Fund is not a mutual fund, a closed-end fund, or any other type of “investment company” within the meaning of the Investment Company Act of 1940, as amended, and is not subject to regulation thereunder.

Proposed Conversion to Exchange-Traded Fund (“ETF”) Structure

On December 19, 2014, the Fund issued a press release announcing that the Manager had approved a plan to convert the Fund (the “Conversion”) into an open-ended ETF. On June 30, 2015, shareholders of the Fund approved amendments to the Fund’s Declaration of Trust that are necessary to complete the Conversion. To facilitate the Conversion, on July 9, 2015, the Fund filed a registration statement with the Securities and Exchange Commission (the “SEC”) to register common shares that may be issued from time to time after the Conversion. As of March 31, 2016 the Conversion remains subject to the receipt of regulatory approvals.

On March 2, 2016, the Fund announced an update on the expected time frame for the Conversion. Assuming receipt of regulatory approvals, the Conversion is expected to be completed in the second quarter of 2016. The Conversion requires regulatory clearance, including the adoption of a new exchange rule pursuant to which the Fund’s shares will trade following the Conversion. The Fund has been working with the NYSE MKT, which has initiated the rule making process for the new rule, which will ultimately require approval by the SEC. There can be no assurance that such clearance will be obtained, or if obtained, that the Conversion will be completed in the anticipated time frame.

The Fund is not currently, and after the Conversion will not be, a mutual fund or any other type of investment company within the meaning of the 1940 Act. Until the Conversion occurs, the Fund will continue to operate as currently structured.

Investment Adviser

The Manager has selected its affiliate, Gresham Investment Management LLC (“Gresham LLC”), acting through its Near Term Active division (in that capacity, “Gresham” or the “Commodity Sub-adviser”), to manage the Fund’s commodity investment strategy and its options strategy. Gresham LLC is a Delaware limited liability company, the successor to Gresham Investment Management, Inc., formed in July 1992. Gresham LLC is registered with the CFTC as a commodity trading adviser and commodity pool operator, is a member of the NFA and is registered with the SEC as an investment adviser.

The Manager has selected its affiliate, Nuveen Asset Management, LLC (“Nuveen Asset Management” or the “Collateral Sub-adviser”), to manage the Fund’s collateral invested in cash equivalents, U.S. government securities and other short-term, high grade debt securities. Nuveen Asset Management is a Delaware limited liability company and is registered with the SEC as an investment adviser.

NUVEEN DIVERSIFIED COMMODITY FUND

NOTES TO FINANCIAL STATEMENTS (Continued) (Unaudited)

March 31, 2016

1. Organization (Continued)

The Manager, the Commodity Sub-adviser and the Collateral Sub-adviser are subsidiaries of Nuveen Investments, Inc. (“Nuveen Investments”). Nuveen Investments is a subsidiary of TIAA Global Asset Management.

Investment Objectives and Principal Investment Strategies

The Fund’s investment objective is to generate higher risk-adjusted total return than leading commodity market benchmarks. Risk-adjusted total return refers to the income and capital appreciation generated by a portfolio (the combination of which equals its total return) per unit of risk taken, with such risk measured by the volatility of the portfolio’s total returns over a specific period of time. In pursuing its investment objective, the Fund invests directly in a diversified portfolio of commodity futures, forward and options contracts to obtain broad exposure to all principal groups in the global commodity markets. The Fund’s investment strategy has three principal elements:

•

An actively managed portfolio of commodity futures and forward contracts utilizing Gresham’s proprietary Tangible Asset Program^®, or TAP^®, a long-only rules-based commodity investment strategy designed to maintain consistent, fully collateralized exposure to commodities as an asset class;

•

An integrated program of writing commodity call options designed to enhance the risk-adjusted total return of the Fund’s commodity investments (TAP^® and this options strategy are collectively referred to as TAP PLUS^SM); and

•

A collateral portfolio of cash equivalents, U.S. government securities and other short-term, high grade debt securities.

2. Summary of Significant Accounting Policies

The Fund follows accounting and reporting guidance under Financial Accounting Standards Board (FASB) Accounting Standards Codification (ASC) Topic 946 “Financial Services-Investment Companies.” The following is a summary of significant accounting policies followed by the Fund in the preparation of its financial statements in accordance with accounting principles generally accepted in the United States (“U.S. GAAP”).

The accompanying unaudited financial statements were prepared in accordance with U.S. GAAP for interim financial information and with the instructions for Form 10-Q and the rules and regulations of the SEC. In the opinion of management, all material adjustments, consisting only of normal recurring adjustments, considered necessary for a fair statement of the interim period financial statements have been made. Interim period results are not necessarily indicative of results for a full-year period. These financial statements and the notes thereto should be read in conjunction with the Fund’s financial statements included in the Fund’s Annual Report on Form 10-K for the year ended December 31, 2015.

Basis of Accounting

The accompanying financial statements have been prepared in conformity with U.S. GAAP. The preparation of financial statements in conformity with U.S. GAAP requires management to make certain 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 increases and decreases in net assets from operations during the reporting period. Actual results could differ from those estimates.

NUVEEN DIVERSIFIED COMMODITY FUND

NOTES TO FINANCIAL STATEMENTS (Continued) (Unaudited)

March 31, 2016

2. Summary of Significant Accounting Policies (Continued)

Futures Contracts

The Fund invests in commodity futures contracts. Upon execution of a futures contract, the Fund is obligated to deposit cash or eligible securities, also known as “initial margin,” into an account at its clearing broker. Generally investments in futures contracts also obligate the investor and the clearing broker to settle monies on a daily basis representing changes in the prior days “mark-to-market” of the open contracts. If the Fund has unrealized appreciation the clearing broker would credit the Fund’s account with an amount equal to appreciation and conversely if the Fund has unrealized depreciation the clearing broker would debit the Fund’s account with an amount equal to depreciation. These daily cash settlements are also known as “variation margin.” In lieu of posting variation margin daily, the Fund has deposited cash with the clearing broker in an amount, generally representing approximately twice the required initial margin to cover the initial margin and the daily changes in the market value of its futures investments. Cash held by the clearing broker to cover both margin requirements on open futures contracts is recognized as “Deposits with brokers” on the Statements of Financial Condition.

During the period the futures contract is open, changes in the value of the contract are recognized as an unrealized gain or loss by “marking-to-market” on a daily basis to reflect the changes in market value of the contract, which are recognized as a component of “Unrealized appreciation or depreciation on futures contracts” on the Statements of Financial Condition and “Change in net unrealized appreciation (depreciation) of futures contracts” on the Statements of Operations. When the contract is closed, the Fund records a realized gain or loss equal to the difference between the value of the contract on the closing date and the value of the contract when originally entered into, which is recognized as a component of “Net realized gain (loss) from futures contracts” on the Statements of Operations.

The Fund expects to invest only in long futures contracts. Some short futures positions may arise in futures contracts traded on the London Metal Exchange (“LME”) solely as the result of closing existing long LME futures positions. For every short LME futures contract outstanding, the Fund had previously entered into a long futures contract. The LME Clearing House is the counterparty for both the long and short positions.

Risks of investments in commodity futures contracts include possible adverse movement in the price of the commodities underlying the contracts, the possibility that there may not be a liquid secondary market for the contracts and the possibility that a change in the value of the contract may not correlate with a change in the value of the underlying commodities.

The average number of futures contracts outstanding during the three months ended March 31, 2016 and year ended December 31, 2015 was as follows:


	Three Months Ended March 31, 2016		Year Ended December 31, 2015
Average number of futures contracts outstanding*		2,206		2,432

*	The average number of contracts is calculated based on the number of contracts outstanding at the beginning of the year and at the end of each quarter within the respective period.

Refer to Note 3 – Derivative Instruments and Hedging Activities within these Notes to Financial Statements for further details on futures contracts activity.

Options Contracts

The Fund may write (sell) and purchase options on commodity futures and forward contracts to enhance the Fund’s risk-adjusted total return. When the Fund writes an option, an amount equal to the premium received is

NUVEEN DIVERSIFIED COMMODITY FUND

NOTES TO FINANCIAL STATEMENTS (Continued) (Unaudited)

March 31, 2016

2. Summary of Significant Accounting Policies (Continued)

recognized as a component of “Call options written, at value” on the Statements of Financial Condition and is subsequently adjusted to reflect the current value of the written option until the option expires or the Fund enters into a closing purchase transaction. The changes in value of the options written during the reporting period are recognized as a component of “Change in net unrealized appreciation (depreciation) of call options written” on the Statements of Operations. When an option is exercised or expires, or the Fund enters into a closing purchase transaction, the difference between the net premium received and any amount paid at expiration or on executing a closing purchase transaction is recognized as a component of “Net realized gain (loss) from call options written” on the Statements of Operations. The Fund, as writer of an option, has no control over whether the underlying instrument may be sold (called) and as a result bears the risk of an unfavorable change in the market value of the instrument underlying the written option. There is also the risk the Fund may not be able to enter into a closing transaction because of an illiquid market. During the three months ended March 31, 2016 and year ended December 31, 2015, the Fund wrote call options on futures contracts.

The Fund did not purchase options on futures or forward contracts during the three months ended March 31, 2016 and year ended December 31, 2015. The purchase of options involves the risk of loss of all or part of the cash paid for the options (the premium). The market risk associated with purchasing options is limited to the premium paid. The counterparty credit risk of purchasing options, however, needs to take into account the current value of the option, as this is the performance expected from the counterparty.

Transactions in call options written during the three months ended March 31, 2016 and year ended December 31, 2015 were as follows:


	Three Months Ended March 31, 2016						Year Ended December 31, 2015
	Number of Contracts			Premiums Received			Number of Contracts			Premiums Received
Outstanding, beginning of period		1,098		$	633,387			1,257		$	952,693
Options written		2,098			1,267,141			11,246			6,566,423
Options terminated in closing purchase transactions		(1,147	)		(636,489	)		(6,402	)		(3,978,394	)
Options expired		(639	)		(377,211	)		(4,217	)		(2,400,362	)
Options exercised		(360	)		(326,733	)		(786	)		(506,973	)

Outstanding, end of the period		1,050		$	560,095			1,098		$	633,387

The average number of call options written outstanding during the three months ended March 31, 2016 and year ended December 31, 2015 was as follows:


	Three Months Ended March 31, 2016		Year Ended December 31, 2015
Average number of call options written outstanding*		1,074		1,183

*	The average number of contracts is calculated based on the outstanding number of contracts at the beginning of the year and at the end of each quarter within the respective period.

Refer to Note 3 – Derivative Instruments and Hedging Activities within these Notes to Financial Statements for further details on options activity.

NUVEEN DIVERSIFIED COMMODITY FUND

NOTES TO FINANCIAL STATEMENTS (Continued) (Unaudited)

March 31, 2016

2. Summary of Significant Accounting Policies (Continued)

Forward Contracts

The Fund may enter into forward contracts but did not make any such investments since its commencement of operations on September 27, 2010. A forward contract is an agreement between two parties to purchase or sell a specified quantity of a commodity at or before a specified date in the future at a specified price. Forward contracts are typically traded in the over-the-counter (“OTC”) markets and all details of the contract are negotiated between the counterparties to the agreement. Accordingly, the forward contracts are valued by reference to the contracts traded in the OTC markets.

The contractual obligations of a buyer or seller may generally be satisfied by taking or making physical delivery of the underlying commodity, establishing an opposite position in the contract and recognizing the profit or loss on both positions simultaneously on the delivery date or, in some instances, paying a cash settlement before the designated date of delivery. The forward contracts are adjusted by the daily fluctuation of the underlying commodity or currency and any gains or losses are recognized on the Statements of Operations as unrealized appreciation or depreciation until the contract settlement date.

Forward contracts are, in general, not cleared or guaranteed by a third party. The Fund may collateralize forward commodity contracts with cash and/or certain securities as indicated on its Statements of Financial Condition or Schedule of Investments, when applicable, and such collateral is held for the benefit of the counterparty in a segregated account at the custodian to protect the counterparty against non-payment by the Fund. In the event of a default by the counterparty, the Fund will seek return of this collateral and may incur certain costs exercising its right with respect to the collateral.

The Fund remains subject to credit risk with respect to the amount it expects to receive from counterparties, as those amounts are not similarly collateralized by the counterparty. If a counterparty becomes bankrupt or otherwise fails to perform its obligations due to financial difficulties, the Fund may experience significant delays in obtaining any recovery in a bankruptcy or other reorganization proceeding. The Fund may obtain only limited recovery or may obtain no recovery in such circumstances.

Participants in trading foreign exchange forward contracts often do not require margin deposits, but rely upon internal credit limitations and their judgments regarding the creditworthiness of their counterparties.

The Fund will enter into forward contracts only with large, well-capitalized and well-established financial institutions. The creditworthiness of each of the firms which is a party to a forward contract is monitored by the Manager.

Netting Agreements

In the ordinary course of business, the Fund has entered into transactions subject to enforceable master repurchase agreements or other similar arrangements (“netting agreements”). Generally, the right to offset in netting agreements allows the Fund to offset any exposure to a specific counterparty with any collateral received or delivered to that counterparty based on the terms of the agreements. The Fund manages its cash collateral and securities collateral on a counterparty basis. As of March 31, 2016 and December 31, 2015, the Fund was not invested in any portfolio securities or derivatives, other than the repurchase agreements further described below, that are subject to netting agreements.

Repurchase Agreements

In connection with transactions in repurchase agreements, it is the Fund’s policy that its custodian take possession of the underlying collateral securities, the fair value of which exceeds the principal amount of the

NUVEEN DIVERSIFIED COMMODITY FUND

NOTES TO FINANCIAL STATEMENTS (Continued) (Unaudited)

March 31, 2016

2. Summary of Significant Accounting Policies (Continued)

repurchase transaction, including accrued interest, at all times. If the counterparty defaults, and the fair value of the collateral declines, realization of the collateral may be delayed or limited.

The following tables present the repurchase agreements for the Fund, presented on the Statements of Financial Condition as of March 31, 2016 and December 31, 2015, and recognized as a component of “Short-term investments, at value,” that are subject to netting agreements as of the end of each reporting period, and the collateral delivered related to those repurchase agreements.


	March 31, 2016
	Counterparty		Short-Term Investments, at Value		Collateral Pledged (From) Counterparty*			Net Exposure
Repurchase Agreements		State Street Bank	$	10,769,892	$	(10,769,892	)	$	—


	December 31, 2015
	Counterparty		Short-Term Investments, at Value		Collateral Pledged (From) Counterparty*			Net Exposure
Repurchase Agreements		State Street Bank	$	1,088,249	$	(1,088,249	)	$	—

*	As of March 31, 2016 and December 31, 2015, the value of the collateral pledged from the counterparty exceeded the value of the repurchase agreements. The value of the collateral pledged from the counterparty as of March 31, 2016 and December 31, 2015 was $10,987,865 and $1,111,113, respectively.

Collateral Investments

Currently, approximately 15% of the Fund’s net assets are committed to secure the Fund’s futures contract positions. These assets are placed in a commodity futures account maintained by the Fund’s clearing broker, and are held in high-quality instruments permitted under CFTC regulations.

The Fund’s remaining assets are held in a separate collateral investment account managed by the Collateral Sub-adviser. The Fund’s assets held in the separate collateral account are invested in cash equivalents, U.S. government securities and other high-quality short-term debt securities with final terms not exceeding one year at the time of investment. The collateral portfolio’s debt securities (other than U.S. government securities) are rated at the highest applicable rating as determined by at least one nationally recognized statistical rating organization, or if unrated, judged by the Collateral Sub-adviser to be of comparable quality.

Investment Valuation

Commodity futures contracts and options on commodity futures contracts which are traded on an exchange are valued at the final settlement price or official closing price as determined by the principal exchange on which the instruments are traded as supplied by independent pricing services. These investments are generally classified as Level 1 for fair value measurement purposes. OTC commodity futures and forward contracts and options on commodity futures and forward contracts which are not traded on an exchange are valued, in order of hierarchy, by independent pricing services, price quotations obtained from counterparty broker-dealers, or through fair valuation methodologies as determined by the Manager. These investments are generally classified as Level 2. Additionally, events may occur after the close of the market, but prior to the determination of the Fund’s net asset value, that may affect the values of the Fund’s investments. In such circumstances, the Manager determines a fair valuation for such investments that in its opinion is reflective of fair market value. These investments are generally classified as Level 2 or Level 3 depending on the priority of the significant inputs.

NUVEEN DIVERSIFIED COMMODITY FUND

NOTES TO FINANCIAL STATEMENTS (Continued) (Unaudited)

March 31, 2016

2. Summary of Significant Accounting Policies (Continued)

Prices of fixed-income securities, including, but not limited to, highly-rated agency discount notes and U.S. Treasury bills, are provided by a pricing service approved by the Fund’s Manager. These securities are generally classified as Level 2. The pricing service establishes a security’s fair value using methods that may include consideration of the following: yields or prices of investments of comparable quality, type of issue, coupon, maturity and rating, market quotes or indications of value from security dealers, general market conditions and other information and analysis, including the obligor’s credit characteristics considered relevant. These securities are generally classified as Level 2 or Level 3 depending on the priority of the significant inputs.

Repurchase agreements are valued at contract amount plus accrued interest, which approximates market value. These securities are generally classified as Level 2.

Fair Value Measurements

Fair value is defined as the price that the Fund would receive upon selling an investment or transferring a liability in an orderly transaction to an independent buyer in the principal or most advantageous market for the investment. A three-tier hierarchy is used to maximize the use of observable market data and minimize the use of unobservable inputs and to establish classification of fair value measurements for disclosure purposes. Observable inputs reflect the assumptions market participants would use in pricing the asset or liability. Observable inputs are based on market data obtained from sources independent of the reporting entity. Unobservable inputs reflect the reporting entity’s own assumptions about the assumptions market participants would use in pricing the asset or liability. Unobservable inputs are based on the best information available in the circumstances. The following is a summary of the three-tier hierarchy of valuation inputs.

Level 1—Inputs are unadjusted and prices are determined by quoted prices in active markets for identical securities.

Level 2—Prices are determined using other significant observable inputs (including quoted prices for similar securities, interest rates, prepayment speeds, credit risk, etc.).

Level 3—Prices are determined using significant unobservable inputs (including management’s assumptions in determining the fair value of investments).

The inputs or methodologies used for valuing securities are not an indication of the risks associated with investing in those securities. The following is a summary of the Fund’s fair value measurements as of March 31, 2016 and December 31, 2015:


	March 31, 2016
	Level 1			Level 2			Level 3		Total
Short-Term Investments:
U.S. Government and Agency Obligations	$	—		$	71,293,332		$	—	$	71,293,332
Repurchase Agreements		—			10,769,892			—		10,769,892
Investments in Derivatives:
Futures Contracts*		1,243,222			—			—		1,243,222
Call Options Written**		(283,004	)		(86,513	)		—		(369,517	)

Total	$	960,218		$	81,976,711		$	—	$	82,936,929

NUVEEN DIVERSIFIED COMMODITY FUND

NOTES TO FINANCIAL STATEMENTS (Continued) (Unaudited)

March 31, 2016

2. Summary of Significant Accounting Policies (Continued)



	December 31, 2015
	Level 1			Level 2			Level 3		Total
Short-Term Investments:
U.S. Government and Agency Obligations	$	—		$	70,000,297		$	—	$	70,000,297
Repurchase Agreements		—			1,088,249			—		1,088,249
Investments in Derivatives:
Futures Contracts*		(629,490	)		—			—		(629,490	)
Call Options Written**		(350,916	)		(88,856	)		—		(439,772	)

Total	$	(980,406	)	$	70,999,690		$	—	$	70,019,284

*	Represents the net unrealized appreciation (depreciation) of futures contracts as reported on the Statements of Financial Condition.

**	Refer to the Schedule of Investments for a breakdown of call options written classified as Level 2, which is comprised of the Fund’s call options written on the LME.

The Manager is responsible for the Fund’s valuation process and has delegated daily oversight of the process to the Manager’s Valuation Committee. The Valuation Committee, pursuant to its valuation policies and procedures, is responsible for making fair value determinations, evaluating the effectiveness of the Fund’s pricing policies, and reporting to the Manager’s senior management. The Valuation Committee is aided in its efforts by the Manager’s Securities Valuation Team, which is responsible for administering the daily valuation process and applying fair value methodologies as approved by the Valuation Committee. When determining the reliability of independent pricing services for investments owned by the Fund, the Valuation Committee, among other things, conducts due diligence reviews of the pricing services and monitors the quality of security prices received through various testing reports conducted by the Securities Valuation Team.

For each portfolio instrument that has been fair valued pursuant to the Valuation Committee’s policies, the fair value price is compared against the last available and next available market quotations. The Valuation Committee reviews the results of such testing and fair valuation occurrences are reported to the Manager’s senior management.

Investment Transactions

Investment transactions are recorded on a trade date basis. Realized gains and losses from investment transactions are determined on the specific identification method, which is the same for federal income tax purposes.

Investment Income

Interest income, which reflects the amortization of premiums and includes accretion of discounts for financial reporting purposes, is recorded on an accrual basis.

Brokerage Commissions and Fees

The Fund pays brokerage commissions, including applicable clearing costs, exchange fees, NFA fees, give-up fees, pit brokerage fees and other transaction-related fees and expenses, incurred in connection with its commodity trading activities.

NUVEEN DIVERSIFIED COMMODITY FUND

NOTES TO FINANCIAL STATEMENTS (Continued) (Unaudited)

March 31, 2016

2. Summary of Significant Accounting Policies (Continued)

Income Taxes

No provision for federal, state, and local income taxes has been made in the accompanying financial statements because the Fund has elected to be classified as a partnership for U.S. federal income tax purposes. Each owner of the Fund’s shares will be required to take into account its allocable share of the Fund’s income, gains, losses, deductions and other items for the Fund’s taxable year.

For all open tax years and all major taxing jurisdictions, the Manager of the Fund has concluded that there are no significant uncertain tax positions that would require recognition in the financial statements. Open tax years are those that are open for examination by taxing authorities (i.e., generally the last four tax year ends and the interim tax period since then). Furthermore, the Manager of the Fund is also not aware of any tax positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will significantly change in the next twelve months.

Expense Recognition

All expenses of the Fund are recognized on an accrual basis. The Fund pays all costs and expenses of its operations, including brokerage expenses, custody fees, transfer agent expenses, professional fees, expenses of preparing, printing and distributing reports, notices, information statements, proxy statements, reports to governmental agencies, and taxes, if any.

In connection with the Conversion described previously, the Fund has incurred certain costs and expenses. Such amounts are recognized as a component of “Accrued conversion expenses” on the Statements of Financial Condition and “Conversion expenses” on the Statements of Operations, when applicable.

Calculation of Net Asset Value

The net asset value per share of the Fund on any given day is computed by dividing the value of all assets of the Fund (including any accrued interest), less all liabilities (including accrued expenses and distributions declared but unpaid), by the total number of shares outstanding.

Distributions

The Fund intends to make regular monthly distributions to its shareholders stated in terms of a fixed cents per share distribution rate. Among other factors, the Manager seeks to establish a distribution rate that roughly corresponds to its projections of the total return that could reasonably be expected to be generated by the Fund over an extended period of time. In the event that the amount of income earned or capital gains realized by the Fund is not sufficient to cover the Fund’s distributions, the Fund may be required to liquidate investments to fund distributions at times or on terms that are disadvantageous to the Fund and its shareholders. As market conditions and portfolio performance may change, the rate of distribution on the shares and the Fund’s distribution policy could change. The Manager reserves the right to change the Fund’s distribution policy and the basis for establishing the rate of the Fund’s monthly distributions, or may temporarily suspend or reduce distributions without a change in policy, at any time and may do so without prior notice to shareholders.

Distributions to shareholders are recorded on the ex-dividend date.

Commitments and Contingencies

Under the Fund’s organizational documents, the Manager, Wilmington Trust Company (the Fund’s Delaware trustee) and the Manager’s Independent Committee members are indemnified against certain liabilities arising out of

NUVEEN DIVERSIFIED COMMODITY FUND

NOTES TO FINANCIAL STATEMENTS (Continued) (Unaudited)

March 31, 2016

2. Summary of Significant Accounting Policies (Continued)

the performance of their duties to the Fund. In addition, in the normal course of business, the Fund enters into contracts that provide general indemnifications to other parties. 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. However, the Fund has not had prior claims or losses pursuant to these contracts and believes the risk of loss to be remote.

Financial Instrument Risk

The Fund utilizes commodity futures and options, whose values are based upon an underlying asset and generally represent future commitments that have a reasonable possibility of being settled in cash or through physical delivery. As of March 31, 2016 and December 31, 2015, the financial instruments held by the Fund were traded on an exchange and are standardized contracts.

Market risk is the potential for changes in the value of the financial instruments traded by the Fund due to market changes, including fluctuations in commodity prices. Investing in commodity futures and forward contracts involves the Fund entering into contractual commitments to purchase or sell a particular commodity at a specified date and price. The market risk associated with the Fund’s commitments to purchase commodities will be limited to the gross or face amount of the contracts held. The Fund’s exposure to market risk may be influenced by a number of factors, including changes in international balances of payments and trade, currency devaluations and revaluations, changes in interest and foreign currency exchange rates, price volatility of commodity futures and forwards contracts and market liquidity, weather, geopolitical events and other factors. These factors also affect the Fund’s investments in options on commodity futures and forward contracts. The inherent uncertainty of the Fund’s investments as well as the development of drastic market occurrences could ultimately lead to a loss of all, or substantially all, of investors’ capital.

Credit risk is the possibility that a loss may occur due to failure of a counterparty performing according to the terms of the forwards, futures and option contracts. The Fund may be exposed to credit risk from its investments in commodity futures and forward contracts and options on commodity futures and forward contracts resulting from the clearing house associated with a particular exchange failing to meet its obligations to the Fund. In general, clearing houses are backed by their corporate members who may be required to share in the financial burden resulting from the nonperformance of one of their members, which should significantly reduce this credit risk. In cases where the clearing house is not backed by the clearing members (i.e., as in some foreign exchanges), it may be backed by a consortium of banks or other financial institutions. There can be no assurance that any counterparty, clearing member or clearing house will meet its obligations to the Fund.

The commodity markets have volatility risk. The commodity markets have experienced periods of extreme volatility. General market uncertainty and consequent repricing risk have led to market imbalances of sellers and buyers, which in turn have resulted in significant reductions in values of a variety of commodities. Similar future market conditions may result in rapid and substantial valuation increases or decreases in the Fund’s holdings. In addition, volatility in the commodity and securities markets may directly and adversely affect the setting of distribution rates on the Fund’s shares.

NUVEEN DIVERSIFIED COMMODITY FUND

NOTES TO FINANCIAL STATEMENTS (Continued) (Unaudited)

March 31, 2016

3. Derivative Instruments and Hedging Activities

The Fund records derivative instruments at fair value, with changes in fair value recognized on the Statements of Operations.

The following tables present the fair value of all derivative instruments held by the Fund as of March 31, 2016 and December 31, 2015, the location of these instruments on the Statements of Financial Condition and the primary underlying risk exposure.

March 31, 2016

Location on the Statements of Financial Condition

Underlying
Risk Exposure

Derivative
Instrument

Asset Derivatives

Liability Derivatives

Location

Value

Location

Value

Commodity

Futures Contracts

Unrealized appreciation on futures contracts

2,027,253

Unrealized depreciation on futures contracts

784,031

Commodity

Options

—

Call options written, at value

369,517

Total

2,027,253

1,153,548

December 31, 2015

Location on the Statements of Financial Condition

Underlying
Risk Exposure

Derivative
Instrument

Asset Derivatives

Liability Derivatives

Location

Value

Location

Value

Commodity

Futures Contracts

Unrealized appreciation on futures contracts

1,629,675

Unrealized depreciation on futures contracts

2,259,165

Commodity

Options

—

Call options written, at value

439,772

Total

1,629,675

2,698,937

The following table presents the amount of net realized gain (loss) and change in net unrealized appreciation (depreciation) recognized on derivative instruments during the three months ended March 31, 2016 and March 31, 2015, the location of these instruments on the Statements of Operations and the primary underlying risk exposure.



Commodity Risk Exposure	Three Months Ended March 31, 2016			Three Months Ended March 31, 2015
Net realized gain (loss) from:
Futures contracts	$	(2,621,452	)	$	(15,565,740	)
Call options written		1,198,143			1,834,913
Change in net unrealized appreciation (depreciation) of:
Futures contracts	$	1,872,712		$	8,176,470
Call options written		(3,037	)		(178,288	)

4. Related Parties

The Manager, the Commodity Sub-adviser and the Collateral Sub-adviser are considered to be related parties to the Fund.

NUVEEN DIVERSIFIED COMMODITY FUND

NOTES TO FINANCIAL STATEMENTS (Continued) (Unaudited)

March 31, 2016

4. Related Parties (continued)

For the services and facilities provided by the Manager, the Fund pays the Manager an annual management fee, payable monthly, based on the Fund’s average daily net assets, according to the following schedule:


Average Daily Net Assets	Management Fee
For the first $500 million		1.250	%
For the next $500 million		1.225
For the next $500 million		1.200
For the next $500 million		1.175
For net assets over $2 billion		1.150

“Average daily net assets” represents the total assets of the Fund, minus the sum of its total liabilities.

The Manager and the Fund have entered into sub-advisory agreements with the Commodity Sub-adviser and the Collateral Sub-adviser. Both the Commodity Sub-adviser and the Collateral Sub-adviser are compensated for their services to the Fund from the management fees paid to the Manager, and the Fund does not reimburse the Manager for those fees.

5. Share Repurchase Program

On December 21, 2011, the Fund adopted an open-market share repurchase program, pursuant to which it was authorized to repurchase up to 10% of its outstanding common shares (approximately 920,000 shares) in open-market transactions at the Manager’s discretion.

On March 6, 2014, the Fund reauthorized its share repurchase program, pursuant to which it may repurchase up to 10% of its outstanding common shares as of the reauthorization date (approximately 920,000 shares) in open-market transactions at the Manager’s discretion.

The Fund did not have any transactions in share repurchases during the three months ended March 31, 2016 and year ended December 31, 2015.

6. Financial Highlights

The following financial highlights relate to investment performance and operations for a Fund share outstanding during the three months ended March 31, 2016 and March 31, 2015. The Net Asset Value presentation is calculated using average daily shares outstanding. The Ratios to Average Net Assets are calculated using average daily net assets and are annualized for periods less than a full fiscal year. The Total Returns at Net Asset Value and Market Value are based on the change in net asset value and market value, respectively, for a share during the period. An investor’s return and ratios will vary based on the timing of purchasing and selling Fund shares.

NUVEEN DIVERSIFIED COMMODITY FUND

NOTES TO FINANCIAL STATEMENTS (Continued) (Unaudited)

March 31, 2016

6. Financial Highlights (continued)


	Three Months Ended March 31,
	2016			2015
Net Asset Value:
Net asset value per share—beginning of period	$	9.47		$	13.62
Net investment income (loss)		(0.04	)		(0.06	)
Net realized and unrealized gain (loss)		0.04			(0.63	)
Distributions		(0.17	)		(0.34	)

Net asset value per share—end of period	$	9.30		$	12.59

Market Value:
Market value per share—beginning of period	$	9.02		$	12.83

Market value per share—end of period	$	8.91		$	11.90

Ratios to Average Net Assets:^(a)
Net investment income (loss)		(1.96	)%		(1.97	)%

Expenses		2.24	%		2.06	%

Total Returns:^(b)
Based on Net Asset Value		0.09	%		(5.13	)%

Based on Market Value		0.77	%		(4.66	)%

(a)	Annualized.

(b)

Total Return Based on Net Asset Value is the combination of changes in net asset value per share and the assumed reinvestment of distributions, if any, at net asset value per share on the distribution payment date. The last distribution declared in the period, which is typically paid on the first business day of the following month, is assumed to be reinvested at the net asset value per share at the end of the period. Total returns are not annualized.

Total Return Based on Market Value is the combination of changes in the market price per share and the assumed reinvestment of distributions, if any, at the ending market price per share on the distribution payment date. The last distribution declared in the period, which is typically paid on the first business day of the following month, is assumed to be reinvested at the ending market price per share at the end of the period. Total returns are not annualized.

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

This information should be read in conjunction with the financial statements and notes to financial statements included in Item 1 of Part I of this Quarterly Report (the “Report”). The discussion and analysis includes forward-looking statements that generally relate to future events or future performance. In some cases, you can identify forward-looking statements by terminology such as “may,” “will,” “should,” “expect,” “plan,” “anticipate,” “believe,” “estimate,” “predict,” “potential” or the negative of these terms or other comparable terminology. These forward-looking statements are based on information currently available to Nuveen Commodities Asset Management, LLC (“NCAM” or the “Manager”), Gresham Investment Management LLC and its Near Term Active division (such division referred to herein as “Gresham” or the “Commodity Sub-adviser”) and Nuveen Asset Management, LLC (“Nuveen Asset Management” or the “Collateral Sub-adviser”) and are subject to a number of risks, uncertainties and other factors, both known and unknown, that could cause the actual results, performance, prospects or opportunities of the Nuveen Diversified Commodity Fund (the “Fund”) to differ materially from those expressed in, or implied by, these forward-looking statements.

You should not place undue reliance on any forward-looking statements. Except as expressly required by the federal securities laws or otherwise, the Fund and the Manager undertake no obligation to publicly update or revise any forward-looking statements or the risks, uncertainties or other factors described in this Report, as a result of new information, future events or changed circumstances or for any other reason after the date of this Report.

Introduction

The Fund is a commodity pool which was organized as a Delaware statutory trust on December 7, 2005 and commenced operations on September 27, 2010, with its public offering. The Fund’s shares trade on the NYSE MKT under the ticker symbol “CFD”. The Fund’s investment objective is to generate higher risk-adjusted total return than leading commodity market benchmarks. In pursuing its investment objective, the Fund invests directly in a diversified portfolio of commodity futures and forward contracts to obtain broad exposure to all principal groups in the global commodity markets. The Fund is unleveraged, and the Fund’s commodity contract positions are fully collateralized with cash equivalents, U.S. government securities and other short-term, high-grade debt securities. The Fund writes commodity call options seeking to enhance the Fund’s risk-adjusted total return. The Manager focuses on the Bloomberg Commodity Index (“BCOM”) when evaluating the performance of the commodity futures, forwards, and options positions (the “commodity portfolio”) in the Fund’s portfolio.

Proposed Conversion to ETF Structure

In connection with the Conversion, the Manager intends to implement a number of additional changes to the Fund that the Manager believes will better align a number of the Fund’s features with its newly-adopted ETF structure, including a reduction of the management fee, and changes to the Fund’s investment strategy, name and distribution policy. None of these expected changes have been finalized, and they remain subject to further revision by the Manager. In addition, following the Conversion, the Manager will continue to have the ability, without shareholder approval, to make subsequent changes to the operation of the Fund.

Fund’s shares will trade following the Conversion. The Fund has been working with the NYSE MKT, which has initiated the rule making process for the new rule, which will ultimately require approval by the SEC. There can be no assurance that such clearance will be obtained, or if obtained, that the Conversion will be completed in the anticipated time frame.

Results of Operations

The Quarter Ended March 31, 2016 – Fund Share Price

The Fund’s shares traded on the NYSE MKT at a price of $8.91 on the close of business on March 31, 2016. This represents a decrease of 1.22% in share price (not including an assumed reinvestment of distributions) from the $9.02 price at which the shares of the Fund traded on the close of business on December 31, 2015. The high and low intra-day share prices for the quarter were $9.16 (March 21, 2016) and $7.88 (January 20, 2016), respectively. During the quarter, the Fund declared distributions totaling $0.174 per share to shareholders, of which $0.058 was paid on April 1, 2016. The remainder was paid during the quarter. The Fund’s cumulative total return on market value for the quarter, which assumes reinvestment of such distributions, was 0.77%. At March 31, 2016, shares of the Fund traded at a 4.19% discount to the Fund’s net asset value of $9.30 per share.

The Quarter Ended March 31, 2015 – Fund Share Price

The Fund’s shares traded on the NYSE MKT at a price of $11.90 on the close of business on March 31, 2015. This represents a decrease of 7.25% in share price (not including an assumed reinvestment of distributions) from the $12.83 price at which the shares of the Fund traded on the close of business on December 31, 2014. The high and low intra-day share prices for the quarter were $13.00 (January 15, 2015) and $11.52 (March 18, 2015), respectively. During the quarter, the Fund declared distributions totaling $0.336 per share to shareholders, of which $0.103 was paid on April 1, 2015. The remainder was paid during the quarter. The Fund’s cumulative total return on market value for the quarter, which assumes reinvestment of such distributions, was -4.66%. At March 31, 2015, shares of the Fund traded at a 5.48% discount to the Fund’s net asset value of $12.59 per share.

The Quarter Ended March 31, 2016 – Net Assets of the Fund

The Fund’s net assets decreased from $85.6 million at December 31, 2015, to $84.1 million at March 31, 2016, a decrease of $1.5 million. The decrease in the Fund’s net assets was due to $1.6 million of distributions to shareholders, offset by net income of $0.1 million.

The Fund generated net income of $0.1 million for the quarter ended March 31, 2016, resulting from interest income of $0.1 million and change in net unrealized appreciation of $1.9 million, offset by expenses of $0.5 million and net realized losses of $1.4 million.

During the quarter ended March 31, 2016, the Fund’s collateral investments generated interest income of $57,750, which represents 0.07% of average net assets for the quarter ended March 31, 2016.

The net asset value per share on March 31, 2016, was $9.30. This represents a decrease of 1.80% in net asset value per share (not including an assumed reinvestment of distributions) from the $9.47 net asset value per share as of December 31, 2015. During the quarter, the Fund declared distributions totaling $0.174 per share to shareholders, of which $0.058 was paid on April 1, 2016. When an assumed reinvestment of these distributions is taken into account, the cumulative total return for the Fund on net asset value was 0.09% for the quarter ended March 31, 2016.

The Quarter Ended March 31, 2015 – Net Assets of the Fund

The Fund’s net assets decreased from $123.2 million at December 31, 2014, to $113.9 million at March 31, 2015, a decrease of $9.3 million. The decrease in the Fund’s net assets was due to a net loss of $6.3 million, in addition to $3.0 million of distributions to shareholders.

The Fund generated a net loss of $6.3 million for the quarter ended March 31, 2015, resulting from change in net unrealized appreciation of $8.0 million, offset by net realized losses of $13.7 million, and total expenses of $0.6 million.

During the quarter ended March 31, 2015, the Fund’s collateral investments generated interest income of $25,959, which represents 0.02% of average net assets for the quarter ended March 31, 2015.

The net asset value per share on March 31, 2015, was $12.59. This represents a decrease of 7.56% in net asset value (not including an assumed reinvestment of distributions) from the $13.62 net asset value as of December 31, 2014. The Fund declared distributions totaling $0.336 per share to shareholders during the quarter. When an assumed reinvestment of these distributions is taken into account, the cumulative total return for the Fund on net asset value was -5.13% for the quarter ended March 31, 2015.

The Quarter Ended March 31, 2016 – Overall Commodity Market Commentary

After a volatile start, the broad commodity market, as measured by the BCOM, ended with a slight gain for the first quarter of 2016. In early January, worldwide financial market turmoil sent global equity and commodity prices tumbling. Risk aversion intensified as the World Bank downgraded its global growth forecast, persistent global supply gluts pushed crude oil prices below $30 per barrel, and concerns about how quickly the U.S. Federal Reserve (the “Fed”) intended to raise short-term interest rates. The Bank of Japan added to the turmoil in the markets with its surprise decision in January to join Europe in adopting a negative interest rate policy.

However, later in February, the commodity market began to rebound. Investor sentiment improved amid signals that fewer-than-expected Fed rate increases were likely in 2016 and speculation that members of the Organization of the Petroleum Exporting Countries (OPEC) and Russia might agree to a production freeze at an upcoming April meeting. With the Fed’s more dovish tone, the U.S. dollar weakened appreciably relative to major world currencies, including those of emerging markets, which provided an additional tailwind to commodity prices.

Weather continued to influence commodities, as El Niño-induced droughts bolstered soybean oil and sugar prices, in particular, during the quarter. However, the El Niño pattern is now waning and investors are monitoring forecasts for a 2016 La Niña weather phenomenon, which produces the opposite effects. Additionally during the quarter, terrorist attacks at Belgium’s Brussels airport and transit system, an Ivory Coast beach and a Nigerian oil pipeline disrupted financial markets, although the impact on commodity markets of these attacks was temporary.

The fundamental outlook for many commodities continued to be challenging. Notably, crude oil, natural gas, corn, copper and nickel remained in oversupply conditions, which pressured prices for those commodities during the quarter. The BCOM as a whole gained 0.4% for the quarter, buoyed by a double-digit return in gold. As gold reasserted its role as a favored “safe haven” asset in times of uncertainty, the precious metals group was by far the best-performing sector, rising 15.2% for the quarter. In contrast, despite a March rally, the energy group stayed in negative territory for the quarter overall, down 9.4%, and was the weakest performer in the BCOM. Returns in foods and fibers, as grouped by Gresham, were down 1.1%, livestock was up 1.1%, agriculture was up 1.4%, and industrial metals posted a gain of 2.2%.

The Quarter Ended March 31, 2015 – Overall Commodity Market Commentary

The broad commodity market, as measured by the BCOM, fell 5.9% for the three-month period, with all commodity groups except precious metals ending the period lower.

The largest group by weight, energy commodities represented 33.2% of the BCOM at the end of the period. All energy commodities except unleaded gasoline traded lower over the period, collectively down 8.2%. Crude oil continued to reel from the OPEC decision at year-end to maintain production levels despite falling prices, as well as expectations for weakening global demand amid a strong U.S. dollar and weak economic data in China and Europe. Natural gas prices also suffered amid plentiful supply as a result of record production and softer demand expectations driven by mild weather forecasts. Unleaded gas and heating oil fared slightly better, as a U.S. refinery strike in February and cold weather hampered refining capacity. Lower gas prices also bolstered consumer demand in the U.S., China and India.

Agricultural commodities, as grouped by Gresham, made up 21.9% of the BCOM at the end of the period. The group fell 7.5% over the period, with all agriculture commodities declining. Wheat fell 12.6% and was the weakest performer in the group, dragged down by its sensitivity to the strong U.S. dollar, which makes foreign crop prices cheaper in comparison. Corn prices fell 7.2% on news that U.S. stockpiles and spring planting estimates were larger than analysts expected.

The commodities in the industrial metals group comprised 16.7% of the BCOM at the end of the period. Concerns about China’s economic slowdown and the rallying U.S. dollar continued to hamper the sector, which ended the period down 5.3%.

The precious metals group represented 16.5% of the BCOM at the end of the period. Gold prices were volatile, topping $1,300 per ounce in January, then falling below $1,150 in mid-March, and advancing in the final weeks of the period to end close to where they started. Silver, however, was one of the few commodities in the BCOM with a positive return for the period. As with gold, silver prices rose early in the period, and a short-covering rally in March in which traders drove prices higher as they bought back contracts to cover open short positions, which helped silver rise 6.1% for the period.

Foods and fibers commodities, as grouped by Gresham, made up a combined 6.7% of the BCOM at the end of the period. Sugar and Arabica coffee, which are predominantly produced in Brazil, experienced sharp sell-offs as growing conditions were expected to improve with favorable weather forecasts and as weakness in the Brazilian currency encourages exports, which could further contribute to global supply gluts. Cocoa futures, which the Fund holds but the BCOM does not, also lost value amid waning chocolate demand, especially in the emerging markets, and an expected bumper crop in the Ivory Coast. In contrast, cotton prices rallied on the back of strong U.S. export sales and lower expected plantings in the U.S.

Livestock is the smallest group, comprising 5.1% of the BCOM at the end of the quarter. Lean hogs were the worst-performing contract in the BCOM, plunging 23.7% during the quarter. Supply continued to outpace demand for several reasons. U.S. exports slackened, due to the stronger U.S. dollar and a port strike in California that created a bottleneck for sales to Asia. Meanwhile, a seasonal increase in a fatal pig virus did not materialize as expected, and cheaper feed costs resulting from weaker grain prices continued to encourage farmers to bulk up their hogs.

The Quarter Ended March 31, 2016 – Fund Commodity Portfolio Commentary

The Fund’s commodity portfolio was up 0.6% for the three-month period, before considering the expenses of the Fund or the performance of its collateral portfolio. The overall commodities market, as measured by the BCOM, rose 0.4%. The Fund’s total return on net asset value for the same period, which includes the effect of the Fund’s expenses and the performance of the collateral portfolio, and assumes reinvestment of the Fund’s distributions, was 0.09%.

The Fund writes – that is, sells – covered call options on its portfolio’s commodity futures, seeking to limit return volatility, and to provide cash flow to support the Fund’s distributions. Gresham generally sells exchange-traded commodity call options on up to 50% of the value of each of the Fund’s commodity futures contracts, when those options are deemed to have sufficient trading volume and liquidity. The Fund receives cash premiums in return.

During the quarter the Fund’s option-writing activity added to performance for the period. Although premiums collected on call options helped manage the Fund’s volatility, as measured by the standard deviation of return, for the quarter the Fund’s standard deviation was slightly higher than the BCOM’s. Commodity prices were especially volatile at the beginning of the period, and the Fund held higher weightings than the BCOM in some of the more volatile commodities, such as crude oil and industrial metals, which resulted in the Fund’s standard deviation for the quarter being slightly higher than the BCOM’s.

At the commodity group level, the largest contributor to the Fund’s outperformance relative to the BCOM was the energy group, with smaller relative gains provided by the industrial metals group. The precious metals group was the chief detractor from the Fund’s relative performance, while the Fund’s agriculture, livestock, and foods and fibers positions had a neutral or slightly negative impact on relative returns. Also, in early January, the Fund’s target weights were rebalanced. No commodities were added to or removed from the portfolio.

Within the energy group, the Fund’s outperformance relative to the BCOM was mainly driven by its underweight in natural gas. Natural gas was the weakest-performing commodity in the energy group and the BCOM overall, as prices continued to be pressured by unseasonal warm weather, ample storage and high production levels. The Fund also benefited from its position in crude oil, which outpaced the BCOM’s position. Early in the year, crude oil prices continued to decline on oversupply concerns and global macroeconomic woes but recovered beginning in late February amid evidence of slowing U.S. production levels and anticipation that key producers might agree to a production freeze at an April meeting in Doha, Qatar. The Fund sold call options on crude oil and unleaded gasoline that went in-the-money as prices for these commodities rose later in the quarter, and the options contracts were exercised. This reduced the Fund’s participation in the petroleum complex rally. However, the heightened price volatility in WTI crude oil contracts during the quarter helped the Fund gain higher premiums on options sold on those contracts, which improved performance.

In industrial metals, the Fund’s overweight position was advantageous to relative returns. The Fund’s underweight in zinc, which rallied in the broad market on expectations of tightening supplies, slightly hurt relative performance but was more than offset by a positive contribution from the Fund’s overweight copper position. Copper prices declined early in the quarter on oversupply fears but weakness in the U.S. dollar later in the quarter helped prices rebound.

The precious metals group was the main detractor from relative performance during the quarter. During the quarter, gold and silver benefited from robust investor demand due to being perceived as “safe haven” assets, as well as weakness in the U.S. dollar. The Fund held a lower weighting than the BCOM in the group, which dampened relative returns. Additionally, gold options written by the Fund went in-the-money and were exercised in March, keeping the Fund from fully participating in gold’s price appreciation during the quarter.

In the agriculture group, the Fund’s underweight in soybean oil detracted from relative performance. El Niño-induced drought continued to hurt palm oil crops, driving prices higher across all vegetable oils, including soybean oil. In addition, a portion of the soybean oil options contracts sold by the Fund were exercised during the quarter when prices were rising, which limited the Fund’s full participation in the rally. However, a positive contribution from an underweight in corn, which saw falling prices due to oversupply concerns, helped to partially mitigate those relative losses.

The livestock group also delivered mixed results for the quarter. The Fund’s greater exposure to live cattle and feeder cattle dampened relative performance, as herd rebuilding in the U.S. and weakening beef demand weighed

on prices. Conversely, the Fund’s lean hogs exposure added to relative performance. Lean hogs prices rose during the quarter due to supply disruptions and stronger demand. However, lean hogs call options sold by the Fund went in-the-money and were exercised, tempering the Fund’s gain from the price increase.

In foods and fibers commodities, as grouped by Gresham, the Fund’s positions in sugar and white sugar aided relative performance, while its cocoa position was detrimental. White sugar and cocoa are not represented in the BCOM. Sugar rallied on expectations of a global production deficit, rising demand for sugar-based ethanol, and favorable currency movements. However, the performance of the Fund’s sugar position was slightly diminished by the exercise of a portion of the Fund’s call options position in February. Cocoa performed poorly amid aggressive selling by investors holding long positions and concerns about waning global demand for chocolate.

The Quarter Ended March 31, 2015 – Fund Commodity Portfolio Commentary

The Fund’s commodity portfolio declined 4.7% for the three-month period, before considering the expenses of the Fund. The overall commodities market, as measured by the BCOM, was down 5.9%. The Fund’s total return on net asset value for the same period, which includes the effect of the Fund’s expenses and the performance of the collateral portfolio and assumes reinvestment of the Fund’s distributions, was -5.13%.

The Fund writes–that is, sells–covered call options on its portfolio’s commodity futures, seeking to limit return volatility, and to provide cash flow to support the Fund’s distributions. Gresham sells exchange-traded commodity call options on up to 50% of the value of each of the Fund’s commodity futures contracts, when those options are deemed to have sufficient trading volume and liquidity. The Fund receives cash premiums in return.

During the quarter, the Fund sold options on approximately 50% of the value of each commodity position. Overall, the Fund’s option-writing activity contributed positively to performance for the period and helped reduce the Fund’s volatility versus the BCOM, as measured by the standard deviation of return. Call options written on the Fund’s agriculture, foods and fibers, and livestock positions expired out of the money, helping the Fund’s comparative performance against the BCOM.

At the commodity group level, relative to the BCOM, the Fund’s commodity portfolio benefited from energy, agriculture, foods and fibers, and industrial metals, while precious metals detracted from relative performance and livestock had a neutral impact.

In the energy group, the Fund was down 6.7% versus the BCOM’s 8.2% drop. The Fund’s natural gas position drove relative outperformance in the energy group. The Fund benefited from a lower weighting in natural gas, the higher premiums collected from writing natural gas options in a higher volatility environment, and favorable contract selection. However, relative gains were somewhat tempered by crude oil, heating oil, and gasoline options that went in the money and were exercised during the period. Heightened price volatility in heating oil and gasoline futures also helped the Fund gain larger premiums on options sold on those contracts, which was additive to performance.

The Fund’s agriculture position lost 5.3%, while the BCOM’s tumbled 7.5%. The Fund’s overall underweight in the group, and particularly in corn and wheat, helped relative performance. Additionally, all of the Fund’s agriculture options expired out of the money, further improving the Fund’s performance relative to the BCOM.

In the industrial metals group, the Fund declined 4.5% and the BCOM lost 5.3%. Copper contributed the most to the Fund’s better relative performance in the sector. The Fund’s more diversified copper position, comprised of both LME and COMEX contracts, outperformed the Index’s copper position, which only has COMEX exposure. However, the Fund was hurt by aluminum options that went in the money during the quarter and were exercised against it.

The Fund’s precious metals position was up 0.8%, trailing the BCOM’s 1.3% return for the group. Gold options that were exercised against the Fund detracted from its relative performance. Additionally, despite the Fund’s outperformance in silver, its underweight to the commodity during the period hurt its performance relative to the BCOM.

The foods and fibers group, driven by declines in sugar and coffee, was the worst performing group in both the Fund and the BCOM for the quarter, down 11.8% and 13.7%, respectively. The Fund’s relative performance benefited primarily from the options strategy, particularly in coffee and sugar, where the Fund wrote call options on a greater share of its contracts. While the Fund typically sells call options on approximately 50% of the value of each commodity contract seeking to reduce risk, in some instances the Fund writes calls on a higher value of a contract to cover a separate contract position within the same commodity type, that may have a relatively illiquid options market. In this case, the Robusta coffee and white sugar (London-traded) options markets lacked sufficient liquidity, and therefore the Fund wrote additional Arabica coffee and NY-traded sugar calls to cover its Robusta coffee and white sugar positions. All of the foods and fibers options sold expired out of the money during the quarter, benefitting the Fund’s relative performance against the BCOM.

The Fund’s livestock position declined 7.5%, and the BCOM’s fell 9.8%. Live cattle contributed positively to the Fund’s relative returns, bolstered by favorable contract selection, a higher weighting than the BCOM, and the options strategy. As with coffee and sugar, the Fund wrote calls on a higher value of the live cattle position to cover its feeder cattle position, given the insufficient liquidity in the feeder cattle options market. The Fund’s relative overweight in lean hogs was disadvantageous to relative performance in a period of falling prices, offsetting the benefits of the cattle positions.

Fund Total Returns

The following table presents selected total returns for the Fund and BCOM as of March 31, 2016. Market value and net asset value total returns are based on the change in market value and net asset value, respectively, for a share during the period presented. The total returns presented assume the reinvestment of distributions at market value on the distribution payment date for returns based on market value, and at net asset value on the distribution payment date for returns based on net asset value. The last distribution declared in the period, which is typically paid on the first business day of the following month, is assumed to be reinvested at the market price at the end of the period for total returns based on market value, and at the net asset value at the end of the period for total returns based on net asset value.


	Total Returns as of March 31, 2016
	Cumulative			Average Annual
	3 Months			1 Year			5 Year			Since Inception
Market Value		0.77	%		-18.29	%		-12.54	%		-9.51	%
Net Asset Value		0.09	%		-19.70	%		-12.86	%		-8.60	%
BCOM		0.42	%		-19.56	%		-14.15	%		-9.82	%

“Since inception” returns present performance for the period since the Fund’s commencement of operations on September 27, 2010.

Returns represent past performance, which is no guarantee of future performance.

Distributions

The Fund makes regular monthly distributions to its shareholders stated in terms of a fixed cents per share distribution rate. The Manager seeks to establish a distribution rate that, among other factors, roughly corresponds to its projections of the total return that could reasonably be expected to be generated by the Fund over an extended period of time. The Fund’s projected or actual distribution rate is not a prediction of what the Fund’s actual total returns will be over any specific future period.

The Fund’s ability to make distributions will depend on a number of factors, including, most importantly, the long-term total returns generated by the Fund’s commodity investments and the gains generated through the Fund’s options strategy. The Fund’s actual financial performance will likely vary significantly from month-to-month and from year-to-year, and there may be periods, perhaps of extended durations of up to several years, when the distribution rate exceeds the Fund’s actual total returns. In the event that the amount of income earned or capital gains realized by the Fund is not sufficient to cover the Fund’s distributions, the Fund may be required to liquidate investments to fund distributions at times or on terms that could be disadvantageous to the Fund and its shareholders.

Because the Fund’s investment performance since its inception has not been sufficient to cover the distributions made, the Fund has effectively been drawing upon its assets to meet payments prescribed by its distribution policy. The Fund also has paid fees and expenses that have also been drawn from the Fund’s assets.

As market conditions and portfolio performance may change, the rate of distributions on the shares and the Fund’s distribution policy could change. The Manager reserves the right to change the Fund’s distribution policy and the basis for establishing the rate of its monthly distributions, or may temporarily suspend or reduce distributions without a change in policy, at any time and may do so without prior notice to shareholders. The reduction or elimination of the Fund’s distributions could have the effect of increasing the Manager’s management fees.

Commodity Portfolio Composition and Weightings

The table below presents the composition and weightings of the Fund’s TAP PLUS^SM strategy (Gresham’s long-only rules-based investment strategy, which uses futures and forward contracts to gain exposure to commodities and options to enhance the Fund’s risk-adjusted total return) and the BCOM as of March 31, 2016. The table below serves as a guide to how the composition and weightings of the Fund’s TAP PLUS^SM investment strategy compared to that of the BCOM, a leading commodity market benchmark, as of March 31, 2016.


		Composition
Commodity Group	Commodity	TAP PLUS^SM		BCOM
Energy	Crude Oil	19.50	%	16.01	%
	Heating Oil	6.01	%	3.90	%
	Natural Gas	5.55	%	6.81	%
	Unleaded Gas	3.54	%	4.28	%

		34.60	%	31.00	%

Industrial Metals	Copper	8.31	%	7.52	%
	Aluminum	5.39	%	4.44	%
	Zinc	1.78	%	2.79	%
	Nickel	1.69	%	2.19	%
	Lead	0.81	%	0.00	%

		17.98	%	16.94	%

Agriculturals	Soybean	5.20	%	5.66	%
	Corn	3.73	%	6.89	%
	Wheat	3.73	%	4.33	%
	Soybean Meal	2.38	%	2.70	%
	Soybean Oil	1.25	%	3.07	%

		16.29	%	22.65	%

Precious Metals	Gold	8.97	%	12.13	%
	Silver	2.48	%	4.39	%
	Platinum	0.70	%	0.00	%
	Palladium	0.54	%	0.00	%

		12.69	%	16.52	%

Livestock	Live Cattle	6.79	%	3.05	%
	Lean Hogs	2.54	%	2.58	%
	Feeder Cattle	2.03	%	0.00	%

		11.36	%	5.63	%

Foods and Fibers	Sugar	2.52	%	3.63	%
	Coffee	2.18	%	2.30	%
	Cotton	1.43	%	1.33	%
	Cocoa	0.95	%	0.00	%

		7.08	%	7.26	%

Total		100.00	%	100.00	%

Liquidity and Capital Resources

The Fund pursues its investment objective by taking long positions in commodity futures contracts and writing commodity call options as part of an integrated program designed to enhance the risk-adjusted total return of the Fund’s commodity investments. The Fund’s investment activity in futures contracts and writing commodity call options does not require a significant outlay of capital. The Fund currently expects to post approximately 10% to 25% of its net assets in a margin account with the Fund’s clearing broker to cover its futures contracts; the remaining assets are held by the Fund in a separate collateral pool managed by the Collateral Sub-adviser. The Fund believes the higher allocation to initial margin will provide a significant buffer to accommodate variations in the required margin posting that may result from market volatility, potential gains and losses on the contracts, and changes in margin rules, and will minimize the frequency of cash transfers from the Fund’s other collateral pool to meet variation margin requirements. The Fund does not intend to utilize leverage and its commodity contract positions are fully collateralized. Ordinary expenses and distributions are met by cash on hand, although distributions may at times consist of return of capital and may require that the Fund liquidate investments. The Fund earns interest on its continuing investments in cash equivalents, U.S. government securities and other short-term, high-grade debt securities. The Fund also generates cash from the premiums it receives when writing call options on the Fund’s futures contracts.

The Fund’s investments in commodity futures contracts and options on commodity futures contracts may be subject to periods of illiquidity because of market conditions, regulatory considerations and other reasons. For example, commodity exchanges limit fluctuations in certain commodity futures contract prices during a single day by regulations referred to as “daily limits.” During a single day, no trades may be executed at prices beyond the daily limit. Once the price of a futures contract for a particular commodity has increased or decreased by an amount equal to the daily limit, positions in the futures contract can neither be taken nor liquidated unless the traders are willing to effect trades at or within the limit. Commodity futures prices have occasionally moved to the daily limit for several consecutive days with little or no trading. Such market conditions could prevent the Fund from promptly liquidating its commodity futures positions.

The Fund’s shares trade on the NYSE MKT and shares are not redeemed by the Fund in the normal course of business (although the Manager may decide to do so at its discretion), thereby alleviating the need for the Fund to have liquidity available for possible shareholder redemptions. On December 21, 2011, the Fund announced the adoption of an open-market share repurchase program, pursuant to which it is authorized to repurchase an aggregate of up to 10% of its outstanding common shares as of the authorization date in open-market transactions. On March 6, 2014, the Fund reauthorized its share repurchase program, pursuant to which it may repurchase up to 10% of its outstanding common shares as of the reauthorization date (approximately 920,000 shares) in open-market transactions, at the Manager’s discretion. Refer to “Part II—Item 2. Unregistered Sales of Equity Securities and Use of Proceeds” in this Report for details of repurchase activity, if any, during the three months ended March 31, 2016.

The Fund is unaware of any other trends, demands, conditions or events that are reasonably likely to result in material changes to the Fund’s liquidity needs.

Because the Fund invests in commodity futures contracts, its capital is at risk from changes in the value of these contracts (market risk) or the inability of clearing brokers or counterparties to perform under the terms of the contracts (credit risk).

Market Risk

Investing in commodity futures and forward contracts involves the Fund entering into contractual commitments to purchase or sell a particular commodity at a specified date and price. The market risk associated with the Fund’s commitments to purchase commodities will be limited to the gross or face amount of the contracts held.

The Fund’s exposure to market risk may be influenced by a number of factors, including changes in international balances of payments and trade, currency devaluations and revaluations, changes in interest and foreign currency exchange rates, price volatility of commodity futures and forwards contracts and market liquidity, weather, geopolitical events and other factors. These factors also affect the Fund’s investments in options on commodity futures and forward contracts. The inherent uncertainty of the Fund’s investments as well as the development of drastic market occurrences could ultimately lead to a loss of all, or substantially all, of investors’ capital.

Credit Risk

The Fund may be exposed to credit risk from its investments in commodity futures and forward contracts and options on commodity futures and forward contracts resulting from the clearing house associated with a particular exchange failing to meet its obligations to the Fund. In general, clearing houses are backed by their corporate members who may be required to share in the financial burden resulting from the nonperformance of one of their members, which should significantly reduce this credit risk. In cases where the clearing house is not backed by the clearing members (i.e., as in some foreign exchanges), it may be backed by a consortium of banks or other financial institutions. There can be no assurance that any counterparty, clearing member or clearing house will meet its obligations to the Fund.

The Fund attempts to minimize market risks, and the Commodity Sub-adviser attempts to minimize credit risks, by abiding by various investment limitations and policies, which include limiting margin accounts, investing only in liquid markets and permitting the use of stop-loss orders. The Commodity Sub-adviser implements procedures which include, but are not limited to:

•

Employing the options strategy to limit directional risk (although there is no guarantee that the Fund’s options strategy will be successful);

•

Executing and clearing trades only with counterparties the Commodity Sub-adviser believes are creditworthy;

•

Limiting the amount of margin or premium required for any one commodity contract or all commodity contracts combined; and

•

Generally limiting transactions to contracts which are traded in sufficient volume to permit the efficient taking and liquidating of positions.

A commodity broker, when acting as the Fund’s futures commission merchant, is required by Commodity Futures Trading Commission (“CFTC”) regulations to separately account for and segregate all assets of the Fund relating to domestic futures investments. A commodity broker is not allowed to commingle such assets with other assets of the commodity broker. In addition, CFTC regulations also require a commodity broker, when acting as the Fund’s futures commission merchant, to hold in a “secured” account the assets of the Fund related to foreign commodity futures investments and not commingle such assets with assets of the commodity broker.

If the Fund purchases over-the-counter (“OTC”) commodity put options, the Fund will be exposed to credit risk that the counterparty to the contract will not meet its obligations. In cases where the Fund purchases OTC commodity put options with a counterparty, the sole recourse of the Fund will be the financial resources of the counterparty to the transaction since there is no clearing house to assume the obligations of the counterparty.

As it relates to the Fund’s assets held as collateral for its investments in commodity futures and forwards contracts, there is credit risk present in the securities used to invest the Fund’s cash. While these consist of cash equivalents, U.S. government securities and other short-term, high-grade debt securities, like any investment, these too would be affected by any credit difficulties that might be experienced by their issuers.

Off-Balance Sheet Arrangements

As of March 31, 2016, the Fund has not utilized, nor does it expect to utilize in the future, special purpose entities to facilitate off-balance sheet financing arrangements and has no loan guarantee arrangements or off-balance sheet arrangements of any kind other than agreements entered into in the normal course of business, which may include indemnification provisions related to certain risks service providers undertake in performing services which are in the best interests of the Fund. While the Fund’s exposure under such indemnification provisions cannot be estimated, these general business indemnifications are not expected to have a material impact on the Fund’s financial position.

Contractual Obligations

The Fund’s contractual obligations are with the Manager, the Collateral Sub-adviser, the Commodity Sub-adviser, the custodian, the transfer agent, the commodity broker and, to the extent that the Fund enters into OTC transactions, dealers. Management fee payments made to the Manager are calculated as a percentage of the Fund’s net assets. The custodian fee is primarily based on the Fund’s assets and trading activity. The transfer agent fee is calculated based on the Fund’s total number of registered accounts. Commission payments to the commodity broker are on a contract-by-contract or round-turn basis, and payments to forward contract dealers are usually based on a fee or percentage of the notional value of the contract. The Manager cannot anticipate the amount of payments that will be required under these arrangements for future periods, as these payments are based on figures which are not known until a future date. Additionally, these agreements may be terminated by either party for various reasons.

Critical Accounting Policies

The Fund’s critical accounting policies are as follows:

•

Preparation of the financial statements and related disclosures in conformity with accounting principles generally accepted in the United States requires the application of appropriate accounting rules and guidance, as well as the use of estimates and assumptions. The Fund’s application of these policies involves judgments and actual results may differ from the estimates used.

•

The Fund holds a significant portion of its assets in futures contracts, options contracts, and short-term, high-grade debt instruments, all of which are recorded on a trade date basis and recognized at fair value in the financial statements, with changes in fair value reported on the Statements of Operations as change in net unrealized appreciation (depreciation).

•

The use of fair value to measure financial instruments, with related unrealized appreciation (depreciation) recognized in earnings in each period, is fundamental to the Fund’s financial statements.

•

The fair value of a financial instrument is the amount 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.

•

Generally, commodity futures and forward contracts and options on commodity futures and forward contracts traded on an exchange will be valued at the final settlement price or official closing price as determined by the principal exchange on which the instruments are traded as supplied by independent pricing services. OTC commodity futures and forward contracts and options on commodity futures and forward contracts not traded on an exchange will be valued, in order of hierarchy, by independent pricing services, price quotations obtained from counterparty broker-dealers, or through fair valuation methodologies as determined by the Manager.

•

Market quotations for exchange-traded commodity futures and forward contracts and options on commodity futures and forward contracts may not be readily available as a result of significant events, which can include, but are not limited to: trading halts or suspensions, market disruptions, or the absence of market makers willing to make a market in such instruments. In addition, events may occur after the close of the market, but prior to the determination of the Fund’s net asset value, which may

affect the values of the Fund’s investments. In such circumstances, the Manager will determine a fair valuation for such investments that in its opinion is reflective of fair market value.

•

Realized gains (losses) on closed positions and changes in unrealized appreciation (depreciation) on open positions are determined on a specific identification basis and recognized in the Statements of Operations during the period in which the contract is closed or the changes occur, respectively.

•

Interest income, which reflects the amortization of premiums and includes accretion of discounts for financial reporting purposes, is recorded on an accrual basis.

Refer to note 2 of the Fund’s Notes to Financial Statements in “Part 1—Item 1. Financial Statements” of this Report for the summary of significant accounting policies of the Fund.

Item 3.

Quantitative and Qualitative Disclosures About Market Risk

Quantitative Disclosure

The Fund is exposed to commodity price risk through the futures and forward contracts and the options on futures and forward contracts that the Fund invests in as part of its investment strategy. These instruments have been entered into for trading purposes. The following table provides information about the Fund’s futures contracts and options on futures contracts, which are sensitive to changes in commodity prices, as of March 31, 2016. The Fund expects to invest only in long futures contracts. Some short futures positions arise in futures contracts traded on the London Metal Exchange (“LME”) solely as the result of closing existing long LME futures positions. For every short LME futures contract held by the Fund, the Fund had previously entered into a long futures contract. As of March 31, 2016, the Fund has not invested in forward contracts.

Futures Contracts


Commodity Group	Contract	Contract Position		Contract Expiration		Number of Contracts		Valuation Price		Contract Multiplier		Notional Amount at Value
Energy	Crude Oil
	ICE Brent Crude Oil Futures Contract		Long		June 2016		146	$	40.3300		1,000	$	5,888,180
	ICE Brent Crude Oil Futures Contract		Long		July 2016		109		40.7700		1,000		4,443,930
	NYMEX Crude Oil Futures Contract		Long		May 2016		107		38.3400		1,000		4,102,380
	NYMEX Crude Oil Futures Contract		Long		July 2016		48		40.6900		1,000		1,953,120
	Heating Oil
	ICE Low Sulphur Gasoil Futures Contract		Long		May 2016		70		358.5000		100		2,509,500
	NYMEX NY Harbor ULSD Futures Contract		Long		May 2016		51		1.1855		42,000		2,539,341
	Natural Gas
	NYMEX Natural Gas Futures Contract		Long		May 2016		170		1.9590		10,000		3,330,300
	NYMEX Natural Gas Futures Contract		Long		July 2016		62		2.1530		10,000		1,334,860
	Unleaded Gas
	NYMEX Gasoline RBOB Futures Contract		Long		May 2016		49		1.4467		42,000		2,977,309
Industrial Metals	Copper
	COMEX Copper Futures Contract		Long		May 2016		21		2.1830		25,000		1,146,075
	LME Copper Futures Contract		Long		April 2016		35		4,872.5000		25		4,263,438
	LME Copper Futures Contract		Short		April 2016		3		4,872.5000		25		(365,438	)
	LME Copper Futures Contract		Long		May 2016		16		4,858.0000		25		1,943,400
	Aluminum
	LME Primary Aluminum Futures Contract		Long		April 2016		120		1,508.7500		25		4,526,250
	Zinc
	LME Zinc Futures Contract		Long		April 2016		36		1,810.7500		25		1,629,675
	LME Zinc Futures Contract		Short		April 2016		3		1,810.7467		25		(135,806	)
	Nickel
	LME Nickel Futures Contract		Long		April 2016		28		8,457.0000		6		1,420,776
	Lead
	LME Lead Futures Contract		Long		April 2016		18		1,698.7500		25		764,437
	LME Lead Futures Contract		Short		April 2016		2		1,698.7500		25		(84,938	)

Futures Contracts (Continued)


Commodity Group	Contract	Contract Position		Contract Expiration		Number of Contracts		Valuation Price		Contract Multiplier		Notional Amount at Value
Agriculturals	Soybean
	CBOT Soybean Futures Contract		Long		May 2016		96	$	9.1075		5,000	$	4,371,600
	Corn
	CBOT Corn Futures Contract		Long		May 2016		138		3.5150		5,000		2,425,350
	CBOT Corn Futures Contract		Long		July 2016		40		3.5575		5,000		711,500
	Wheat
	CBOT Wheat Futures Contract		Long		May 2016		66		4.7350		5,000		1,562,550
	KCBT Wheat Futures Contract		Long		May 2016		66		4.7625		5,000		1,571,625
	Soybean Meal
	CBOT Soybean Meal Futures Contract		Long		May 2016		74		270.3000		100		2,000,220
	Soybean Oil
	CBOT Soybean Oil Futures Contract		Long		May 2016		51		0.3422		60,000		1,047,132
Precious Metals	Gold
	CEC Gold Futures Contract		Long		June 2016		61		1,235.6000		100		7,537,160
	Silver
	CEC Silver Futures Contract		Long		May 2016		27		15.4640		5,000		2,087,640
	Platinum
	NYMEX Platinum Futures Contract		Long		July 2016		12		977.5000		50		586,500
	Palladium
	NYMEX Palladium Futures Contract		Long		June 2016		8		564.0000		100		451,200
Livestock	Live Cattle
	CME Live Cattle Futures Contract		Long		April 2016		70		1.3293		40,000		3,721,900
	CME Live Cattle Futures Contract		Long		June 2016		40		1.2403		40,000		1,984,400
	Lean Hogs
	CME Lean Hog Futures Contract		Long		April 2016		46		0.6835		40,000		1,257,640
	CME Lean Hog Futures Contract		Long		June 2016		27		0.8085		40,000		873,180
	Feeder Cattle
	CME Feeder Cattle Futures Contract		Long		May 2016		16		1.5525		50,000		1,242,000
	CME Feeder Cattle Futures Contract		Long		August 2016		6		1.5508		50,000		465,225
Foods and Fibers	Sugar
	ICE Sugar Futures Contract		Long		May 2016		113		0.1535		112,000		1,942,696
	ICE White Sugar Futures Contract		Long		May 2016		5		444.7000		50		111,175
	ICE White Sugar Futures Contract		Long		August 2016		3		440.2000		50		66,030
	Coffee
	ICE Coffee C Futures Contract		Long		May 2016		33		1.2745		37,500		1,577,194
	LIFFE Coffee Robusta Futures Contract		Long		May 2016		17		1,501.0000		10		255,170
	Cotton
	ICE Cotton Futures Contract		Long		May 2016		36		0.5844		50,000		1,051,920
	ICE Cotton Futures Contract		Long		July 2016		5		0.5831		50,000		145,775
	Cocoa
	ICE Cocoa Futures Contract		Long		May 2016		14		2,950.0000		10		413,000
	ICE Cocoa Futures Contract		Long		July 2016		13		2,959.0000		10		384,670

Commodity Call Options Written


Commodity Group	Contract	Contract Expiration		Number of Contracts			Strike Price		Value
Energy	Crude Oil
	ICE Brent Crude Oil Futures Options		June 2016		(127	)	$	45.00	$	(41,910	)
	NYMEX Crude Oil Futures Options		April 2016		(77	)		43.00		(10,010	)
	Heating Oil
	NYMEX NY Harbor ULSD Futures Options		April 2016		(51	)		130.00		(22,919	)
	Natural Gas
	NYMEX Natural Gas Futures Options		April 2016		(116	)		2.10		(48,720	)
	Unleaded Gas
	NYMEX Gasoline RBOB Futures Options		April 2016		(25	)		164.00		(9,030	)
Industrial Metals	Copper
	LME Copper Futures Options		April 2016		(29	)		4,800.00		(73,841	)
	Aluminum
	LME Primary Aluminum Futures Options		April 2016		(60	)		1,600.00		(105	)
	Zinc
	LME Zinc Futures Options		April 2016		(16	)		1,800.00		(12,264	)
	Nickel
	LME Nickel Futures Options		April 2016		(14	)		9,200.00		(301	)
	Lead
	LME Lead Futures Options		April 2016		(8	)		1,900.00		(2	)
Agriculturals	Soybean
	CBOT Soybean Futures Options		April 2016		(48	)		930.00		(10,500	)
	Corn
	CBOT Corn Futures Options		April 2016		(89	)		395.00		(1,113	)
	Wheat
	CBOT Wheat Futures Options		April 2016		(33	)		495.00		(8,044	)
	CBOT Wheat Futures Options		April 2016		(33	)		500.00		(5,981	)
	Soybean Meal
	CBOT Soybean Meal Futures Options		April 2016		(37	)		290.00		(2,220	)
	Soybean Oil
	CBOT Soybean Oil Futures Options		April 2016		(25	)		34.00		(11,550	)
Precious Metals	Gold
	COMEX Gold Futures Options		May 2016		(30	)		1,320.00		(25,500	)
	Silver
	CEC Silver Futures Options		April 2016		(13	)		16.75		(4,875	)
Livestock	Live Cattle
	CME Live Cattle Futures Options		April 2016		(69	)		142.00		(690	)
	Lean Hogs
	CME Lean Hogs Futures Options		April 2016		(37	)		74.00		(370	)
Foods and Fibers	Sugar
	ICE Sugar Futures Options		April 2016		(61	)		14.50		(66,271	)
	Coffee
	ICE Coffee C Futures Options		April 2016		(19	)		130.00		(9,191	)
	Cotton
	ICE Cotton Futures Options		April 2016		(20	)		64.00		(600	)
	Cocoa
	ICE Cocoa Futures Options		June 2016		(13	)		3,250.00		(3,510	)


CBOT		Chicago Board of Trade
CEC		Commodities Exchange Center
CME		Chicago Mercantile Exchange
COMEX		Commodities Exchange, Inc.
ICE		Intercontinental Exchange
KCBT		Kansas City Board of Trade
LIFFE		London International Financial Futures Exchange
LME		London Metal Exchange
NY Harbor ULSD		New York Harbor Ultra-Low Sulfur Diesel
NYMEX		New York Mercantile Exchange
RBOB		Reformulated Gasoline Blendstock for Oxygen Blending

The Fund also invests the assets held as collateral for its investments in commodity futures and forward contracts in cash equivalents, U.S. government securities, and other short-term, high-grade debt securities, which exposes the Fund to interest rate risk. These instruments are deemed to be entered into for non-trading purposes, with an emphasis on current income, liquidity and preservation of capital. As of March 31, 2016, the Fund held U.S. Treasury bills worth $71,293,332 with a total par value of $71,420,000 and a repurchase agreement worth $10,769,892.

Qualitative Disclosure

The Fund’s primary trading risk exposure is commodity price risk, which affects the futures contracts and options on futures contracts in which the Fund invests. There are numerous uncertainties, contingencies and risks associated with these investments (as discussed in Part I—Item 1A. Risk Factors in the Fund’s annual report on Form 10-K for the year ended December 31, 2015 and Part II—Item 1A. Risk Factors in the Fund’s subsequent quarterly reports on Form 10-Q, filed with the SEC) which include, but are not limited to, government interventions, defaults and expropriations, adverse weather conditions, commodity supply factors, illiquid markets, the emergence of dominant fundamental factors, political upheavals, changes in historical price relationships, an influx of new market participants, and increased regulation. Investors may lose all or substantially all of their investment in the Fund.

The Fund invests in a diversified portfolio of commodity futures and forward contracts to obtain broad exposure to all principal groups in the global commodity markets, thereby limiting its exposure to the commodity price risk of any one futures contract or any specific commodity group. To further help manage commodity price risk, the Fund uses its options strategy in an attempt to enhance the Fund’s risk-adjusted total returns. In up markets, the portion of the Fund on which call options have been sold will forego potential appreciation in the value of the underlying contracts to the extent the price of those contracts exceeds the exercise price of options written plus the premium collected by writing the call options. In flat or sideways markets, the portion of the Fund on which call options have been sold will generate current gains from the premium collected by writing the call options. In down markets, the Fund will experience declines in the value of the underlying contracts to the extent that the amount of the decline in the value of the underlying contracts exceeds the option premium collected by writing the call options. There can be no assurance that the Fund’s options strategy will be successful. The Fund’s risk-adjusted returns over any particular period may be positive or negative.

The Fund’s primary non-trading risk exposures are interest rate risk and credit risk related to the collateral portfolio. Interest rate risk is mitigated by the short-term nature of the collateral portfolio’s debt securities. Credit risk is mitigated by the fact that the collateral portfolio’s debt securities (other than U.S. government securities) are rated at the highest applicable rating as determined by at least one nationally recognized statistical rating organization (“NRSRO”) or, if unrated, judged by the Collateral Sub-adviser to be of comparable quality.

Item 4.

Controls and Procedures

Disclosure Controls and Procedures

Under the supervision and with the participation of the principal executive officer and principal financial officer of the Manager of the Fund, the Manager has evaluated the effectiveness of the Fund’s disclosure controls and procedures pursuant to Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934 (the “Exchange Act”). Based upon that evaluation, the principal executive officer and principal financial officer concluded that the Fund’s disclosure controls and procedures were effective as of the end of the period covered by this Report to provide reasonable assurance that information required to be disclosed in the reports that the Fund files or submits to the SEC under the Exchange Act is recorded, processed, summarized and reported, within the time periods specified in the applicable rules and forms, and that it is accumulated and communicated to the management of the Manager as appropriate to allow timely decisions regarding required disclosure.

Changes in Internal Control Over Financial Reporting

There were no changes in the Fund’s internal control over financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) of the Exchange Act) that occurred during the reporting period covered by this Report that have materially affected, or are reasonably likely to materially affect, the Fund’s internal control over financial reporting.

PART II. OTHER INFORMATION

Item 1.

Legal Proceedings

None.

Item 1A.

Risk Factors

There have been no changes to the Risk Factors since last reported on Part I, Item 1A of the Fund’s annual report on Form 10-K dated December 31, 2015, filed with the SEC.

Item 2.

Unregistered Sales of Equity Securities and Use of Proceeds

a) None.

b) The Fund did not issue new shares within the three month period ended on March 31, 2016.

c) On December 21, 2011, the Fund adopted an open-market share repurchase program pursuant to which it was authorized to repurchase an aggregate of up to 10% of its outstanding common shares (approximately 920,000 shares) in open-market transactions at the Manager’s discretion. On March 6, 2014, the Fund reauthorized its share repurchase program, pursuant to which it may repurchase an aggregate of up to 10% of its outstanding common shares as of the reauthorization date (approximately 920,000 shares). During the three month period ended March 31, 2016, the Fund did not repurchase any shares. A cumulative total of 220,000 shares have been repurchased through the repurchase program described above. No shares have been repurchased outside of the program described.

Item 3.

Defaults Upon Senior Securities

None.

Item 4.

Mine Safety Disclosures

Not applicable.

Item 5.

Other Information

None.

Item 6.

Exhibits



4.1		Second Amended and Restated Trust Agreement of the Fund. (1)

31.1		Certification of Principal Executive Officer Pursuant to Rule 13a-14(a) or Rule 15d-14(a), as adopted pursuant to Section 302 of the Sarbanes-Oxley Act of 2002.

31.2		Certification of Principal Financial Officer Pursuant to Rule 13a-14(a) or Rule 15d-14(a), as adopted pursuant to Section 302 of the Sarbanes-Oxley Act of 2002.

32.1		Certification of Principal Executive Officer Pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002.

32.2		Certification of Principal Financial Officer Pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002.

101.INS		XBRL Instance Document.

101.SCH		XBRL Taxonomy Extension Schema Document.

101.CAL		XBRL Taxonomy Extension Calculation Linkbase Document.

101.LAB		XBRL Taxonomy Extension Label Linkbase Document.

101.PRE		XBRL Taxonomy Extension Presentation Linkbase Document.

101.DEF		XBRL Taxonomy Extension Definition Linkbase Document.

(1)	Filed on March 30, 2012 as an exhibit to Registrant’s Form 8-K dated March 30, 2012 and incorporated by reference herein.

SIGNATURES

Pursuant to the requirements of Section 13 or 15(d) 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, in the City of Chicago, State of Illinois, on May 9, 2016.


Nuveen Diversified Commodity Fund

By:		Nuveen Commodities Asset Management, LLC, its Manager

By: /s/ William Adams IV
President (Principal Executive Officer)

Pursuant to the requirements of the Securities Exchange Act of 1934, this report has been signed below by the following persons on behalf of the Registrant and in the capacities and on the dates indicated.

Nuveen Commodities Asset Management, LLC

Manager of Registrant


/s/ William Adams IV
President (Principal Executive Officer) May 9, 2016

/s/ Stephen D. Foy
Chief Financial Officer (Principal Financial and Accounting Officer) May 9, 2016