Systematic Momentum Ii 10-Q 2007 Q2 Quarterly report

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 June 30, 2007
OR
o	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 0-52384

ML APM GLOBAL COMMODITY FUTURESACCESS LLC

(Exact Name of Registrant as

specified in its charter)

Delaware	20-5269618
(State or other jurisdiction of incorporation or organization)	(IRS Employer Identification No.)

c/o Merrill Lynch Alternative Investments LLC

Princeton Corporate Campus

800 Scudders Mill Road - Section 2G

Plainsboro, New Jersey 08536

 (Address of principal executive offices)

(Zip Code)

609-282-6091

(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 o

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

Large accelerated filer o   Accelerated filer o   Non-accelerated filer x

Indicate by check mark whether registrant is a shell company (as defined by Rule 12b-2 of the Exchange Act).

Yes  o   No x

Indicate by check mark whether the registrant has filed all documents and reports required to be filed by Sections 12, 13 or 15(d) of the Securities Exchange Act of 1934 subsequent to the distribution of securities under a plan confirmed by a court.

Yes o   No o

ML APM GLOBAL COMMODITY FUTURESACCESS LLC

QUARTERLY REPORT FOR JUNE 30, 2007 ON FORM 10-Q

Table of Contents

		Page
PART I
Item 1.	Financial Statements	1
Item 2.	Management’s Discussion and Analysis of Financial Condition and Results of Operations	7
Item 3.	Quantitative and Qualitative Disclosures About Market Risk	9
Item 4.	Controls and Procedures	11
PART II
Item 1.	Legal Proceedings	12
Item 2.	Unregistered Sales of Equity Securities and Use of Proceeds	12
Item 3.	Defaults Upon Senior Securities	13
Item 4.	Submission of Matters to a Vote of Security Holders	13
Item 5.	Other Information	13
Item 6.	Exhibits	13

PART I - FINANCIAL INFORMATION

Item 1.    Financial Statements

ML APM GLOBAL COMMODITY FUTURESACCESS LLC
(a Delaware Limited Liability Company)

STATEMENTS OF FINANCIAL CONDITION

	June 30, 2007		December 31, 2006
	(unaudited)
ASSETS:
Equity in commodity futures trading accounts:
Cash (including restricted cash of $1,794,729 for 2007 and $1,272,271 for 2006)	$	30,146,217	$	10,138,738
Options at market (premium paid $2,224,238 for 2007 and $772,643 for 2006)	2,172,945		585,476
Net unrealized profit on open contracts	201,103		208,001
Cash	8,688		—
Deferred initial offering costs	25,000		55,000
Accrued interest	123,381		43,979
TOTAL ASSETS	$	32,677,334	$	11,031,194
LIABILITIES AND MEMBERS’ CAPITAL
LIABILITIES:
Brokerage commissions payable	$	3,391	$	1,782
Management fee payable	40,566		13,694
Initial offering costs payable	54,073		60,000
Sponsor fee payable	37,152		—
Redemptions payable	88,663		4,449,999
Other	194,716		18,285
Total liabilities	418,561		4,543,760
MEMBERS’ CAPITAL:
Members’ Interest (32,428,501 and 6,615,200 Units outstanding, unlimited Units authorized)	32,258,773		6,487,434
Total members’ capital	32,258,773		6,487,434
TOTAL LIABILITIES AND MEMBERS’ CAPITAL	$	32,677,334	$	11,031,194
NET ASSET VALUE PER UNIT (NOTE 2)

See notes to financial statements.

1

ML APM GLOBAL COMMODITY FUTURESACCESS LLC
(a Delaware Limited Liability Company)

STATEMENTS OF OPERATIONS
(unaudited)

	For the three months ended June 30, 2007			For the six months ended June 30, 2007
TRADING PROFIT:
Realized	$	397,624		$	236,996
Change in unrealized	112,609			128,976
Brokerage commissions	(11,956		)	(18,360		)
Total trading profit	498,277			347,612
INVESTMENT INCOME:
Interest	343,329			488,819
EXPENSES:
Management fee	117,730			171,491
Sponsor fee	90,537			115,496
Other	122,486			241,817
Total expenses	330,753			528,804
NET INVESTMENT INCOME (LOSS)	12,576			(39,985		)
NET INCOME	$	510,853		$	307,627
NET INCOME PER UNIT:
Weighted average number of Units outstanding
Class A	3,678,022			3,550,239
Class C	10,949,880			6,571,528
Class D	13,875,571			11,446,501
Class I	3,377,560			2,257,722
Net income per weighted average Unit
Class A	$	0.0156		$	0.0033
Class C	0.0179			0.0226
Class D	0.0138			0.0089
Class I	0.0197			0.0198

See notes to financial statements.

2

ML APM GLOBAL COMMODITY FUTURESACCESS LLC
(a Delaware Limited Liability Company)

STATEMENT OF CHANGES IN MEMBERS’ CAPITAL
For the six months ended June 30, 2007
(unaudited)

	Members’ Capital				Members’ Capital
	December 31, 2006	Subscriptions	Redemptions		June 30, 2007
Class A	—	3,807,148	(22,374	)	3,784,774
Class C	—	14,176,180	(424,450	)	13,751,730
Class D	6,615,200	14,204,149	(9,900,933	)	10,918,416
Class I	—	4,009,705	(36,124	)	3,973,581
Total Members’ Units	6,615,200	36,197,182	(10,383,881	)	32,428,501

	Members’ Capital									Members’ Capital
	December 31, 2006		Subscriptions		Redemptions			Net Income		June 30, 2007
Class A	$	—	$	3,800,506	$	(22,423	)	$	11,702	$	3,789,785
Class C	—		13,962,100		(417,494		)	148,830		13,693,436
Class D	6,487,434		13,865,995		(9,664,640		)	102,382		10,791,171
Class I	—		3,975,557		(35,889		)	44,713		3,984,381
Total Members’ Interest	$	6,487,434	$	35,604,158	$	(10,140,446	)	$	307,627	$	32,258,773

See notes to financial statements.

3

ML APM GLOBAL COMMODITY FUTURESACCESS LLC
(a Delaware Limited Liability Company)

NOTES TO FINANCIAL STATEMENTS

(unaudited)

1.     SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

In the opinion of management, the financial statements contain all adjustments necessary to present fairly the financial position of ML APM Global Commodity FuturesAccess LLC (the “Fund”) as of June 30, 2007, and the results of its operations for the three months and six months ended June 30, 2007.  However, the operating results for the interim period may not be indicative of the results for the full year.

Certain information and footnote disclosures normally included in annual financial statements prepared in accordance with accounting principles generally accepted in the United States of America (“US GAAP”) have been omitted.  It is suggested that these financial statements be read in conjunction with the financial statements and notes thereto included in the Fund’s Annual Report on Form 10-K filed with the Securities and Exchange Commission for the period ended December 31, 2006.

The preparation of financial statements in conformity with US GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period.  Actual results could differ from those estimates.

2.NET ASSET VALUE PER UNIT

For financial reporting purposes, in conformity with US GAAP, the Fund amortizes over a twelve-month period the initial offering costs for purposes of determining Net Asset Value. Such costs initially were paid by Merrill Lynch Alternative Investments (“MLAI”).  For all other purposes,

	Net Asset Value					Net Asset Value per Unit
	All Other Purposes		Financial Reporting		Number of Units	All Other Purposes		Financial Reporting
Class A	$	3,792,928	3,789,785		3,784,774	$	1.0022	$	1.0013
Class C	13,699,088		13,693,436		13,751,730	0.9962		0.9958
Class D	10,808,276		10,791,171		10,918,416	0.9899		0.9958
Class I	3,986,481		3,984,381		3,973,581	1.0032		1.0027
	$	32,286,773	$	32,258,773	32,428,501

At December 31, 2006 the Net Asset Values of the different Classes of Units are as follows:

	Net Asset Value					Net Asset Value per Unit
	All Othe Purposes		Financial Reporting		Number of Units	All Other Purposes		Financial Reporting
Class D	$	6,491,434	$	6,487,434	6,615,200	$	0.9813	$	0.9807

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3.MARKET AND CREDIT RISKS

The nature of this Fund has certain risks, which cannot be presented on the financial statements.  The following summarizes some of those risks.

Market Risk

Derivative instruments involve varying degrees of market risk.  Changes in the level or volatility of interest rates, foreign currency exchange rates or the market values of the financial instruments or commodities underlying such derivative instruments frequently result in changes in the Fund’s unrealized profit on such derivative instruments as reflected in the Statements of Financial Condition.  The Fund’s exposure to market risk is influenced by a number of factors, including the relationships among the derivative instruments held by the Fund as well as the volatility and liquidity of the markets in which the derivative instruments are traded. Investments in foreign markets may also entail legal and political risks.

The Sponsor of the Fund, MLAI, has procedures in place intended to control market risk exposure, although there can be no assurance that they will, in fact, succeed in doing so.  These procedures focus primarily on monitoring the trading of Absolute Plus Management LLC (“APM”), the trading advisor, calculating the Net Asset Value of the Fund as of the close of business on each day and reviewing outstanding positions for over-concentrations.  While MLAI does not intervene in the markets to hedge or diversify the Fund’s market exposure, MLAI may urge APM to reallocate positions in an attempt to avoid over-concentrations.  However, such interventions are expected to be unusual.  It is expected that MLAI’s basic risk control procedures will consist of the ongoing process of advisor monitoring, with the market risk controls being applied by APM.

Credit Risk

The risks associated with exchange-traded contracts are typically perceived to be less than those associated with over-the-counter (non-exchange-traded) transactions, because exchanges typically provide clearinghouse arrangements in which the collective credit (in some cases limited in amount, in some cases not) of the members of the exchange is pledged to support the financial integrity of the exchange.  In over-the-counter transactions, on the other hand, traders must rely solely on the credit of their respective individual counterparties. Margins, which may be subject to loss in the event of a default, are generally required in exchange trading, and counterparties may also require margin in the over-the-counter markets.

The credit risk associated with these instruments from counterparty nonperformance is the  unrealized profit, if any, included in the Statements of Financial Condition. The Fund attempts to mitigate this risk by dealing exclusively with Merrill Lynch & Co. Inc. (“Merrill Lynch”) entities as clearing brokers.

The Fund, in its normal course of business, enters into various contracts with Merrill Lynch Pierce Fenner & Smith Inc. (“MLPF&S”) acting as its commodity broker.  Pursuant to the brokerage arrangement with MLPF&S (which includes a netting arrangement), to the extent that such trading results in receivables from and payables to MLPF&S, these receivables and payables are offset and reported as a net receivable or payable and included in Equity in commodity futures trading accounts in the Statements of Financial Condition.

5

4.RECENT ACCOUNTING PRONOUNCEMENTS

In June 2006, the Financial Accounting Standards Board (“FASB”) issued Interpretation No. 48 (“FIN 48”), Accounting for Uncertainty in Income Taxes — an interpretation of FASB Statement No. 109.  In May 2007, FASB amended this guidance by issuing FASB Staff Position No. FIN 48-1, Definition of settlement in FASB Interpretation No. 48.  FIN 48, as amended, prescribes the minimum recognition threshold a tax position must meet in connection with accounting for uncertainties in income tax positions taken or expected to be taken by an entity before being measured and recognized in the financial statements.  Adoption of FIN 48, as amended, is required for fiscal years beginning after December 15, 2006.  The Fund has evaluated its tax positions and has determined that the implementation of this pronouncement does not have a material impact to the financial statements.

In September 2006, the FASB issued Statement of Financial Accounting Standards No. 157, Fair Value Measurements (“FAS 157”).  FAS 157 establishes a common definition for fair value under accounting principles generally accepted in the United States of America, establishes a framework for measuring fair value and expands disclosure requirements about such fair value measurements.  FAS 157 is effective for fiscal years beginning after November 15, 2007.  The Fund is currently evaluating the impact of adopting FAS 157 on its financial statements.

6

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

MONTH-END NET ASSET VALUE PER UNIT

(NON US GAAP)

MLAI believes that the Net Asset Value used to calculate subscription and redemption value and to report performance to investors throughout the year is the most valuable to the Members of the Fund. Therefore, the charts below referencing Net Asset Value and performance measurements are based on the Net Asset Value for all other purposes, as discussed in Note 2 to the Financial Statements.

Class A
	Jan.	Feb.		Mar.		Apr.		May.	Jun.
2007	N/A	$	0.9932	$	0.9869	$	0.9853	0.9827	$	1.0022

Class C
	Jan.		Feb.		Mar.		Apr.		May.		Jun.
2007	$	0.9982	$	0.9906	$	0.9835	$	0.9810	$	0.9776	$	0.9962

Class D
	Jan.		Feb.		Mar.		Apr.		May.		Jun.
2007	$	0.9816	$	0.9762	$	0.9712	$	0.9708	$	0.9695	$	0.9899

Class I
	Jan.		Feb.		Mar.		Apr.		May.		Jun.
2007	$	0.9994	$	0.9930	$	0.9870	$	0.9857	$	0.9834	$	1.0032

Performance Summary

January 1, 2007 to June 30, 2007

January 1, 2007 to March 31, 2007

The Fund posted an overall loss for the quarter. The energy and interest rate sectors posted gains while the currency, metals and agriculture sectors posted losses.

The energy sector was the most profitable for the Fund.  Energy prices dropped sharply at the beginning of the quarter only to recover mid-quarter through the end of the quarter due to a combination of weather, sanguine geo-political concerns and near term inventory patterns worldwide.

The interest rate sector was flat for the quarter. Profits were posted at the beginning  of the quarter due to the U.S. Federal Reserve, now data driven, refraining from another interest rate increase, but remained tilted to higher inflationary outcomes. Concurrently, the European Central Bank and the Bank of England continued aggressive focus on reigning in inflationary expectations through higher market interest rates. Across the Group of Four (G-4), the intent still remains biased towards reducing excess market liquidity and containing inflationary pressures stemming from, historically low risk premiums, higher confidence and higher economic activity. Long term bond prices retreated and the ten year sector European bonds finished down approximately 0.9% while U.S. bond prices fell 1.0% in value. Japanese prices countered the trend increasing 0.3% with revised uncertainty of near term monetary policy changes. Short term yields continued to move up outside the U.S. as global fixed income trading had a positive impact on performance.  Losses were posted mid-quarter however, due to the revisions of market sentiment based on seeming evidence of some slowing in U.S. real growth coupled with a continuation of rising growth prospects particularly in Europe and Asia. The quarter ended with profits posted to the Fund as short

7

term yields continued to move up, outside the U.S. coupled with the fixed income trading causing a positive impact on performance.

The currency sector was not profitable for the Fund.  The quarter began with gains posted for the Fund as the U.S. dollar reversed losses to move slightly higher by 1.2% due to the new evidence of sustained U.S. growth. However, losses posted mid-quarter through the end of the quarter as the U.S. dollar resumed to move slightly lower again subject to the new evidence of moderating U.S. growth and inflation.

The metals sector also incurred losses for the Fund. Due to volatility in the market, profits were posted mid-quarter only with losses posted to the Fund at the beginning of the quarter and the end of the quarter due to the response in the market specific demand data which caused copper to move lower and broader commodities to fluctuate.

The agricultural sector was the least profitable for the Fund. The agricultural market was soft which attributed to the difficult trading environment resulting in the Fund posting losses for the sector.

April 1, 2007 to June 30, 2007

The Fund posted profits for the quarter with interest rates, agriculture and currency sectors posting gains while the energy and metal sectors posted losses.

The interest rate sector was the most profitable for the Fund.  The fixed income market started the month with a strong U.S. non-farm payroll number that suggested a resumption of an upward growth path, but later in the beginning of the quarter the  GDP came out at only +1.3%, the lowest seen in 4 years, which suggested a possible continuation of slowing. In Europe, the macroeconomic numbers still suggest that the European Central Bank (“ECB”) and the Bank of England (“BOE”) must continue aggressive focus on reigning in inflationary expectations through higher interest rates. The intent across the Group of Four (G-4) still remains a bias towards raising rates and containing inflationary pressures. Net for the period, long-term bond prices moved sideways at best while short term yields continued to move up, outside the U.S. In the ten year sector, European bonds finished down approximately 0.7%, while U.S. bond prices rose 0.1% in value. Japanese fixed income prices finished up 0.3% with revised uncertainty of near term monetary policy changes. The fixed income portfolio provided a positive impact with a short position in rates across markets brought the overall strategy close to flat mid quarter. The fixed income sector benefited at the quarter’s end from liquidations in global bond markets as consensus shifted from an ease to a tightening.

The agriculture sector was profitable for the Fund. Profits were posted throughout the quarter. The quarter ended as wheat was the best performer in grains as dry conditions throughout the world has estimates of wheat stocks at a 30-year low. The ending stocks to use ratio is expected to be 20% for 2007-2008 (the lowest in 11 years). Soybeans had a strong month as forecasts on planting acreage is the lowest in 12 years as more focus shifts to corn for ethanol production. Dry weather in China contributed to a squeeze in supply as they are the world’s largest buyer of oilseed.

The currency sector was also profitable for the Fund. The quarter began with a small loss being posted to the Fund due to market volatility and a minimal gain mid-quarter. The U.S. dollar long and the British Gilt markets provided most of the gains.  The Japanese and Australian markets were also a small positive to performance while the Euro zone ended roughly unchanged.

The energy sector posted losses for the Fund. Losses were posted to the Fund the beginning of the quarter through mid-quarter in lieu of energy prices recovering from a combination of weather, keenly heightened geopolitical concerns and continued draw in near term inventory patterns worldwide. Profits were posted at the end of the quarter due to lower than expected inventories of gasoline and forecasts of exceptionally high demand during upcoming summer driving season.

8

The metals sector was the least profitable for the Fund. At the beginning of the quarter profits were posted to the Fund due to the Asian demand for copper and zinc. Zinc is used as a coating for preventing rust in steel when making buildings, cars and appliances. A shortage of zinc was caused by Chinese demand which is likely to continue as exploration is a long process and no new mines are expected until early 2008.

Item 3.    Quantitative and Qualitative Disclosures About Market Risk

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

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

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

Value at Risk is a measure of the maximum amount which the Fund could reasonably be expected to lose in a given market sector. However, the inherent uncertainty of the Fund’s speculative trading and the recurrence in the markets traded by the Fund of market movements far exceeding expectations could result in actual trading or non-trading losses far beyond the indicated Value at Risk or the Fund’s experience to date (i.e., “risk of ruin”). In light of the foregoing, as well as the risks and uncertainties intrinsic to all future projections, the quantifications included in this section should not be considered to constitute any assurance or representation that the Fund’s losses in any market sector will be limited to Value at Risk or by the Fund’s attempts to manage its market risk.

Quantifying The Fund’s Trading Value At Risk

Quantitative Forward-Looking Statements

The following quantitative disclosures regarding the Fund’s market risk exposures contain “forward-looking statement” within the meaning of the safe harbor form civil liability provided for such statements by the Private Securities Litigation Reform Act of 1995 (set forth in Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934).  All quantitative disclosures in this section are deemed to be forward-looking statements for purposes of the safe harbor, except for statements of historical fact.

The Fund’s risk exposure in the various market sectors traded by APM is quantified below in terms of Value at Risk.  Due to the Fund’s mark-to-market accounting, any loss in the fair value of the Fund’s open positions is directly reflected in the Fund’s earnings (realized or unrealized) and cash flow (at least in the case of exchange-traded contracts in which profits and losses on open positions are settled daily through variation margin).

9

Exchange maintenance margin requirements have been used by the Fund as the measure of its Value at Risk.  Maintenance margin requirements are set by exchanges to equal or exceed the maximum loss in the fair value of any given contract incurred in 95%-99% of the one-day time periods included in the historical sample (generally approximately one year) researched for purposes of establishing margin levels.  The maintenance margin levels are established by dealers and exchanges using historical price studies as well as an assessment of current market volatility (including the implied volatility of the options on a given futures contract) and economic fundamentals to provide a probabilistic estimate of the maximum expected near-term one-day price fluctuation.

In the case of market sensitive instruments which are not exchange-traded (almost exclusively currencies in the case of the Fund), the margin requirements for the equivalent futures positions have been used as Value at Risk.  In those rare cases in which a futures-equivalent margin is not available, dealers’ margins have been used.

100% positive correlation in the different positions held in each market risk category has been assumed.  Consequently, the margin requirements applicable to the open contracts have been aggregated to determine each trading category’s aggregate Value at Risk.  The diversification effects resulting from the fact that the Fund’s positions are rarely, if ever, 100% positively correlated have not been reflected.

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

The following table indicates the average, highest and lowest trading Value at Risk associated with the Fund’s open positions by market category for the fiscal period. For the six months ended June 30, 2007, the Fund’s average Month-end Net Asset Value for all other purposes was approximately $19,036,661.34.

	June 30, 2007
	Average		% of Average		Highest Value		Lowest Value
Market Sector	Value at Risk		Capitalization		At Risk		At Risk
Agricultural Commodities	$	6,161	0.03	%	$	13,034	$	2,586
Energy	5,250		0.03	%	7,614		1,215
Interest Rates	1,091,828		5.74	%	1,800,957		390,839
Metals	5,505		0.03	%	10,837		2,545
Currencies	919		0.00	%	3,150		9
TOTAL	$	1,109,663	5.83	%	$	1,835,592	$	397,194

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

The face value of the market sector instruments held by the Fund is typically many times the applicable maintenance margin requirement (maintenance margin requirements generally ranging between approximately 1% and 10% of contract face value) as well as many times the capitalization of the Fund.  The magnitude of the Fund’s open positions creates a “risk of ruin” not typically found in most other investment vehicles.  Because of the size of its positions, certain market conditions — unusual, but historically recurring from time to time — could cause the Fund to incur severe losses over a short period of time.   The foregoing Value at Risk table — as well as the past performance of the Fund — gives no indication of this “risk of ruin.”

10

Non-Trading Risk

Foreign Currency Balances; Cash on Deposit with MLPF&S

The Fund has non-trading market risk on its foreign cash balances not needed for margin. However, these balances (as well as the market risk they represent) are immaterial.

The Fund also has non-trading market risk on the approximately 90%-95% of its assets which are held in cash at MLPF&S. The value of this cash is not interest rate sensitive, but there is cash flow risk in that if interest rates decline so will the cash flow generated on these monies. This cash flow risk is immaterial.

Item 4.    Controls and Procedures

MLAI, the Sponsor of ML APM Global Commodity FuturesAccess LLC (the “Fund”), with the participation of the Sponsor’s Chief Executive Officer and the Chief Financial Officer, has evaluated the effectiveness of the design and operation of its disclosure controls and procedures with respect to the Fund as of the end of the period of this quarterly report, and, based on this evaluation, has concluded that these disclosure controls and procedures are effective.  Additionally, there were no significant changes in the Fund’s internal controls or in other factors that could significantly affect these controls subsequent to the date of this evaluation, including any corrective actions with regard to significant deficiencies and material weaknesses.

11

PART II - OTHER INFORMATION

Item 1.    Legal Proceedings

On July 31, 2007, the CFTC issued an order against MLAI and an advisory affiliate, to which MLAI and the affiliate consented, containing findings, which MLAI and the affiliate neither admitted nor denied, that MLAI and the affiliate filed with the NFA a number of annual reports for commodity pools for which they acted as commodity pool operators after the deadline established by the CFTC’s regulations, in violation of CFTC Regulation 4.22(c).  MLAI and the affiliate were ordered to cease and desist from violating Regulation 4.22(c) and to pay a civil penalty in the amount of $500,000.

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

(a) Issuance to accredited investors pursuant to Regulation D and Section 4(6) under the Securities Act.  The selling agent of the following Class of Units was MLPF&S.

CLASS A

	Subscription
	Amount		Units	NAV(1)
Jan-07	$	—	—	$	n/a
Feb-07	3,235,749		3,235,749	1.0000
Mar-07	243,961		245,631	0.9932
Apr-07	22,424		22,722	0.9869
May-07	215,499		218,714	0.9853
Jun-07	82,873		84,332	0.9827
Jul-07	352,944		352,169	1.0022

CLASS C

	Subscription
	Amount		Units	NAV (1)
Jan-07	$	439,000	439,000	$	1.0000
Feb-07	680,997		682,225	0.9982
Mar-07	3,861,433		3,898,075	0.9906
Apr-07	3,852,933		3,917,573	0.9835
May-07	1,670,563		1,702,918	0.9810
Jun-07	3,457,174		3,536,389	0.9776
Jul-07	3,592,585		3,606,289	0.9962

CLASS D

	Subscription
	Amount		Units	NAV (1)
Jan-07	$	4,095,999	4,174,054	$	0.9813
Feb-07	1,699,999		1,731,865	0.9816
Mar-07	2,099,999		2,151,198	0.9762
Apr-07	5,969,998		6,147,032	0.9712
May-07	—		—	0.9708
Jun-07	—		—	0.9750
Jul-07	750,000		757,652	0.9899

CLASS I

	Subscription
	Amount		Units	NAV (1)
Jan-07	$	20,000	20,000	$	1.0000
Feb-07	1,040,000		1,040,624	0.9994
Mar-07	1,263,495		1,272,402	0.9930
Apr-07	223,565		226,510	0.9870
May-07	1,028,998		1,043,926	0.9857		��
Jun-07	399,499		406,243	0.9834
Jul-07	767,379		764,932	1.0032

(1)Net Asset Value for all other purposes

(b)None.

(c)None.

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Item 3.Defaults Upon Senior Securities

None.

Item 4.Submission of Matters to a Vote of Security Holders

None.

Item 5.Other Information

None.

Item 6.Exhibits

The following exhibits are incorporated by reference or are filed herewith to this Quarterly Report on Form 10-Q:

31.01 and

31.02               Rule 13a-14(a)/15d-14(a) Certifications

Exhibit 31.01

and 31.02:      Are filed herewith.

32.01 and

32.02               Section 1350 Certifications

Exhibit 32.01

and 32.02       Are filed herewith.

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SIGNATURES

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

ML APM GLOBAL COMMODITY FUTURESACCESS LLC

	By: MERRILL LYNCH ALTERNATIVE
	INVESTMENTS LLC
	(Manager)
Date: August 14, 2007	By	/s/ ROBERT D. OLLWERTHER
		Robert D. Ollwerther
		Chief Executive Officer and President
		(Principal Executive Officer)
Date: August 14, 2007
	By	/s/ BARBRA E. KOCSIS
		Barbra E. Kocsis
		Chief Financial Officer
		(Principal Financial and Accounting Officer)

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