Systematic Momentum Ii 10-Q 2007 Q3 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 September 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	(IRS Employer Identification No.)
incorporation or organization)

c/o Merrill Lynch Alternative Investments LLC
Hopewell Building No. 2
1200 Merrill Lynch Drive - First Floor
Pennington, New Jersey 08534
(Address of principal executive offices)
(Zip Code)

609-274-5838
(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 SEPTEMBER 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	10
Item 4.	Controls and Procedures	12
PART II
Item 1.	Legal Proceedings	13
Item 2.	Unregistered Sales of Equity Securities and Use of Proceeds	13
Item 3.	Defaults Upon Senior Securities	14
Item 4.	Submission of Matters to a Vote of Security Holders	14
Item 5.	Other Information	14
Item 6.	Exhibits	14

PART I - FINANCIAL INFORMATION

Item 1. Financial Statements

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

STATEMENTS OF FINANCIAL CONDITION

	September 30,			December 31,
	2007			2006
	(unaudited)
ASSETS:
Equity in commodity futures trading accounts:
Cash (including restricted cash of $2,893,400 for 2007 and $1,272,271 for 2006)	$	40,452,977		$	10,138,738
Options at market (premium paid $2,980,653 for 2007 and $772,643 for 2006)	5,355,850			585,476
Net unrealized profit (loss) on open contracts	(42,795		)	208,001
Cash	36,331			—
Deferred initial offering costs	2,800			55,000
Accrued interest	151,564			43,979
TOTAL ASSETS	$	45,956,727		$	11,031,194
LIABILITIES AND MEMBERS’ CAPITAL
LIABILITIES:
Brokerage commissions payable	$	3,357		$	1,782
Management fee payable	57,038			13,694
Initial offering costs payable	36,074			60,000
Sponsor fee payable	56,840			—
Performance fee payable	433,015			—
Redemptions payable	2,479,170			4,449,999
Other	238,406			18,285
Total liabilities	3,303,900			4,543,760
MEMBERS’ CAPITAL:
Members’ Interest (39,898,730 and 6,615,200 Units outstanding, unlimited Units authorized)	42,652,827			6,487,434
Total members’ capital	42,652,827			6,487,434
TOTAL LIABILITIES AND MEMBERS’ CAPITAL	$	45,956,727		$	11,031,194

NET ASSET VALUE PER UNIT (NOTE 2)

See notes to financial statements.

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

STATEMENTS OF INCOME
(unaudited)

	For the three			For the nine
	months ended			months ended
	September 30,			September 30,
	2007			2007
TRADING PROFIT:
Realized	$	1,273,691		$	1,510,687
Change in unrealized	2,182,592			2,311,568
Brokerage commissions	(17,021		)	(35,381		)
Total trading profit	3,439,262			3,786,874
INVESTMENT INCOME:
Interest	438,015			926,834
EXPENSES:
Management fee	155,554			327,045
Sponsor fee	152,644			268,140
Performance fee	433,015			433,015
Other	113,382			355,199
Total expenses	854,595			1,383,399
NET INVESTMENT LOSS	(416,580		)	(456,565		)
NET INCOME	$	3,022,682		$	3,330,309
NET INCOME PER UNIT:
Weighted average number of Units outstanding
Class A	4,160,330			3,779,023
Class C	18,722,033			10,621,696
Class D	11,676,068			11,523,023
Class I	5,316,326			3,277,256
Net income per weighted average Unit
Class A	$	0.0740		$	0.0845
Class C	$	0.0739		$	0.1443
Class D	$	0.0773		$	0.0872
Class I	$	0.0805		$	0.1443

See notes to financial statements.

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ML APM GLOBAL COMMODITY FUTURESACCESS LLC

(a Delaware Limited Liability Company)

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

	Members’ Capital				Members’ Capital
	December 31, 2006*	Subscriptions	Redemptions		September 30, 2007
Class A	—	4,259,433	(222,719	)	4,036,714
Class C	—	21,324,642	(1,517,133	)	19,807,509
Class D	6,615,200	14,961,801	(11,598,523	)	9,978,478
Class I	—	6,142,475	(66,446	)	6,076,029
Total Members’ Units	6,615,200	46,688,351	(13,404,821	)	39,898,730

	Members’ Capital								Members’ Capital
	December 31, 2006*		Subscriptions		Redemptions			Net Income	September 30, 2007
Class A	$	—	$	4,255,472	$	(233,025	)	319,456	$	4,341,903
Class C	—		21,150,256		(1,553,655		)	1,533,113	21,129,714
Class D	6,487,434		14,615,995		(11,476,308		)	1,004,970	10,632,091
Class I	—		6,144,935		(68,586		)	472,770	6,549,119
Total Members’ Interest	$	6,487,434	$	46,166,658	$	(13,331,574	)	3,330,309	$	42,652,827

* The Fund commenced operations on December 1, 2006.

See notes to financial statements.

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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 September 30, 2007, and the results of its operations for the three months and nine months ended September 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, including computing Net Asset Value for purposes of member subscription and redemption activity, such costs are amortized over 60 months. Consequently, the Net Asset Value and Net Asset Value per Unit of the different Classes for financial reporting purposes and for all other purposes are as follows:

	Net Asset Value					Net Asset Value per Unit
	All Other Purposes		Financial Reporting		Number of Units	All Other Purposes		Financial Reporting
Class A	$	4,345,184	$	4,341,903	4,036,714	$	1.0764	$	1.0756
Class C	21,136,160		21,129,714		19,807,509	1.0671		1.0668
Class D	10,649,436		10,632,091		9,978,478	1.0672		1.0655
Class I	6,551,499		6,549,119		6,076,029	1.0783		1.0779
	$	42,682,279	$	42,652,827	39,898,730

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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 Other 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

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 or market value 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 or market value of options, 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.

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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.

4.RECENT ACCOUNTING PRONOUNCEMENT

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.

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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.		July		Aug.		Sept.
2007	N/A	$	0.9932	$	0.9869	$	0.9853	0.9827	$	1.0022	$	1.0161	$	1.0259	$	1.0764

Class C

	Jan.		Feb.		Mar.		Apr.		May.		Jun.		July		Aug.		Sept.
2007	$	0.9982	$	0.9906	$	0.9835	$	0.9810	$	0.9776	$	0.9962	$	1.0092	$	1.0181	$	1.0671

Class D

	Jan.		Feb.		Mar.		Apr.		May.		Jun.		July		Aug.		Sept.
2007	$	0.9816	$	0.9762	$	0.9712	$	0.9708	$	0.9695	$	0.9899	$	1.0049	$	1.0160	$	1.0672

Class I

	Jan.		Feb.		Mar.		Apr.		May.		Jun.		July		Aug.		Sept.
2007	$	0.9994	$	0.9930	$	0.9870	$	0.9857	$	0.9834	$	1.0032	$	1.0175	$	1.0277	$	1.0783

Performance Summary

January 1, 2007 to September 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

7

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 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 ECB and the 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 10-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 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.

July 1, 2007 to September 30, 2007

The Fund posted profits for the third quarter with gains being posted in all the sectors.

The agriculture sector posted the highest gains for the Fund. The rally in commodities has made the deltas in certain options such as cotton, sugar, hogs and cattle move up to 80% at the beginning of the quarter. Profits continued to be posted to the Fund mid-quarter as wheat had a strong month off of a continued drought in Australia, Canada, and other parts of Europe. U.S. supplies and inventories were at their lowest in 26 years. Wheat continued to trade strong at the end of the quarter due to the on-going drought conditions and estimates from United States Department of Agriculture (“USDA”) that projected inventories for 2007/2008 will be the lowest since 1973/1974. U.S. wheat exports are already up 66% from last year and the USDA is predicting a further 18% rise for 2007/2008.

The metals sector posted profits for the Fund. At the beginning of the quarter profits were posted to the Fund as copper remained strong due to the labor unrest in Central and South America. However, losses were posted to the Fund mid-quarter as industrial metals weakened from expected slowing demand. The quarter ended with profits posted to the Fund as gold prices firmed on the continued weakness of the dollar and overall credit concerns.

The energy sector posted profits for the Fund. Crude oil traded over $78.00 a barrel on continued high demand beginning of the quarter plus the International Energy Agency forecasted that global demand will rise by 1.8% next year without any output increase from OPEC. The biggest news was the Contango that existed from the first quarter of 2005 for oil corrected and moved to backwardation. Losses were posted to the Fund mid-quarter as crude oil traded down to $70.00 a barrel on reported liquidation from hedge funds raising cash for redemptions. Hurricane Dean did not impact U.S. oil production, but it later traded back up with inventory levels falling and a record demand for gasoline. The quarter ended with profits posted to the Fund as crude oil had strong recovery as the Department of Energy’s Short-Term Energy Outlook saw a continued low surplus production and weak inventories. According to Cambridge Energy Research Associates, 100 new rigs could be built in the next four years, but new supply won’t hit until mid to late 2009.

The interest rate sector posted profits for the Fund.  The beginning of the quarter was challenging due to the subprime mortgage problems impacting global markets and U.S. interest rates started to reverse their trends of factoring a tightening of rates causing the losses to be posted to the Fund. The U.S. Federal Funds futures have factored in an ease of 25 basis points by December 2007. The shorter end of international curves showed less of a reaction due to a view that the problem will be contained in the U.S. Also, continued strength in underlying economic fundamentals brought another rate hike by the Bank of England. Profits were posted to the Fund mid-quarter as the U.S. Federal Reserve lowered the discount rate to 5.75% from 6.25% in an attempt to boost credit markets. Continued money market concerns caused short term U.S. treasury bills to have wild swings up to 100 basis points in one day. European Central Bank changed tone away from inflation by saying that the Central Bank is not committed to raising rates. The United Kingdom is showing first signs that past interest rate hikes are having an impact on its economy.  Even though the U.S. Federal Reserve further cut rates by 50 basis points bringing the U.S. Federal Funds rate down to 4.75% and adding stability into financial markets at the end of the quarter, but it was not enough to offset the losses posted to the Fund.

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The currency sector was also profitable for the Fund. The quarter began with profits being posted to the Fund as the fixed income portions were set up well to take in a period of global equity volatility. Profits continued to be posted through mid-quarter as the fixed income book continued to benefit from a period of global equity volatility. The quarter ended with a small loss being posted to the Fund as the fixed income portion went long in Euro dollars and shorted the short duration instruments in the Euro zone.

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 from civil liability provided for such statements by the Private Securities Litigation Reform Act of 1995 (set forth in Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934).  All quantitative disclosures in this section are deemed to be forward-looking statements for purposes of the safe harbor, except for statements of historical fact.

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).

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.

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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 nine months ended September 30, 2007, the Fund’s average Month-end Net Asset Value for all other purposes was approximately $25,376,727.

September 30, 2007

Market Sector	Average Value at Risk		% of Average Capitalization		Highest Value At Risk		Lowest Value At Risk
Agricultural Commodities	$	82,422	0.32	%	$	629,565	$	2,587
Energy	50,612		0.20	%	355,242		1,215
Interest Rates	1,222,733		4.82	%	2,092,721		390,839
Metals	30,948		0.12	%	166,653		2,545
F/X	10,252		0.04	%	84,535		9
TOTAL	$	1,396,967	5.50	%	$	3,328,716	$	397,195

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.”

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.

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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.

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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
Aug-07	71,174		70,046	1.0161
Sep-07	30,848		30,070	1.0259
Oct-07	186,639		173,392	1.0764

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	—		—	0.9695
Jul-07	750,000		757,652	0.9899
Aug-07	—		—	1.0049
Sep-07	—		—	1.0160
Oct-07	5,127,434		4,804,567	1.0672

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
Aug-07	1,214,985		1,203,909	1.0092
Sep-07	2,380,586		2,338,264	1.0181
Oct-07	1,338,306		1,254,152	1.0671

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
Aug-07	371,999		365,601	1.0175
Sep-07	1,030,000		1,002,237	1.0277
Oct-07	1,082,198		1,003,615	1.0783

(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: November 14, 2007	By	/s/ ROBERT D. OLLWERTHER
		Robert D. Ollwerther
		Chief Executive Officer and President
		(Principal Executive Officer)
Date: November 14, 2007
	By	/s/ BARBRA E. KOCSIS
		Barbra E. Kocsis
		Chief Financial Officer
		(Principal Financial and Accounting Officer)

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