Chicago Capital Management, LLC

Bond Program

The Picks N' Shovels T-Bond System is a short-term technical program that trades in the T-Bond market at the Chicago Board of Trade on an intra-day basis. The system is designed to be used primarily as an add-on to the other longer-term trading systems of the Advisor, but the Advisor may accept smaller accounts on a limited basis. There are no restrictions on which commodity interest the Advisor will trade or which trading system will be used. The Advisor may trade your account in any market that is now traded or may be traded in the future, as well as other systems of the Advisor. Trading decisions may require the exercise of judgement by the Advisor. Therefore, the success of trading may depend largely on the trading ability, knowledge and judgement of the Advisor. The Advisor may exercise its judgment and discretion in interpreting the trading signals generated by a trading system and will make all decisions regarding the trading of commodity interests, including selecting the markets which will be followed and the commodities and markets which will be actively traded. In addition, the Advisor will determine the time at which orders are to be placed with and executed by a broker, the method by which orders are to be placed, the types of orders that are to be placed and the overall leverage for the portfolio. The Advisor may employ various strategies for phasing an account in and out of the markets. Occasionally, when the markets traded are unstable the Advisor may order a temporary reduction of positions and may exit the markets entirely and therefore hold no open positions. The decision by the Advisor not to trade certain commodities or not to make certain trades may result at times in missing price moves and hence profits of great magnitude, which other trading managers who are willing to trade these commodities may be able to capture. The Advisor's program is dependent in part on the existence of stable price trends in a sufficient number of commodity interests. There have been periods in the past without such trends, and those periods may recur. The Advisor believes that the development of a commodity trading program is a continual process. As a result of further analysis and research into the performance of the systems that make up its program, changes have been made from time to time in the specific manner in which such systems evaluate price movements, and it is likely that similar revisions will be made in the future. The trading program to be followed by the Advisor does not assure successful trading. Investment decisions made in accordance with this strategy will be based on an assessment of available facts. However, because of the large quantity of facts at hand, the number of available facts that may be overlooked and the variables that may shift, any investment decision must, in the final analysis, be based on the judgment of the Advisor. Please note that the details of the Advisor's trading program are proprietary and confidential and are not generally known to its clients. Accordingly, the description above is of necessity general and not intended to be exhaustive. Consequently, you will not be able to determine the full details of the program, or whether the program is being followed. There can be no assurance that any trading program of the Advisor and the systems therein will produce profitable results or will not result in losses