Clarke Capital Management, Inc.

Jupiter Program

The Jupiter program currently trades approximately 61 domestic and international commodity interests. 17 of these are either long or short interest rate contracts reflecting interest rates in Europe, the US, Canada, Japan and Australia. The balance of the commodity interests followed are currencies, grains, softs, metals, meats and fuels, both foreign and domestic. The number of models used in this program is 66. Unlike many of the other programs of CCM, the Jupiter Program uses several very long term models among the 66 in its portfolio. These very long term models generally produce larger profits per trade, but lower profits per day than shorter models. When used in a portfolio with shorter time frame models, as is the case here, they can produce smoother overall equity curves even though these models generally give much more room to a position before exiting. It should be noted that there will be times when there is significant correlation between markets within a market sector or between market sectors, possibly in an adverse direction to positions held in the client’s account. Clients of the Jupiter program should be aware that this factor alone, although there are others, will lead to periods of extreme volatility. Regarding the level of funding, the Advisor strongly recommends that Clients fund their account as a Fully-Funded account. The Advisor will consider a Client's desire to open a Notionally-Funded account on a case by case basis.