Pixley Capital Management

Program Description: General Objective The objective of the Advisor's trading methodology (the "Program") is to achieve consistent and reasonable capital appreciation of clients' assets through speculative trading of commodity futures and options on futures. The Program is technical in nature, developed from the Advisor's internally conducted research and analysis of historical and current patterns of price behavior. The Program may be further described as methodical, but not a mechanical system, relying instead primarily on the judgment of the Advisor to determine which trades (both long and short) are deemed appropriate from a risk/reward and money management perspective. Trades may be held for a very brief time or many weeks, depending upon the trading advisors assessment of the market conditions and the opportunities they present. Whereas many technical traders intentionally ignore consideration of the steady stream of news and information that comprises fundamental analysis, the Advisor constantly monitors and measures the market's response to these events against his expectations born of technical analysis. The Advisor will engage primarily in outright trades, taking a futures position long or short, seeking to capitalize on directional moves. The Program also includes the use of exchange for physical transactions ("EFP"). A transaction permitted under the rules of many exchanges in which two traders holding futures and cash or forward positions may close out their positions without making an open, competitive trade on the exchange floor. The Advisor will not be engaged in exotic derivative strategies. All trades will occur on regulated futures and option exchanges. The markets traded by the Advisor are the financial and energy based commodities. It should be noted that the effort to improve the Program through further research is an ongoing effort. As such, when new tools emerge that the principals believe will add value, the model will be upgraded to include them. This does not indicate major changes in the way that trading decisions are made, but rather improvements at the margin. Since the trading methodology incorporated in the Program is proprietary and confidential, the above discussion is of a general nature and is not intended to be exhaustive. Randy Pixley Mr. Pixley is the Managing Member of Pixley Capital Management, LLC and in such role is responsible for the executive decisions of the advisor along with running the day-to-day operations. He has been registered as a principal and associated person of the Advisor since August 18, 2003. Mr. Pixley has been involved in trading and brokerage for over ten (10) years. At the beginning of his career, Mr. Pixley served as a registered representative for several independent research firms specializing in the over-the-counter foreign currency ("Forex") markets. His responsibilities included systems design for the major currencies and their crosses. In addition, he also worked on the testing and development of computerized trading programs for equity, debt, and energy market instruments. From March of 1997 to August of 2000, Mr.Pixley was employed as a registered representative by Prudential Securities. He worked as a trader and analyst for retail and commercial market participants who rely on market timing expertise to help maximize the profitability of their operations. Also in 1997, Mr. Pixley began trading a personal trading account, spending the years between 1997 and 2000 developing a deeper understanding of markets, traders, and trading systems. In 1998, he began to assemble clients necessary to create a consistent trading system. His expertise in technical market analysis prompted one of his clients to hire him as a trader for Forex and equity futures in August 2000. Mr. Pixley left Prudential Securities to concentrate on consulting and trading advisory as a sole proprietor and under the name of Pixley Capital Management ("PCM") in August of 2000. Since October 2000, Mr. Pixley has been working as an independent consultant and trading advisor for Kate Yuen Trust and has also provided trading advice to other firms requiring his services. There have never been any material administrative, civil or criminal actions (whether pending, on appeal, or concluded) against Mr. Pixley.