Villano Capital Management, Inc.

Global Diversified

The methodology of the trading program Global Diversified has evolved through the study of market prices that often do not exhibit purely random behavior, but instead, have shown a propensity to exhibit persistent trends. Through the use of pattern recognition techniques, models of trend, volatility, and money management rules, the objective of the program is to exploit these trends for profit by trading futures and options contracts. The advisor believes that in an information driven world where news events are disseminated and acted upon in seconds, often jarring the smoothness of market trends, the comprehensive control of volatility represents the embodiment of sound money management. This key concept applies for both initial positions as well as positions with significant open profits where considerable upward shifts in volatility will profoundly impact profitability. With the control of volatility on both a per trade basis and on the portfolio level as its focal point, the program utilizes its proprietary models to isolate market environments that exhibit a high probability for sustainable trends to develop. It should be noted that strict adherence to money management principles are of paramount importance for the Global Diversified Trading Program to meet its objective. One such principle, known as risk-adjusted equity, assumes that what is at risk is lost and such amount is subtracted from the net liquidating value of the account. An account's risk-adjusted equity is then used to determine the size of new positions from new trade signals. In addition, careful decisions are made when allocating risk-adjusted equity for the creation of a well-balanced diversified portfolio. Because not all markets perform as anticipated, there is no guarantee that VCM will obtain its objective. The Trading Advisor, in his discretion, ultimately retains discretion to determine whether a particular trade will be entered in a client's account. This decision will be based on a number of factors, including but not limited to risk-adjusted equity, market volatility and risk tolerance and the trading advisor's interpretation of his technical models. Therefore, it is possible that some clients may participate in a particular trade while others may not. VCM reserves the right to expand trading into other domestic markets and international markets. The average margin to equity is 15% with approximately 2,500 round-turns per million dollars of nominal account equity per year.