Ny Form Cadv - Commodity Investment Advisor Statement (Page 4 of 5) in pdf

14.

a. Does the advisor make specific recommendations or assign ratings on

securities or commodities [ ] yes; [ ] no.

b. Does the advisor give advice to clients as to the investment of funds on the

basis of analysis of the individual needs of the clients? [ ] yes; [ ] no.

c. Does the advisor issue periodic publications on a subscription basis? [ ]

yes; [ ] no.

d. Does advisor issue special reports or analysis? [ ] yes; [ ] no.

e. What are the general methods of commodities analysis by the advisor?

Indicate the importance of each.

f. What are the principal sources of information for the advisor's research?

Indicate the importance of each.

g. To what extent and how does the advisor verify or test the accuracy of

externally provided information and data?

h. How many advisory services does the advisor subscribe to (on either a paid

or exchange basis)? ____________________________

i. Does advisor publish and maintain a list of recommended or rated

commodities? [ ] yes; [ ] no. If yes: What is the approximate size of such list?

__________________________. How frequently does advisor add to, delete

from, or review such recommended or rated list?

________________________. What is the maximum length of time a

recommendation or rating can be so listed without a comprehensive,

mandatory review?

_____________________________________________________

j. Set forth a schedule of the advisor's fees and charges; attach a sample form

of contract, if any.

15. Does advisor or any person named herein have discretionary authority to make

any of the following determinations without obtaining the consent of the client

before the transaction is effected?

a. Whether the transaction is to be one of purchase or sale [ ] yes; [ ] no.

b. Which commodity is to be bought or sold [ ] yes; [ ] no.

c. The total amount of the commodity to be bought or sold [ ] yes; [ ] no.

16. Does advisor or any person named herein have custody or possession, or

authority to obtain custody or possession of:

a. Commodities or commodity contracts of any clients [ ] yes; [ ] no.

b. Funds of any client [ ] yes; [ ] no.

17. Does advisor's business consist of or include any type of investment advisory

service not described above? [ ] yes; [ ] no.

If Yes, on a separate sheet describe in detail any other type of investment

advisory service performed and the basis of recommendations made.

18. Does advisor:

a. As principal, sell commodities to or buy commodities from any clients to

whom it has recommended such purchase or sale? [ ] yes; [ ] no.

Ny Form Cadv - Commodity Investment Advisor Statement Page 4