Capital Trading Group

CTA Profile - Covenant Capital Mgt of Tennessee
Program - Optimal Prg
Principal(s): Scot Billington and Brince Wilford
Trading Strategy: Systematic Long-Term Trend Follower

Trading Description:
The probability curve of historical price distribution is non-normal, marked by a high peak and extremely fat tails. CCM attempts to participate in long term trends in order to profit from these fat tails. We do not predict trends. We do not predict when they will start, how long they will last, or how high or low they will move. CCM uses one technical indicator to define the current market trend and joins the trend at that time. After a trend has occurred, we do not seek to explain why it may have occurred or why it behaved as it did. The only prediction we ever make is that trends will continue to exist as a phenomenon of the market place. CCM uses a volatility trade filter, which eliminates many losing signals while preserving our ability to participate in the most profitable large trends.

The managers and creators of CCM trading programs insist that prospective clients commit to a minimum three-year holding period. Ideally, an investment in a CCM program should be held a minimum of seven years to sufficiently normalize the distribution of monthly returns. CCM is highly selective in choosing new clients, investors with short-term investment objectives will not be accepted under any circumstances. Additionally, although CCM clients may terminate trading at anytime, doing so within three years of opening the account shall result in an “early withdrawal fee” as described in the CCM Disclosure Document.

Trading Approach

Systematic - 100.00%
Discretionary - 0.00%
Trading Methodology
Trend Following: Long Term
Markets Traded
Diversified
Sector
Global Markets
Contracts Traded
Futures

Annual Performance Since 2003

2003	0.00%
2004	0.00%
2005	0.00%
2006	4.56%
2007	-0.10%
2008	27.08%
2009	65.19%

Recent Performance

Currency Denomination - US Dollars

2010	Monthly Return	YTD Return	Assets Under Mgt
07/31/10	-14.53%	4.36%	292,360
06/30/10	3.42%	22.11%	342,074
05/31/10	8.72%	18.07%	322,000
04/30/10	21.18%	8.60%	300,000
03/31/10	-0.75%	-10.38%	251,064
02/28/10	-0.71%	-9.70%	252,959
01/31/10	-9.05%	-9.05%	254,780
2009	Monthly Return	YTD Return	Assets Under Mgt
12/31/09	-15.51%	65.19%	509,089
11/30/09	57.37%	95.51%	509,089
10/31/09	-27.36%	24.24%	323,493
09/30/09	14.94%	71.03%	445,311
08/31/09	20.81%	48.80%	387,000

VAMI Chart (Based on a $1,000 Initial Value)

Monthly Percentage Returns Chart

PAST PERFORMANCE IS NOT INDICATIVE OF FUTURE RESULTS

Investment Details

Disclosure Document Date	03/31/10
Starting Date of Program	08/01/06
Accepting New Money?	Yes
Average Annual Rate of Return	25.27%
Peak to Valley Drawdown	-27.36 %
Average Margin as % of Equity	40.00%
Round Turns per Million	800
Minimum Sized Account	250,000
Currency Denomination	US Dollars
Management Fee	2.00%
Incentive Fee	20.00%
Notional Funding?	Yes
Member of NFA	Yes
Other Memberships

Statistical Definitions
(1) From January 1990 or Starting Date of Program - The Annual Average Rate of Return represents the compounded rate of return for each year or portion thereof presented. It is computed by applying successively respective monthly rate of return for each month beginning with the first month of that period. This includes all monthly data from the inception of the program or from January 1990, whichever is less.
(2) From January 1990 or Starting Date of Program - The Worst Peak-to-Valley Drawdown is defined as the greatest cumulative percentage decline in net asset value due to losses sustained by the trading program during any period in which the initial net asset value is not equaled or exceeded by a subsequent asset value. "Monthly" indicates that the Worst-Peak-to-Valley Drawdown" is based on monthly Data.

Risk Disclosure
THE RISK OF TRADING COMMODITY FUTURES, OPTIONS AND FOREIGN EXCHANGE ("FOREX") IS SUBSTANTIAL. THE HIGH DEGREE OF LEVERAGE ASSOCIATED WITH COMMODITY FUTURES, OPTIONS AND FOREX CAN WORK AGAINST YOU AS WELL AS FOR YOU. THIS HIGH DEGREE OF LEVERAGE CAN RESULT IN SUBSTANTIAL LOSSES, AS WELL AS GAINS. YOU SHOULD CAREFULLY CONSIDER WHETHER COMMODITY FUTURES, OPTIONS AND FOREX IS SUITABLE FOR YOU IN LIGHT OF YOUR FINANCIAL CONDITION. IF YOU ARE UNSURE YOU SHOULD SEEK PROFESSIONAL ADVICE. PAST PERFORMANCE DOES NOT GUARANTEE FUTURE SUCCESS. IN SOME CASES MANAGED ACCOUNTS ARE CHARGED SUBSTANTIAL COMMISSIONS AND ADVISORY FEES. THOSE ACCOUNTS SUBJECT TO THESE CHARGES, MAY NEED TO MAKE SUBSTANTIAL TRADING PROFITS JUST TO AVOID DEPLETION OF THEIR ASSETS. EACH COMMODITY TRADING ADVISOR ("CTA") IS REQUIRED BY THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") TO ISSUE TO PROSPECTIVE CLIENTS A RISK DISCLOSURE DOCUMENT OUTLINING THESE FEES, CONFLICTS OF INTEREST AND OTHER ASSOCIATED RISKS. A HARD COPY OF THESE RISK DISCLOSURE DOCUMENTS ARE READILY AVAILABLE BY CLICKING ON EACH CTA'S "REQUEST DISCLOSURE DOCUMENT" BUTTON. THE FULL RISK OF COMMODITY FUTURES, OPTIONS AND FOREX TRADING CAN NOT BE ADDRESSED IN THIS RISK DISCLOSURE STATEMENT. NO CONSIDERATION TO INVEST SHOULD BE MADE WITHOUT THOROUGHLY READING THE DISCLOSURE DOCUMENT OF EACH OF THE CTAS IN WHICH YOU MAY HAVE AN INTEREST. REQUESTING A DISCLOSURE DOCUMENT PLACES YOU UNDER NO OBLIGATION AND EACH DOCUMENT IS PROVIDED AT NO COST. THE CFTC HAS NOT PASSED UPON THE MERITS OF PARTICIPATING IN ANY OF THE FOLLOWING PROGRAMS NOR ON THE ADEQUACY OR ACCURACY OF THE DISCLOSURE DOCUMENTS. OTHER DISCLOSURE STATEMENTS ARE REQUIRED TO BE PROVIDED TO YOU BEFORE AN ACCOUNT MAY BE OPENED FOR YOU.

PAST PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS. PROSPECTIVE CLIENTS SHOULD NOT BASE THEIR DECISION ON INVESTING IN THIS TRADING PROGRAM SOLELY ON THE PAST PERFORMANCE PRESENTED. ADDITIONALLY, IN MAKING AN INVESTMENT DECISION, PROSPECTIVE CLIENTS MUST ALSO RELY ON THEIR OWN EXAMINATION OF THE PERSON OR ENTITY MAKING THE TRADING DECISIONS AND THE TERMS OF THE ADVISORY AGREEMENT INCLUDING THE MERITS AND RISKS INVOLVED.

THE ABOVE PERFORMANCE NUMBERS HAVE BEEN SUPPLIED BY THE CTAS. CAPTIAL TRADING GROUP LP NO WAY GUARANTEES THE ACCURACY OF THESE NUMBERS AND HAS SUPPLIED THEM TO YOU FOR INFORMATIONAL PURPOSES ONLY. THIS DOES NOT CONSTITUTE A SOLICITATION TO BUY OR AN OFFER TO SELL. NO INVESTMENT SHOULD BE MADE WITHOUT FULLY REVIEWING THE ASSOCIATED RISK FACTORS, FEES AND CONFLICTS OF INTEREST AS OUTLINED IN EACH CTA'S RISK DISCLOSURE DOCUMENT. THERE MAY BE CTAS WHO HAVE CHOSEN NOT TO PARTICIPATE THAT MAY HAVE BETTER OR WORSE PERFORMANCE THAN THOSE CTAS IN OUR DATABASE.

PLEASE NOTE THAT THERE IS AN INHERENT RISK OF LOSS ASSOCIATED WITH TRADING FUTURES AND OPTIONS CONTRACTS. PLEASE CAREFULLY CONSIDER YOUR FINANCIAL CONDITION BEFORE INVESTING IN FUTURES AND OPTIONS CONTRACTS. FUTURES TRADING IS NOT SUITABLE FOR ALL INVESTORS