Privacy Policy

IN ACCORDANCE WITH NFA REGULATIONS, WE HAVE INSTITUTED

A PRIVACY POLICY. PLEASE RETAIN THIS FOR YOUR RECORDS.

Privacy Policy

1. Cutler obtains and/or maintains nonpublic personal information regarding each client such as, but not limited to, social security number, occupation, income level, net worth, account number and account status.

2. Cutler and its principals and employees shall not disclose any nonpublic personal information regarding its existing and past clients to any third party except as permitted by law, such as lawyers, accountants, auditors and regulators.

3. Cutler will restrict access to clients’ personal information to those employees who need to know such information in order to provide services to clients. Cutler will maintain physical, electronic, and procedural safeguards to guard each client’s personal financial information. Such safeguards include:

· restricting the use of any personal information to each client’s personal account executive, that person’s supervisor and such other persons as the CCO deems as needing to know the information,

· hard copies of clients’ personal information will be maintained in Cutler’s central files, and will be secured (locked) after normal business hours,

· electronic access to client personal information will be restricted via passwords and

· whenever an employee leaves Cutler any password or code used to gain access by that employee is extinguished or changed.
4. Each client will initially be provided with a copy of Cutler’s privacy policy by receiving a copy of its Disclosure Document that contains a notice therein.
5. Cutler will provide notice to its clients on an annual basis that states the following:
We consider privacy to be fundamental to our relationship with you. In order to invest in the Fund you must provide us with personal information about you, such as your occupation, income level and net worth. We collect this information to know who you are so that we can meet our obligations under the laws and regulations that govern us. It is our policy and practice to respect your privacy and to protect all personal information entrusted to us. Our employees will only have access to such information if they need to know in order to service you. We also do not disclose any nonpublic information about our clients or former clients to third parties except as permitted by law, such as lawyers, accountants, auditors and regulators.
6. Annual notice will be provided every year by March 30. Cutler will send such notice by US Mail.

Risk of Investing in Managed Futures

THE RISK OF LOSS IN TRADING COMMODITIES CAN BE SUBSTANTIAL. YOU SHOULD THEREFORE CAREFULLY CONSIDER WHETHER SUCH TRADING IS SUITABLE FOR YOU IN LIGHT OF YOUR FINANCIAL CONDITION.

THE HIGH DEGREE OF LEVERAGE THAT IS OFTEN OBTAINABLE IN COMMODITY TRADING CAN WORK AGAINST YOU AS WELL AS FOR YOU. THE USE OF LEVERAGE CAN LEAD TO LARGE LOSSES AS WELL AS GAINS.

IN SOME CASES, MANAGED COMMODITY ACCOUNTS ARE SUBJECT TO SUBSTANTIAL CHARGES FOR MANAGEMENT AND ADVISORY FEES. IT MAY BE NECESSARY FOR THOSE ACCOUNTS THAT ARE SUBJECT TO THESE CHARGES TO MAKE SUBSTANTIAL TRADING PROFITS TO AVOID DEPLETION OR EXHAUSTION OF THEIR ASSETS. THE DISCLOSURE DOCUMENT CONTAINS A COMPLETE DESCRIPTION OF THE PRINCIPAL RISK FACTORS AND EACH FEE TO BE CHARGED TO YOUR ACCOUNT BY THE COMMODITY TRADING ADVISOR ("CTA").

THE REGULATIONS OF THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") REQUIRE THAT PROSPECTIVE CLIENTS OF A CTA RECEIVE A DISCLOSURE DOCUMENT WHEN THEY ARE SOLICITED TO ENTER INTO AN AGREEMENT WHEREBY THE CTA WILL DIRECT OR GUIDE THE CLIENT'S COMMODITY INTEREST TRADING AND THAT CERTAIN RISK FACTORS BE HIGHLIGHTED. THIS DOCUMENT IS READILY ACCESSIBLE AT THIS SITE. THIS BRIEF STATEMENT CANNOT DISCLOSE ALL OF THE RISKS AND OTHER SIGNIFICANT ASPECTS OF THE COMMODITY MARKETS. THEREFORE, YOU SHOULD PROCEED DIRECTLY TO THE DISCLOSURE DOCUMENT AND STUDY IT CAREFULLY TO DETERMINE WHETHER SUCH TRADING IS APPROPRIATE FOR YOU IN LIGHT OF YOUR FINANCIAL CONDITION. YOU ARE ENCOURAGED TO ACCESS THE DISCLOSURE DOCUMENT BY CLICKING BELOW. YOU WILL NOT INCUR ANY ADDITIONAL CHARGES BY ACCESSING THE DISCLOSURE DOCUMENT. YOU MAY ALSO REQUEST DELIVERY OF A HARD COPY OF THE DISCLOSURE DOCUMENT, WHICH ALSO WILL BE PROVIDED TO YOU AT NO COST. THE CFTC HAS NOT PASSED UPON THE MERITS OF PARTICIPATING IN THIS TRADING PROGRAM NOR ON THE ADEQUACY OR ACCURACY OF THE DISCLOSURE DOCUMENT.

OTHER DISCLOSURE STATEMENTS ARE REQUIRED TO BE PROVIDED TO YOU BEFORE A COMMODITY ACCOUNT MAY BE OPENED FOR YOU.

PLEASE ACKNOWLEDGE YOUR UNDERSTANDING Of THIS IMPORTANT STATEMENT.