Covenant Capital Management Need help with terms? United States Type: Commodity Trading Advisor (CTA) Registrations: NFA ID: 0295798 Program Past 12 Months Sep YTD CAROR WDD AUM Min Inv Visits Aggressive Program N/A 11.91 -28.71 $ 3,000k 31313 Hedged Equity Program -5.37 86.45 - -8.65 $ 2.5M $ 100k 224 Optimal Program N/A -30.23 -95.11 $ 10k 16638 Original Program N/A 9.11 -28.61 $ 5,000k 24803 Tactical Growth Program 1.24 10.33 10.29 -10.53 $ 1.1M $ 100k 6746 Total Volatility Program (P&C) 6.05 16.64 18.98 -13.84 $ 16.4M $ 100k 4260 Past performance is not necessarily indicative of future results. The risk of loss in trading commodity futures, options, and foreign exchange ("forex") is substantial. CTA Introduction Company Profile Founded in 1999, Covenant Capital Management, LLC (CCM) is an alternative asset manager. CCM is registered with the Commodity Futures Trading Commission as a Commodity Trading Advisor (CTA), and manages client assets using global futures markets as an investment vehicle. CCM currently trades in over 40 different markets including equity indexes, fixed income, foreign exchange, agricultural, metals, soft commodities, and energy. CCM offers three primary programs, the Original Program, the Aggressive Program and the Optimal Program. The Programs use the same trading signals and vary only in the amount of risk taken on each trade. Investment Strategy and Philosophy CCM’s investment strategy is rooted in strict adherence to a quantitative and mechanical trading program that is engineered to generate profits from the non-normal distribution of price movements in financial markets. We believe that freely traded market moves follow a non-normal distribution curve highlighted by large tails, narrow mid-ranges and a high peak. This phenomenon is measurable and has been thoroughly evidenced in academia. CCM does not try to predict when trends will emerge, how long they will last, or even how high or low they will go. The only prediction that CCM makes is that trends will continue to emerge as a function of the market place. CCM’s goal is to capture these large and unexpected price changes in the most efficient manner possible providing competitive risk adjusted returns over a five year investment horizon. Principle Biographies: Mr. Billington began his career trading futures at J. C. Bradford & Co. where he was responsible for executing client orders, advising clients, and developing trading systems. Mr. Billington later worked for Ronin Capital, a proprietary trading firm at the Chicago Board Options Exchange, where his main function was making markets in the S&P 100 Index options market. Mr. Billington has been a principal and associated person of CCM since inception on July 30, 1999, and he became a branch office manager of CCM on July 13, 2005. Mr. Wilford’s prior work history includes serving as Senior Vice-President of Investments for Healthcare Realty Trust, Inc. (NYSE:HR), a publicly-traded real estate investment trust; where his primary responsibilities included development, financial modeling, consulting and asset acquisitions. Mr. Wilford manages the CCM headquarters in Nashville, TN and has been registered as a principal and associated person of CCM since co-founding the company on July 30, 1999.