BelAir Capital Asset Management

Trading Philosophy and Methodology The Advisor’s objective is to achieve capital appreciation for its clients through speculative trading of futures and options. In order to do so, the Advisor currently offers one trading program. Although the system is primarily technical and rule based, the Advisor does give consideration to available fundamental data in order to give the best risk/reward possible and therefore, will exercise a certain level of discretion over the program. Decisions on whether or not to act upon a trade signal depends upon a combination of technical timing and potential risk points associated with trades. Entry points are determined by the market itself. Market psychology and market action suggests that that the lowest risk time to buy or to sell occurs after a directional move (with the trend or counter to the trend) has been exhausted. Set ups for low risk entry into markets is associated with previous supply or demand price points (highs and lows). Once a potential set up point is identified, the market will move to confirm that a new high or new low has been established. The proprietary technical parameters used in association with the system determine at the earliest time when a high or low has been established. This method also helps in determining the risk associated with each trade. Stop losses may be used in association with the risk points associated with the potential new high or new low. The use of stop loss orders are at the discretion of the Advisor. Further discretion can be used to enter or exit trades by measuring volatility, risk associated with a trade and to determine the validity of the setup points. Fundamental analysis is the consideration of factors external to the market of a particular instrument. For example, weather, imports/exports, and political events that affect the supply and demand of that particular instrument, in order to predict future prices of that instrument. Technical analysis is not based on the anticipated supply and demand of the "cash" or "physical" (i.e., actual) commodity; instead, technical analysis is based on the theory that a study of the markets themselves (in particular, of trends of prices established by the markets for various instruments during selected historical periods) provides a means of anticipating prices. Technical analysis of the markets often includes a study of the actual daily, weekly and monthly price fluctuations, as well as volume variations and changes in open interest, utilizing charts and/or computers for analysis of these items and other technical market data. The program primarily involves buying and selling futures on United States regulated exchanges. The Advisor may trade options. The Advisor follows most commodity futures markets in the United States but focuses on currencies, financials, soft commodities, metals, grains, meats, agricultural products, stock indices, and other markets as the Advisor may determine in the future. The Advisor currently does not trade on international exchanges and does not trade FOREX, however there are no restrictions or limitations on what commodity interests or other interests the Advisor may or may not trade. If the Advisor decides to trade these markets and products, the Advisor will notify you before doing so. The average amount of funds invested for margin purposes at one time will generally be approximately 5% to 10% however, the percentage may be substantially higher or lower based upon the current market conditions. On the average, the Advisor expects the Program to trade 3,500 to 5,000 round turn contracts per $1,000,000; however, this average can fluctuate substantially based upon market conditions and volatility. Generally, when new client accounts are established, the Advisor will need approximately three to four weeks to initiate new positions or enter markets until the account is fully invested in the program. During this period, it is possible that the performance of new accounts will vary from accounts that have been existing in the program. <br><br> Principle Bio: <br><br> Mr. Eisen has been in the financial service business for nearly 25 years. In January 1982, Mr. Eisen joined Conti Commodity Services and served as an associated person of Conti Commodity Services from January 1982 through November 1983. Conti Commodity Services was registered as a futures commission merchant and was a Member of NFA and was headquartered in Chicago, IL. In November 1983, Mr. Eisen left Conti Commodity Services to join Prudential Equity Group, LLC (doing business as Prudential Bach Securities), a financial service company that was registered as a broker dealer and was a registered futures commission merchant headquartered in New York. Between December 1983 and April December 1, 2008 4 1988, Mr. Eisen was a registered associated person of Prudential Equity Group, LLC. In April 1988, Mr. Eisen left Prudential Equity Group, LLC to join Dean Witter headquartered in New York, subsequently known as known as Morgan Stanley DW, Inc. <br><br> When Mr. Eisen joined Dean Witter in April 1988, Dean Witter was a registered futures commission merchant and Member of NFA. Mr. Eisen became a registered associated person under Dean Witter in November 1988 and became a branch manager in May 1991. While at Dean Witter, Mr. Eisen was responsible for supervising the branch office, servicing customers and operating the branch office. Mr. Eisen left Dean Witter in April 1994 at which time he also terminated his associated person license and branch office manager status in April 1994. In April 1994, Mr. Eisen rejoined Prudential Equity Group, LLC. From May 1994 through September 1997, Mr. Eisen was a registered associated person and listed branch office manager of Prudential Equity Group, LLC and served as the Senior Vice President of Investments. <br><br> In September 1997, Mr. Eisen left Prudential Equity Group, LLC to start his own introducing broker operations called Belair Capital Corp. Mr. Eisen became a registered associated person and listed principal of Belair Capital Corp in October 1997. Belair Capital Corp became a Member of NFA on August 29, 1997 and effectively registered as an introducing broker on October 17, 1997. Belair Capital Corp. reorganized in February 2006 and created a new entity and name, Belair Capital Advisors, Corp. Belair Capital Corp. transferred all of its customer business and operations over to the new and current entity upon Belair Capital Advisors, Corp becoming effectively registered. Mr. Eisen became a registered associated person and listed principal of Belair Capital Advisors Corp. on March 21, 2006.