NY FORM CADV ** File No. _____________ (1/87) (for renewals only) STATE OF NEW YORK Office of the Attorney General BUREAU OF INVESTOR PROTECTION AND SECURITI ES COMMODITY INVESTMENT ADVISOR STATEMENT (Section 359-e(14) Gen. Bus. Law) PART I. BACKGROUND OF ADVISOR 1. Name of Advisor: a. State full name of advisor:__________________________________ b. State trade names or publication names used by advisor: __________________________________________________________ __________________________________________________________ 2. Principal place of business of advisor is at __________________________ _______________________________________________________________ _______________________________________________________________ (Zip) . It has been at this location for _________________ years and [ ] does [ ] does not share this space with any other entity. (If space shared, indicate with whom on separate sheet). The telephone number at this location is ( ) ___________________ which number [ ] is [ ] is not shared with any other entity. (If shared, state details on separate sheet). 3. The advisor [ ] does [ ] does not maintain other offices or facilities. If it does, state where. 4. Is advisor engaged in any business or profession, directly or indirectly, other than that of a commodity investment advisor? [ ] yes; [ ] no. Describe the nature of each such other business and state what the principal business of the commodity advisor is on a separate sheet. If the principal business is other than that of a commodity investment advisor, the balance of the questions need be answered only as they relate to the commodity advisor portion of such business. 5. The advisor is a [ ] corporation; [ ] partnership; [ ] sole proprietorship; organized under the laws of ________________ ___________________ on (date)________________________________________________________________. >>>> 26. Has the commodity advisor acquired, merged, or otherwise succeeded to the business of another commodity investment advisor within the last five years? [ ] yes [ ] no. If yes, provide details. Filing Fee Enclosed as Please indicate to whom you wish Follows: ommodity Investment Advisor the fee receipt sent. Statement ............ $100 ( ) Attorney ( ) Firm Personal checks not accepted. Send remittance to: Attorneys check, bank check, Bureau of Investor Protection certified check, money order and Securities, 23rd Floor N.Y.S. Office of the Attorney only, payable to the N.Y.S. General Office of the Attorney 120 Broadway General New York, NY 10271 ** Found on the fee receipt you received for original filing. 7. Has the advisor, within the last five years, discontinued business, changed its name or merged with another company? [ ] yes [ ] no. If yes, provide details. 8. The following is a complete list of the names and equity interests of all officers, directors, principals, partners, managers, supervisors or any 10% or more equity holder. For each person listed, submit form CI-1. 9. The advisor [ ] is [ ] is not registered with the SEC as an Investment Advisor. If registered, the advisor [ ] does; [ ] does not use the title "Investment Counsel" under Section 208 (c) of the Federal Investment Act of 1940. 10. The advisor [ ] is [ ] is not registered with the CFTC. 11. The commodity investment advisor is licensed or registered to do business as such in the following states: PART II. BACKGROUND OF PRINCIPALS AND EMPLOYEES 12. State whether any individual named in Questions 8 or 9, or any entity in which such individual was a principal has ever: A. been suspended or expelled from membership in any securities or commodities exchange, association of securities or commodities dealers or investment or commodities trading advisors or counsel? ............ Yes [ ] No [ ] B. had a license or registration as a securities or commodity dealer, broker, investment advisor, salesperson, futures commission merchant, associated person, commodity pool operator or commodity trading advisor denied, suspended, revoked, cancelled or refused? .......................................... Yes [ ] No [ ] >>>> 3 C. been enjoined or restrained by any court or government agency from: 1. the issuance, sale or offer for sale of securities or commodities? ...................................................................Yes [ ] No [ ] 2. rendering securities or commodities advice or counsel? .Yes [ ] No [ ] 3. handling or managing trading accounts? .....................Yes [ ] No [ ] 4. continuing any practices in connection with securities commodities ...................................................................... Yes [ ] No [ ] D. Is any action or proceeding seeking the relief enumerated in A - C presently pending? ..................................................................................... Yes [ ] No [ ] E. been convicted of any crime? ..................................................Yes [ ] No [ ] F. used or been known by any other name? ............................... Yes [ ] No [ ] G. been the subject of any professional disciplinary proceeding?.................................................................................. Yes [ ] No [ ] H. been adjudged a bankrupt or made a general assignment for benefit of creditors; been the subject of a receivership or bankruptcy proceeding; been an officer, director, principal, partner, manager, supervisor or any 10% or more equity holder of any entity which was reorganized in bankruptcy, adjudged a bankrupt or made a general assignment for benefit of creditors? ..........................Yes [ ] No [ ] I. has a judgment entered against them or it which is presently unsatisfied? (Not including judgments involving domestic relations.) ................................................................................... Yes [ ] No [ ] J. been a party in any litigation or administrative proceeding in which it is alleged that they or it committed fraud or otherwise violated any provision of the Martin Act or any other securities laws ? ........................................................................................ Yes [ ] No [ ] K if any answer to any of the above is "YES", attach statement of full particulars. 13. As of the date of this statement, the advisor has approximately ____________ clients located in New York State. 14. a. Does the advisor make specific recommendations or assign ratings on securities or commodities [ ] yes; [ ] no. b.