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DISCLOSURE DOCUMENT for

THE COMMODITY FUTURES TRADING COMMISSION HAS NOT PASSED UPON THE MERITS OF PARTICIPATING IN THIS TRADING PROGRAM NOR HAS THE COMMISSION PASSED ON THE ADEQUACY OR ACCURACY OF THIS DISCLOSURE DOCUMENT.

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. IN CONSIDERING WHETHER TO TRADE OR TO AUTHORIZE SOMEONE ELSE TO TRADE FOR YOU, YOU SHOULD BE AWARE OF THE FOLLOWING:

IF YOU PURCHASE A COMMODITY OPTION, YOU MAY SUSTAIN A TOTAL LOSS OF THE PREMIUM AND OF ALL TRANSACTION COSTS.

IF YOU PURCHASE OR SELL A COMMODITY FUTURE OR SELL A COMMODITY OPTION, YOU MAY SUSTAIN A TOTAL LOSS OF THE INITIAL MARGIN FUNDS AND ANY ADDITIONAL FUNDS THAT YOU DEPOSIT WITH YOUR BROKER TO ESTABLISH OR MAINTAIN YOUR POSITION. IF THE MARKET MOVES AGAINST YOUR POSITION, YOU MAY BE CALLED UPON BY YOUR BROKER TO DEPOSIT A SUBSTANTIAL AMOUNT OF ADDITIONAL MARGIN FUNDS, ON SHORT NOTICE, IN ORDER TO MAINTAIN YOUR POSITION. IF YOU DO NOT PROVIDE THE REQUESTED FUNDS WITHIN THE PRESCRIBED TIME, YOUR POSITION MAY BE LIQUIDATED AT A LOSS, AND YOU WILL BE LIABLE FOR ANY RESULTING DEFICIT IN YOUR ACCOUNT.

UNDER CERTAIN MARKET CONDITIONS, YOU MAY FIND IT DIFFICULT OR IMPOSSIBLE TO LIQUIDATE A POSITION. THIS CAN OCCUR, FOR EXAMPLE, WHEN THE MARKET MAKES A "LIMIT MOVE."

THE PLACEMENT OF CONTINGENT ORDERS BY YOU OR YOUR TRADING ADVISOR, SUCH AS A "STOP LOSS" OR "STOP LIMIT" ORDER, WILL NOT NECESSARILY LIMIT YOUR LOSSES TO THE INTENDED AMOUNTS, SINCE MARKET CONDITIONS MAY MAKE IT IMPOSSIBLE TO EXECUTE SUCH ORDERS.

A "SPREAD" POSITION MAY NOT BE LESS RISKY THAN A SIMPLE "LONG" OR "SHORT" POSITION.

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. THIS DISCLOSURE DOCUMENT CONTAINS, AT PAGE 10, A COMPLETE DESCRIPTION OF EACH FEE TO BE CHARGED TO YOUR ACCOUNT BY THE COMMODITY TRADING ADVISOR.

THIS BRIEF STATEMENT CANNOT DISCLOSE ALL THE RISKS AND OTHER SIGNIFICANT ASPECTS OF THE COMMODITY MARKETS. YOU SHOULD THEREFORE CAREFULLY STUDY THIS DISCLOSURE DOCUMENT AND COMMODITY TRADING BEFORE YOU TRADE, INCLUDING THE DESCRIPTION OF THE PRINCIPAL RISK FACTORS OF THIS INVESTMENT, AT PAGE 8.

THIS COMMODITY TRADING ADVISOR IS PROHIBITED BY LAW FROM ACCEPTING FUNDS IN THE TRADING ADVISOR'S NAME FROM A CLIENT FOR TRADING COMMODITY INTERESTS. YOU MUST PLACE ALL FUNDS FOR TRADING IN THIS TRADING PROGRAM DIRECTLY WITH A FUTURES COMMISSION MERCHANT.

FUTURES AND MANAGED FUTURES 2 THE COMMODITY TRADING ADVISOR: STANLEY DASH 4 THE TRADING PROGRAM 5 YOUR FUTURES ACCOUNT 7 PRINCIPAL RISK FACTORS AND CONFLICTS OF INTEREST 8 FEES 10 GLOSSARY OF TERMS 12 PERFORMANCE RECORD 14

Commodity Trading Advisor:

Stanley Dash, CTA, a sole proprietorship,

registered with the Commodity Futures Trading Commission

and a member of National Futures Association.

Registration effective March 1993.

The Commodity Trading Advisor's main office is at:

494 Gower Street

Staten Island, New York 10314

Telephone: 718-761-2257

FUTURES AND MANAGED FUTURES

FUTURES MARKETS

Many people are not aware that a key financial tool in our dynamic global economy was developed on the American frontier: futures markets.

As the pioneers turned the westward expansion into agricultural abundance, farmers and ranchers, as well as lumber mills and meat packers, needed a way to buy and sell their production ahead. By doing so, farmers could avoid the rush to market at harvest time. And industrial consumers of commodities could lock in their raw material purchases before they needed the goods. In response to these needs, the futures markets were born.

At the time of the Civil War, the first contracts were traded on the Chicago Board of Trade. These contracts allow commodity producers and consumers to manage the risks of changing commodity prices and the risks of finding buyers and sellers. Additionally, these contracts permit speculative risk capital to participate in the price movements.

Here is how the futures industry serves the free market economy today:

• Individuals and businesses that handle the actual commodities use futures to manage the risks of producing, owning or processing these commodities. These participants are called hedgers.

• Speculators use the futures markets to search for profit opportunities in the prices of these goods.

As the world economy has evolved, the scope and size of these markets has expanded tremendously. Agricultural raw materials are still a critical portion of the futures markets. These include cattle and hogs, corn, wheat, cotton, sugar and others.

More recently, industrial raw materials have also grown in importance. Some of these are crude oil, crude oil products, and copper. Finally, financial raw materials have gained prominence in the futures markets. Among these are futures on foreign currencies, interest rates and stock indexes.

In 1995, over 400 million futures and options on futures contracts traded on U.S. markets.

MANAGED FUTURES

Many speculators are unable to devote the time needed to the study of these markets and the trading of their accounts. Instead, they choose to have a professional manage their trading accounts. These professionals are known as Commodity Trading Advisors (CTA's).

Using various methods of analysis, CTA's focus their knowledge and experience on the trading management of client accounts. Funds under management by Commodity Trading Advisors exceeded $24 billion at the end of 1994.

This form of participation in the futures markets enables investors to diversify their portfolios. Markets available through futures differ from many other markets in their content and their price relationship to traditional stocks and bonds.

When engaging the services of a CTA, each client has an individual account at a futures brokerage firm. No client funds are ever mixed with other client funds, or with the CTA's own funds. The client grants to the Commodity Trading Advisor the authority to buy and sell futures and options on futures in the client's account, but not to withdraw funds from the account.

While there is risk present even with professional management, the amount of capital managed by Commodity Trading Advisors indicates the importance of these markets, the drive for diversification and the value of professional management. This Disclosure Document is provided to assist you in considering a managed futures account directed by Stanley Dash.

THE COMMODITY TRADING ADVISOR: STANLEY DASH

Stanley Dash is the sole principal and trader for the Richmond Trading Program. In this role, Mr. Dash brings more than 20 years of futures industry experience to bear on the trading management of this program.

Mr. Dash began his career on Wall Street in 1975 with E. F. Hutton's National Futures Department, becoming licensed as a Registered Commodity Representative and a General Securities Representative while serving as administrative manager. In 1980, Mr. Dash moved into the trading side of financial services with Shearson Loeb Rhoades.

Returning to E. F. Hutton, Mr. Dash worked with a clientele of both retail and institutional accounts, with an emphasis on futures and options trading. In 1987, Mr. Dash relocated to Dean Witter Reynolds, where the core of his activities remained the futures and options markets.

In 1991 and 1992, Mr. Dash spent time as an active trading member of the Commodity Exchange, Inc. (now a division of the New York Mercantile Exchange), the world's largest metals futures exchange. During this time, he traded futures and options on futures on gold, silver and copper. While a member, Mr. Dash was registered as a Floor Broker, effective April 1991.

Mr. Dash then served as the Branch Manager of the New York office of American Futures Group, a Futures Commission Merchant (FCM), effective September 1993. He then joined Lloyd, Stevens & Co., Inc., an Introducing Broker (IB), effective November 1994. While serving as the manager of the futures brokerage division, Mr. Dash began development of the Richmond Trading Program.

Since May of 1996, and concurrent with management of the Richmond Trading Program, Mr. Dash has been an Associated Person (AP) of U. S. Securities and Futures, an FCM.

Since 1987, Mr. Dash has been a resident instructor at the New York Institute of Finance. Located in the Wall Street area, the Institute is known for its wide range of courses on finance, investments and capital markets. The Institute takes pride in having its curriculum designed and delivered by practicing professionals.

Mr. Dash lectures on the subject of futures and options on futures. These lectures are designed for those within the brokerage community and others who perceive the critical importance of the futures markets to a free market economy. Among these other groups are executives from foreign countries (including India, Saudi Arabia, Korea, and Russia) exploring the U.S. futures and options markets. In recent years, Mr. Dash has also acted as a training consultant for the banking community on topics ranging from compliance to technology.

No administrative, civil, or criminal proceedings have ever been held against Mr. Dash.

Mr. Dash is married and has three children.

Performance information for Mr. Dash may be found on pages 14 and 15.

THE TRADING PROGRAM

Successful futures trading begins with discipline.

Building on that axiom the Commodity Trading Advisor has laid out parameters for the Richmond Trading Program designed to maximize the use of trading capital while probing the futures and options markets for profit opportunities.

While the search for profit opportunities is conducted, risk, always an aspect of trading futures and options on futures, is addressed through evaluation prior to taking positions, and continuous re-evaluation as trade progress is monitored.

With that foundation, other elements of the trading program focus on such areas as capitalization, trade selection, commitment of capital and selection of instruments, i.e. futures and options on futures.

MINIMUM ACCOUNT SIZE

The minimum account size is $10,000. Clients are invited to establish their accounts with a larger initial deposit, generally in increments of $7,500. Additional funds may be added to an account at any time.

The Commodity Trading Advisor (CTA) will not accept notional funds.

Generally, it will not be possible for accounts that begin trading with a $10,000 initial deposit to earn interest in their accounts. The CTA will make every effort to have larger client accounts earn interest on at least some portion of their trading funds. No assurance is made that this will be accomplished.

NO MINIMUM INVESTMENT PERIOD

Although they are under no term of commitment, clients are encouraged to consider a 2 year time horizon in evaluating the program. Trading in futures and options on futures requires patience. Results are often incremental, as opportunities are being searched out. The willingness to wait through several market cycles can be an important factor in long-term results.

Nonetheless, clients maintain the right to cease trading and withdraw their funds following notice to the Commodity Trading Advisor. The CTA reserves the right to liquidate open positions and verify balances in an orderly fashion. The remaining funds in the account may be greater or lesser than the net sum of funds deposited.

IN THE EVENT OF A DRAWDOWN

If the value of a client account falls 60% from the initial deposit (or from the total value of initial and subsequent deposits net of withdrawals), the CTA will take no new positions pending a re-evaluation of the client's participation in the program. The client may decide at that time to close the account or to re-capitalize it.

FUTURES AND OPTIONS ON FUTURES

The CTA anticipates taking positions in futures and in options on futures at his discretion. For reasons of money management and overall risk control, the trading program may make greater use of options on futures.

MARKETS TRADED

The CTA carries out market analysis on many commodities and will take appropriate positions in any market or group of markets without restriction. These include, but are not limited to grains, livestock, other agricultural materials, metals, energy, currency, interest rates, and stock indexes. Due to exceptional volatility or capital requirements, and with an emphasis on capital preservation, some potentially profitable trades may not be made, and some markets may be avoided.

Generally, attempts will be made to carry positions in several different commodity groups to achieve some diversification.

Typically, between 30% and 70% of account equity will be committed to the markets at a time.

The CTA will be trading only on licensed and regulated U.S. futures exchanges.

TRADE SELECTION

Technical analysis is the primary method of trade selection employed by the CTA. Technical analysts use various methods to analyze futures prices and related market statistics. This mode of price analysis is based on the theory that underlying supply and demand forces are revealed in futures prices. That is, the individual needs and concerns of the marketplace participants are reflected in the price. It follows that the study of these prices may form the basis for forecasting future prices.

The CTA's focus in these analyses is to identify the trend of the market under study. Market positions will generally be taken in the direction of the trend with the goal being to participate in this overall price movement. Trend identification is done according to a methodology used by the CTA, but does involve subjective judgment. Positions commonly have a 2 to 8 week life span.

Along with this work to identify price trends is analysis designed to establish risk levels. In trade selection and money management, the CTA must allow for the possibility of loss as well as the possibility of profit. If the capital required to be put at risk on a trade is deemed excessive, the trade may be modified or simply forgone.

RISK ASSESSMENT

Risk assessment is a critical part of money management. An estimate of the risk of each position is made prior to its establishment. The CTA uses a guideline of 5% of the account value as the risk on each position. Further risk assessment is determined by the trading strategy.

The CTA will exercise judgment in the management of each trade. Regardless of planning, no firm assurance can be made in advance of the exact number of dollars, or the exact percentage of account value, at risk on any trade.

YOUR FUTURES ACCOUNT

Clients of the Commodity Trading Advisor, must establish an account with a Futures Commission Merchant (FCM) that will hold all client funds and through which futures trades will be cleared.

Clients are free to choose any FCM they wish.

Clients may also establish their accounts with an FCM using the services of an Introducing Broker (IB). In this case, also, clients are free to choose any IB they wish.

The CTA will be happy to assist the client in establishing the account if the client so desires.

PRINCIPAL RISK FACTORS AND CONFLICTS OF INTEREST

MARKET VOLATILITY

Prices of futures and options on futures often display a high degree of volatility. This volatility can be a source of risk as well as profit opportunity. As described in the section entitled "The Trading Program", the Richmond Trading Program seeks to capitalize on market volatility, while managing trading capital with caution. There is no assurance that this will be accomplished profitably, and may result in losses.

MARKET LIQUIDITY

The Richmond Trading Program will focus on markets in which, in the judgment of the CTA, there is adequate liquidity for entry into and exit from positions at intended prices. Liquidity factors change in markets from time to time and this may make entry and exit at desired prices difficult to achieve.

COUNTERPARTY CREDITWORTHINESS

As described in the section entitled "The Trading Program", the CTA will confine the trading to United States exchange-traded futures and options on futures. Therefore, clients in the Richmond Trading Program will be assured of the creditworthiness of counterparties through the futures exchanges and their clearing houses.

LEVERAGE

Trading in futures and options on futures affords the trader a high degree of leverage. This leverage can magnify the effects of price movement on profits and losses. As described in the section entitled "The Trading Program", the CTA will often use options, frequently in combination with futures or with other options, in an attempt to use this leverage profitably. There is no assurance that this will be accomplished.

EXECUTION OF TRADES AND ALLOCATION OF PRICES

Because of price volatility, variations in liquidity, and differences in order execution, the CTA cannot always obtain identical trade execution for all clients. Variations and differences may produce differences in performance among accounts. To treat clients fairly when block orders are filled at different prices, the CTA assigns trades systematically among all accounts it manages so as not to favor any one client or group of clients.

TRADE ERRORS

Though the Commodity Trading Advisor will attempt to correct trading errors as soon as they are discovered, it is not responsible for poor executions or trading errors committed by floor brokers, Futures Commission Merchants, Introducing Brokers, or itself.

POSITION LIMITS

Certain commodities which may be traded in accounts owned by the Commodity Trading Advisor, its employees, its affiliates, or any of its clients are limited with respect to the number of futures and options on futures that any one speculative trader or trading concern may directly or indirectly own or control in any one futures market. None of these accounts will be deliberately favored by the CTA over other client accounts in determining the size of a given position for any account in anticipation of reaching a speculative position limit. If the CTA reaches a speculative position limit across client accounts and its own accounts, it will reduce the positions in all accounts equitably.

PROPRIETARY TRADING BY THE COMMODITY TRADING ADVISOR

The Commodity Trading Advisor trades a proprietary account. Conflicts may exist between the CTA's duty to appropriately select markets to trade on behalf of clients and its interest in avoiding competition for trades in markets traded for its proprietary accounts. Orders for the Commodity Trading Advisor's proprietary accounts might inadvertently be placed before or after other orders for client accounts. In those instances, the Commodity Trading Advisor's order may or may not obtain more favorable execution than the client's order.

Nevertheless, no accounts owned by the Commodity Trading Advisor, its employees, its affiliates, or any of its clients will be deliberately favored by the CTA over other client accounts. Records of the proprietary trading accounts of the CTA are not open to client inspection.

DUAL AFFILIATION OF THE COMMODITY TRADING ADVISOR

Mr. Dash also maintains registration as an Associated Person of U.S. Securities and Futures, an FCM, in addition to registration as a Commodity Trading Advisor. In this capacity, he receives transaction-based compensation for providing research and brokerage services to clients of that FCM who are not part of the Richmond Trading Program.

CTA compensation for accounts in the Richmond Trading Program will be based solely on the fees outlined in the section titled FEES (page 8). Mr. Dash will not receive any other direct compensation, including commissions, from these accounts. The CTA may, however, benefit from support services provided by U.S. Securities and Futures such as research, data and clerical assistance.

Although Mr. Dash is also employed elsewhere, he anticipates neither actual nor potential conflicts of interest that could affect the execution of his responsibilities on clients' behalf.

FEES

There are no "up-front loads", set-up fees or surrender fees charged by the Commodity Trading Advisor.

For the management of their accounts, clients will be charged:

• A quarterly management fee of a maximum of 1.25% of the Account Equity, as of the end of each calendar quarter, defined in MANAGEMENT FEES below.

• A quarterly incentive fee of a maximum of 25% of "Net New Trading Profits", as of the end of each calendar quarter, defined in INCENTIVE FEES below.

The CTA reserves the right to negotiate different fee schedules.

The fees, to be paid directly from the client's account, will be determined as follows:

MANAGEMENT FEES

The Commodity Trading Advisor will receive a quarterly management fee of 1.25% of the Account Equity or the amount negotiated with each client. Account Equity will include the sum of all cash, Treasury bills and other interest-bearing obligations carried at cost, and the current market value of all open commodity positions, as indicated by the settlement price determined by the exchanges on which such positions are maintained. No reduction shall be made for brokerage commissions and other charges which would be incurred upon liquidation.

New Accounts will be charged a management fee at the end of their first calendar quarter, pro-rated for the portion of the quarter the account was open.

Management fees on funds withdrawn from a client's account are deemed due and payable at the time of the withdrawal, pro-rated for the portion of the quarter the funds were on deposit.

Management fees will be paid to the Commodity Trading Advisor whether or not trading has been profitable.

INCENTIVE FEES

The Commodity Trading Advisor will receive a quarterly incentive fee of 25% of each quarter's "Trading Profit", or the percentage negotiated with the client. "Trading Profit(s)", for purposes of calculating the CTA's incentive fee, is the net profit during the calendar quarter, including realized and unrealized profits and losses and all interest earned by the client on its assets, after deduction of brokerage fees paid and before deducting the CTA's incentive and management fees payable.

If the account experiences a "Trading Loss" during the quarter, no incentive fees will be charged. Incentive fees will next be charged at the end of the quarter in which "Trading Profits", aggregated since the last quarter in which there was a "Trading Loss", now exceed the "Trading Losses" aggregated since the last quarter in which there was a "Trading Profit". These fees will be calculated

only on the amount by which the aggregated "Trading Profits" exceed the aggregated "Trading Losses".

If there are aggregate "Trading Losses" at the time of a withdrawal of funds from a client's account, any loss attributed to those withdrawn funds shall be deducted from the aggregated "Trading Loss".

If there are aggregate "Trading Profits" at the time of a withdrawal, the incentive fees on that portion of the "Trading Profits" attributed to the withdrawn funds shall be deemed due and payable.

Management and incentive fees will be billed quarterly (calendar quarters ending March, June, September and December).

Management and incentive fees are based upon, among other things, unrealized appreciation of open futures positions. All fees paid will be retained by the CTA even if the account subsequently experiences losses or the appreciation is never realized. The amount of unrealized appreciation may be substantial. Since the incentive fee is payable quarterly, incentive fees may be paid to the CTA during a year even though the account sustains a net trading loss.

GLOSSARY OF TERMS

CLEARING MEMBER

A member of an exchange clearinghouse. All trades of a non-clearing member must be registered and eventually settled through a clearing member.

COMMODITY FUTURES TRADING COMMISSION (CFTC)

The federal oversite agency which monitors the futures and options markets to detect and prevent commodity price distortion and market manipulation and to protect the rights of customers who use the markets for either commercial or investment purposes.

COMMODITY TRADING ADVISOR (CTA)

A person who, for compensation or profit, directly or indirectly advises others as to the value of or the advisability of buying or selling futures contracts or commodity options. Providing advice indirectly includes exercising trading authority over a customer's account. Registration with the Commodity Futures Trading Commission is generally required.

DISCLOSURE DOCUMENT

The document that must be provided to and signed by prospective customers that describes fees, performance, etc.

FUTURES COMMISSION MERCHANT (FCM)

An individual or organization which solicits or accepts orders to buy or sell futures contracts or commodity options and accepts money or other assets from customers in connection with such orders. Must be registered with the Commodity Futures Trading Commission.

INTRODUCING BROKER (IB)

A firm or individual that solicits and accepts commodity futures orders from customers but does not accept money, securities or property from the customer. An IB must be registered with the Commodity Futures Trading Commission and must carry all of its accounts through an FCM on a fully disclosed basis.

MANAGED ACCOUNT

An arrangement by which the owner of the account gives written power of attorney to someone else, usually the broker or a Commodity Trading Advisor, to buy and sell without prior approval of the account owner.

NATIONAL FUTURES ASSOCIATION (NFA)

Designated by the CFTC in 1982 as a "registered futures association," NFA is the industrywide self-regulatory organization of the futures industry.

PERFORMANCE RECORD

Table 1 provides a summary of the trading performance of the Richmond Trading Program.

PAST PERFORMANCE IS NOT NECESSARILY INDICATIVE OF FUTURE RESULTS.

Table 1

Monthly rate of return is calculated by dividing monthly performance, net of brokerage and CTA fees, by beginning net asset value. Material additions and withdrawals of funds are accounted for by adjustment of the beginning net asset value using the "time-weighting" method.

Table 2 provides a summary of information concerning the Commodity Trading Advisor and the Richmond Trading Program.

Table 2

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