Fixed Premium Managed Program (FPMP) is designed to target net annual returns that exceed the S&P 500 Benchmark while providing non-correlation. In addition, risk is minimized through the use of fixed profit targets, low multiple stops, and laddered entries. Alpha is achieved by selling far out of the money weekly S&P 500 ES (e-mini SP) futures put options. This is executed through selling premium more than 3 months until expiration. CBCM’s research has shown that option expirations more than 3 months have a better volatility buffer than shorter term expirations. The use of a predefined fixed profit target allows for an accelerated rate of return compared to the premium decay of the entire term. In addition, CBCM has determined that low multiple stops are beneficial due to the non-linear nature of options during a volatility load. Low multiple stops may decrease the win rate; however, losses are more controlled. Lastly, the laddering entry method disperses risk over multiple volatility environments providing a more robust portfolio during increased volatility. Due to laddering positions, new accounts are fully positioned after approximately 6 weeks.

Crescent Bay Capital Management, Inc., a California corporation, became registered with the Commodity Futures Trading Commission as a Commodity Trading Advisor ("CTA") on August 23rd, 2004. CBCM was previously registered as a Commodity Pool Operator ("CPO") from November 14th, 2006 to October 18th, 2009. CBCM has been a member of the National Futures Association since August 23rd, 2004. David Bedford (the "Principal") is the sole shareholder of CBCM. He was registered as an Associated Person and listed as a Principal of the firm on August 23rd, 2004. The business office of CBCM is located at: 1201 Puerta Del Sol, Ste. 227; San Clemente, CA 92673; telephone: (949) 276-8718; facsimile: (949) 276-8448.

David Bedford is President of Crescent Bay Capital Management and has over 20 years of experience researching and developing investment strategies. He has managed over 500 accounts for individuals and institutions. David is registered with the NFA and the CFTC