The Artemis Program is a fully systematic swing trading system whereby system signals are predetermined by a computer and executed by the Advisor manually. The Artemis Program exclusively trades E-Mini S&P 500 futures, Micro E-Mini S&P 500 futures, E-Mini Nasdaq U.S. futures, and Micro E-Mini Nasdaq futures and is expected to carry trades overnight. The trading program is always in the market, long or short, in the E-Mini S&P 500 or the Micro E-Mini S&500 futures and long only at times in the E-Mini Nasdaq or Micro E-Mini Nasdaq futures contract.
The Advisor will trade 4 Micro E-Mini S&P 500 futures contracts and 1 Micro E-Mini Nasdaq futures per $35,000. For each additional $7,000 in customer accounts this will trigger a change in position sizing. Once the sizing of the micro contracts gets to the point where there is an equivalent e-mini contract, The Advisor will reduce the micro contracts and hold one full e-mini in its place.
Contract position sizing is calculated on a trade close to close basis. Should the initial $35,000 have a losing trade resulting for example in losses of $7,000, then the Advisor will switch to trading 3 Micro EMini S&P 500 contracts and 1 Micro E-Mini Nasdaq futures contract. There will be a reduction to the previous teer for every loss of $7,000 in the account. Additional risk management includes technical stops in highly volatile market environments.

Comhla LLC is a Commodity Trading Advisory Service domiciled in Delaware USA. The company uses research from Comlatech Ltd, a Canadian research and development company in Ontario, Canada to build and trade its strategies which are based on extensive cycle research and pattern recognition with the use of Machine Learning.

John P. Bannan (“Mr. Bannan”) co-founded the Advisor in November 2021 and is a 50% owner of the Advisor. Mr. Bannan became a listed principal of the Advisor on April 27, 2022 and a registered associated person of the Advisor on the same date. Mr. Bannan will serve as the Advisor’s trading principal. Specifically, he will be responsible for making trading decisions for all accounts that have granted power of attorney to the Advisor.

Prior to forming the Advisor, Mr. Bannan co-founded and serves as the Chief Investment Officer (“CIO”) of ComhlaTech Limited in May 2020. ComhlaTech Limited is a predictive-analytics and pattern recognition technology company operating out of Waterloo, Ontario. Currently, ComhlaTech Limited is focused on using its technology to assist investors in making informed investment decisions and reduce their risk. Mr. Bannan is actively engaged in the research and development of the predictive technology that is the backbone of the Comhla strategies John uses for his trading personally and for the Advisor. Following his degree from Glasgow Caledonian University in retail management in June 1997,

Mr.Bannan worked as a Market Analyst at McCurrach UK, Ltd. a multiservice field consulting group, in the United Kingdom from July 1997 to July 2003. After leaving McCurrach’s, Mr. Bannan worked as a self employed trader. He invested a large amount of time and money on his own trading education and has built algorithms on multiple trading platforms. Mr. Bannan co-founded the stock market education website and service, HowDoITradeStocks.com (“HDITS”) in June 2011 with his wife and partner Anne Marie Heinrichs, and focused his efforts on educating new traders and providing follow-my-trades services until the launch in May 2020 of ComhlaTech Limited in 2020, a company collectively started by Bannan and Heinrichs. Mr. Bannan has developed a loyal following of retail and professional traders through HDITS and many of these clients followed him to ComhlaTech Limited. In May 2020, howdoitradestocks.com was closed to facilitate the opening of ComhlaTech Limited. ComhlaTech Limited is a predictive-analytics and pattern-recognition financial technology company operating out of Waterloo, Ontario. licensing its intellectual property.

Mr. Bannan currently trades futures for his own account. Mr. Bannan reserves the right to continue trading for his own account in the future while the Advisor manages Client accounts. The proprietary trading records and written policies related to such trading will be made available to Clients following the same rules and procedures allowed for inspection of client performance records and only upon written request and during normal business hours.