The BULPRED PROGRAM has been designed to to generate consistent and relatively low-risk capital appreciation with minimal monthly return variance. Monthly drawdowns are strictly limited to 10.0%. This program is designed to take advantage of intraday trading opportunities employing interbank spot transactions only, no forwards or options. Open positions are seldom held longer than 48 hours. All assets are traded within a managed account structure, either minimally funded or unfunded, and no interest income is included in the return.