Turning Wheel Capital, Inc

(Pure Alpha)

Fund Investment Objectives

Pure Alpha uses proprietary statistical modeling and pattern search to trade the most liquid CFTC approved futures contracts with a maximum hold time of 24 hours. The program is neither trend-following nor counter-trend in orientation. Instead, Pure Alpha pursues specific market inefficiencies opportunistically, seeking short-term profitability without bias. The strategy is 100% systematic and highly system diversified (a wide range of uncorrelated systems comprise the overall strategy). Strategy development leverages somewhat unusual disciplines and experiences that influence Turning Wheel's dynamic approach towards inefficiency alpha capture. The program has strict loss limits for each trade as well as per day, per week, and per month.