COMMISSION ADVISORY

Beware of Websites Selling Commodity Trading Systems that Guarantee High Profits with Minimal Risks

The United States Commodity Futures Trading Commission (CFTC), the federal agency that regulates commodity futures and options markets in the United States, has witnessed an increase in the number of Internet websites fraudulently promoting commodity trading systems and advisory services. Among other things, these websites falsely claim that advertised performance results are based on real trading when, in fact, the results are based on hypothetical trading. The CFTC urges you to be skeptical when promoters of trading systems and advisory services claim that their products and services will earn high profits with minimal risks. You also should be forewarned that systems which trigger frequent trading signals as part of a daytrading strategy can result in substantial commissions and fees.

NO TRADING SYSTEM CAN GUARANTEE PROFITS

Commodity trading systems typically are computerized programs that signal members of the public when to buy and sell commodity futures and options contracts. Systems produce buy and sell signals based on mathematical formulas and are typically based on technical analysis of trading data (trading volume and prices), as opposed to fundamental analysis (analysis of economic factors such as supply and demand). Trading systems that are based on technical analysis attempt to predict future price movements based on historical prices, price relationships and price trends.

In deciding whether to purchase a particular trading system to trade commodity futures or options, members of the public should remember that no commodity trading system can guarantee profits. And, whether or not a trading system is used, commodity futures and options are typically high-risk endeavors.

HYPOTHETICAL TRADING RESULTS CAN BE UNRELIABLE

Many trading system promoters advertise their systems by reporting hypothetical trading results. Hypothetical trading results typically are based on trading simulations using historical price data or simulated "real time" computer trading. To obtain these results, trading system promoters typically pretend that they traded futures contracts at market prices that occurred some time in the past. They then calculate the trading results that these purported trades would have achieved had they been placed, based on actual historical prices. These results often show impressive trading results and large net profits with only a few, small margin calls.

Whether based on historical data or simulated "real time" trading, hypothetical results do not reflect the results of any actual trading. In other words, there is no actual futures account, no actual investment, no actual trading, and no actual profits. The results are purely the product of simulation.

Hypothetical trading results have several inherent limitations:

• 20/20 Hindsight with Historical Results -- Since the trading systems that produced the results were not actually traded under real market conditions, the purported results fail to take into account market circumstances that affect traders and their decision-making process, such as anticipated news events that could have an impact on the supply, demand or price of the commodity.

• "Real-time" is not Real -- When marketing trading systems, some promoters claim that their systems have performed successfully in "Real-time Trading." "Real-time Trading" only means that the system has been tested using a live data-feed, rather than being tested using historical market data. In "Real-time Trading," however, no trades have actually been placed in the market. Performance results based on "Real-time Trading" are merely a form of hypothetical results, with the same limitations.

• Financial Limitations -- Hypothetical results may not adequately take into account the ability of a trader to absorb trading losses or to meet margin calls. Trading systems assume that the trader can withstand all losses generated by the system and can meet resulting margin calls. It is much easier to absorb a trading loss on paper (hypothetically) than to do so in reality. Many traders find it unacceptable to sustain several consecutive trading losses and/or margin calls. Moreover, in an actual trading environment, a trader's financial condition may change over time and affect his or her ability to continue following a trading system.

• Not Tested Under Real Market Conditions -- Hypothetical trading results assume that futures contracts have been bought and sold at specific prices. Since these assumptions have not been subjected to actual market conditions, they may overestimate or underestimate the performance of a system. In addition, some market conditions may make it impossible to execute a trade. For instance, many systems assume that stop-loss orders will be executed at their stop price. Under actual market conditions a stop-loss order might be executed at a better or worse price, or not be executed at all. Further, actual market conditions include bid/ask spreads which might not be reflected in the prices used in hypothetical trading. Moreover, the actual execution of a trade could impact the price paid, especially in less liquid or illiquid markets.

• Possible "Rigging" of Results -- A member of the public should be alert to the possibility that the system promoter manufactured results by selecting historical trades that would have yielded the greatest returns.

• Trading and System Costs -- The profit claims of promoters may fail to take into consideration the cost of purchasing or leasing a trading system. While the prices of systems vary, many are sold for thousands of dollars. In addition, most of these systems require that the user obtain a data feed from a vendor. System promoters may also fail to take into consideration the impact on profits of commissions and fees charged by brokers in connection with futures and options trading. Such commissions can have a substantial effect on profitability, particularly when the system generates frequent trading signals. A user should take all of these costs into account because they raise the break-even point in trading.

Because of these limitations, CFTC Regulations require that the presentation of hypothetical trading results be accompanied by a specific cautionary statement warning of the inherent limitations of these results.

FUTURES CONTRACTS ARE VOLATILE AND RISKY

Persons considering trading commodity futures or options should educate themselves about futures and options and realize that they may lose large sums of money. Remember: "If it sounds too good to be true, it probably is too good to be true." The following checklist should help consumers in deciding whether to use a trading system.

IS A FUTURES/OPTIONS TRADING SYSTEM RIGHT FOR YOU?

• Do you have the financial ability to sustain trading losses and meet margin calls? When trading futures contracts on margin, you risk losing much more money than the initial margin amount. If the market moves against you, you may be required to pay additional funds. The use of margin creates potentially large exposures to loss.

• Can you lose your entire investment and more without a change in your lifestyle?

• Do the trading results sound too good to be true?

• Are the advertised trading results based on actual trading or "hypothetical" trading?

• Has any trader used the system in actual trading? If so, how has the trader fared?

• Will the system promoter provide you with independent verification of the claimed trading results?

• What is the total cost of the system?

• Have you factored into your purchasing decision the impact of commissions and fees that can result from frequent trading?

• What are the additional costs (data feed, etc)?

• Not all system promoters are required to be National Futures Association (NFA) members or registered with the CFTC. A call to the NFA (800-621-3570 or 800-676-4NFA) or the CFTC, or a visit to the NFA's website at http://www.nfa.futures.org/basicnet/, can confirm the status of a particular promoter.

• Have you checked with the NFA whether the system promoter has been disciplined by commodity regulators?

Questions concerning this advisory may be addressed to the CFTC's Office of Public Affairs at (202) 418-5080.

Commodity Futures Trading Commission
Three LaFayette Centre
1155 21^st Street, N.W.
Washington, D.C. 20581

• For other consumer advisories concerning possible fraudulent activity in the commodity futures and options industry, click on Consumer Alerts.

• The CFTC's website also offers general information about trading in the commodity futures and options markets. For example, the CFTC offers brochures on-line, such as "Futures and Options What You Should Know Before You Trade" and "Glossary: The Language of the Futures Industry." To obtain this and other information, go to the CFTC site map.

• The Federal Trade Commission's Advisory - Day Trading Ads: Cutting Through the "Bull "