The risk of loss in trading commodities can be substantial. You should therefore carefully consider whether such trading is suitable for you in light of your financial condition. The high degree of leverage that is often obtainable in commodity trading can work against you as well as for you. The use of leverage can lead to large losses as well as gains. In some cases, managed commodity accounts are subject to substantial charges for management and advisory fees. It may be necessary for those accounts that are subject to these charges to make substantial trading profits to avoid depletion or exhaustion of their assets.

The disclosure document contains a complete description of the principal risk factors and each fee to be charged to your account by the commodity trading advisor ("CTA"). The regulations of the commodity futures trading commission ("CFTC") require that prospective clients of a CTA receive a disclosure document when they are solicited to enter into an agreement whereby the CTA will direct or guide the client's commodity interest trading and that certain risk factors be highlighted. This document is readily accessible at this site. This brief statement cannot disclose all of the risks and other significant aspects of the commodity markets. Therefore, you should proceed directly to the disclosure document and study it carefully to determine whether such trading is appropriate for you in light of your financial condition.

You are encouraged to access the disclosure document by clicking below. You will not incur any additional charges by accessing the disclosure document. You may also request delivery of a hard copy of the disclosure document, which also will be provided to you at no cost. The CFTC has not passed upon the merits of participating in this trading program nor on the adequacy or accuracy of the disclosure document.

We are required to provide other disclosure statements to you before a commodity account may be opened for you. Please acknowledge your understanding of the above statement by clicking the button below. You may then continue to view the site.

Privacy

PRIVACY POLICY
ITB CAPITAL ADVISORS, LLC (the “Company”) is committed to safeguarding the personal
information that you provide us. This Privacy Policy describes how we handle and protect personal
information we collect about individuals, such as you, who apply for or receive our products and services.
The provisions of this notice apply to former Clients as well as our current Clients.
Privacy of Your Personal Information, Generally
The Company will keep confidential non-public personal information pertaining to each current and
former Client (i.e., information and records pertaining to personal background, investment objectives,
financial situation, investment holdings, account numbers, account balances and the like) unless the General
Partner is previously authorized to disclose information to individuals and/or entities not affiliated with the
investment advisor, including, but not limited to the Client's other professional advisors and/or service
providers (i.e., attorneys, accountants, partners, insurance agents, broker/dealers, investment advisors,
account custodians, and the like); or, required to do so by judicial or regulatory process; or, otherwise
permitted to do so in accordance with the parameters of Regulation S-P.
The disclosure of such information contained in any document completed by the Client for
processing and/or transmittal by the investment advisor, investment manager or related entity in order to
facilitate the commencement, continuation, or termination of any business relationship between the Client,
investor and/or non-affiliated third party service provider (i.e., broker/dealer, investment advisor, account
custodian, insurance company, and the like), including information contained in any document completed
and/or executed by the Client and/or investor for the investment advisor/investment manager or related entity
(i.e., advisory agreement, Client information form, and the like), shall be deemed as having been
automatically authorized by the Client with respect to the corresponding non-affiliated third party service
provider. Each individual and/or entity affiliated with the investment advisor or investment manager or
related entity is aware of the aforesaid privacy policy and has acknowledged his or her or its requirement to
comply with same. In accordance with this privacy policy, each such affiliated individual and/or entity shall
have access to information to the extent reasonably necessary for the performance of its service for the
Client/investor and to comply with regulatory procedures and requirements.
Why and How the Company Collects Personal Information
When Clients apply for or maintain an account with the Company, the General Partner collects
personal information about the Clients for business purposes, such as evaluating Clients needs, processing
Clients requests and transactions, informing Clients about products and services that may be of interest to
a Client, and providing customer service.
Types of Personal Information Collected by the Company
The personal information we collect about Clients includes:
• information provided to the General Partner on applications and other forms, such as investor’s
name, address, date of birth, social security number, occupation, assets, and income;
• information about Client transactions with the Company and with Company affiliates;
• information the General Partner receives from consumer reporting agencies, such as credit history
and creditworthiness, and other entities not affiliated with the Company; and
• information Clients provide to the General Partner to verify identity, such as a passport, or received
from other entities not affiliated with the Company.
How the General Partner Protects Personal Information
The General Partner limits access to Client personal information to those employees who need to
know in order to conduct Company business, service the Client’s account, and provide information to allow
the Client to accomplish the Client’s financial objectives. Employees of the General Partner are required to
maintain and protect the confidentiality of Clients’ personal information and are instructed to follow
established procedures to do so. The Company maintains physical, electronic, and procedural safeguards to
protect Clients’ personal information. The General Partner does not rent or sell Clients’ names or personal
information to anyone.
Sharing Information With Company Affiliates
The General Partner may share personal information described above with our affiliates for business
purposes, such as servicing Client accounts and informing Clients about new products and services, and as
permitted by applicable law.
The information the General Partner shares with affiliates for marketing purposes may include the
information described above, such as name, address and account information, but will not include other credit
information, such as credit history appearing on a consumer credit report or net worth and income
information appearing on applications for our products and services.
Disclosure to Non-Affiliated Third Parties
In order to support the financial products and services provided to Clients, the General Partner may
share the personal information described above with third-party service providers and joint marketers not
affiliated with us, including:
• financial service institutions (e.g., advisers, dealers, brokers, trust companies and banks) with whom
we have joint marketing agreements, such as agreements to market financial services or products that
we jointly offer, endorse or sponsor; and
• companies under contract to perform services for the Company or on its behalf, such as vendors that
prepare and mail statements and transaction confirmations or provide data processing, computer
software maintenance and development, transaction processing, administration, accounting, auditing,
and marketing services.
These companies acting on behalf of the Company are required to keep personal information
confidential.
Also, the General Partner may disclose personal information with non-affiliated companies and
regulatory authorities as permitted or required by applicable law. For example, the General Partner may
disclose personal information to cooperate with regulatory authorities and law enforcement agencies to
comply with subpoenas or other official requests, and as necessary to protect our rights or property. Except
as described in this privacy policy, the General Partner will not use Client’s personal information for any
other purpose unless the General Partner describes how such information will be used at the time the Client
discloses it to the General Partner or the General Partner obtains the Client’s permission to do so.
Accessing and Revisiting Client Personal Information
The General Partner endeavors to keep Client files complete and accurate. The General Partner will
give Clients reasonable access to the information the Company has about the Client requesting same. Most
of this information is contained in account statements that Clients’ receive from the Company and
applications that Clients submit to obtain Company products and services. The General Partner encourages
Clients to review this information and notify the Company if any Client believes any information should be
corrected or updated. If Clients have a question or concern about their personal information or this privacy
notice, please contact the General Partner.
Right to Opt Out
Clients have the right to opt out of with respect to General Partner’s ability to share Clients’ personal
information with our affiliates and certain third parties. If you desire that the General Partner not share
Clients’ personal information, please send an e-mail to the manager of the General Partner, Gerald Black
(geraldblack@jamesiblack.com), with “Privacy Policy Opt Out” in the subject line. Within 48 hours of
receipt of such opt-out e-mail, the Company will cease sharing any of your personal information.