Paragon Advisors, Inc.

Paragon often serves as the financial alter ego of its clients. Paragon does not typically manage stock portfolios or make investments that require direct management; rather, Paragon will in such circumstances, research and recommend other investment advisors and commodity trading advisors to directly manage client investments. Paragon will access these managers for its clients either directly or through a pooling of clients' assets in a partnership-type entity. This pooling allows Paragon's clients to invest with managers (Underlying Investment Funds) who have high minimum investment limits and which would not otherwise be accessible to clients individually. For pooled investments, Falmouth Investment Company, Inc. ("Falmouth"), an affiliate of Paragon, will form a private investment company and will serve as manager member to such entity. Falmouth provides investment advisory services to the investment pools, including the formation and organization of the pool, performing due diligence on investment managers to be utilized by each pool, ongoing monitoring and performance evaluation of the managers and annual accounting for each pool.