HEDGING PROGRAM

DISCLOSURE DOCUMENT

OF

RICHARD A. BROCK & ASSOCIATES, INC.

A Wisconsin corporation registered with

the Commodity Futures Trading Commission

as a Commodity Trading Advisor

and a Commodity Pool Operator

2050 West Good Hope Road

Milwaukee, Wisconsin 53209

(414) 351-5500

THE COMMODITY FUTURES TRADING COMMISSION HAS NOT PASSED

UPON THE MERITS OF PARTICIPATING IN THIS TRADING

PROGRAM NOR HAS THE COMMISSION PASSED ON THE ADEQUACY

OR ACCURACY OF THIS DISCLOSURE DOCUMENT

No person is authorized by Richard A. Brock &

Associates, Inc. to give any information or to

make any representations not contained herein.

The date of this Disclosure Document is  January 31, 2008

The delivery of this Disclosure Document at any time

does not imply that the information contained herein

is correct as of any time subsequent to the date shown above.

THIS DISCLOSURE DOCUMENT IS FOR USE BY HEDGE CONSULTING CLIENTS

AND PROSPECTIVE CLIENTS OF RICHARD A. BROCK & ASSOCIATES, INC.

 RISK DISCLOSURE STATEMENT

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. IN CONSIDERING WHETHER TO TRADE OR TO AUTHORIZE SOMEONE ELSE TO TRADE FOR YOU, YOU SHOULD BE AWARE OF THE FOLLOWING: 

 IF YOU PURCHASE A COMMODITY OPTION YOU MAY SUSTAIN A TOTAL LOSS OF THE PREMIUM AND OF ALL TRANSACTION COSTS. 

 IF YOU PURCHASE OR SELL A COMMODITY FUTURE OR SELL A COMMODITY OPTION YOU MAY SUSTAIN A TOTAL LOSS OF THE INITIAL MARGIN FUNDS AND ANY ADDITIONAL FUNDS THAT YOU DEPOSIT WITH YOUR BROKER TO ESTABLISH OR MAINTAIN YOUR POSITION. IF THE MARKET MOVES AGAINST YOUR POSITION, YOU MAY BE CALLED UPON BY YOUR BROKER TO DEPOSIT A SUBSTANTIAL AMOUNT OF ADDITIONAL MARGIN FUNDS, ON SHORT NOTICE, IN ORDER TO MAINTAIN YOUR POSITION. IF YOU DO NOT PROVIDE THE REQUIRED FUNDS WITHIN THE PRESCRIBED TIME, YOUR POSITION MAY BE LIQUIDATED AT A LOSS, AND YOU WILL BE LIABLE FOR ANY RESULTING DEFICIT IN YOUR ACCOUNT. 

UNDER CERTAIN MARKET CONDITIONS, YOU MAY FIND IT DIFFICULT OR IMPOSSIBLE TO LIQUIDATE A POSITION. THIS CAN OCCUR, FOR EXAMPLE, WHEN THE MARKET MAKES A "LIMIT MOVE". 

THE PLACEMENT OF CONTINGENT ORDERS BY YOU OR YOUR TRADING ADVISOR, SUCH AS A "STOP‑LOSS" OR "STOP‑LIMIT" ORDER, WILL NOT NECESSARILY LIMIT YOUR LOSSES TO THE INTENDED AMOUNTS, SINCE MARKET CONDITIONS MAY MAKE IT IMPOSSIBLE TO EXECUTE SUCH ORDERS. 

A "SPREAD" POSITION MAY NOT BE LESS RISKY THAN A SIMPLE "LONG" OR "SHORT" POSITION. 

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. THIS DISCLOSURE DOCUMENT CONTAINS, ON PAGES 3 & 4, A COMPLETE DESCRIPTION OF EACH FEE TO BE CHARGED TO YOUR ACCOUNT BY THE COMMODITY TRADING ADVISOR. 

THIS BRIEF STATEMENT CANNOT DISCLOSE ALL THE RISKS AND OTHER SIGNIFICANT ASPECTS OF THE COMMODITY FUTURES MARKETS. YOU SHOULD THEREFORE CAREFULLY STUDY THIS DISCLOSURE DOCUMENT AND COMMODITY TRADING BEFORE YOU TRADE, INCLUDING THE DESCRIPTION OF THE PRINCIPAL RISK FACTORS OF THIS INVESTMENT, AT PAGE 4. 

THIS COMMODITY TRADING ADVISOR IS PROHIBITED BY LAW FROM ACCEPTING FUNDS IN THE TRADING ADVISOR'S NAME FROM A CLIENT FOR TRADING COMMODITY INTERESTS. YOU MUST PLACE ALL FUNDS FOR TRADING IN THIS TRADING PROGRAM DIRECTLY WITH A FUTURES COMMISSION MERCHANT.

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TABLE OF CONTENTS

RISK DISCLOSURE STATEMENT 

THE TRADING ADVISOR 

    Richard A. Brock & Associates, Inc.
    Date of the Disclosure Document

 BUSINESS BACKGROUND OF THE TRADING ADVISOR & ITS PRINCIPALS 

TRADING METHODS 

FEES 

    Farm Marketing Consulting Account
    Industrial Hedge Consulting Account 

PRINCIPAL RISK FACTORS 

AFFILIATION WITH FUTURES COMMISSION MERCHANTS; CONFLICTS OF INTEREST 

TRADING BY RICHARD A. BROCK & ASSOCIATES, INC. AND ITS PRINCIPALS 

PAST PERFORMANCE 

ADDITIONAL INFORMATION 

Farm Marketing Consulting Account Fee Example
     (for Clients Joining Program Before July 1, 1991) 

Farm Marketing Consulting Account Fee Example
     (for Clients Joining Program after July 1, 1991) 

Farm Marketing Consulting Account Fee Example
     (for Clients Joining Program after June 1, 2006)

Hedge Recommendation Experience of the Advisor

Explanation of the Tables

Marketing Years
National Prices
The Brock Report Prices 

TRACK RECORD CORN 

TRACK RECORD SOYBEANS 

TRACK RECORD WHEAT 

TRACK RECORD COTTON 

TRACK RECORD LIVE CATTLE 

TRACK RECORD LIVE HOGS, MILK (CLASS III) 

INVESTMENT TRACK RECORD

The Trading Advisor

Richard A. Brock & Associates, Inc.

        Richard A. Brock & Associates, Inc., a Wisconsin corporation, is located at 2050 West Good Hope Road, Milwaukee, Wisconsin 53209. The Company's books and records are maintained at this address. Its telephone number is (414)351‑5500. The firm is called the "Advisor" in this Disclosure Document.

The sole shareholder of the Advisor is Richard A. Brock. Mr. Brock is President, Chief Executive Officer, Treasurer and Chairman of the Board of Directors. Cathy C. Brock, wife of Mr. Brock, is Vice President and Secretary of the corporation.  Timothy P. Brusnahan is Vice President of the company and a Principal.

Date of the Disclosure Document
The Trading Advisor first intends to use this Disclosure Document on January 31, 2008.  The delivery of this document at any time does not imply that the information contained therein is correct as of any time subsequent to the date shown above. This Disclosure Document is not to be distributed under any circumstances after January 7, 2007 and will be superseded after that date by a Disclosure Document containing then current information about this program.

Business Background of the Advisor and its Principals

     Richard A. Brock & Associates, Inc. was formed as a corporation in March, 1980 but did not begin business operations until October, 1980. The company's registration as a Commodity Trading Advisor first became effective on August 6, 1980. It became registered as a Commodity Pool Operator on May 6, 1981. Since its organization, the Advisor has acted as a consultant to grain and livestock producers in managing their cash grain and livestock sales and also as a commodity trading advisor for hedging accounts in the commodity futures market. The Advisor managed speculative accounts from December, 1980 to February, 1984, when trading was stopped to devote full time to hedging accounts. In July, 1985, the Advisor decided to accept two small speculative accounts that traded from January 1, 1986 to December 31, 1990 and managed a small commodity fund for Merrill Lynch from August, 1993 to March, 1995.  

In April, 1981, the Advisor began publishing a commodity advisory letter called The Brock Report, a weekly publication which offers generally to its subscribers specific recommendations concerning the marketing of certain agricultural commodities as well as offering to its subscribers certain specific recommendations concerning hedging positions to be taken or lifted in the appropriate related futures and options markets. Subscribers to The Brock Report are also offered a daily tape recorded service providing market news and daily updates to the cash marketing and futures options hedging recommendations of the Advisor. 

Since the Advisor began its business operations it has also acted as a consultant to clients who are grain and livestock producers. In that consultant's role, the Advisor makes recommendations with respect to both cash marketing decisions (except in case of livestock) and appropriate hedging transactions in the futures and options markets based on the needs and circumstances of each particular client. In its role as a consultant to particular clients, the Advisor generally holds a power of attorney which permits it to enter futures and options orders on its clients' behalf but does not enter orders without the prior approval of the client. The Advisor does not, however, have any authority to enter into cash market transactions on behalf of its clients. Although, as a consultant, the Advisor tailors its recommendations to the particular needs and circumstances of each client, its individualized recommendations are based on the same recommendations generally available to subscribers to The Brock Report. In December, 1982, the Advisor expanded its consulting business beyond producers of agricultural commodities and began to act in a similar capacity as a consultant to industrial processors, consumers and distributors of certain agricultural commodities.

On May 26, 2005, Brock Capital Management LLC was registered as a CTA and CPO with the NFA. The majority of BCM is owned by Richard A. Brock with a minority interest held by a family trust. BCM is engaged in the management of speculative trading accounts. From 1999 to 2006 the firm traded the Millenium Fund which closed in December, 2006. Starting in February 2007 BCM will trade a new fund, Heartland Agricultural Fund, LP. 

     The Advisor is registered under the Commodity Exchange Act, as amended, as a commodity trading advisor and as a commodity pool operator. In addition to its two principals, the Advisor currently has ten full‑time employees and five part‑time employees.  Past performance of the said advisor is included in pages 12-18.  The Advisor is a member of National Futures Association.  

     Richard A. Brock is President, Chief Executive Officer, Treasurer and Chairman of the Board of Directors of the Advisor. He also serves as Vice President of Brock Investor Services, Inc., but is not active in the daily operations of that firm. Mr. Brock first became registered as an Associated Person in 1975. From August, 1975, to July, 1976, Mr. Brock was a commodity broker for Geldermann Inc. in Lafayette, Indiana. In July, 1976, Mr. Brock joined Top Farmers of America in Milwaukee, Wisconsin as a commodity market analyst. In 1978, he was promoted to the position of Director of Market Analysis and stayed in that capacity until October, 1980 when he left Top Farmers of America to start Brock Associates.  Mr. Brock obtained his Bachelor of Science degree in Agricultural Economics from Purdue University and his Master of Science degree from Cornell University. 

Cathy C. Brock is Secretary and Vice President of the Advisor. Prior to July, 1980, Mrs. Brock was employed as a music therapist. From July, 1980 until September, 1981, she was business manager for a professional chorus group. From October, 1981 to the present, Mrs. Brock has been a housewife. She does not maintain an active role in the management of the Advisor. 

Timothy P. Brusnahan is Vice President of Consulting of the Advisor.  Mr. Brusnahan has been employed by the Advisor since May, 1985.  Prior to coming to the Advisor, Mr. Brusnahan was employed as a commodity broker with Gerstenberg & Co. in Chicago.  He is a 1981 graduate of Purdue University and has been registered as an Associated Person since May, 1986. 

There have never been any administrative, civil or criminal actions pending, concluded or on appeal against the Advisor or any of its principals. 

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Trading Methods 

In managing a hedge account, the Advisor will utilize a trading philosophy based on fundamental analysis and technical, trend‑following systems. Fundamental analysis consists of using supply and demand analysis to predict average prices for commodities over a given period of time. The difficulty with only using fundamental analysis is that it provides no means for timing of purchases or sales. Technical, trend‑following analysis is based on the theory that the study of the markets themselves provides the means of anticipating futures prices. A technical, trend‑following approach bases trading decisions primarily on the price behavior of each commodity and provides the timing technique used by the Advisor for implementing positions in the futures and options markets. 

The Advisor employs several different technical methods for analyzing the price behavior of a commodity to determine the time and price at which commodities should be bought or sold. The selection of which of the methods is to be used is determined subjectively by the Advisor but is influenced to a large extent by the major trend of the commodity in question. The performance of any technical trading system may be adversely affected by unexpected changes in fundamental factors. Performance may also be adversely affected by trendless periods which occur from time to time in the commodity markets. 

The underlying premise of a technical trading system is that all commodities will, from time to time, enter into periods of major price change to either a higher or lower price level. These major price changes are known as trends. Ordinarily, the Advisor will not attempt to predict the extent or the duration of such a price trend but, rather, make decisions to either purchase or sell a commodity based on the directional indications of its technical system. If the Advisor is of the opinion that execution of the indicated hedge would be difficult or would expose the account under management to undue risk, the Advisor may choose to modify the trading indicators of its technical system. 

Technical analysis of the futures markets by the Advisor will consist of an analysis of daily, weekly and monthly price fluctuations along with changes in the volume of trading and open interest. Commodity charts will be used in this analysis as well as computers.  Computers play a major role in the analysis of daily data for the Advisor in the selection of buy and sell points for hedge consulting accounts. Through the use of technical analysis, the Advisor will attempt to detect price trends and to establish or exit positions when the favorable trend either reverses or does not materialize. No such methods will be successful if the trend is adverse to the direction incorrectly predicted by the system or the market is moving in an erratic and non-trending manner. Such trading methods may also result in adverse price movement over the short‑term even though the long‑term trend of the market is favorable for the position and thus for the performance of the account. 

The purpose of three separate trading systems in based on the beliefs of the Advisor that commodity markets are characterized by different types of price behaviors different at different times and that no single trading method can work effectively under all conditions since each differs in the specific way in which it hedges price behavior. Some are designed to take advantage of longer‑term price trends, while others attempt to identify short or intermediate term trends. Some methods will usually maintain a position in a particular commodity, while others may have long periods of time with no positions. Since the system has methods with different degrees of sensitivity to price changes, they will usually buy and sell at different times and different prices and, in fact, may even indicate opposing positions from time to time.

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Fees

FARM MARKETING CONSULTING ACCOUNT: The fee for clients joining the consulting program after June 1, 2006 consists of a management fee of $0.04 cents per bushel for corn/milo; $0.05 cents per bushel for wheat; $0.06 cents per bushel for soybeans; ½ cent per pound for all cotton; 50 cents per head for all hogs; $1.00 per head for all cattle and $6.00 per head for all dairy cows under management. The fee for a farm marketing consulting account opened prior to June 1, 2006 consists of a "management fee" plus an incentive payment based on hedging profits. The management fee is 3 cents per bushel for all corn under management; 4 cents per bushel for all wheat under management; 5 cents per bushel for all soybeans under management; 1/2 cent per pound for all cotton under management; 50 cents per head for all hogs under management; $1 per head for all cattle under management; and $6 per head for all dairy cows under management. 

The minimum management fee is $3,000 per year. One year's fee shall be paid to the Advisor within fifteen (15) days from the beginning of the contract. In subsequent years, one‑half of the annual fee shall be paid at the beginning of each subsequent six‑month period. 

In addition, clients who joined the consulting program prior to July 1, 1991 shall pay the Advisor an incentive payment equal to ten (10) percent of the net profits in the hedging account during the previous six months. "Net Profits" consist of the sum of (a) the net of any profits and losses on all trades closed out during the six‑month period  and (b) the net of any profits and losses on open positions as of the end of the six‑month period, minus (y) brokerage commissions accrued during the six‑month period, and (z) cumulative net trading losses, carried forward from all preceding six‑month periods since the last six‑month period for which an incentive was payable to the Advisor. The incentive payment (if any) will be paid at the end of the first six‑month period following the beginning of the advisory relationship, and every six months when there are net profits thereafter as long as the advisory agreement is in effect. If the client's hedging account shows a loss for any six‑month period, said loss will carry over into the following six‑month period or periods, and shall be subtracted from the profits against which any incentive payment due to the Advisor is computed for that period or periods. Hedging activity may include both commodity futures and commodity option transactions. In addition, in the case of very large clients, the Advisor will negotiate a flat fee for its services. 

     For clients joining the consulting program after July 1, 1991, the incentive fee calculation is changed significantly. If the final average selling price is in the upper one‑third of the annual price range, the client will pay the advisor incentive fees of 1 1/2 cents per bushel on corn, milo and wheat; 3 cents per bushel on soybeans; and 1/2 cent per pound on cotton. There are no incentive fees on cattle and hogs. For dairy clients, the incentive fee is structured differently. There will be an incentive of 10% of all milk and feed hedge profits over $20,000, regardless of the final average selling price. 

     The final average selling price includes the weighted average of all cash sales adjusted to the midpoint of the marketing year and adjusted for futures and options P/L. The midpoint of the marketing year for corn, milo and soybeans is March 1. The midpoint for wheat is December 1 and cotton is February 1. Carrying cost on corn is calculated at 3 cents/bushel/month; wheat at 4 cents; soybeans at 5 cents; and cotton at 1/2 cents/pound/month. 

INDUSTRIAL HEDGE CONSULTING ACCOUNT: The base fee for industrial commodity consulting accounts is negotiated with the client prior to the beginning of a relationship. These fees range anywhere from $4,500 to $25,000 per client per year. The fee that is negotiated is based on the amount of hedging discretion that the Advisor is given, how much effort it must put forth with cash commodity advice, frequency of client contact and whether or not that contact is largely verbal or written, the frequency of meetings at the client's main office which may necessitate traveling to various parts of the country, the degree of the Advisor's involvement in the development of purchase contracts for organizations that sell commodities to its clients and other considerations too extensive and complex to list. Management fees are to be paid in advance for one year at the inception of the management agreement. Each year thereafter, management fees are paid six months in advance. 

In addition, some clients, but not all, will pay the Advisor an incentive payment equal to ten percent (10%) of net profits (as defined above) in the hedging account. The incentive payment will be paid at the end of the first six‑month period following the beginning of the advisory relationship, and every six months when there are net profits thereafter as long as the advisory agreement is in effect. If the client's hedging account shows a loss for any six‑month period, said loss will carry over into the following six‑month period, or periods, and shall be subtracted from the profits against which any incentive payment due to the Advisor is computed for the period or periods. Hedging activity may include both commodity futures and commodity option transactions. The existence and size of incentive fees are part of the negotiating of total fees prior to the beginning of a consulting relationship. 

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Principal Risk Factors 

As indicated above, investing in commodity interests involves a high degree of risk. Although the trading advisor will attempt to reduce risk through the measures described above, there can be no guarantee that substantial losses will not, in fact, be incurred. Listed below are the principal risk factors associated with the trading advisor's trading program. Prospective investors in Brock Associates' Hedging Program should carefully consider the risk set forth below, as well as the risk set forth in the Risk Disclosure Statement in the forepart of this document, before deciding to participate in the trading advisor's hedging program: 

1.     Commodity interest trading is speculative. While this is a hedging and not a speculative program, clients should anticipate substantial losses at certain time periods on the futures and/or options side of the hedging transaction. Grain producers should anticipate significant losses in short grain positions during periods of crop shortages or other fundamentals that could cause prices to rise. Buyers of grain could likewise experience significant losses on the futures side of a hedge due to declining prices.  

2.     Commodity interest trading is highly leveraged. The low margin requirements in trading commodity interests may allow for a high degree of leverage. Thus, a relatively small movement in a commodity may result in substantial losses or gains to the client. In all leveraged investments, there is always a possibility that losses can far exceed the amount invested. 

3.     Commodity interest trading may be illiquid. The markets typically traded by the trading advisor have been chosen for their historical performance, and for their customary liquidity. However, from time to time, the trading advisor could possibly trade in nearby futures contracts that possess less liquid markets. While the trading advisor has never accepted or made delivery on any futures contract, the risk always exist that acceptance or delivery could occur at some point in time. In the event of delivery, it may be necessary for the account to borrow funds. Such borrowing may be arranged through the FCM, at rates above the market rate for short term loans, and will be at the client's expense.

4.     Substantial fees and expenses. Clients may be subject to substantial brokerage commissions, management fees and incentive fees. It is possible that substantial brokerage commission fees may be generated by the trading advisor's trading program, which could negatively impact the profitability of a client's account. 

5.     Participating customer's FCM may fail. Under CFTC regulations, FCM's are required to maintain customer's assets in a segregated account. If a customer's FCM fails to do so, the customer may be subject to risk of loss of funds in the event of its bankruptcy. Even if such funds are properly segregated, the customer may still be subject to a risk of a loss of his funds on deposit with the FCM should another customer of the FCM or the FCM itself fail to satisfy deficiencies in such other customer’s accounts. Bankruptcy law applicable to all U.S. futures brokers requires that, in the event of the bankruptcy of such a broker, all property held by the broker, including certain property specifically traceable to the customer, will be returned, transferred or distributed to the broker’s customers only to the extent of each customer’s pro-rata share of all property available for distribution to customers. If any futures broker retained by the customer were to become bankrupt, it is possible that the customer would be able to recover none or only a portion of its assets held by such futures broker.

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Affiliation with Futures Commission Merchants; Conflicts of Interest 

Richard A. Brock, sole stockholder of Richard A. Brock & Associates, Inc., also owns 100% of Brock Investor Services, Inc., an introducing broker clearing through FC Stone and Company in Chicago, Illinois. For accounts managed by the Advisor whose futures transactions are handled through Brock Investor Services, Inc. (BIS), there is a conflict of interest. Mr. Brock will directly benefit from commissions generated in such accounts at BIS as a result of his 100% ownership of said firm, and therefore there is an incentive to overtrade. BIS receives approximately 30% of gross commissions charged thus indicating Mr. Brock's share at approximately 30% before deducting any operating costs, salaries or overhead. However, due to the methods used in making trading decisions, the likelihood of overtrading occurring is small. Clients do receive competitively low commission rates and in most cases, lower rates than they could receive elsewhere. Each client is free to choose the futures commission merchant and introducing broker of his choice. However, the Advisor does encourage each client to use Brock Investor Services, Inc. as the introducing broker to make the order entry process easier and more efficient for the Advisor. Brock Investor Services, Inc. uses FC Stone, a Futures Commission Merchant, to clear its trades for customers. There is no material conflict of interest between FC Stone and Brock Associates. There is no material conflict of interest between FC Stone and Brock Investor Services, Inc. 

THERE HAVE NEVER BEEN ANY MATERIAL ADMINISTRATIVE, CIVIL OR CRIMINAL PROCEEDINGS PENDING, CONCLUDED OR ON APPEAL AGAINST BROCK INVESTOR SERVICES OR ANY OF ITS PRINCIPALS. 

THERE HAVE NEVER BEEN ANY MATERIAL ADMINISTRATIVE, CIVIL OR CRIMINAL PROCEEDINGS PENDING, CONCLUDED OR ON APPEAL AGAINST FC STONE AND COMPANY OR ANY OF ITS PRINCIPALS. 

The Advisor does not trade for its own account nor does it intend to trade for its own account. The Advisor provides quote equipment, copying equipment and other services to BIS on a cost basis. 

A real estate investment firm owned by Mr. Brock owns a building at 2050 West Good Hope Road, Milwaukee, Wisconsin, which leases office space to Richard A. Brock & Associates, Inc.. The firm also leases space in this building to Brock Investor Services, Inc. Lease terms for office space were negotiated in an "arms‑length" manner and are comparable to the cost of other office space in competitive properties in the area.  There are no conflicts of interest on the part of the Advisor or Mrs. Brock. 

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Trading by Richard A. Brock & Associates, Inc. and its Principals 

Richard A. Brock & Associates, Inc. does not currently trade or intend to trade commodity interest for its own corporate account. The principals and associates of the Advisor may, from time to time, trade commodity interests for their own account. Any such trading activity may or may not be in accordance with the positions recommended by the Advisor. Any client or prospective client of the Advisor desiring further information concerning trading activity of the principals or associates may request such information at the office of the corporation or by telephoning the number listed in this disclosure document.

Commodity trading advisors are limited in the amount of assets which they can successfully manage by, among other things, the difficulty of obtaining execution of substantially larger trades in order to reflect larger equity under management and by the restrictive effects of possible market illiquidity. Performance achieved trading a limited amount of assets may have little relationship to the performance an Advisor can reasonably expect to achieve trading larger amounts of funds. There can be no assurance that the Advisor's trading methods will not be adversely affected by the size of the future accounts or by additional equity accepted by the Advisor. 

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Past Performance 

The primary business of the Advisor, in addition to the publication of The Brock Report, consists of consulting with farmers who produce various agricultural commodities and with businesses that distribute, consume or process such commodities. The Advisor assists its clients in developing marketing or purchasing plans and in establishing hedges in futures and options contracts to reduce price risk in connection with the marketing of these commodities. 

The Advisor addresses the marketing problems of its clients on an individual basis and seeks to tailor its hedging advice to the specific needs of each client. Due to their diversity, clients of the Advisor frequently will be on opposite sides of the market from one another. For example, a livestock farmer would be faced with problems related to the purchase of corn to use for feed for his stock, while a farmer would be concerned with marketing problems related to the sale and distribution of corn. A business engaged in the processing of agricultural products, such as corn, would have an entirely different set of factors to consider in acquiring necessary supplies of corn. Unlike a trading advisor who manages only speculative accounts and who would be likely to provide the same recommendations or to make the same trades for each speculative account, the Advisor does not, and cannot, provide a single series of recommendations for hedging transaction to its client. Although the Advisor makes specific trading recommendations to its clients, such recommendations are not implemented without prior approval of the client; and the client may decline to follow any recommendation or follow it only with significant client modification. The Advisor has not had complete or exclusive discretionary authority over any hedging account due to the consultative and customized nature of its services to clients. 

Because of the diversity of the Advisor's clients, the variation in the scope and types of services provided to them, and the limited and variable nature of the Advisor's control over the futures transactions executed by those clients, the Advisor does not have any hedge trading "performance record" in the same sense as a speculative trading advisor who has had discretion over the trading of customer funds. 

However because the Advisor does hold a discretionary power of attorney from its clients for the purpose of entering orders after consultation with clients has taken place, the Advisor is required by CFTC rules to present its performance record. For the reasons and pursuant to the methodology explained in detail in Appendix I, the Advisor has prepared the tables that are presented there. Certain assumptions, stated there, have been made about futures and cash transaction prices. Essentially, these assumptions have been made in an attempt to summarize concisely the hedge recommendation experience of the Advisor. To the extent that the assumptions are not met in practice by all of its clients' accounts, the information presented in these tables contains certain hypothetical reports. Although, even for speculative futures advisors with full discretionary control over clients' accounts and a well‑defined performance record, it is the case that past results are not necessarily indicative of future performance, prospective investors should be aware that no conventional or standardized performance record for the Advisor is available to them as information  which may be relevant to evaluating the likelihood of a client achieving its objectives. 

Appendix I presents the performance information prepared by the Advisor to satisfy CFTC performance disclosure requirements. This information compares, on an approximate basis, the advice given in The Brock Report with respect to cash market transactions with the actual price range for the relevant period and the national average cash price. The information presented also indicates the results of the futures and options hedging transactions which would have been achieved if the recommendations presented in The Brock Report had been implemented. Although the information presented with respect to the recommendations contained in The Brock Report is to that extent hypothetical, the Advisor believes it may be relevant to a prospective client's decision whether to establish a relationship with it. 

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Additional Information 

Any current client or prospective client of Richard A. Brock & Associates, Inc. that desires additional information on the performance records of the Advisor may do so by writing to the address on this Disclosure Document or by visiting the office of Richard A. Brock & Associates, Inc. at the same address.

Farm Marketing Consulting Account Fee Example
(For clients joining program before July 1, 1991)

The example below is provided to illustrate the computation of Farm Marketing Consulting Account Fees charged by Richard A. Brock & Associates, Inc.

Assume the following:
        700 acres of corn producing 115 bushels per acre
        100 acres of wheat producing 55 bushels per acre
        200 acres of soybeans producing 45 bushels per acre

Total Production                                                    Management Fee:
               Corn               80,500 bushels                                  Corn               3.0 cents per bushel
               Wheat              5,500 bushels                                 Wheat            4.0 cents per bushel
               Soybeans      9,000 bushels                                    Beans             5.0 cents per bushel

Management Fee Calculation:
                80,500 bushels corn x .03 =                  $2,415.00
                5,500 bushels wheat x .04 =                 $   220.00
                9,000 bushels soybeans x .05 =          $   450.00
               Total Management Fee =                      $3,085.00

1.  At year end, assume a net profit in the hedging account of $9,000. The incentive payment is 10% of $9,000 = $900. Total payment for the year to Richard A. Brock & Associates, Inc.

Management Fee                        $3,085.00
                Incentive Fee                              $   900.00
               Total Fee                                      $3,985.00 

2. If instead of a $9,000 profit in hedging account, assume it showed a net reduction of $4,000. In this case, the fee payment to Richard Brock & Associates, Inc. would be $3,085.00. 

Farm Marketing Consulting Account Fee Example
(For clients joining program after July 1, 1991)

The example below is provided to illustrate the computation of Farm Marketing Consulting Account Fees charged by Richard A. Brock & Associates, Inc.

Assume the following:
        1. Farm produces 100,000 bushels of corn.
        2. 50,000 bushels were sold on November 1 at 2.60 and 50,000 bushels were sold April 2 at 2.80.
        3. Lowest cash price at farmers market for the marketing year was 2.00/bushel and the high was 3.00/bushel.
        4. Futures hedge account showed a net cash flow loss of $2,000.

Management Fee Calculation:
                Base Fee = 100,000 bu (3 cents)=                                                                                             $3,000
        Incentive Calculation:
               *2.67 need for top 1/3
               *50,000 sold at 2.60 on November 1: 2.60 + 4 months (3 cents)              2.72
               *50,000 sold a 2.80 on April 1: 2.80 ‑ 1 month (3 cents)                           2.77
               Net cash selling price                                                                                    2.745
               Futures adjustment=$2,000/100,000 bu.                                                    (0.02)
              Adjusted Average                                                                                          2.725
        Since in top 1/3 100,000 bu. (1 1/2 cents) =                                                                                     $1,500
              Total fees for the year                                                                                                                  $4,500 

Farm Marketing Consulting Account Fee Example
(For clients joining program after June 1, 2006)

The example below is provided to illustrate the computation of Farm Marketing Consulting Account Fees charged by Richard A. Brock & Associates, Inc.

Assume the following:
        700 acres of corn producing 115 bushels per acre
        100 acres of wheat producing 55 bushels per acre
        200 acres of soybeans producing 45 bushels per acre
              Total Production                                                    Management Fee:
              Corn               80,500 bushels                                  Corn               4.0 cents per bushel
              Wheat            5,500 bushels                                    Wheat            5.0 cents per bushel
              Soybeans      9,000 bushels                                     Beans             6.0 cents per bushel

Management Fee Calculation:
              80,500 bushels corn x .04 =                 $3,220.00
              5,500 bushels wheat x .05 =                $   275.00
              9,000 bushels soybeans x .06 =          $   540.00
             Total Management Fee =                     $4,035.00

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APPENDIX I: HEDGE RECOMMENDATION EXPERIENCE OF THE ADVISOR
      Difficulties in Presenting Hedging Performance Records 

The format for the presentation of the performance of commodity trading advisors mandated by the rules of the Commodity Futures Trading Commission is addressed only to performance in the futures market. Hedging, however, involves the establishment of futures positions in relation to a client's existing or anticipated positions in the cash market. Unlike speculative trading, hedging is not intended solely for the purpose of generating a profit from commodity futures trading. Instead, hedging is intended to reduce risk by locking in a price at the current time by establishing a long or a short futures or options position, depending on the cash position of the trader, which will then be liquidated at or near the same time the cash market position is liquidated. In a perfect hedge situation, the profit or loss on the futures transaction would offset exactly the loss or profit on the cash position. Accordingly, the performance of a trading advisor providing advice on hedging can be evaluated only by taking into account both the futures and cash market performance. 

The need to obtain price data for both cash and futures markets complicates presentation of performance results. The futures markets provide a centralized pricing mechanism for futures contracts, but there is no corresponding centralized market for pricing cash agricultural commodities. While financial instruments which are the subject of futures trading are actively traded in the cash markets, and up‑to‑the‑minute cash price quotations are generally available, there is no corresponding centralized market for cash agricultural commodities. This market is decentralized and on a given day cash prices for a particular agricultural commodity may vary significantly from one location to another. 

Presentation of the hedge recommendation experience for accounts of clients of the Advisor is further complicated by the fact that the Advisor exercises no power of attorney over its clients' cash market transactions. Furthermore, although it does receive from its clients powers of attorney for futures transactions, all futures trades are subject to prior client approval or modification; a client may reject any proposals for specific futures transactions made to it by the Advisor or take positions differing from the Advisor's recommendations. The Advisor has no control over the cash market transactions of its clients, and performance on the futures side is also affected to a variable extent by client decisions over which the Advisor has no control.   

Prospective investors should consider the difficulties connected with the presentation of agricultural hedging performance results in general, and with the presentation of the hedging experience of client accounts of the Advisor in particular, in reviewing the following tables, which the Advisor has developed for the following agricultural commodities which are sold by its clients and for which it provides hedging advice: corn, wheat, cotton, hogs and cattle; a table is also included for soybean oil in which market the Advisor gives advice concerning purchases.

Each of the following tables begins in the first year for which the Advisor or its principals developed comparative data for its hedging accounts. The tables reflect the hedge recommendation experience for all commodities for which the Advisor has made marketing and hedging recommendations. The Advisor has consulted with respect to client accounts since October 1, 1980; from 1978 to October 1, 1980, Richard Brock as an individual consulted with respect to hedging and farm marketing accounts. 

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EXPLANATION OF THE TABLES
        Marketing Years

In conformity with industry practice, the following tables are presented on a "marketing year" basis for grains and a calendar year basis for livestock. The respective "marketing years" (each of which are 12 months long) for the various grains are established by the United States Department of Agriculture (the "USDA") and are selected so as to reflect the production cycle of each crop. Marketing years are, in general, timed so that they begin approximately when the first crop of summer (the principal growing season) is harvested and marketing begins in the cash markets. (Forward market sales for delivery in the following marketing year may have been made prior to harvest and at prices outside the National Price Range in the cash market during that upcoming marketing year.) 

The calendar year is used as the marketing year for livestock because livestock production is not seasonal. Livestock is marketed on a continuous basis throughout the year as it reaches market weight, whereas other commodities are marketed (in the cash markets) only as harvested. The marketing years for the non‑livestock commodities with respect to the Advisor publishing hedging recommendations are as follows:

Corn:                       September 1‑‑August 31 (prior to September 1, 1986, October 1‑‑September 30)
                Cotton:                   August 1‑‑July 31
                Soybeans:              September 1‑‑August 31
                Soybean Oil:          October 1‑‑September 30
               Wheat:                   June 1‑‑May 31 

National Prices
       The following tables, in general, compare the National Price Range (non‑livestock commodities) and National Average Cash Price to the results which a hypothetical farmer would have achieved had he followed the cash market and hedging recommendations included in The Brock Report for the marketing/calendar year in question.

National Price Range figures are based on the prices in a local market which the Advisor considers to be representative of the overall national market. Prices can vary significantly between different markets and it is not practicable to attempt to identify the minimum and maximum prices at all markets throughout the country. Consequently, a single representative market for which accurate and complete price figures are available to the Advisor is used. The representative markets used for the non‑livestock commodities are: 

Corn Central Illinois
                Cotton Memphis
                Soybeans Central Illinois
                Soybean Oil Decatur, Illinois (purchases)
               Wheat Toledo, Ohio prior to 1997. From 1997 to the present St. Louis, MO is used. 

In certain years, actual selling prices exceed the upper level of the National Price Range due to aggressive forward cash market contracting prior to the beginning of the marketing year. No National Price Range (as opposed to average price) information is presented for Live Cattle or Live Hogs because livestock must be marketed when it has reached a certain weight. Unlike the non‑livestock commodities which can be stored in the anticipation or hope of obtaining better prices in the future, there is little discretion over when to sell livestock. Consequently, a price range has little significance in that such range does not represent the highest or lowest price a hypothetical farmer could have obtained; only the prevailing price when his livestock reach market weight throughout the year. Similarly, because there is little discretion over when to market livestock, The Brock Report presents no cash market recommendation and, hence, no such recommendations are reflected in the livestock tables. Instead, these tables compare (i) the Brock Net Average Price, including hedging profit and loss, which would have been obtained by a hypothetical farmer hedging in the futures markets (in which, unlike the cash markets, the farmer has discretion as to when to execute transactions) in accordance with The Brock Report recommendations with (ii) the prices the same farmer would have obtained simply by selling his livestock as it reached market weight throughout the year, without hedging his price risk.

National Average Cash Price is a figure published by the USDA based on the weighted average price (weighted on the basis of the number of bushels sold) obtained for all reported sales during the marketing year. For Live Cattle and Live Hogs, respectively, the average price in Omaha, Nebraska (the major cattle market in the United States) and a "7 Market Average" published by the USDA are used, in conformity with industry practice.

In the case of certain grains, information about various USDA‑sponsored price support, PIK ("payment in kind") and crop loan programs is provided because these programs have had a material effect on price levels. 

The Brock Report Prices
       The prices against which the foregoing national figures are compared are the weighted average cash market selling (buying, in the case of soybean oil) price and the weighted average futures market position recommendations included in The Brock Report. In The Brock Report, recommendations will be given, for example, to hedge 30% of one's crop in the futures market, sell 20% of one's harvest in the cash or forward markets, etc.. The Brock Report weighted average figures are calculated based on the overall results which a hypothetical farmer would have achieved disposing of his entire crop pursuant to such recommendations, while at the same time executing hedging transactions in the futures markets as per such recommendations.

The following tables do not reflect the results which any actual farm obtained through use of The Brock Report; rather, The Brock Report statistics constitute no more than weighted averages of all recommendations given by the Advisor during the marketing year.

During any one marketing year The Brock Report will make cash market sales recommendations totaling, on a cumulative basis, 100% of the hypothetical farmer's crop. The Brock Report does not make cash sale recommendations which suggest a sale of a percentage of whatever remains unsold, such that a 10% sale recommendation could be applied to the entire crop if a subscriber had rejected an earlier 20% sale recommendation. Rather, the Advisor takes into consideration prior sale recommendations, and the cumulative result of all recommendations of The Brock Report during a marketing year is the sale of 100% of a cash crop. As a result, it is not the case that in the weighted averaging process subsequent profitable recommendations could mitigate the adverse effect of earlier unprofitable advice (in soybean oil, in which The Brock Report recommends purchases rather than sales, the cumulative recommendation during a marketing year equals 100% of the hypothetical purchaser's soybean oil requirement).

In the futures markets, the cumulative total of The Brock Report recommendations during a marketing year could, of course, equal substantially more than 100% of a farmer's cash crop because futures positions are used as a means, not of disposing of the crop, but of hedging, on an ongoing basis, a percentage of that crop against price risk. The hedge positions recommended by The Brock Report at any one time will, of course, never exceed 100% of a farmer's crop.

The prices at which the hypothetical farmer is deemed to have sold his crop (bought in the case of soybean oil) or established his futures hedge is the price determined by the Advisor at the time it makes its recommendation for publication in the weekly edition of The Brock Report. This price might vary substantially from the price in effect several days later when The Brock Report containing such recommendation is actually received by most farmers. In all cases, however, the recommendation which appeared in The Brock Report should have been available on a substantially "real time" basis to farmers through the daily telephone report of the Advisor. It is because of the price volatility in the markets concerning which it gives advice, that The Brock Report is updated on a daily basis by taped telephone information available to all subscribers.

Grain price levels are adjusted to reflect "carrying charges". Unlike livestock, which is marketed as soon as it reaches market weight, grain is typically stored for some time prior to sale. Storage not only involves a storage fee (or an implicit storage fee if a farmer stores his grain in his own facilities), but also an interest cost. During the period when the grain is stored and not sold, the farmer is foregoing the interest which could have been earned on the sale price of the crop. As a result, sales made early in a marketing year are effectively worth more than sales made at the same price later in the marketing year. As all grains of the same variety are harvested at generally the same time (so that the carrying cost component of sales prices vary in a relatively uniform pattern for all farmers throughout the marketing year), the industry has adopted the convention of adjusting sale prices prior to the mid‑point of the marketing year upwards (on a sliding scale) and sales made after the mid‑point to the end of the marketing year downwards (also on a sliding scale) to reflect the effect of carrying charges on "real" sales prices. This convention has been adopted in the following tables in respect of both the national average and The Brock Report prices.

 The following tables do not reflect any management fees paid to the Advisor or any brokerage commissions paid upon execution of futures trades recommended by the Advisor. 

The data presented in the following tables is hypothetical in the sense that it assumes that the recommendations presented in The Brock Report were followed and that transactions were effected at the recommended prices. The Commodity Futures Trading Commission requires that the following legend be presented in any futures fund disclosure document which contains a hypothetical performance record. The legend is however, inapplicable in that the Advisor's hedging recommendation tables have not been designed with the benefit of hindsight, but rather on the basis of the actual recommendations given by the Advisor on a current basis. 

Hypothetical or simulated performance results have certain inherent limitations. Unlike an actual performance record, simulated results do not represent actual trading. Also, since the trades have not actually been executed, the results may have under‑or‑over compensated for the impact, if any, of certain market factors, such as lack of liquidity. Simulated trading programs in general are also subject to the fact that they are designed with the benefit of hindsight. No representation is being made that any account will or is likely to achieve profits or losses similar to those shown. 

No actual farm achieved the results presented. Past results are not necessarily indicative of future performance, and the following tables do not represent actual results buy only hypothetical consequences of following the recommendations in The Brock Report. 

THE NATIONAL PRICE INFORMATION INCLUDED IN THE TABLE IS APPROXIMATE ONLY AND DOES NOT REFLECT THE PRICE WHICH MAY IN FACT BE OBTAINED BY A PARTICULAR PRODUCER.

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Track Record of Richard A. Brock & Associates

CORN

      *Preliminary data as of January 31, 2008. 

SOYBEANS