Just2Trade TOS

DISCLOSURE:

Disclosures
NOTICE OF SUCCESS TRADE SECURITIES, INC. PRIVACY POLICY

Our commitment to Your Privacy:
Success Trade Securities, inc. has a longstanding policy of protecting the confidentiality and security of information we collect about customers. We will not share nonpublic information about you (Information) without your consent, except for specific purposes described below. This notice describes the Information we may gather and the circumstances under which we may share it.

Why do we gather information?
We collect information required to open an account, to transact business effectively and to safeguard your assets or your privacy. But we also continually strive to improve our services and provide you opportunities to use additional products and services you may find of interest. To do this, we gather information to help us assess your needs and preferences.

What information do we collect?
The information we collect directly from you includes information required to communicate with you, including your name, mailing address, telephone number, e-mail address and fax number, gender, education, occupation employer name and address. And to identify who you are, including birth date and Social Security number. Additionally, as required by law, to assess your experience in margin use and trading, we may also collect your approximate annual income, approximate net worth, approximate worth, and credit reports to assess your financial position.

When do we obtain information?
You directly provide to us the majority of information we collect. You do this by completing the account application and related documentation, placing a trade, sending us an e-mail for questions or comment.

How do we use your personal information?
Again, the trust of our clients is our most valued asset. Therefore, we use personal information only as appropriate to provide you quality service and security.
For example, Success Trade Securities, inc. may use the information collected from you to verify your identity and contact information. We may also use this information to establish and set up your trading account, issue an account number and a secure password, maintain your portfolio and trading activity, and contact you with account information. This information helps us improve our services to you, customize your browsing experience and inform you about additional products, services or promotions that may be of interest to you.
Success Trade Securities, inc. may also use demographic information provided by others on our clients so that we can develop products and services for our clients.
Should you close your account with us, Success Trade Securities, inc. will retain your information as needed to comply with regulatory requirements.

What information does Success Trade Securities, inc. share with affiliates, alliances and partners?
Success Trade Securities, inc. may share information with affiliates if the information is required to provide the product or service you have requested or to provide you the opportunity to participate in the products or services our affiliates offer. Success Trade Securities, inc. also forges partnerships and alliances, which may include joint marketing agreements, with other companies who offer high-quality products and services that might be of value to our clients. In order to ensure that these products and services meet your needs and are delivered in a manner that is useful and relevant, Success Trade Securities, inc. may share some information with partners, affiliates and alliances.
This allows them to better understand the offers that are most relevant and useful. We may also compare our client lists with those of our partners and affiliates to ensure that they are not sending messages to you if you've elected not to be so notified. In our strategic relationships, we will require that it be identified that an offer is being extended because of the relationship with us. The use of your personal information is limited to the purposes identified in our relationship with the partner or affiliate.
An affiliate is a company that we own or control or with which there is common ownership with us and our parent company. We may share with our affiliate’s information about our transactions and experiences with you such as name, e-mail address, mailing address, date of birth, employment status, and general account and demographic information. This information may be used for internal reporting, anticipating margin calls, and development strategies. We do not share information other than the types of transaction and experience information described above with our affiliates.

Do we share the information collected with any other third parties?
The cornerstone of our Privacy Statement is the commitment to keep our clients' personal information confidential. Success Trade Securities, inc. does not sell, license, lease or otherwise disclose your personal information to any third party for any reason, except as noted earlier and as described below:
To help us improve our services to you, we may engage another business to help us to carry out certain internal functions such as account processing, fulfillment, client service, client satisfaction surveys or other data collection activities relevant to our business. We may also provide a party with client information from our database to help us to analyze and identify client needs and notify clients of product and service offerings. Use of the information shared is strictly limited to the performance of the task we request and for no other purpose.
All third parties with which we share personal information are required to protect personal information in a manner similar to the way we protect personal information. Examples of information shared are identifying information such as name, mailing address, e-mail address, telephone number, and information on account activity. If at any time you choose to purchase a product or service offered by another company, any personal information you share with that company will no longer be controlled under our Privacy Statement.
Success Trade Securities, inc. also reserves the right to disclose your personal information to third parties where permitted by law or where required by law to regulatory, law enforcement or other government authorities. We may also disclose your information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property.

Does our Privacy Statement apply to the sites to which we link?
No. We are not responsible for the privacy policies or the content of sites we link to and have no control of the use or protection of information provided by you or collected by those sites. Whenever you elect to link to a co-branded Web site or to a linked Web site, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third party and you should familiarize yourself with the privacy policy provided by that third party.

What about "cookies" and other tracking devices?
Cookies are small text files sent from the Web server to your computer. Success Trade Securities, inc. may maintain a website that contains cookies. Cookies also may be placed by third parties when you access their sites through linking from a Web site. We do not have access to these cookies or any information that these cookies may contain. Please contact the third-party site for more information on these cookies. Although we encourage third parties to adhere to appropriate privacy policies and standards, we are not responsible for the actions or policies of such parties.
To administer and improve the Success Trade Securities, inc. Web site, we may use a third party to track and analyze usage and volume statistical information, including page requests, form requests, and click paths. All data collected for this purpose is owned and used by Success Trade Securities, inc. The third party may use cookies to track behavior and may set cookies on behalf of Success Trade Securities, inc. These cookies do not contain any personally identifiable information.

Will I be able to review, change or correct my information?
Yes. Personal identifying information may be reviewed, changed or corrected at any time. You are responsible for maintaining the accuracy and completeness of your personal and other information. At least once every 36 months we will send you a letter asking you to confirm the information we have on file. If you would like to review your personal information or if you believe that any of your information is incorrect, or if you have any questions regarding your personal information, or if you have any other questions or concerns regarding this privacy policy, simply contact our office.
How will I know if there are any changes to this Privacy Statement?
Success Trade Securities, inc. will provide each client an annual Privacy Statement that will include all changes. Should you have any additional questions concerning our privacy policy, you may submit a written request for additional information to our Customer Service Department located at 1900 L Street NW, Suite 525, Washington, DC 20036.
Success Trade Securities, Inc. SIPC Statement
Success Trade Securities, Inc. is a member of the Securities Investor Protection Corporation (SIPC), which currently protects securities customers of its members up to $500,000 (including $100,000 for claims for cash).
Additionally, our customer securities accounts are carried by Legent Clearing Corp. Ltd., who has also acquired “Excess SIPC” insurance from a third party insurer to protect client accounts up to their net equity for loss of securities and cash held at Legent Clearing Corp., up to an overall firm aggregate of US $200,000,000 over all customer accounts.
This “Excess SIPC” protection is in addition to the protection provided by the Securities and Investors Protection Act, which is administered by SIPC, and is subject to certain conditions and limitations, details of which are available upon request. The above coverage does not protect against loss of the market value of securities.
SIPC and the supplemental policy do not cover commodity contracts and options on futures. An explanatory brochure is available upon request or at http://www.sipc.org.

Or you may contact SIPC direct at:

Securities Investor Protection Corporation
805 15th Street, N.W. Suite 800
Washington, D.C. 20005-2215

Tel: (202)371-8300
Fax: (202)371-6728
Email: asksipc@sipc.org

Llyod’s of London
One Lime Street
London
EC3M 7HA UK
Tel: +44 (0)20 7327 1000

SUCCESS TRADE SECURITIES, INC. SEC Rule 606 Order Disclosure
The U.S. Securities and Exchange Commission's client disclosure rule, SEC Rule 606, requires all broker/dealers that route orders in equity and option securities to make available quarterly reports that present a general overview of their routing practices. These reports must identify the significant venues to which the client orders were routed for execution during the applicable quarter and disclose the material aspects of the broker/dealer's relationship with such venues.
These reports are divided into four sections: one for securities listed on the New York Stock Exchange and reported as a Network A eligible security; one for securities listed on the NASDAQ Stock Market; one for securities listed on the American Stock Exchange or regional exchanges and reported as a Network B eligible security; and one for exchange-listed options. For each section, this report identifies the venues most often selected by Success Trade Securities Inc., sets forth the percentage of various types of orders routed to the venues, and discusses the material aspects of Success Trade Securities Inc.'s relationship with the venues. These reports may be viewed at www.just2trade.com

SUCCESS TRADE SECURITIES, INC. MUTUAL FUND DISCLOSURE STATEMENT
Before investing in mutual funds, it is important that you understand the sales charges, expenses, and management fees that you will be charged, as well as the breakpoint discounts to which you may be entitled. Understanding these charges and breakpoint discounts will assist you in identifying the best investment for your particular needs and may help you reduce the costs of your investment. This disclosure document will give you general background information about these charges and discounts. However, sales charges, expenses, management fees, and breakpoint discounts vary from mutual fund to mutual fund. Therefore, you should discuss these issues with your financial advisor and review each mutual fund’s prospectus and statement of additional information, which are available from your financial advisor, to get the specific information regarding the charges and breakpoint discounts associated with a particular mutual fund.
Sales Charges
Investors that purchase mutual funds must make certain choices, including which funds to purchase and which class share is most advantageous. Each mutual fund has a specified investment strategy. You need to consider whether the mutual fund’s investment strategy is compatible with your investment objectives. Additionally, most mutual funds offer different share classes. Although each share class represents a similar interest in the mutual fund’s portfolio, the mutual fund will charge you different fees and expenses depending upon your choice of share class. As a general rule, Class A shares carry a “front-end” sales charge or “load” that is deducted from your investment at the time you buy fund shares. This sales charge is a percentage of your total purchase. As explained below, many mutual funds offer volume discounts to the front-end sales charge assessed on Class A shares at certain predetermined levels of investment, which are called “breakpoint discounts.” In contrast, Class B and C shares usually do not carry any front-end sales charges. Instead, investors that purchase Class B or C shares pay asset-based sales charges, which may be higher than the charges associated with Class A shares. Investors that purchase Class B and C shares may also be required to pay a sales charge known as a contingent deferred sales charge when they sell their shares, depending upon the rules of the particular mutual fund.
Breakpoint Discounts
Most mutual funds offer investors a variety of ways to qualify for breakpoint discounts on the sales charge associated with the purchase of Class A shares. In general, most mutual funds provide breakpoint discounts to investors who make large purchases at one time. The extent of the discount depends upon the size of the purchase. Generally, as the amount of the purchase increases, the percentage used to determine the sales load decreases. In fact, the entire sales charge may be waived for investors that make very large purchases of Class A shares. Mutual fund prospectuses contain tables that illustrate the available breakpoint discounts and the investment levels at which breakpoint discounts apply. Additionally, most mutual funds allow investors to qualify for breakpoint discounts based upon current holdings from prior purchases through “Rights of Accumulation,” and future purchases, based upon “Letters of Intent.” This document provides general information regarding Rights of Accumulation and Letters of Intent. However, mutual funds have different rules regarding the availability of Rights of Accumulation and Letters of Intent. Therefore, you should discuss these issues with your financial advisor and review the mutual fund prospectus to determine the specific terms upon which a mutual fund offers Rights of Accumulation or Letters of Intent.

1. Rights of Accumulation – Many mutual funds allow investors to count the value of previous purchases of the same fund, or another fund within the same fund family, with the value of the current purchase, to qualify for breakpoint discounts. Moreover, mutual funds allow investors to count existing holdings in multiple accounts, such as IRAs or accounts at other broker-dealers, to qualify for breakpoint discounts. Therefore, if you have accounts at other broker-dealers and wish to take advantage of the balances in these accounts to qualify for a breakpoint discount, you must advise your financial advisor about those balances. You may need to provide documentation establishing the holdings in those other accounts to your financial advisor if you wish to rely upon balances in accounts at another firm.
In addition, many mutual funds allows investors to count the value of holdings in accounts of certain related parties, such as spouses or children, to qualify for breakpoint discounts. Each mutual fund has different rules that govern when relatives may rely upon each other’s holdings to qualify for breakpoint discounts. You should consult with your financial advisor or review the mutual fund’s prospectus or statement of additional information to determine what these rules are for the fund family in which you are investing. If you wish to rely upon the holdings of related parties to qualify for a breakpoint discount, you should advise your financial advisor about these accounts. You may need to provide documentation to your financial advisor if you wish to rely upon balances in accounts at another firm.
2. Mutual funds also follow different rules to determine the value of existing holdings. Some funds use the current net asset value (NAV) of existing investments in determining whether an investor qualifies for a breakpoint discount. However, a small number of funds use the historical cost, which is the cost of the initial purchase, to determine eligibility for breakpoint discounts. If the mutual fund uses historical costs, you may need to provide account records, such as confirmation statements or monthly statements, to qualify for a breakpoint discount based upon previous purchases.
You should consult with your financial advisor and review the mutual fund’s prospectus to determine whether the mutual fund uses either NAV or historical costs to determine breakpoint eligibility.
3. Letters of Intent – Most mutual funds allow investors to qualify for breakpoint discounts by signing a Letter of Intent, which commits the investor to purchasing a specified amount of Class A shares within a defined period of time, usually 13 months. For example, if an investor plans to purchase $50,000 worth of Class A shares over a period of 13 months, but each individual purchase would not qualify for a breakpoint discount, the investor could sign a Letter of Intent at the time of the first purchase and receive the breakpoint discount associated with $50,000 investments on the first and all subsequent purchases. Additionally, some funds offer retroactive Letters of Intent that allow investors to rely upon purchases in the recent past to qualify for a breakpoint discount. However, if an investor fails to invest the amount required by the Letter of Intent, the fund is entitled to retroactively deduct the correct sales charges based upon the amount that the investor actually invested. If you intend to make several purchases within a 13 month period, you should consult your financial advisor and the mutual fund prospectus to determine if it would be beneficial for you to sign a Letter of Intent.
As you can see, understanding the availability of breakpoint discounts is important because it may allow you to purchase Class A shares at a lower price. The availability of breakpoint discounts may save you money and may also affect your decision regarding the appropriate share class in which to invest. Therefore, you should discuss the availability of breakpoint discounts with your financial advisor and carefully review the mutual fund prospectus and its statement of additional information, which you can get from your financial advisor, when choosing among the share classes offered by a mutual fund. If you wish to learn more about mutual fund share classes or mutual fund breakpoints, you may wish to review the investor alerts available on FINRA Web site.

See Understanding Mutual Fund Classes at:
http://www.finra.org/Investors/ProtectYourself/InvestorAlerts/MutualFunds/p006022

Mutual Fund Breakpoints: a Break worth Taking at:
http://www.finra.org/Investors/ProtectYourself/InvestorAlerts/MutualFunds/p006008

Should you have any additional questions concerning mutual fund breakpoint discounts, you may submit a written request for additional information to our Customer Service Department located at 1900 L. Street NW, Suite 525, Washington, DC 20036

SUCCESS TRADE SECURITIES, INC. Customer Identification Program Notice
Important Information You Need to Know About Opening a New Account
To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify, and record information that identifies each person who opens an account.
This Notice answers some questions about the firm’s Customer Identification Program.
What types of information will I need to provide?
When you open an account, we are required to collect information such as the following from you:
- Your name
- Date of birth
- Address
- Identification number:
U.S. Citizen: taxpayer identification number (social security number or employer identification number)
Non-U.S. Citizen: taxpayer identification number, passport number, and country of issuance, alien identification card number, or government-issued identification showing nationality, residence, and a photograph of you.
You may also need to show your driver’s license or other identifying documents.
A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement, or trust agreement.

U.S. Department of the Treasury, Securities and Exchange Commission, FINRA, and New York Stock Exchange rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience, objectives and risk tolerance.
What happens if I don’t provide the information requested or my identity can’t be verified?
We may not be able to open an account or carry out transactions for you. If we have already opened an account, we may have to close it.
We thank you for your patience and hope that you will support the financial industry’s efforts to deny terrorists and money launderers access to America’s financial system.
Special Measures against Specified Banks pursuant to Section 311 of the USA Patriot Act
Pursuant to U.S. regulations issued under section 311 of the USA PATRIOT Act, 31 CFR 103.192, we are prohibited from opening or maintaining a correspondent account for, or on behalf of, VEF Bank (Republic of Latvia) or any of its subsidiaries (including Veiksmes lïzings).
The regulations also require us to notify you that your correspondent account with our firm may not be used to provide VEF Bank or any of its subsidiaries with access to our financial institution. If we become aware that VEF Bank or any of its subsidiaries is indirectly using the correspondent account you hold at our firm, we will
take appropriate steps to prevent such access, including terminating your account.

Should you have any additional questions concerning our customer identification program, you may submit a written request for additional information to our Customer Service Department located at 1900 L. Street NW, Suite 525, Washington, DC 20036.

Success Trade Securities, Inc. Business Continuity Plan
Success Trade Securities, Inc. has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.
Contacting Us – If after a significant business disruption you cannot contact us as you usually do at 202-466-6890, you should call our alternative number 202-464-0567. If you cannot access us through either of those means, you should contact our clearing firm, Legent Clearing Corp., at 1-800-811-3487 for instructions on how it may provide prompt access to funds and securities, execute orders and process other trade-related, cash, and security transfer transactions for your customer.
Our Business Continuity Plan – We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.
Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.
Our clearing firm, Legent Clearing Corp., has the ability for real time back up capability of our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by our clearing firm that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments as they occur. Your orders and requests for funds and securities could be delayed during this period.
Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within 2 hours.
In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within 1 business day. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.
If the Securities Investor Protection (SIPC) determines that we are unable to meet our obligations to our customers or if our liabilities exceed our assets in violation of Securities Exchange Act Rule 15c3-1, SIPC may seek to appoint a trustee to disburse our assets to customers. We will assist the appointed trustee by providing our books and records identifying customer accounts subject to SIPC regulation.

Additional Contacts
Securities Investor Protection Services Legent Clearing Corp.
805 15th Street, NW, Suite 800 Corporate Headquarters
Washington DC 20005-2207 9300 Underwood Avenue
202-371-8300 Omaha, NE 68114
www.sipc.org 1-800-811-3487

For more information – Should you have any questions concerning our business continuity plan, you may submit a written request for additional information to our Customer Service Department at located at 1900 L. street, NW, Suite 525, Washington, DC 20036 or contact us by phone at 202-466-6890.


CUSTOMER COMPLAINT NOTICE - SEC Rule 17a-3(a)(18)(ii) DISCLOSURE STATEMENT
Success Trade Securities, Inc. in accordance with Rule 17a-3(a)(18)(ii), is furnishing this statement to provide you with a name, telephone number and address, if you ever need to report or notify us of a possible complaint. If, for any reason, you feel you have a complaint, please contact our offices immediately, either by mail at Success Trade Securities, Inc. 1900 L. Street NW, Suite 525, Washington, DC 20036, Attention: Compliance Department or 202-466-6890 and ask to speak with our Chief Compliance Officer.

SUCCESS TRADE SECURITIES, INC. MARGIN DISCLOSURE STATEMENT
Success Trade Securities, Inc. is furnishing this document to you to provide some basic facts about purchasing securities on margin, and to alert you to the risks involved with trading securities in a margin account. Before trading stocks in a margin account, you should carefully review the margin agreement provided by your firm. Consult the firm regarding any questions or concerns you may have with your margin accounts.
When you purchase securities, you may pay for the securities in full or you may borrow part of the purchase price from your brokerage firm. If you choose to borrow funds from your firm, you will open a margin account with the firm. The securities purchased are the firm’s collateral for the loan to you. If the securities in your account decline in value, so does the value of the collateral supporting your loan, and, as a result, the firm can take action, such as issue a margin call and/or sell securities or other assets in any of your accounts held with the member, in order to maintain the required equity in the account.
It is important that you fully understand the risks involved in trading securities on margin. These risks include the following:
You can lose more funds than you deposit in the margin account
A decline in the value of securities that are purchased on margin may require you to provide additional funds to the firm that has made the loan to avoid the forced sale of those securities or other securities or assets in your account(s).
The firm can force the sale of securities or other assets in your account(s)
If the equity in your account falls below the maintenance margin requirements or the firm’s higher “house” requirements, the firm can sell the securities or other assets in any of your accounts held at the firm to cover the margin deficiency. You also will be responsible for any short fall in the account after such a sale.
The firm can sell your securities or other assets without contacting you
Some investors mistakenly believe that a firm must contact them for a margin call to be valid, and that the firm cannot liquidate securities or other assets in their accounts to meet the call unless the firm has contacted them first. This is not the case. Most firms will attempt to notify their customers of margin calls, but they are not required to do so. However, even if a firm has contacted a customer and provided a specific date by which the customer can meet a margin call, the firm can still take necessary steps to protect its financial interests, including immediately selling the securities without notice to the customer.
You are not entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call
Because the securities are collateral for the margin loan, the firm has the right to decide which security to sell in order to protect its interests.
The firm can increase its “house” maintenance margin requirements at any time and is not required to provide you advance written notice
These changes in firm policy often take effect immediately and may result in the issuance of a maintenance margin call. Your failure to satisfy the call may cause the member to liquidate or sell securities in your account(s).



You are not entitled to an extension of time on a margin call
While an extension of time to meet margin requirements may be available to customers under certain conditions, a customer does not have a right to the extension.
Should you have any additional questions concerning margin accounts, you may submit a written request for additional information to our Customer Service Department located at 1900 L. Street NW, Suite 525, Washington, DC 20036.

A margin account involves an extension of credit by Legent Clearing LLC (“Legent”) in connection with your securities. The Margin Agreement and consent to loan securities below enables Legent to pledge or lend securities carried for the margin account when money is loaned to you.

Informational Statement

Initial margin requirements established by the Board of Governors of the Federal Reserve specify the minimum amount of collateral you must provide when you buy securities on margin. This requirement is expressed as a percentage of the purchase price. It may change from time to time, and it may be a different percentage for different securities. For example, if the current margin requirement is 50%, and you purchase stocks on margin costing $15,000, only 50% of that amount ($7,500) is required to be paid. Under Regulation T, the required margin must be deposited into your account by settlement date. The balance due on the purchase will be paid by Legent, and your account will be debited accordingly. As part of the initial margin requirement, you must have a minimum of $2,000 equity every time you enter a new commitment in your margin account. The term “equity” means the excess market value of the securities in the account less any liabilities.

Maintenance margin requirements are established by Legent and by regulatory authorities for the purpose of maintaining a sound financial condition for Legent and the customer. If there is a decline in the market value or liquidity of securities that are the collateral for your Legent loan or in other circumstances where, in Legent’s judgment, adequate collateral does not exist, it may be necessary to issue a call (request) for additional margin collateral (cash or deposit of additional marginable securities). Ordinarily, a request for additional margin will be made when the equity in an account falls below 30% of the market value of all qualified securities in the account.

Additional margin will ordinarily be required if there is an undue concentration of one or more collateral securities, if your credit-worthiness significantly declines, or if the market value of low-priced stocks declines below $6 per share. Stocks priced from $3 to $6 require 50% maintenance, and stocks priced below $3 require 100% maintenance.

A margin call may be satisfied by the prompt deposit of cash or additional acceptable securities. While most call notices are delivered with a three day response time, Legent retains the right to require additional margin in any amount and in any time frame considered prudent. Legent’s determination is based on market conditions, concentration in one or more securities and other relevant factors. If you do not meet a margin call, Legent may liquidate securities in the account to the extent necessary to satisfy the call. Legent can sell your securities or other assets without contacting you. Legent or your broker may attempt to notify you of margin calls but is not required to do so. However, even if Legent or your broker has contacted you and provided a specific date by which you must meet a margin call, Legent or your broker can still take necessary steps to protect its financial interests, including immediately selling the securities without notice to you. You are not entitled to choose which securities or other assets in your account(s) are liquidated or sold by Legent to meet a margin call. Legent can increase its “house” maintenance margin requirements at any time and is not required to provide you advance written notice. You are not entitled to an extension of time on a margin call.

Interest Maintenance charged by Legent is based on the amount of money loaned to you. Interest is calculated in the manner described on the reverse side of this form and posted to your account statement as an addition to your debit balance.

The Interest Rate will vary from time to time without prior notice, in accordance with shifts in money rates. If Legent’s interest rate is to be increased for any other reason, you will be notified in writing at least 30 days prior to such change.

Short account securities will be “marked to the market” daily. The value of the short security will be considered as a debt to your account.

Securities in a margin account are registered in Legent’s name and are collateral for any margin loan. You still receive credit for all dividends or interest as long as all account requirements have been met. Your account will be charged for any dividends or interest on short positions.


Margin Agreement

Your Broker will be pleased to answer any questions You may have regarding Your margin account. This Margin Agreement is part of the Client Agreement (“Agreement”) between Legent and the undersigned (“You & Your”). In consideration of Legent’s acceptance of Your account under this Margin Agreement, You agree to the following supplemental terms and provisions:

Cleared Through Legent Clearing • 9300 Underwood Avenue, Suite 400• Omaha, Nebraska 68114-2685 • (401) 384-6101
www.legentclearing.com • Member FINRA, SIPC

Provision of Credit. Pursuant to Regulation T under the Securities Exchange Act of 1934, as amended, and the rules and regulations of the Securities Exchange Commission (“SEC”) and the Board of Governors of the Federal Reserve System, it is agreed that You may purchase, carry and trade certain securities on margin. You authorize Legent to obtain reports concerning Your credit-worthiness and business conduct. Upon Your request, Legent agrees to provide you a copy of said reports.

Maintenance of Margin. You agree to maintain such positions and margins as are required by Regulation T and all other applicable statutes, rules and regulations, or as Legent deems necessary, (which requirements may be more stringent than those required by law or exchange regulations). Legent may change or modify such requirements without prior notice to You. You shall promptly satisfy all margin and maintenance calls.

Short Sales. You shall clearly designate any order to sell “short” or “short exempt;” all other sales shall be deemed to be “long.”

Interest on Margin. On demand, You shall pay interest on credit extended by Legent under this Margin Agreement for the purpose of purchasing, carrying or trading securities. The rate of interest charged for the provision of credit shall be calculated on a 360-day year and actual days elapsed, and in accordance with the following schedule determined by Your Broker. For purposes of this provision, the following definitions apply:

“Average Debit Balance” means the average daily amount of money loaned by Legent to You during the calculation period.
“Broker Call Rate” means the daily rate of interest quoted by Legent’s primary bank from time to time as its “broker call rate.” On demand, You also shall pay any balance owing with respect to Your Accounts, including fees and any cost of collection (including attorney’s fees). All payments received in Your Account, including interest, dividends, premiums and principals, may be applied to the balance owed to Legent.

Securities Lending. For any securities held by Legent as property on margin under this Margin Agreement or as collateral for Your obligations under this Margin Agreement, You authorize Legent to lend such securities, either separately or with other securities, to Legent or to other entities. Until written revocation is received by Legent, this Margin Agreement constitutes Your continuing consent to effect securities lending transactions. Upon such written revocation, Legent shall have reasonable time to deliver such securities to You.

Hypothecation of Securities. For any amount due to Legent, Your authorize Legent to pledge and re-pledge, and hypothecate and re-hypothecate, any security held or carried by Legent in an account, without notice to You, either separately or with other securities of other bona fide Legent clients. You represent that You will not cause or allow any collateral in any of Your Accounts to become subject to any liens, security interests, mortgages or encumbrances. You further represent that You are not controlled by or in control of any issuer of any securities You have provided as collateral to Legent.

Disclosure Regarding Liquidation. You acknowledge that: (i) Legent is not required to provide notice to You of a margin deficiency, and (ii) Legent may, under certain circumstances, liquidate Property held in Your Account, without notice, to satisfy minimum maintenance or margin calls. You also acknowledge that failure of Legent to promptly enforce its margin requirements does not prevent Legent from subsequently enforcing such margin requirements with respect to Your Account.

Liquidation. It is understood and agreed that to satisfy Legent’s policy regarding margin maintenance requirements, Legent may, in its discretion, require You to provide additional collateral or liquidate any part of the Property in Your Account. Without limitation, any of the following circumstances may give rise to Legent’s exercise of this power: (i) Your failure to meet promptly any call for additional collateral; (ii) the filing of a petition in bankruptcy by or again You.; (iii) the appointment of a receiver is filed by or against You; (iv) a significant judgment is entered against You, and any levy on Your Account is made; (v) Your death; or (vi) the occurrence of any event which, in Legent Clearing’s judgment, operates to impair Client’s ability to perform its obligations under this Margin Agreement. In any such event, and without further notice, you authorize Legent (i) to sell any Property held in the Account; (ii) to buy any security or other property which may be short; (iii) to cancel any open order; (iv) to close any outstanding order; and 9v) otherwise to take such action as Legent, in its discretion, deems necessary to comply with applicable statutes, rules and regulations governing a margin account.


Cleared Through Legent Clearing • 9300 Underwood Avenue, Suite 400• Omaha, Nebraska 68114-2685 • (401) 384-6101
www.legentclearing.com • Member FINRA, SIPC


I hereby request that my broker (“My Broker”) and Legent (“Legent”) amend the account in the name(s) listed as account owner(s) on this MARGIN application and to that purpose endorse this account as a MARGIN ACCOUNT.

By signing below, I acknowledge that I have received, read, understand and agree to be bound by the terms & conditions are set forth in the MAIN Customer Agreement as currently in effect and as amended from time to time. I acknowledge that I have received, read, understand and agree to be bound by the terms & conditions as set forth in the Margin Account Agreement as currently in effect and as amended from time to time. I represent that I am of required legal age to enter into this Agreement. I understand and acknowledge that Legent does not provide investment, tax, legal, accounting, financial or other advice.

Please Note: Legent and/or My Broker will verify information provided on this form through a third-party vendor in accordance with the USA Patriot Act.

I UNDERSTAND THAT THIS ACCOUNT IS GOVERNED BY A PRE-DISPUTE ARBITRATION AGREEMENT, WHICH IS SET FORTH IN SECTION 28 OF PAGE 3 IN THE MAIN CUSTOMER AGREEMENT. I ACKNOWLEDGE THAT I HAVE RECEIVED AND READ THE PRE-DISPUTE ARBITRATION AGREEMENT.

CUSTOMER AGREEMENT

TO: My Broker and My Broker or Legent Clearing LLC ("Legent") (collectively "You” and/or “Your"): In consideration of You opening one or more accounts on my behalf, I represent and agree with respect to all accounts, whether upon margin or cash, as follows:

1. Representation as to Capacity. If an individual, I am of legal age under the laws of the State where I reside and authorized to enter into this agreement and, except as otherwise disclosed to You, I am not an employee of any exchange or the FINRA and I am not an employee or associated person of a member firm of any exchange or of a member firm of the FINRA. I will promptly notify You if I become so employed or associated. To the extent that I have not already disclosed to you the following, I will notify You in writing if I, my spouse or immediate family member living in my household become a director, 10% beneficial shareholder, or an affiliate of a publicly traded company. If an entity, I am duly formed, validly existing and in good standing in my state of organization, have full power and authority to enter and perform this agreement, and the persons signing the account application are fully authorized to act on my behalf. No person, except Myself (or any person named in a separate agreement), has any interest in the account opened pursuant to this Agreement. I acknowledge that unless Legent receives written objection from me, under SEC Rule 14B-1(c), Legent may provide my name, address, and security positions to requesting companies in which I hold securities.

2. Authorization. I appoint You as my agent for the purpose of carrying out my directions to You in accordance with the terms and conditions of my agreement with You for my account and risk with respect to the purchase or sale of securities. To carry out your duties, You are authorized to open or close brokerage accounts, place and withdraw orders and take such other steps as are reasonable to carry out my directions. Unless I give You discretion by written authorization, all transactions will be done only on my order or the order of my authorized delegate except as described in paragraph 8.

3. Effect of Reports and Statements. I agree that reports of execution of orders and statements of my account shall be conclusive if not objected to within ten (10) days after transmittal to me by mail or otherwise. Such objection may be oral or in writing, but any oral objection must be immediately confirmed in writing.

4. Important Information About Procedures for Opening a New Account. To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents and subsequently make copies for the records.

5. SIPC and Other Insurance Coverage. I understand that Legent is a member of the Securities Investor Protection Corporation (SIPC), which provides protection for accounts up to $500,000 (including $100,000 for claims of cash) per client as defined by SIPC rules. An explanatory brochure is available upon request or at www.sipc.org or via telephone at (202) 371-8300. I understand that such coverage does not include transactions or trading losses or declines in the value of securities.

6. Telephone Recordings. I understand and agree that any telephone conversation with You will or may be recorded for accuracy and I consent to such recording.

7. Oral Authorization. I agree that You shall be entitled to act upon any oral instructions given by Me so long as You reasonably believe such instruction was actually given by Me.

8. Payment of Indebtedness. In the event I become indebted to You in the course of operation of this account, I agree that I will repay such indebtedness upon demand. I agree that if after demand I fail to pay the indebtedness, You may close my account and liquidate any assets in my account at Your discretion in an amount sufficient to pay my indebtedness. As security for any and all liabilities arising in favor of You, I pledge to Legent a security interest in all property held by Legent in any account maintained by Legent for Me individually, jointly or in the name of another person or entity. Legent is hereby authorized to make whatever disposition of pledged property it may deem appropriate to realize the security afforded by this provision, and I will remain liable for any deficiency. I further agree that Legent shall be entitled to exercise the rights and remedies, with respect to the pledged property, generally afforded a secured party under the Uniform Commercial Code. The reasonable costs of collection of any debit balance and any unpaid deficiency in my accounts, including attorney’s fees incurred by You shall be reimbursed by Me to You.

9. Sell Orders; Deliveries and Settlements. Unless otherwise specifically designated, any order directing the sale of Property shall be deemed to be a “long” sale, and in connection with any such order, I represent that I am the owner of the property subject of such order and agree to deliver the property to You in negotiable form on or before the settlement date. In the event that I fail to deliver the property to You by the close of business on the settlement date, You are authorized, in your discretion and without notice to Me, to (i) delay settlement, (ii) purchase comparable property to cover My position, or (iii) cancel the transaction. You may also charge any loss (including Interest), commission and fees to My account.

10. Buy Orders; Settlements. When I have directed that property be purchased, I agree to provide sufficient collected funds to cover such purchase on or before the settlement date. In the event that I fail to provide sufficient funds, You may, at your option and without notice to Me, (i) charge a reasonable rate of interest, (ii) liquidate the property subject of the buy order, or (iii) sell other property owned by Me and held in any account. You may also charge any consequential loss to My account

11. Distributions. In the event that I sell a security prior to its ex-dividend/distribution date, and I receive the related cash/stock dividend or distribution in error, I direct You on my behalf to pay such dividend/distribution to the entitled purchaser of the securities I sold, and I guarantee to promptly reimburse You for, or deliver to You, said dividend or distribution.

12. Restrictions on Trading. I understand that You may, in Your discretion, prohibit or restrict the trading of securities, or the substitution of securities, in any of My accounts. I understand that You may execute all orders by Me on any exchange or market, unless I specifically instruct You to the contrary.

13. Governing and Applicable Law. This Agreement and all transactions made in my account shall be governed by the laws of the State of California, (regardless of the choice of law rules thereof) except to the extent governed by federal securities law, the Federal Arbitration Act, and to the constitution, rules, regulations, customs and usage of the exchanges or market (and its clearing house) where executed.

14. Ratification; Sub-Brokers and Agents; Extraordinary Events; Indemnification. You may employ sub-brokers or other agents in connection with the execution of any order or the consummation of any other transaction hereunder, and You shall be responsible only for reasonable care in their selection. I understand that You shall not be liable for loss caused directly or indirectly by government restrictions, exchange or market rulings, suspension of trading, war, strikes, natural disasters or any other conditions or causes beyond Your control or anticipation, including, but not limited to, delays in the transmission of orders due to breakdown or failure of transmission or communication facilities. I agree to indemnify and hold You harmless from any loss, damage or liability arising out of any transaction in which You act, directly or indirectly, as My agent, absent any willful or grossly negligent conduct by You.

15. Mutual Fund Transactions. In the event that I purchase or hold a mutual fund, I agree to read and understand the terms of its prospectus. I understand that certain mutual funds reserve the right to change their purchasing, switching or redemption procedures and/or suspend or postpone redemptions under certain market conditions. I further understand that any mutual fund order entered with You is placed by You on a best efforts basis as prescribed and recognized by the individual fund, and that You are not responsible for unexecuted orders due to the failure of any communication system. I agree to be fully responsible for the information contained within the mutual fund prospectus and to hold You harmless for any deficiencies contained therein. I authorize You to act as my agent in the purchase and redemption of fund shares.

16. Joint Account Authorization. In consideration of Legent’s carrying a joint account for the undersigned persons, we jointly and severally agree to be fully and completely responsible and liable for this account and to pay on demand any balance due. Each of us, or any person authorized to act on behalf of the account under a separate agreement, has full power and authority to make purchases and sales, withdraw funds and securities from, or to do anything else with reference to the account. You are authorized and directed to act upon instructions received from any of us. Suitability information provided on the front page reflects the combined interests of all joint owners. We understand that tax reporting information is processed using the social security number of the person first named in the registration. Each of us agrees to hold Legent and its employees and agents harmless from and indemnify them against any losses, causes of action, damages and expenses (including attorney’s fees) arising from or as the result of Legent, its employees or agents following the instructions of any of us. Legent in its sole discretion may at any time suspend all activity in the joint account pending instructions from a court of competent jurisdiction or require that instructions pertaining to the joint account or the property therein be in writing, signed by all of us. Legent may recover from the account or from any of us such costs as it may incur, including reasonable attorney’s fees, as the result of any dispute among us relating to or arising from the account. Upon any event that causes a change in the ownership of the joint account (divorce, death, assignment, etc.), all remaining accountholders or survivors shall immediately notify Legent in writing. Legent may take such actions in the account as Legent deems advisable to protect against any tax, liability, penalty or loss under any present or future laws or otherwise. The estate of the decedent or departing accountholder shall be liable together with each of the remaining or surviving accountholders, jointly and severally, to Legent for any net debit balance or loss in the account in any way resulting from any transactions initiated prior to notification to Legent or incurred in the liquidation of the account or the adjustment of the interests of the respective parties. Notwithstanding the governing law provisions of Section 17 (a) of this Agreement, the legal ownership of our accounts shall be governed by the internal laws of the state of residence.

17. Liens. I further agree, jointly and severally if this is a joint account, that all property including cash or securities You may at any time be holding or carrying for me shall be subject to a lien in your favor for the discharge of obligations of the account to You. Such lien is to be in addition to and not in substitution of the rights and remedies You otherwise would have.

18. Definitions of the Word “Property.” For all purposes of this agreement, the word “Property” means of all kinds, monies and all contracts, investments and options relating thereto, whether for present or future delivery, and all distributions, proceeds, products and accessions of all such property. This includes all such property held, maintained or carried by Legent in any manner for Me.

19. Effect of Attachment or Sequestration of Accounts. Legent shall not be liable for refusing to obey any orders given by or for Me with respect to any account(s) that has or have been subject to an attachment or sequestration in any legal proceeding against Me, and Legent shall be under no obligation to contest the validity of any such attachment or sequestration.

20. Event of Death. It is further agreed that in the event of my death or the death of one of the joint account holders, the representative of my estate or the survivor or survivors shall immediately give You written notice thereof, and You may, before or after receiving such notice, take such proceedings, require such papers and inheritance or estate tax waivers, retain such portion of and/or restrict transactions in the account as You may deem advisable to protect You against any tax, liability, penalty or loss under any present or future laws or otherwise. Notwithstanding the above, in the event of my death or the death of one of the joint Account Holders, all open orders shall be canceled, but You shall not be responsible for any action taken on such orders prior to the actual receipt of notice of death. Further, You may in your discretion close out any or all of my accounts without awaiting the appointment of a personal representative for my estate and without demand upon or notice to any such personal representative. The estate of any of the account holders who shall have died shall be liable and each survivor shall continue liable, jointly and severally, to You for any net debit balance or loss in said account in any way resulting from the completion of transactions initiated prior to the receipt by You of the written notice of the death of the decedent or incurred in the liquidation of the account or the adjustment of the interests of the respective parties. Such notice shall not affect Your rights under this agreement to take any action that You could have taken if I had not died.

21. Tax Reporting. The proceeds of sales transactions and dividends paid will be reported to the Internal Revenue Service in accordance with applicable law.

22. Information Accuracy. I (a) certify that the information contained in this agreement, the account application, and any other document that I furnish to You in connection with my account(s) is complete, true and correct, and acknowledge that knowingly giving false information for the purpose of inducing You to extend credit is a federal crime, (b) authorize You to contact any individual or firm noted herein or on the documents referred to in subsection (a) of this Section and any other normal sources of debit or credit information, (c) authorize anyone so contacted to furnish such information to You as You may request, and (d) agree that this agreement, the account application and any other document I furnish in connection with my account is Your property, as the case may be. I shall promptly advise you of any changes to the information in such agreements and documents. You may retain this agreement, the account application, and all other such documents and their respective records at Your sole discretion, whether or not credit is extended.

23. Credit information and investigation. I authorize You to obtain reports and provide information to others concerning My creditworthiness and business conduct. Upon My request, You agree to provide Me a copy of any report so obtained.

24. Equity Orders And Payment For Order Flow. Securities and Exchange Commission rules require all registered broker-dealers to disclose their policies regarding any “payment for order flow” arrangement in connection with the routing of customer orders. “Payment for order flow” includes, among other things, any monetary payment, service, property, or other benefit that results in remuneration, compensation, or consideration to a broker or dealer from any broker or dealer in return for directing orders. You transmit customer orders for execution to various exchanges or market centers based on a number of factors. These include: size of order, trading characteristics of the security, favorable execution prices (including the opportunity for price improvement) access to reliable market data, availability of efficient automated transaction processing and reduced execution costs through price concessions from the market centers. Certain of the market centers may execute orders at prices superior to the publicly quoted market in accordance with their rules or practices. While a customer may specify that an order be directed to a particular market center for execution, the order-routing policies, taking into consideration all of the factors listed above, are designed to result in favorable transaction processing for customers. The nature and source of any payments and /or credits received by You in connection with any specific transactions will be furnished upon written request.

25. Fees and Charges. I understand that there are charges for commissions and fees for executing buy and sell orders and for other services provided under this agreement. I agree to pay such commissions and fees at the then prevailing rate. I acknowledge that the prevailing rate of commissions and fees may change and that change may occur without notice. I agree to be bound by such changes. I specifically agree to pay a reasonable rate of interest on the principal amount of any debit balance carried with respect to the account. Interest due on the account is payable on demand. I also agree to pay such expenses incurred by You in connection with collection of any unpaid balance due on My accounts, including, but not limited to, attorney’s fees allowed by law.

26. Arbitration.
THE FOLLOWING ARBITRATION AGREEMENT SHOULD BE READ IN CONJUNCTION WITH THESE DISCLOSURES:
a. ALL PARTIES TO THIS AGREEMENT ARE GIVING UP THE RIGHT TO SUE EACH OTHER IN COURT, INCLUDING THE RIGHT TO A TRIAL BY JURY EXCEPT AS PROVIDED BY THE RULES OF THE ARBITRATION FORM IN WHICH A CLAIM IS FILED;
b. ARBITRATION AWARDS ARE GENERALLY FINAL AND BINDING; A PARTY’S ABILITY TO HAVE A COURT REVERSE OR MODIFY AN ARBITRATION AWARD IS VERY LIMITED.
c. THE ABILITY OF THE PARTIES TO OBTAIN DOCUMENTS, WITNESS STATEMENTS AND OTHER DISCOVERY IS GENERALLY MORE LIMITED IN ARBITRATION THAN IN COURT PROCEEDINGS;
d. THE ARBITRATORS DO NOT HAVE TO EXPLAIN THE REASON(S) FOR THEIR AWARD.
e. THE PANEL OF ARBITRATORS WILL TYPICALLY INCLUDE A MINORITY OF ARBITRATORS WHO WERE OR ARE AFFILIATED WITH THE SECURITIES INDUSTRY.
f. THE RULES OF SOME ARBITRATION FORUMS MAY IMPOSE TIME LIMITS FOR BRINGING A CLAIM IN ARBITRATION. IN SOME CASES, A CLAIM THAT IS INELIGIBLE FOR ARBITRATION MAY BE BROUGHT IN COURT.
g. THE RULES OF THE ARBITRATION FORUM IN WHICH THE CLAIM IS FILED, AND ANY AMENDMENTS THERETO, SHALL BE INCORPORATED INTO THIS AGREEMENT.

27. ARBITRATION AGREEMENT. ANY AND ALL CONTROVERSIES, DISPUTES OR CLAIMS BETWEEN THE UNDERSIGNED AND YOU, OR THE INTRODUCING BROKER, OR THE AGENTS, REPRESENTATIVES, EMPLOYEES, DIRECTORS, OFFICERS OR CONTROL PERSONS OF YOU OR THE INTRODUCING BROKER, ARISING OUT OF, IN CONNECTION WITH, FROM OR WITH RESPECT TO (a) ANY PROVISIONS OF OR THE VALIDITY OF THIS AGREEMENT OR ANY RELATED AGREEMENTS, (b) THE RELATIONSHIP OF THE PARTIES HERETO, OR (c) ANY CONTROVERSY ARISING OUT OF YOUR BUSINESS, THE INTRODUCING BROKER'S BUSINESS OR THE UNDERSIGNED'S ACCOUNTS, SHALL BE CONDUCTED PURSUANT TO THE CODE OF ARBITRATION PROCEDURE OF THE FINRA. ARBITRATION MUST BE COMMENCED BY SERVICE OF A WRITTEN DEMAND FOR ARBITRATION OR A WRITTEN NOTICE OF INTENTION TO ARBITRATE. THE DECISION AND AWARD OF THE ARBITRATOR (S) SHALL BE CONCLUSIVE AND BINDING UPON ALL PARTIES, AND ANY JUDGMENT UPON ANY AWARD RENDERED MAY BE ENTERED IN A COURT HAVING JURISDICTION THEREOF, AND NEITHER PARTY SHALL OPPOSE SUCH ENTRY.
The Internal Revenue Service does not require your consent to any provision of this document other than the certifications required to avoid backup withholding.