Terms of Usage | First Factor Financials

First Factor Financials Terms And Conditions Version[5] Revised_2024

TERMS AND CONDITIONS

IMPORTANT INTERNATIONAL REGULATORY COMPLIANCE INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT Prior to the opening of any new account, First Factor Financials will:

A– Document the identity, nature of business, income, source of funds, and investment objectives of each prospective customer.

B– Request your driver’s license number, passport or other identifying documents.

C– Review account activity for evidence of transactions that may be indicative of money laundering activities. Every officer, employee, and associated person of First Factor Financials is responsible for assisting in the firm’s efforts to uncover and report any activity that might constitute, or otherwise indicate or raise suspicions of, money laundering. To this end, First Factor Financials provides continuing education and training of all such persons.

D– Comply with all trade and economic sanctions imposed by the U.S. Office of Foreign Assets Control against targeted foreign countries and shall cooperate fully with government agencies, self-regulatory organizations and law enforcement officials. As provided by the Act, First Factor Financials may supply information about former, current, or prospective clients to such bodies.

APPOINTMENT OF BROKER

THE FOLLOWING AGREEMENT is made on (month) ____________(day) _____________, 20____ between First Factor Financials,

hereinafter “IB (Introducing Broker)”, and _____________________________________________________, hereinafter known as “CLIENT”.

1. APPOINTMENT OF INTRODUCING BROKER This Agreement constitutes the entire Agreement and understanding of the parties with respect to its subject matter and supersedes any and all prior oral communications and writings with respect thereto. CLIENT hereby appoints First Factor Financials.

hereinafter referred as “IB or Introducing Broker” as CLIENT’S broker for CLIENT’S purchases and sales of Energy, Precious Metals, and Foreign Currency or other derivatives (hereinafter “options”) by and through an appointed clearing firm of discretion at that given time, (hereinafter “First Factor Financials”), a firm organized under the laws of a country outside the United States, which is engaged in the business of options transactions. The IB will introduce the CLIENT’S account for the purchase and sale of options on a fully disclosed basis to the First Factor Financials pursuant to the terms and conditions which follow. The CLIENT agrees to execute appropriate documents or account forms which the First Factor Financials might require for the CLIENT to establish an account through them. The CLIENT shall deliver all notices and any other communications to the offices of the IB and/or the First Factor Financials. All communications from the IB and/or the First Factor Financials to the CLIENT may be sent to the CLIENT at the address indicated on the Account Information Form or to such other address as the CLIENT hereafter directs in writing.

2. DESCRIPTION OF PRODUCTS An option gives the Customer the right, but not the obligation, to sell (a “put”) or to buy (a “call”) a specified quantity of a particular product on or before a certain date (“expiration date”) for a particular price (“strike price”). The CLIENT purchases the option for a specified sum of money, which the First Factor Financials determines based upon prevailing rates in the international market or its own market which is known as the premium (in addition to fees, commissions, and other charges to be described hereinafter in the “OPTIONS FEE DISCLOSURE”). The premium is considered fully earned by the First Factor Financials at the time of payment and is therefore non-refundable. CLIENT may thereafter sell the option back to the First Factor Financials at any time prior to the expiration date for the price the First Factor Financials is then quoting, based upon prevailing rates. If on the date of expiration, the prevailing market price of the particular option does not exceed the strike price of the call option (or in the case of a put option, be less than the strike price), CLIENT will lose the entire premium, in addition to all fees and commissions. However, CLIENT will not be liable for any further fees, charges or commissions. The First Factor Financials will provide written specifications for options including the product, the amount of the option product, and the option expiration dates.

3. PROHIBITION OF DISCRETIONARY ORDERS the CLIENT is responsible for transmitting any and all orders for the purchase; sale or exercise of the CLIENT’S options either orally or in writing to the IB and/or the First Factor Financials. Under no circumstances will the IB and/or the First Factor Financials or any of its officers, managers, agents, employees, or representatives exercise any form of discretion or control over the

CLIENT’S account, nor will the IB and/or the First Factor Financials accept any order for the CLIENT’S account, other than by an authorized

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signatory whose name appears hereupon. The CLIENT acknowledges that the trading in the CLIENT’S account will be at the discretion and instruction of the CLIENT

ONLY. The CLIENT further acknowledges the CLIENT’S responsibility to monitor and control the trading in the CLIENT’S account. The CLIENT agrees and acknowledges that in entering into options transactions, the CLIENT will rely solely on his/her own judgment. The IB and/or the First Factor Financials, their officers, agents, employees, or representatives, shall not have any responsibility with respect to any advice or views given to the CLIENT by the IB and/or the First Factor Financials in relation to options trading. The IB and/or the First Factor Financials shall not have any responsibility with respect to advice or views not given to the CLIENT regarding options trading. The CLIENT acknowledges that market information and/or advice provided by the IB and/or the First Factor Financials may be based upon information which is incomplete and unverified and that IB and/or the First Factor Financials makes no representation, warranty, or guarantee as to the accuracy of any such information. Furthermore, the CLIENT acknowledges that any market information or advice furnished to the CLIENT by the IB and/or the First Factor Financials may not necessarily result in trading profits to the CLIENT’S account even if followed.

4. PERMISSION TO RECORD TELEPHONE CONVERSATIONS CLIENT hereby grants the IB permission to tape record the CLIENT’S placement of orders and such other of the CLIENT’S telephone conversations as the IB in its discretion determines to tape record; provided, however, that nothing herein shall require the IB to make or to maintain any tape OR MP3 recordings of the CLIENT’S orders or other telephone conversations.

5. FRACTIONAL PURCHASE OF OPTIONS IS PROHIBITED the IB will not accept orders for and the First Factor Financials will not sell any fractional or partial interest in any option. However, the IB will accept joint accounts established and indicated as such on the New Account Opening Agreement at the time of the opening of the account.

6. CONFIRMATION AND ACCOUNT STATEMENTS the First Factor Financials will give the CLIENT a username and password to log online to view the account statements and status if the portfolio. When an option has been purchased or sold, the First Factor Financials shall promptly confirm the terms of the transaction by completing and issuing to the CLIENT a confirmation of the trade within forty -eight (48) business hours of execution of the order, with a copy to the IB. This confirmation will be posted on the First Factor Financials website, where the CLIENT will log in with his username and password to view it. Unless the CLIENT notifies the IB and/or the First Factor Financials of any error or emission in such confirmation within three (3) business days of receipt of any such confirmation, the CLIENT shall be deemed to have ratified and accepted the contents of such document and shall not thereafter be entitled to dispute the contents of any such document and, in the absence of any manifest error, such document shall be conclusive evidence of the matters stated therein. Each option transaction will be governed by the conditions set forth in this Agreement and in the relevant confirmation. Each confirmation constitutes a supplement to and forms

7. DEPOSITS Prior to the purchase of any option, the CLIENT shall pay to the First Factor Financials in cleared funds sufficient amounts to cover the total costs of the transactions. Said funds will be held by the First Factor Financials in a customer segregated account. The CLIENT authorizes the First Factor Financials to pay from said account all sums due and owing the IB and the First Factor Financials including, but not limited to, option premiums, clearing fees, and commissions. Without limiting the CLIENT’S obligation to pay deposits, the IB shall have no obligation to ensure deposit requirements have been satisfied by the CLIENT before placing an order with the First Factor Financials on the CLIENT’S behalf and the CLIENT’S obligations with respect to an options contract will not be diminished by any failure by the IB or the First Factor Financials to require payments of outstanding deposits prior to entering the trade for the options contract. The CLIENT acknowledges that the First Factor Financials may deposit any CLIENT funds, together with funds from other clients, in banks or other financial institutions into accounts in the name of the First Factor Financials or its affiliates and that such funds may earn interest. The First Factor Financials shall not be liable to pay interest to the CLIENT with respect to any funds held by it on behalf of the CLIENT, irrespective of whether interest is earned.

Part of this Agreement. The First Factor Financials will provide a monthly statement of account to the CLIENT with a copy to the IB. All communications sent to the CLIENT by the IB and/or the First Factor Financials to the CLIENT’S address, whether by mail, telephone, email, telegraph, messenger or otherwise, shall be deemed given to the CLIENT personally whether or not actually received by the CLIENT, and the CLIENT hereby waives all claims resulting from failure to receive such communications. Such communication shall be deemed delivered (a) in the case of messenger, telegraph, overnight delivery service, email, or facsimile, when delivered to the CLIENT’S address, email address, or facsimile number given to the First Factor Financials; (b) in the case of telephone, when the communication occurs; or (c) in the case of mail, three (3) days after posting.

8. RESERVATION OF RIGHT OF ACTION BY IB AND/OR THE First Factor Financials IN THE EVENT OF A DISPUTE OR DEFAULT; APPLICABLE LAW, JURISDICTION AND VENUE If at any time, a dispute arises between the IB and/or the First Factor Financials and the

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CLIENT relating to the existence or terms of any contract, or if the CLIENT fails to make any required payment hereunder, dies, or becomes the subject of a bankruptcy or receivership, the IB and/or the First Factor Financials may, at any time, and in its absolute discretion without prior notice to, or any further authority from the CLIENT, take whatever action that it considers appropriate for the CLIENT’S account in relationship to the disputed contract. The IB and/or the First Factor Financials will notify the client, orally or in writing, as soon as is practical thereafter, of any action it has taken. However, any failure by the IB and/or the First Factor Financials to give such notice will not prejudice the validity of such action. The liability of the party found to be at fault with respect to any disputed contract shall not exceed the amount of loss suffered by the other party. The reasonable costs and expenses of collection of such indebtedness and obligation, including reasonable attorneys’ fees incurred by the IB and/or the First Factor Financials in connection with any such dispute, shall be payable to the IB and/or the First Factor Financials. Interest at the rate of two percent (2%) above the then prevailing prime rate at Lloyds Bank, PLC, or such other bank or financial institution designated by the IB and/or the First Factor Financials shall also be due. This Agreement, and the interpretation, operation, and construction thereof, shall be governed by the laws of the applicable country in which the First Factor Financials is incorporated. THE CLIENT IRREVOCABLY AGREES ANY JURISDICTION CHOSEN BY THE First Factor Financials SHALL HAVE EXCLUSIVE JURISDICTION OVER ANY DISPUTES WHICH MAY ARISE OUT OF OR IN CONNECTION WITH THIS AGREEMENT AND THAT ANY PROCEEDING (COLLECTIVELY “PROCEEDINGS”) ARISING OUT OF OR IN CONNECTION WITH THIS AGREEMENT SHALL BE BROUGHT ONLY BEFORE SAID COURTS. CLIENT irrevocably waives any objection which it may have now or hereafter to the commencement or the venue of any proceedings in any forum referred to herein and any claim that any such proceeding has been brought in an inconvenient forum. THE CLIENT further agrees, irrevocably, that a judgment in any proceeding brought in any such forum shall be conclusive and binding upon it. If the CLIENT commences any proceeding against the IB and/or the First Factor Financials, the IB and/or the First Factor Financials may, at any time prior to the conclusion of the proceeding, make an offer of settlement in writing to the CLIENT. If the CLIENT rejects such offer, and the amount awarded to the CLIENT is equal to or less than the amount offered by the IB and/or the First Factor Financials, the CLIENT shall be liable to the IB and/or the First Factor Financials for any legal fees and expenses incurred by the IB and/or the First Factor Financials after such offer is made. Further, if no such offer is made and the CLIENT receives no award, the CLIENT shall be liable to the IB and/or the First Factor Financials for the entire amount of legal fees and expenses incurred in defending against the proceeding brought by the CLIENT.

9. CUSTOMER ACKNOWLEDGMENT OF RISK OF LOSS All transactions effected for the CLIENT’S account, benefit and risk and all fluctuations in the market prices of the contracts purchased by the CLIENT are at the CLIENT’S risk and the CLIENT shall be solely liable for any losses under all circumstances. THE CLIENT REPRESENTS AND WARRANTS THAT THE CLIENT IS WILLING AND FINANCIALLY ABLE TO SUSTAIN SUCH LOSSES, AND THAT THE TRADING OF OPTIONS IS A SUITABLE INVESTMENT VEHICLE FOR THE CLIENT. THE CLIENT FURTHER REPRESENTS AND WARRANTS THAT THE CLIENT HAS READ AND UNDERSTOOD THE RISK DISCLOSURE STATEMENT ATTACHED HERETO AND THAT CLIENT FULLY UNDERSTANDS THE NATURE AND EXTENT OF THE RISKS DESCRIBED THEREIN. CLIENT HEREBY ACKNOWLEDGES THAT CLIENT HAS NOT RECEIVED OR RELIED UPON ANY STATEMENT, EITHER WRITTEN OR ORAL, TENDING TO MINIMIZE THE RISKS INHERENT IN TRADING OPTIONS OR OTHERWISE GUARANTEEING OR ASSURING THAT SUCH TRANSACTIONS WILL BE PROFITABLE IN DECIDING TO OPEN AN ACCOUNT WITH First Factor Financials AND TO ENGAGE IN OPTION TRANSACTIONS.

10. OTHER CLIENT ACKNOWLEDGMENTS THE CLIENT agrees and acknowledges that in entering into option contracts, THE CLIENT will rely solely on his/her own judgment. The IB and/or the First Factor Financials not responsible for the obligations of the persons or entities with whom the CLIENT’S transactions are affected, nor is the IB and/or the First Factor Financials responsible for delays in the communication facilities or other causes beyond the IB’S and/or the First Factor Financials reasonable control or anticipation. The CLIENT represents that the information on the Account Information Form is true and complete and that the representations in this Agreement and any applicable ancillary documents are accurate and that the IB and/or the First Factor Financials and their agents and assigns are entitled to rely on such information and representations for all purposes, unless the IB and/or the First Factor Financials receives notice in writing of any change. The CLIENT shall notify the IB and/or the First Factor Financials of any material change in such Account Information Form or other documents. If any provision of this Agreement shall be held invalid or unenforceable, the remainder of the Agreement shall nevertheless remain in full force and effect. If any provision is held invalid or unenforceable with respect to particular circumstances, that provision shall nevertheless remain in full force and effect in all other circumstances.

11. AMENDMENTS TO AGREEMENT The parties may make changes or amendments to this Agreement only by written documents, which must be agreed to and signed by both parties.

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12. SUCCESSION AND ASSIGNMENT This Agreement shall inure to the benefit of and be binding on both the IB and the First Factor Financials and the IB’S and the First Factor Financials respective successors and assigns, if CLIENT may not assign any of his/her rights and obligations under this Agreement without the First Factor Financials prior written consent.

13. NOTICES AND PAYMENTS Except as otherwise set out in this Agreement, any notice, demand, or other communication to be given shall be in writing and delivered to the address indicated in the Account information by CLIENT and the First Factor Financials. CLIENT shall make all payments to the First Factor Financials

CLIENT shall deliver all notices and any other communications to the offices of the First Factor Financials at the address indicated on the front of this document, or such other address as the First Factor Financials informs the CLIENT from time to time. All communications from the IB and/or the First Factor Financials to the CLIENT may be sent to CLIENT at the address indicated on the Account Application Form or to such other address as the CLIENT hereafter directs in writing.

14. GENERAL This Agreement constitutes the entire Agreement and understanding of the parties with respect to its subject matter and supersedes all oral communication and prior written communication. Where more than one person is named as the CLIENT, the obligations of the CLIENT under this Agreement shall bind each of them, jointly and severally. The CLIENT represents and warrants that all sums by way of deposit are and shall remain unencumbered property of the CLIENT.

15.DISCLAIMER THE UNDERSIGNED ACKNOWLEDGES READING AND UNDERSTANDING THE FOREGOING AND AGREES TO ACCEPT THE FOREGOING RISKS INHERENT IN TRADING OPTIONS.

__________________________________		____________________________________
Print Name		Client Signature
Date: /	/20	Date:	/	/20

__________________________________________

Authorized Representative – First Factor Financials – ACCEPTED AND APPROVED

Date: / /20

CLIENT ACKNOWLEDGEMENT OF RISK FACTORS

By signing this Agreement, the CLIENT hereby acknowledges the CLIENT’S understanding and knowledge that transactions in Energy, Precious Metals, Foreign Currencies and other derivatives (hereinafter “options”) are subject to highly material risk factors AND THAT THE CLIENT KNOWINGLY AND WILLINGLY ASSUMES ALL SUCH RISKS. Risks include, but are not limited to:

A. Markets can be volatile and unpredictable Commodity prices may fluctuate in accordance with unexpected political or economic developments in foreign countries which cannot be predicted or reasonably foreseen.

B. Energy, Precious Metals, Foreign Currency, or other Options Fluctuations Trading in these markets is subject to small and large fluctuations in prices. Many factors influence the trading in the markets including, but not limited to, economic and political events, government intervention or the lack thereof, the actions of speculators and the weather.

C. Past Performance is not an Indicative of Future Profitability. The CLIENT’S risk of loss when speculating in options is great regardless of how current prices compare to past market prices of those options.

D. Conflict of Interest. The IB may act as counterparty to transactions for the CLIENT’S account and sell options to the CLIENT from its own account or may buy options from the customer for its own account and there is an inherent conflict of interest in such case. The counterparty will have a conflict of interest in giving the highest price it can from any such sale and the lowest possible price for any such purchase. As these (derivative) options are not traded on any exchange, all sales and purchases for the CLIENT’S account will be executed by the IB at whatever price it is then quoting. The IB

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will attempt to secure fair pricing to its clients by the First Factor Financials. However, no guarantees can be made as to the ultimate equitability of the prices obtained from the First Factor Financials. Furthermore, from time to time there may be rebates and/or incentives paid by the First Factor Financials to the IB based on trading volume and/or premiums raised. An inherent conflict of interest would exist in this instance because the IB may receive revenue in addition to its commissions based upon higher trading volume of its clients with the First Factor Financials. This would not violate the fiduciary responsibility of the IB to its clients.

E. Risk of Insolvency. There is no clearing firm which assures performance for open positions, nor is CLIENT’S account insured. The CLIENT may face a risk of loss of unrealized gains and all the CLIENT funds due to the risk of failure, the inability or refusal to perform with respect to options, or the bankruptcy or liquidation of the counterparty or carrying firm.

F. Suitability. Speculation in options is not suitable for all investors. Some studies have shown that more than 80% of small investors who trade in options ultimately lose money. Only investors who appreciate and understand the risks involved and the nature of options trading should invest. Any additional funds added to your account should be discretionary capital set aside strictly for speculative purposes. All funds used for this type of speculation should only be disposable income so that a loss of part or all of this money will not affect your lifestyle.

G. Limited Diversification. The CLIENT’S account will take positions in option products. Accordingly, an account invested solely in option transactions will not achieve the diversification that might be expected in a balanced portfolio.

H. Substantial Fees and Costs. The trading of option contracts may involve frequent purchases and sales of such contracts, resulting in significant fees and commissions. In order to achieve a net profit from any option transaction in the CLIENT’S account, the price received by the client upon the sale of the option will have to exceed the client’s purchase price and/or premium plus commission plus any other fees and costs. There is no guarantee that any trading will result in a profit to the customer and the customer may in fact incur a loss of all or part of his/her investment.

I. Liquidity Risk. Option contracts are executed with various non-U.S. firms. Although the market is generally a liquid market, there is no limit on daily price movements in options contracts; therefore, options trading is not subject to position limits. Firms are not required to continue to make markets in options. Certain firms may refuse to quote prices for option contracts or may quote prices with an unusually wide buy-sell spread. Therefore, under these or other circumstances, it may be difficult or not possible to liquidate an existing position at the desired price, which could result in a loss of unrealized profit or even an outright loss on the position.

J. Options Trading. An option is an extremely complicated trading vehicle which carries substantial risks not inherent in the trading of the underlying asset. For example, options lose value with the passage of time (time-decay); they also are generally not fully responsive to the price movement of the underlying asset (delta). Option profitability is substantially dependent on the exercise (strike) price of the option. An option with a strike price which is deep out-of-the-money has less probability of becoming profitable. You should familiarize yourself with the specific and systematic risks, terminology, and workings of long and short, call and put options before investing any money. Placing stop-loss orders, which are intended to limit the amount of loss, may not be effective because market conditions can make it impossible to execute such orders. Strategies utilizing spreads and/or straddles may have as much risk as simple long and short positions. It may be difficult or impossible to execute orders and offset or liquidate open market positions due to market liquidity and/or operations.

K. Lack of Regulation. At the current time, no banking authority regulates options or the international market. In addition, certain trades may occur in foreign markets in which there may be little or no governmental regulation of the trading. Neither the IB nor the First Factor Financials are registered as a broker-dealer with any government agency nor have the options been registered with any governmental agency. The IB and the First Factor Financials are of a view that ultimate CLIENT profitability depends on fluctuations in world prices and not on the efforts of the IB and/or the First Factor Financials, and that each CLIENT individually owns the commodity option thereby removing these vehicles from the definition of securities. The CLIENTS are subject to the risks that the IB’S and the First Factor Financials business is not regulated by any regulatory agency and, thus, do not enjoy those protections which are inherent in a regulated business. Moreover, the IB and/or the First Factor Financials could become the subject of adverse regulatory actions or determinations by one or more governmental agencies or courts. At any given time, officers, managers, or agents, of the companies may have had previous regulatory sanctions by governmental agencies. Neither the IB, the First Factor Financials, or its officers, managers, nor agents are licensed with any governmental agency. Finally, there is a risk that a government agency could assume regulatory authority over the IB, the First Factor Financials or the options market, and that the IB and/or the First Factor Financials could not comply with the resulting regulatory scheme and would have to cease doing busines

THE FOREGOING RISK FACTORS ARE NOT ALL INCLUSIVE. CLIENTS ARE URGED TO STUDY THE WORLD OPTION MARKET BEFORE DECIDING TO SPECULATE IN THESE MARKETS.

I (WE) HAVE CAREFULLY READ, UNDERSTOOD AND CONSIDERED THE RISKS ABOVE AND HAVE DETERMINED TO KNOWINGLY AND WILLINGLY ASSUME SAID RISKS.

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________________________________________			_____________________________________
Print Name			Client Signature
Date:	/	/20	Date:	/	/20

COMMISSIONS AND FEES DISCLOSURE

The following commissions and fees will be charged to the CLIENT’S account in connection with the BUY and SALE of all option contracts:

A 10% commission is charged by the “IB” per option contract sold, only when capital gains are 30% or more.

Any dispute o or questions regarding these costs and charges must be brought to the attention of the IB and/or the First Factor Financials in writing within two (2) business days of delivery to the CLIENT of any account statement including or referring to any such costs and charges. The CLIENT’S failure to so notify the IB and/or the First Factor Financials shall be deemed conclusive ratification of such charges and costs.

BY SIGNING BELOW THE CLIENT ACKNOWLEDGES AND AGREES TO THE ABOVE-MENTIONED COMMISSIONS AND FEES.

_____________________________________

____________________________________

Print Name

Client Signature

Date:

/20

Date:

/20

CLIENT REQUEST FOR ELECTRONIC TRANSMISSION OF ACCOUNT STATEMENTS

The undersigned ______________________________ (“CLIENT”) requests that First Factor Financials (hereinafter known as “IB”) provides

confirmation statements of activity solely by electronic transmission through the IB’s web site or to the E-mail address indicated below upon the CLIENT’s request. Please do not mail hard copies of such statements.

The CLIENT warrants and represents that the below-referenced E-mail will promptly print out the relevant CLIENT statements in the form that the First Factor Financials transmits. The CLIENT understands that there is a risk of failure of any electronic transmission and will not hold the First Factor Financials or the IB liable directly or indirectly for such failure. If the CLIENT fails to receive any confirmation statement that reflects activity of which the CLIENT is aware in the account, the CLIENT will contact a First Factor Financials client service representative by 10:00a.m. (CTS), on the business day following the day of any such activity.

This consent shall be effective until revoked by the CLIENT in writing, signed by the undersigned and e-mailed to the following electronic address contact@unitedroyalinvestments.com. In addition, the CLIENT acknowledges that for its protection and the protection of the First Factor Financials and the IB as introducing broker, any request to change the e-mail address listed below must be in writing and must bear signature of the undersigned. In the event such a request is received from a legal entity, such as a corporation, LLC or partnership, the request must be accompanied by appropriate documentation establishing that the person signing the request possesses the requisite authority to bind the entity.

The IB will provide the CLIENT with following in its website: • A segregated account number for your account.

• A username and a password to log into the First Factor Financials website: to view the status of the CLIENT’s portfolio 24 hours a day.

• Account statements online 24 to 48 business hours after a purchase or a sell has been made.

• Market news, as well as market price quotes and charts.

BY SIGNING BELOW, THE CLIENT REPRESENTS THAT THE DELIVERY AND EXECUTION OF THIS CONSENT HAS BEEN DULY AUTHORIZED.

___________________________________	_____________________________________	__________________________
Print Name	Client Signature	Date:

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PRIVACY POLICY

Please Read This Privacy Policy Carefully First Factor Financials believes in respecting the privacy and security of your personal information. We do not disclose any nonpublic information about our clients or former clients to anyone, except as permitted by law. Collection of Information We collect nonpublic personal information about you from the following sources:

• Information we receive from you on application for other forms;

• Information about your transactions with us, our affiliates or others; and

• Information we receive from a consumer reporting agency

Information Sharing with Non-affiliated Third Parties as Permitted by Law We are permitted by law to share all the information we collect, as described above, with (1) companies that perform marketing services on our behalf and (2) other third parties that assist us with preparing and processing orders and statements.

Confidentiality and Security. We resist access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards that are designed to protect your nonpublic information.

NOTICE TO CLIENTS To help the government fight the funding of terrorism and money laundering activities, and in compliance with the U.S. Patriot Act, 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 the Compliance Department will verify information you provided in the New Account Opening Agreement such as but not limited to your name, address, date of birth and other relevant information that will allow us to identify you. Failure to comply with international regulatory compliance procedures can result in the no authorization for the CLIENT’s account to be opened.

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