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Business Continuity Plan Statement for Ram Financial LLC

At Ram Financial LLC, we are committed to ensuring the highest level of service and reliability for our clients. As an introducing brokerage, we understand the critical importance of uninterrupted operations, particularly in executing and clearing trades through our clearing partner, Apex.

In alignment with our commitment to operational resilience, we have established a comprehensive Business Continuity Plan (BCP) designed to mitigate risks associated with unexpected disruptions, whether they stem from natural disasters, technology failures, or other unforeseen events. Our BCP encompasses procedures to maintain or promptly resume essential operations to ensure that our clients' trading activities continue seamlessly.

Key features of our BCP include:

• Data Protection: Secure backup systems and redundancy measures are in place to protect client data and ensure the integrity of our trading systems.

• Communication Protocols: In the event of a disruption, we will promptly communicate with clients, employees, and other key stakeholders through various channels, including email, phone, and our website (Aries.com).

• Geographic Dispersal: To enhance recovery capabilities, critical systems and infrastructure are hosted in geographically diverse locations.

• Third-Party Coordination: We maintain regular contact with Apex and other critical third-party vendors to ensure a coordinated response in times of disruption.

• Regular Testing and Review: The BCP is tested and reviewed periodically to incorporate lessons learned, regulatory updates, and evolving business needs.

Please note that while our BCP is robust, it is not infallible, and certain situations may exceed its scope. In such instances, we will make every effort to address the situation and return to normal operations as swiftly as possible.

For further information regarding our Business Continuity Plan, please contact us at [email protected] or visit us at our office located at 1420 Washington Blvd, Detroit, MI, 48226.

Stocks & Options

Regulatory & Clearing Fees

Index Options

For simple VIX, a priority surcharge is assessed on contracts executed electronically that are Maker and not Market Turner by $0.20 more.

There is no exchange proprietary index options fee for Nanos, SPIKEs, and XND.

Deposit & Withdrawal Fees

Tiered Margin Interest Rates

Aries provides up to four times day-trade buying power and two times overnight buying power with a margin account. You must have at least $2,000 to qualify.

Interest on margin trading is calculated on a daily basis and paid on a monthly basis. The margin rate is variable and is determined by the size of the margin loan.

The margin rate is set at our discretion and is subject to change without notice.

An account which places 390 option orders per day on average for a calendar month is designated as a “professional customer.” This rule, adopted by the options exchanges, is designed to identify professional customers who compete with market makers that otherwise should not receive priority over retail clients’ orders. Accounts marked as “professional customers” require special order handling procedures, which currently Ram Financial does not support. Therefore, if your account is classified as a “professional customer” during any calendar month in a given quarter, you will be set to liquidate only for the next quarterly period.

If an account ever exceeds 390 option orders for a given a day a notification will be sent. Clients are advised not to exceed the 390 option orders threshold for a given calendar month or they will be designated as a professional trader.

An option order is counted as one order if it is submitted as one of the following order types:

-Single leg order

-Complex order of less than 8 legs

-Cancel and replace

-Pegged Orders

Please pay careful attention to the number of orders placed each day so the account does not exceed 390 option orders per day on average for a calendar month.

Aries Financial, Inc. Terms and Conditions

Welcome to Aries Financial, Inc. (“Aries,” “we,” “us,” or “our”). These Terms and Conditions (“Terms”) govern your use of our services, website, mobile applications, and other digital platforms (collectively, the “Services”). By accessing or using our Services, you agree to these Terms, including any supplemental agreements that may apply to specific services.

1. General Terms

These Terms apply to all users of the Services. Aries operates as an introducing broker, and Apex Clearing Corporation (“Apex”) serves as the clearing firm for your accounts. By using the Services, you agree to comply with these Terms and any additional agreements applicable to your account, including the Customer Agreement with Apex.

2. Account Setup and Maintenance

2.1 Account Registration

You must provide accurate and complete information when creating an account. You agree to promptly update any changes to your registration information to maintain accuracy.

2.2 User Eligibility

To open an account, you must be at least 18 years old and legally capable of entering into agreements. You also agree to abide by all applicable laws and regulations governing securities trading.

2.3 Electronic Communication

By providing your email address and phone number, you consent to receiving electronic communications from Aries. You are responsible for keeping your contact information up to date.

3. Relationship with Apex Clearing Corporation

Aries acts as the introducing broker and Apex acts as the clearing firm. While Aries facilitates the execution of your trades, Apex performs clearing and back-office services. You understand that Apex holds and maintains your account and processes trades submitted by Aries.

4. Trading and Market Data

4.1 Self-Directed Accounts

Aries offers self-directed trading services and does not provide investment advice or recommendations. You are responsible for all trading decisions and agree that Aries is not liable for any trading losses.

4.2 Market Data

Market data provided through our Services is sourced from third-party providers. While we strive to provide accurate and timely information, Aries and its providers do not guarantee the accuracy or completeness of such data. You acknowledge that market data is provided “as is” and “as available.”

4.3 Order Execution

Aries facilitates electronic trading through various channels. However, we cannot guarantee order execution due to factors such as market conditions, network disruptions, or regulatory restrictions. You agree that Aries and Apex are not responsible for missed or delayed executions.

5. Risks and Disclaimers

5.1 Investment Risk

Investing in securities involves risk, including the loss of principal. You agree that Aries is not liable for any losses or damages resulting from investment decisions made using our Services.

5.2 No Warranty

The Services and market data are provided on an "as is" and "as available" basis. Aries disclaims all warranties, whether express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, or non-infringement.

5.3 Liability Limitation

Aries and Apex shall not be liable for any indirect, incidental, or consequential damages, including loss of profits, data, or use, arising from your use of the Services.

6. Account Management

6.1 Margin Accounts

If you choose to open a margin account, you agree to the terms of the Margin Agreement with Apex. You understand that trading on margin involves risks, including the risk of losing more than your initial investment.

6.2 Monitoring Account Activity

You are responsible for monitoring all account activity, including trade confirmations, account balances, and statements. Aries may, at its discretion, liquidate or limit your positions to manage risk.

6.3 Termination of Accounts

Aries and/or Apex may terminate or restrict your account at any time, with or without notice, if deemed necessary to protect against risk or potential breaches of these Terms.

7. Fees and Charges

You agree to pay all applicable fees and charges related to your account, including commissions, clearing fees, and other costs outlined in the Fee Schedule. Aries reserves the right to modify its fees with notice provided through its website or other communication methods.

8. Privacy and Data Security

Aries is committed to protecting your privacy. Our collection and use of personal information are governed by the Aries Privacy Policy. You agree to take reasonable steps to protect your account information, including your password, and to notify us immediately if you suspect any unauthorized use.

9. Indemnification

You agree to indemnify and hold harmless Aries, its officers, directors, employees, and agents from any claims, losses, damages, liabilities, or expenses arising from your use of the Services, breach of these Terms, or violation of any applicable laws or regulations.

10. Governing Law and Dispute Resolution

These Terms are governed by the laws of the state of Michigan. Any disputes arising under these Terms will be resolved through binding arbitration conducted in accordance with the rules of the American Arbitration Association.

11. Changes to Terms

Aries reserves the right to modify these Terms at any time. Changes will be posted on the Aries website and become effective immediately upon posting. Your continued use of the Services constitutes acceptance of the modified Terms.

12. Contact Information

If you have any questions about these Terms, please contact us at:

Aries Financial, Inc. 1420 Washington Blvd, Detroit, MI, 48226 [email protected]

The Option Paper Trading Simulator Disclaimer

The Option Paper Trading Simulator is an educational tool meant to familiarize investors with Options Trading without having to risk their own capital. The tool is limited in its features and does not replicate every real-life scenario. Investors who use the Option Paper Trading Simulator should be aware of these nuances before employing similar option strategies in real life.

1) No Order Restriction on Liquidity. The simulator does not restrict orders that exceed the available size of inventory in the market. Therefore, the simulator will allow users to be able to acquire and dispose of positions of greater quantity without any price impact than you could in real life. For example, if a user wishes to purchase 5,000 contracts of ABC $100 JAN 23, 2025 while the market is only offering 100 contracts for sale, all 5,000 can be filled with no impact on price. In real life, the market would only be able to fill 100 contracts at the going price, and once filled subsequently would result in a higher offering price for a given order size.

2) Order Handling. The simulator will execute Market Orders at the bid-ask price for sell and buy orders, respectively. Real life orders may not be filled as quickly at favorable prices due to large volume of orders and fast-moving markets. The order types available are Limit and Market Orders. In the simulator option positions can be opened until the close on expiration date, whereas in real life Ram Financial, LLC restricts opening orders on expiration date up until a certain time before market close.

3) Corporate Actions. Options that undergo corporate actions will be automatically closed in the simulator after the market closes. In real life, there are a myriad of adjustments an option contract can experience because of a corporate action.

4) Market Data Delay. Unless you are subscribed to OPRA real-time market data, the market data displayed is based on a 15-minute delay.

5) Legging Out Limitations. Certain limitations apply to legging out of strategies. The short call position in a buy-write option strategy cannot be closed independently of the underlying long stock position. Both positions of the buy-write must be closed at the same time.

6) Option Assignments. Option assignments will not occur in the Option Paper Trading Simulator. Therefore, the entire life-cycle of an option’s mechanics and various associated risks cannot be fully realized in the simulator. These include dividend risk, pin risk, and early assignment risks.

This disclaimer attempts to address the major differences between the simulator and real- life option trading. It is, however, not all encompassing of all the possible differences between the two. Ram Financial, LLC is not liable for any adverse outcomes in real life option trading that are not able to be replicated in, or derived from, the simulator. The results of the Options Paper Trading Simulator are not intended to be relied upon as a track record or validation of any trading strategies.

Option Spread Risk Disclosure

Before using our spread order entry screen, options spread traders must understand the additional risks associated with this type of trading.

While it is generally accepted that spread trading may reduce the risk of loss of trading of the outright purchase of a standardized option contract, an investor/trader MUST understand that the risk reduction can lead to other risks.

1. Early exercise and assignment can create risk and loss. Spreads are subject to early exercise or assignment that can remove the very protection that the investor/trader sought. This can lead to margin calls and greater losses than anticipated when the trade was entered. Ram Financial reserves the right to close an option position that may be subject to exercise or assignment (in- or out-of-the money), depending upon account equity, buying power, and market conditions.

2. Execution of spread orders is "not held" and discretionary. Spreads are not standardized contracts as are exchanged traded put and calls. Spreads are the combination of standardized put and call contracts. There is NO spread market in securities that are subject such benchmarks such as "time and sales" or "NBBO" (National Best Bid/Offer) and therefore the "market" cannot be "held" to a price.

3. Spreads are executed differently than "legged" orders. Spreads are used by strategists as examples of risk protection, profit enhancement and as a basis for results and return on investments. However, these strategies assume that the trade can actually be executed as a spread when market forces may and can make the actual execution impossible. Spreads are a bona-fide trades and not "legged" or "paired" of individual separate trades. For example: options prices on cross-markets are misleading for the spread trader. An option may be offered on one exchange and bid on another exchange that can lead the trader to believe that their spread trade should be filled, when, in fact, the bids and offers must be on the SAME exchange. As all bona-fide spreads are routed and executed on "one" exchange.

4. Spreads are entered on a single exchange and are acted upon by a market maker. Spreads are executed at the discretion of a market maker and when cancelled or filled require that the market maker take manual action and require manual reporting at times. Delays for reporting of fills and cancels may create additional risks in fast or changing markets. Spreads entered through Ram Financial’s spread order entry screen are ALWAYS entered as spreads and as such are subject to the market risk and conditions as explained above.

Can be found here: https://apexfintechsolutions.com/legal/privacy-and-legal/

How does it work? Upon approval of your brokerage application with Ram Financial LLC, Ram will credit your account with one share of stock for free. You can sell or retain the stock after it has been held for two trading days.

How does Ram determine which stock I receive? The free stock you get is randomly selected from a pool of settled shares in our inventory. Since the selection process is random, your stock may differ from what others receive. The stock's value can range between $2.00 and $200, fluctuating with market conditions. We primarily source shares from the most popular companies with the highest market capitalization available on Aries.

Can I open another Ram account to claim more free stock? No, although you can have multiple Aries accounts, only one is eligible to participate in this promotion.

What if it didn’t work for me? If you registered through the free stock promotion link but did not receive your stock, reach out to us at [email protected].

Terms & Conditions

This offer is available only to select individuals who haven't completed their Ram application, those with approved accounts that have no activity, and individuals without an Ram account, provided they open a retail brokerage account within 30 days of receiving the offer. To qualify, users must sign up through the promotional page or advertisement. The stock bonus will typically be credited to the designated account within about one week.

Ram reserves the right to modify or terminate the offer at any time without prior notice. Each account is eligible for only one stock bonus, with a limit of one enrolled account per customer. The total value of stock bonuses combined with all other offers received in the last 12 months cannot exceed $5,000 per household per year. The offer is non-transferable, non-saleable, and cannot be combined with certain other promotions. This offer is available exclusively to U.S. residents. Employees, contractors, affiliates of Aries, members of their household, and employees of any securities regulatory body or exchange are not eligible for this promotion. Aries retains discretion to decline any request to participate in the offer. Additional restrictions may apply.

The stock bonus consists of one share, chosen randomly , once all criteria for the bonus are met. Shares in the inventory are sourced from companies with the highest market capitalization, in different price ranges between approximately $2 and $200. The selected stocks are typically from companies widely held by Aries users. Based on stock prices at the time of acquisition, there is approximately an 88.14% chance of receiving a stock valued between $2.50 and $10, a 6.54% chance of receiving one valued between $10 and $50, and a 1.51% chance of receiving a stock valued between $50 and $200. Odds displayed on the Ram platform reflect the likelihood of receiving stocks from specific companies at the time of viewing but may differ when the stock bonus is awarded.

Receiving stock through this program or mentioning a specific stock in related communications does not constitute a recommendation to buy, sell, or hold the stock. Ram does not offer investment advice or endorsements for any securities or transactions.

Please consult a tax advisor regarding the tax implications of receiving a stock bonus and how it should be reported. For taxable accounts, the value of any Ram offers you receive may be reported as "Other Income" on a Form 1099-MISC, as required by law. Ram is not responsible for any tax obligations resulting from the receipt of a stock bonus.

Note: Customer must agree to allow Ram Financial LLC to purchase shares on behalf of the customer and to place such shares into the customers account pursuant to this offer prior to participation.

It is important to remember if you are selling options (covered or uncovered), the risk of being assigned is always present. The likelihood of your option being assigned early increases when the underlying security announces an ex-dividend date.

When a dividend for a stock is declared an investor must own the stock before the ex-dividend date to receive the payment. Dividend risk may occur in this situation because short calls are exposed to early assignment. Investors who are looking to receive the dividend payment may exercise a long call option early so that they are eligible to collect the dividend payment. This can occur whether the contract is in the money or not. The investor who wrote (sold) the call option would be responsible to deliver the shares if the option is exercised against them which may put them in a short position. If a short position is held through the ex-dividend date, then the investor would be responsible for paying the dividend on the payable date. This risk exposure can be avoided if an investor closes out the short option the day before the ex-date to prevent them from being assigned early.

Here are a few helpful tips that may help avoid Dividend Risk Exposure when trading options.

• Do your research ahead of time. Know if the stock or ETF pays a dividend, and if it does what date will it start trading ex-dividend?

• Avoid selling options on dividend-paying stocks or ETFs when your trade includes ex-dividend

• Think about investing in European-style options: American-style options can be assigned at any time before the option expires, while European-style options can only be exercised on the day of expiration.

Example:

An investor is Short 1 ABC March 5th $130 Call and Long 1 ABC March 5th $135 Call.

- The Ex-dividend date is 3/3/21

- The Dividend Payment $0.50

In the scenario above the investor is at risk of being assigned early on 3/2/21 which is the day before the ex-date. If the contract is exercised, in addition to the strategy being broken by early assignment the investor could be short 100 shares of ABC on 3/3/21 (ex-dividend date) which means the trader would be responsible to pay the dividend on the payable date. The cost for the trader in this situation would be $50 (100 shares x $0.50). If the trader wanted to try and avoid this situation from occurring the trader could buy back the ABC $130 Call before the end of the trading day on 3/2/21 to flatten out his position and avoid being assigned early, or they could close out the entire strategy.

*Not all dividends are announced with fore-warning – some securities may announce the dividend on the day of the ex-date.

Option trading entails significant risk and is not appropriate for all investors. Option investors can rapidly lose the value of their investment in a short period of time and incur permanent loss by expiration date. Additionally, investors can lose more than their initial investment. You need to complete an options trading application and get approval on eligible accounts. Please read the Characteristics and Risks of Standardized Optionsand Option Spread Risk Disclosure before trading options.

· Stop prices are not guaranteed execution prices. A “stop order” becomes a “market order” when the “stop price” is reached and firms are required to execute a market order fully and promptly at the current market price. Therefore, the price at which a stop order ultimately is executed may be very different from the investor’s “stop price.” Accordingly, while a customer may receive a prompt execution of a stop order that becomes a market order, during volatile market conditions, the execution may be at a significantly different price from the stop price if the market is moving rapidly.

· Stop orders may be triggered by a short-lived, dramatic price change. Customers should be informed that, during periods of volatile market conditions, the price of a stock can move significantly in a short period of time and trigger an execution of a stop order (and the stock may later resume trading at its prior price level). Investors should understand that if their stop order is triggered under these circumstances, they may sell at an undesirable price even though the price of the stock may stabilize during the same trading day.

· Sell stop orders may exacerbate price declines during times of extreme volatility. The activation of sell stop orders may add downward price pressure on a security. If triggered during a precipitous price decline, a sell stop order also is more likely to result in an execution well below the stop price.

· Placing a “limit price” on a stop order may help manage some of these risks. A stop order with a “limit price” (a “stop limit” order) becomes a “limit order” when the stock reaches the “stop price.” A “limit order” is an order to buy or sell a security for an amount no worse than a specific price (i.e., the “limit price”). By using a stop limit order instead of a regular stop order, a customer will receive additional certainty with respect to the price the customer receives for the stock. However, investors also should be aware that, because brokers cannot sell for a price that is lower (or buy for a price that is higher) than the limit price selected, there is the possibility that the order will not be executed at all. Customers should be encouraged to use limit orders in cases where they prioritize achieving a desired target price more than getting an immediate execution irrespective of price.

· Advanced Orders may have increased risks due to their reliance on trigger processing, market data, and other internal and external system factors. Due to market conditions and/or timing, advanced orders you enter, or those that are triggered just prior to or near market close may not execute. It is possible that such order(s) will not be executed during that session, or at all if good for the Day only. While a verification process is in place to avoid false triggers of orders, it is possible for an order to be triggered by an erroneous trade or print. By using advanced orders, you agree that Ram Financial is not responsible for losses or damages resulting from market data problems, system issues, and user misuse among other factors. Ram Financial also does not recommend these orders as acceptable for a particular purpose or to meet a specific trading or financial need. Advanced orders can be cancelled at any time based on the above factors. Your use of advanced orders indicates your understanding and acceptance of the risks associated with these orders.

Disclosure of Fractional Share Trading

In consideration of Apex Clearing Corporation (“Apex”) and Ram Financial LLC (“Ram Financial”) allowing me to purchase and sell fractional interests of certain securities (“fractional shares”), I agree, with respect to any Account, whether margin or cash, to the terms in this addendum (“Addendum”) to the Customer Account Agreement (“Agreement”). Unless noted otherwise, capitalized terms have the same meaning here as in the Agreement. In the case of conflict between the Agreement and the Addendum, the terms of the Addendum will control for purposes of the subject matter herein.

I acknowledge and understand that:

1. Engaging in fractional share trading poses unique risks and limitations, including but not limited to those set forth herein. I agree that Ram Financial and Apex shall not be held liable for risks such as those disclosed herein, including risks in connection with the execution, handling, purchasing, and selling of fractional shares for my account.

2. Apex will administer the purchase, sale, and holding of fractional shares. All holdings of fractional shares are rounded to the fifth decimal place, the value of fractional shares to the nearest cent, and any dividends paid on fractional shares to the nearest cent. I understand this may affect, among other things, my ability to be credited for dividends and stock splits.

3. Apex will not accept purchases of less than $5.00. I will receive proceeds from the sale of any whole or fractional shares, less any regulatory trading fees, rounded to the nearest $0.01.

4. For a variety of reasons, including those set forth herein, the actual amount of an executed order to buy or sell a dollar value of a security may be higher or lower than the amount requested.

5. Apex will aggregate any proxy votes for fractional shares of Ram Financial customers. I understand that, while Apex will report proxy votes, the issuer or issuer’s designated vote tabulator may not fully count such votes.

6. Orders containing fractional shares (“Fractional Orders”) will be executed by Apex at the price Apex receives in the market. The fractional share component of any Fractional Order will be executed by Apex as a whole share order in the market, with the fractional share then allocated to my Account.

7. Ram Financial only accepts market orders for fractional shares at this time and does not permit limit orders for fractional shares. Fractional Orders may only be placed during market hours and are subject to all applicable market rules and conditions, including but not limited to restrictions, suspensions of trading, and delays.

8. Ram financial and Apex reserve the right to limit the stocks available for fractional share trading at any time.

9. Any and all fractional shares within my Account

(i) are unrecognized, unmarketable, and illiquid outside the Ram Financial platform,

(ii) are not transferrable in-kind, and

(iii) may only be liquidated and the proceeds withdrawn or transferred out.

Day-­Trading Risk Disclosure Statement – FINRA Rule 2270

You should consider the following points before engaging in a day-­‐trading strategy. For purposes of this notice, a “day trading strategy” means an overall trading strategy characterized by the regular transmission by a customer of intra-­‐day orders to effect both purchase and sale transactions in the same security or securities.

Day trading can be extremely risky. Day trading, generally, is not appropriate for someone of limited resources and limited investment or trading experience and low risk tolerance. You should be prepared to lose all of the funds that you use for day trading. In particular, you should not fund day-­‐trading activities with retirement savings, student loans, second mortgages, emergency funds, funds set aside for purposes such as education or home ownership or funds required to meet your living expenses. Further, certain evidence indicates that an investment of less than $50,000 will significantly impair the ability of a day trader to make a profit. Of course, an investment of $50,000 or more in no way guarantees success.

Be cautious of claims of large profits from day trading. You should be wary of advertisements or other statements that emphasize the potential for large profits as a result of day trading. Day trading can lead to large and immediate financial losses.

Day trading requires knowledge of securities markets. Day trading requires in-­‐depth knowledge of the securities markets and trading techniques and strategies. In attempting to profit through day trading, you must compete with professional, licensed traders employed by securities firms. You should have appropriate experience before engaging in day trading.

Day trading requires knowledge of a firm’s operations. You should be familiar with a securities firm’s business practices, including the operation of the firm’s order execution systems and procedures. Under certain market conditions, you may find it difficult or impossible to liquidate a position quickly at a reasonable price. This can occur, for example, when the market for a stock suddenly drops, or if trading is halted due to recent news events or unusual trading activity. The more volatile a stock is, the greater the likelihood that problems may be encountered in executing a transaction. In addition to normal market risks, you may experience losses due to system failures.

Day trading will generate substantial commissions, even if the per trade cost is low. Day trading involves aggressive trading, and generally you will pay commissions on each trade. The total daily commissions that you pay on your trades will add to your losses or significantly reduce your earnings. For instance, assuming that a trade costs $16 and an average of 29 transactions are conducted per day, an investor would need to generate an annual profit of $111,360 just to cover commission expenses.

Day trading on margin or short selling may result in losses beyond your initial investment. When you day trade with funds borrowed from a firm or someone else, you can lose more than the funds you originally placed at risk. A decline in the value of the securities that are purchased may require you to provide additional funds to the firm to avoid the forced sale of those

securities or other securities in your account. Short selling as part of your day trading strategy also may lead to extraordinary losses, because you may have to purchase a stock at a very high price in order to cover a short position.

Potential Registration Requirements. Persons providing investment advice for others or managing securities account for others may need to register as either an “Investment Advisor” under the Investment Advisors Act of 1940 or as a “Broker” or “Dealer” under the Securities Exchange Act of 1934. Such activities may also trigger state registration requirement.

Aries Financial, Inc. ("Aries," "we," "our," or "us") is committed to protecting your privacy and personal information. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal data when you visit our website aries.com or use our services.

1. Scope and Acceptance

This Privacy Policy applies to all users of our website, mobile applications, and other online services (collectively, the "Services"). By accessing or using our Services, you agree to the collection, use, and disclosure of your personal information as outlined in this policy.

2. Information We Collect

a. Information You Provide

We collect personal information you provide directly to us when you:

• Create an account with us

• Apply for our financial services

• Communicate with our customer support

• Participate in surveys, contests, or promotions

The types of personal information we may collect include:

• Identity Data: Full name, date of birth, social security number, or other government-issued identification.

• Contact Data: Email address, mailing address, and phone number.

• Financial Data: Bank account information, income details, credit history, and tax information.

• Profile Data: Usernames, passwords, and account preferences.

b. Information Collected Automatically

We automatically collect certain information when you interact with our Services, such as:

• Usage Information: Device identifiers, IP addresses, browser type, pages visited, and interaction times.

• Location Data: Approximate location information based on IP address.

• Cookies and Tracking Technologies: We use cookies and similar technologies to enhance your experience and gather information about your interactions with our Services.

3. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our Services

• Verify your identity and comply with regulatory requirements

• Process transactions, manage accounts, and provide customer support

• Personalize user experience and tailor content

4. How We Share Your Information

We may share your personal information in the following ways:

• With Service Providers: We share information with trusted partners who assist us in operating our Services, conducting our business, or providing services to you (e.g., payment processors, cloud service providers).

• With Affiliates: We may share information with our affiliates for internal business purposes, such as processing transactions or offering additional services.

• For Legal Purposes: We may disclose information when required by law, to protect our rights, or to comply with legal processes.

5. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information, including:

• Right to Access: You can request a copy of your personal information.

• Right to Correction: You can request corrections to inaccurate or incomplete information.

• Right to Deletion: You can request deletion of your personal data, subject to legal or business requirements.

• Right to Opt-Out: You may opt out of certain types of data processing, such as marketing communications.

To exercise these rights, please contact us using the information provided below.

6. Data Security

We implement reasonable and appropriate security measures to protect your information. However, no system is completely secure, and we cannot guarantee the absolute security of your data. We encourage you to use strong passwords and safeguard your personal information.

7. Data Retention

We retain your personal information as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with our legal obligations, resolve disputes, and enforce agreements.

8. International Data Transfers

Aries operates globally and may transfer your information across borders to provide Services. We ensure that appropriate safeguards are in place to protect your information during international transfers.

9. Children’s Privacy

Our Services are not directed to individuals under 16 years of age, and we do not knowingly collect personal information from minors. If we learn that we have collected such information, we will take steps to delete it promptly.

10. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically.

11. Contact Us

If you have questions or concerns about this Privacy Policy, please contact us at:

Aries Financial, Inc. 1420 Washington Blvd, Detroit, MI, 48226 [email protected]

Feel free to review and suggest any revisions or additional elements you'd like to include.

The following terms and disclaimers cover all data and information (“Data”) provided on Aries’s mobile application, desktop application, website, and any other product or service (collectively, “Applications”) provided by Aries Financial Inc. and its affiliates (“Aries”). Data includes, but is not limited to, market data from different exchanges, fundamental data such as financial reports, analysis, corporate action, and news reports.

Data on the Applications is provided by third-party service providers, and Aries is not involved in preparing or editing, nor does it explicitly or implicitly endorse or approve any Data. The third-party service providers do not explicitly or implicitly endorse or approve the Data of other third parties, nor do they give investment advice or advocate the purchase or sale of any security or investment. Aries and third-party service providers do not guarantee the accuracy or reliability of any Data. Aries does not bear any legal liability to the user for any loss or damage arising from the delay, error, inaccuracy, or omission of any Data.

Users should use Data on Aries’s Applications in accordance with the policies of Aries and the third-party service providers, as well as applicable local laws, rules, and regulations. No content on Aries’s Applications may be reproduced, stored, modified, transmitted or distributed in any form or by any means (including digital, electronic, mechanical, photocopy, recording or otherwise), without the prior written permission of Aries.

While Aries makes every attempt to provide accurate and timely Data to serve the needs of its users, it does not guarantee the accuracy, completeness, timeliness, or applicability of the Data. Data provided in the Applications does not constitute investment advice. Users are solely responsible for the consequences of any actions taken in response to the Data and Aries does not bear any legal liability for such actions.

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 your firm’s Customer Identification Program.

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.

Electronic Delivery of Trade and E-Signature

All communications, including Account statements, trade confirmations, margin calls, notices, disclosures, regulatory communications and other information, documents, data and records regarding your account, or an alert that such communication has been posted on the secure section of Ram Financial LLC (“Ram”) corporate website, and is available for viewing, may be sent to you at the mailing address for the account or email address that you have given us in your account application (to either email address in the case of joint accounts where each account holder has given an email address; notice to both email addresses is not required) or at such other address as you may hereafter give us in writing or by email at least ten (10) days prior to delivery, and all communications so sent, whether in writing or otherwise, shall be deemed given to you personally, whether actually received or not.

You understand that to receive electronic delivery of notifications, you must have Internet access, a valid email address, the ability to download such applications as Ram Financial LLC may specify and to which users must access and a printer or other device to download and print or save any information you may wish to retain. You are responsible for all the potential costs associated with electronic access to your account and with account communications.

Extended Hours Trading Risk Disclosure: FINRA Rule 2265

• Risk of Lower Liquidity

Lower liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for investors to buy or sell securities, and as a result, investors are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower levels of liquidity in extended hours trading as compared to regular market hours. As a result, your order may only be partially

• Risk of Higher Volatility

Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater levels of volatility in extended hours trading than in regular market hours. As a result, your order may only be partially executed, or not at all, or you may receive an inferior price in extended hours trading to what you might receive during regular market hours.

I HEREBY CERTIFY that at a meeting, duly called, of the Board of Directors of

_____

a corporation formed under the laws of

_____

, at which said meeting a quorum was present and acting throughout, the following preamble and resolution was adopted and ever since has been and now is in full force and effect: WHEREAS this Corporation is duly authorized and permitted by its Charter and By-Laws to deal in stocks, bonds, and other securities; NOW THEREFORE BEITRESOLVED that this Corporation open an account or accounts in its name with my introducing firm(“the Introducing Firm”),to be carried by Apex Clearing Corporation(“ClearingFirm”),and that the President,Vice President,Treasurer,otherofficers, or any one of them or their successors in office, individually or jointly, may, on behalf of this Corporation,(1) give orders in the said account or accounts for the purchase, sale or other disposition of stocks, bonds,andother securities(2)instruct,deliver to,or receive from Introducing Firmor Clearing Firm monies,stocks,bonds,andother securities, (3) sign acknowledgements of the correctness of all statements of accounts and (4) make, execute and deliver under the corporate authority and seal any and all written end or sements and documents necessary or proper to effectuate the authority hereby conferred.

This Authorization and its enforcement shall be governed by the laws of the State of Texas, shall cover individually and collectively all accounts covered by this agreement and authorization which the undersigned may open or reopen with you, and shall inure to the benefit of the Introducing Firm’s and the Clearing Broker’s present organization,and any successor organization,irrespective of any change or changes of any kind of the personnel thereof for any cause whats oever,and of the assigns of the Introducing Firm’s and the Clearing Broker’s present organization or any success or organization.

Special Statement for Uncovered Option Writers

There are special risks associated with uncovered option writing, which expose the investor to potentially significant loss. Therefore, this type of strategy may not be suitable for all customers approved for options transactions.

1. The potential loss of uncovered call writing is unlimited. The writer of an uncovered call is in an extremely risky position, and may incur large losses if the value of the underlying instrument increases above the exercise price.

2. As with writing uncovered calls, the risk of writing uncovered put options is substantial. The writer of an uncovered put option bears a risk of loss if the value of the underlying instrument declines below the exercise price. Such loss could be substantial if there is a significant decline in the value of the underlying instrument.

3. Uncovered option writing is thus suitable only for the knowledgeable investor who understands the risks, has the financial capacity and willingness to incur potentially substantial losses, and has sufficient liquid assets to meet applicable margin requirements. In this regard, if the value of the underlying instrument moves against an uncovered writer’s options position, the investor’s broker may request significant additional margin payments. If an investor does not make such margin

payments, the broker may liquidate stock or options positions in the investor’s account, with little or no prior notice in accordance with the investor’s margin agreement.

Option Expiration: Expiration Day typically occurs Friday, or Thursday if that is the last trading day of the week. However, certain securities may also have Monday, Wednesday, or Quarterly expiration days.

Automatic Exercise on Expiration Day:If you hold an expiring long option through expiration day that is a $0.01 or more in-the-money, the OCC (Options Clearing Corporation) will automatically exercise this option. The OCC will use the official closing price to make this determination. In-the-money would be $0.01 higher than the strike price for call options and $0.01 or lower for put options. The automatic exercise will result in your account purchasing or selling the deliverable of the option at the strike price. If you do not want your option to be automatically exercised, then you may submit a Do- Not-Exercise instruction via the app or speaking with a broker. You have up until 4:00 PM or market close to submit a Do-Not-Exercise instruction. *Please Note: Deliverables are subject to change.

Out-of-the-Money Exercise or At-the-money Exercise on Expiration Day:An option that is out-of-the money or at-the-money will not be automatically exercised by the OCC (remember $0.01 threshold). However, you may still exercise these options, but you must instruct us to do so. You can submit the exercise instruction in the app or speaking with a broker by 4:00 PM on expiration day or market close on market half days.

Short Options, Assignment & Delivery: Assignment - The owner of a long option has exercised their right against an option writer. For equity and index options, OCC makes assignments on a random basis.

Delivery: The process of meeting the terms of a written option contract when notification of assignment has been received. In the case of a short equity call, the writer must deliver stock and in return receives cash for the stock sold. In the case of a short equity put, the writer pays cash and in return receives the stock. *Please Note: Deliverables are subject to change.

Out-of-The-Money Short Options: Your short option may be assigned even if it is out-of-the-money or at-the-money. There are certain cases where it may be economical for an out-of-the-money option to be assigned, for example: extended hour market activity or to claim a dividend. Please know that even if your option is out-of-the-money it is by no means an assurance that you will NOT be assigned.

In-the-money Short Options at Expiration:In-the-money short options are also at risk of not being assigned. The long option holder may choose not to exercise the option by submitting a ‘Do-Not-Exercise’ instruction. There also may be extended session market activity which no longer make the exercise economical. Please know that just because your short option is in-the-money it is by no means an assurance that you WILL be assigned.

Expiration & Account Equity:It is your responsibility to review your expiring option positions and ensure your account has sufficient equity to support an exercise/assignment. Please be sure to read the risks and maintain sufficient equity to support a short option assignment. Please know that even if your option is out-of-the-money it is by no means an assurance that you will NOT be assigned. Please familiarize yourself with the deliverable of the option and the responsibility you incur from the assignment/exercise process. The resulting position may result in margin charges, hard-to-borrow charges and is subject to market risk.

Aries Auto-Liquidation & Expiration Risk: Aries may take action in your account. Aries does not offer the opening of same day expiring options at 1 hour prior to market close. Two hours prior to market close Aries will cancel any opening orders for a same day expiring option. Please understand that we expect every customer to close any out of the money, in the money, or at the money option position at least 35 minutes prior to market close that may pose a risk to your account or to Aries. If you fail to do so you may be subject to be either an auto-liquidation, a do-not-exercise, an exercise, or an assignment, depending on if there’s sufficient equity in the account to support the underlying position or not. Aries is under no obligation to take this action and it is expected that each customer manages their positions through expiration and understand the potential risks and characteristics of options.

Ram Financial, LLC reserves the right to close out options that pose a risk if exercised or assigned.

Spreads & Expiration Risks: Spreads may be known as a ‘defined-risk’ trade, but this refers to the maximum theoretical max loss or gain of the trade at time of entry. Keyword in the sentence is “theoretical”. Spreads at expiration pose a particular risk to your account. Spread Expiration Risk is when there is a creation of an unhedged underlying position in your account from an exercise/assignment. Essentially, if you hold the strategy through expiration, it may lead to a different risk profile and margin requirement. What can happen is as follows:

- The trader establishes a 10-lot short vertical call spread on XYZ that is $10.00 wide:

o Sell 10 XYZ Jun 16 $100 Call

o Buy 10 XYZ Jun 16 $110 Call

§ The margin requirement for the above trade is $10,000.00 – 1000 shares / $10 wide.

o There are two scenarios that can happen.

§ 1) XYZ closes expiration day at $105.00 pinning between the strikes. The $100 call will be in-the-money and the $110 call will expire out-of-the money. Your defined risk trade of $10,000.00 has now changed to you assuming a potentially a $100,000.00 assignment through expiration. This is known as ‘pin-risk’ as the underlying pins between the strikes and should be managed appropriately going into expiration.

§ 2) XYZ closes expiration day at $99.00 – Both legs are out-of-the-money, and the trader takes no action. XYZ in the extended session has a large price movement and climbs to $103.00.

§ In the above situation, the short $100 call is likely to be assigned but we do not know for sure, and we do not know exactly how many of the 10 contracts will be assigned.

§ Let us fast forward. On Monday the trader is assigned on 8 of the 10 contracts (random allocation) which results in the account taking delivery on 800 shares of XYZ at $100.00. XYZ continues to rally to $115.00 before the short is closed. The trader has now lost $12,000, $2,000 greater than the theoretical max loss of the strategy. XYZ happened to be a hard-to-borrow security, and the trader was subsequently charged hard-to-borrow fees for holding the short position over the weekend.

o If the inverse were to happen and the long option closed in-the-money, please instruct us to submit a Do-Not-Exercise on your behalf by 4:00PM or market close on expiration day.

You are responsible to understand these risks and managing all risks associated with spreads.

After Expiration: In the event the exercise/assignment results in a Reg T or a Money Due Call – you can avoid restrictions/penalties if you cover the call on T+1 of expiration date.

Early Exercise of Options: If you would like to submit an early exercise request you can do so from the app or by speaking to a broker. Currently, the exercise in-app feature is only for single-leg options. If you would like to submit exercise instructions for an option that is part of a complex strategy you will need to submit verbal or written instructions via in-app feedback. You need to submit the request by 4:30 PM or 30 minutes after market close on market half days. Any requests submitted after 4:30 PM EST will be reviewed on a best-efforts basis. On expiration day you have up until 4:00 PM or market close to submit exercise instruction. If we are unable to process your request, you will receive an exercise cancellation from us and you are free to submit an instruction the next trading day. If you submit your requests after 5:30PM EST or 1.5 hour after market close it will be rejected and you will need to resubmit the instruction next trading day. Once you submit an exercise instruction your option will be frozen until we have submitted the instruction to the OCC. You must maintain sufficient equity or corresponding underlying shares to support the early exercise of a call or a put option contract. Sufficient buying power or corresponding underlying shares must be held throughout the day until the end of trading at 8 pm. For example, if you are exercising 1 ZYX $1 Call option you will need to maintain $100 in buying power in the account until 8 pm on the day the exercise request is submitted. The exercise request is processed overnight, and your position and balances will be updated on the next business day. We are working to make this a real-time process and appreciate your patience!

To reiterate the points – Prior to expiration day you may submit an early exercise request until 4:30PM or 30 minutes after market close. On expiration – you must submit all instructions by 4:00 PM or market close.

Option trading entails significant risk and is not appropriate for all investors. Option investors can rapidly lose the value of their investment in a short period of time and incur permanent loss by expiration date. Additionally, investors can lose more than their initial investment. You need to complete an options trading application and get approval on eligible accounts. Please read the Characteristics and Risks of Standardized Options and Option Spread Risk Disclosure before trading options.

Margin Trading may not be right for everyone. It is important to understand the rules and conditions margin trading or borrowing may have on your investments.

In consideration of my opening and carrying a limited liability company account in the name of

_____

a duly organized limited liability company(the“LLC”) organized under the laws of the state of the United States with you my Introducing Firm (the “Introducing Firm”), to be carried by Apex Clearing Corporation (the “Clearing Broker”), of which the undersigned is a duly elected or authorized member of the LLC, I hereby certify that each of the Officers and Managers of the customer entity is set forth on the undersigned’s New Account Application and Agreement and has been duly elected and is now legally holding the office as are set forth in the undersigned’s New Account Application&Agreement.

All such Officers and Managers, as applicable, are hereby appointed the authorized agents and attorneys-in-fact of the LLC (the “Authorized Agents”) to act jointly or individually, and shall have authority on behalf of the LLC, and for its account and risk, to buy, sell (including short sales), tender, convert, exchange, trade and otherwise deal in stocks, bonds, options and any other securities (on margin or otherwise)in accordance with the terms and conditions for the LLC account asset forth in the New Account Applicationand Agreement otherwise.

The Introducing Firm and the Clearing Broker are authorized to follow the instructions of the Authorized Agents in every respect concerning the account(s), and to deliver to the account(s) or Authorized Agents on behalf of the LLC account(s), all demands, notices, confirmations, reports, statements of accounts, and communications of every kind, money, securities, and property of every kind. The Authorized Agents are hereby authorized to execute and deliver on behalf of the LLC and the account(s) any agreements or documentation relating to any of the foregoing matters and to terminate or modify the same or waive any of the provisions thereof, and generally to deal with the Introducing Firm and the Clearing Broker on behalf of the LLC and the account as fully and completely as if each alone were interested in the LLC and/or account(s), all without notice of the other or others interested in said account.

This authorization is in addition to, and in no way limits or restricts , any rights which the Introducing Firm and the Clearing Broker have under any other agreement or agreements between the Introducing Firm and the Clearing Broker and the LLC and/or undersigned(s), individually or jointly, now existing or hereafter entered into, and is binding on the LLC, its managers and members, and its legal representatives, successors and assigns. This authorization is also a continuing one and shall remain in full force and effect until revoked by a written notice, addressed to the Introducing Firm and delivered to the Introducing Firm at the Introducing Firm’s principal office or such other location as the Introducing Firm may instruct. No such revocation shall affect any liability arising out of any transaction initiated prior to such revocation and delivery.

The undersigned hereby certify that all of the members and managers of the LLC are as follows:*

_____

The undersigned further authorizes the Introducing Firm and the Clearing Broker, in the event of death or retirement of any of the members of the LLC, to take such proceedings, require such papers, retain such portions or restrict transactions in said account as the Introducing Firm or the Clearing Broker may deem advisable to protect you and the Clearing Broker against any liability, penalty or loss under any present or future laws or otherwise. It is further agreed that in the event of the death or retirement of any member of the LLC the remaining members will immediately cause you to be notified of such fact.

This authorization and its enforcement shall be governed by the laws of the State of Texas, shall cover individually and collectively all accounts covered by this agreement and authorization which the undersigned may open or reopen with you, and shall inure to the benefit of your present organization, and any successor organization, irrespective of any change or changes of any kind of the personnelthereof for any cause what so ever,and of the assigns of your present organization or any success ororganization.

Customer consent to loan or pledge of securities and other property (not applicable to cash accounts):each of the undersigned has signed the enclosed Customer’s Agreement and Customer’s Loan Consent which are intended to cover, in addition to the provisions hereof, the terms upon which the LLC is to be carried.

SIGNATURE

I, Secretary, or the equivalent, of the Customer, a limited liability company, hereby certify that the resolutions herein were duly adopted at a meeting of the Members of the Customer, duly held on the

_____

, at which a quorum of said Members was present and acting throughout and that no action has been taken to rescind or amend said resolutions andthe same are now in full force and effect.

I certify that the Customer, a limited liability company, is duly organized, existing, and in good standing in the jurisdiction of its incorporation and any other jurisdiction where it may be required to be registered , and that the Customer , through its Primary Officer above, has the power to take the action called for by the resolutions here.

IN WITNESS WHEREOF, I, the Secretary of the Customer, on behalf of the Customer, have hereunto affixed my hand this

_____.

Safety of Customer Assets at Apex Clearing Corporation

Apex Clearing Corporation (Apex) is fully committed to principles of safety and soundness. We run our business with a sound capital structure and have taken appropriate actions to help give you peace of mind about the safety and security of your accounts. We take the protection of your assets very seriously and want to make you aware of the measures our firm is taking to safeguard your accounts and your information.

MARGIN RISK DISCLOSURE STATEMENT

Apex Clearing and Ram Financial LLC

FINRA Rule 2264

We are furnishing this document to provide you with basic facts about purchasing securities on margin, and to alert you to the risks involved with trading securities in a margin account. Before trading in a margin account, you should carefully review the margin agreement provided by your broker. Consult your broker 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 in your account, 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 in your account.

• The firm can force the sale of securities in your account. If the equity in your account falls below the maintenance margin requirements under the law, or the firm’s higher “house” requirements, the firm can sell the securities in your account to cover the margin deficiency. You also will be responsible for any shortfall in the account after such a sale.

• The firm can sell your securities 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 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 interest, including immediately selling the securities without notice to the customer.

• You are not entitled to choose which security in your margin account is 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 requirement 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.

• 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.

• The IRS requires Broker Dealers to treat dividend payments on loaned securities positions as a “substitute payment” in lieu of a dividend. A substitute payment is not, a “qualified dividend” and is not taxed as ordinary income.

• Industry regulations may limit, in whole or in part, your ability to exercise voting rights of securities that have been lent or pledged to others. You may receive proxy materials indicating voting rights for a fewer number of shares than are in your account, or you may not receive any proxy materials.

APEX CREDIT TERMS AND POLICIES

The following Disclosure of Credit Terms and Policies is required by the Securities and Exchange Commission and is part of your Apex Account - Customer Account Agreement. It describes the terms under which Apex Clearing extends credit and charges interest and how your obligations are secured by property in your Account.

Interest Charges. We will charge interest on a daily basis on the credit extended to you. The daily interest charges are calculated by multiplying your "daily adjusted debit balance" by the "daily margin interest rate." Generally speaking, your daily adjusted debit balance is the actual settled debit balance in your Margin and Short Account, increased by the value of securities held short and reduced by the amount of any settled credit balance carried in your Cash Account.

We calculate your daily-adjusted debit balance each day by adjusting your previous day's balance by any debits and credits to your account and by changes in the value of short positions. If your daily-adjusted debit balance is reduced because you deposit a check or other item that is later returned to Apex Clearing unpaid, Apex Clearing may adjust your account to reflect interest charges you have incurred.

We reserve the right to charge interest on debit balances in the Cash Account. Periodically, we will send you a comprehensive statement showing the activity in your account, including applicable interest charges, interest rates and adjusted daily debit balances.

Daily Margin Interest Rate. The "daily margin interest rate" is based on a 360-day year. It is calculated for each day by dividing the applicable margin interest rate shown in the table below by 360. Note that the use of a 360-day year results in a higher effective rate of interest than if a year of 365 days were used.

We set the Base Rate at our discretion with reference to commercially recognized interest rates, industry conditions relating to the extension of margin credit and general credit market conditions. Your margin interest rate will be adjusted automatically and without notice to reflect any change in the Base Rate. If your interest rate increases for any reason other than a change in the Base Rate, we will give you written notice at least 30 days prior to that change.

Compounding Interest Charges. We compound interest on a daily basis. Interest charges will accrue to your account each day. We will include the charges in the next day's opening debit balance and charge interest accordingly. The interest rates described above do not reflect compounding of unpaid interest charges; the effective interest rate, taking into effect such compounding, will be higher.

Initial Margin Requirements. The Federal Reserve Board and various stock exchanges determine margin loan rules and regulations. When you purchase securities on margin, you agree to depos it the required initial equity by the settlement date and to maintain your equity at the required levels. The maximum amount we currently may loan for common stock (equity) securities is 50% of the value of marginable securities purchased in your Margin and Short Account; different requirements apply to nonequity securities, such as bonds or options. If the market value of stock held as collateral increases after you have met the initial margin requirements, your available credit may increase proportionately. Conversely, if the market value decreases, your available credit may proportionately decrease.

Initial margin requirements may change without prior notice. We may impose anytime and without prior notice more stringent requirements on positions that in our sole discretion involve higher levels of risk; for example, higher limits may apply for thinly traded, speculative or volatile securities, or concentrated positions of securities.

You may purchase only certain securities on margin or use them as collateral in your Margin and Short Account. Most stocks traded on national securities exchanges, and some over-the-counter (OTC) securities are marginable. At our discretion, we reserve the right not to extend credit on any security.

Equity securities with a market value of less than $3 per share may not be purchased on margin or deposited as margin collateral. If the market value of a security drops below $3.00 per share, the security will not be assigned any value as collateral to secure your margin obligations.

Margin Maintenance Requirements. You must maintain a minimum amount of equity in your account to collateralize your outstanding loans and other obligations. Margin maintenance requirements are set:

• By the rules and regulations of the New York Stock Exchange, the American Stock Exchange, and other regulatory agencies to the jurisdiction of which Apex Clearing are subject; and

• According to our sole discretion and judgment.

You agree to maintain in your Margin and Short Account collateral of the type and amount required by:

• Applicable exchange rules and federal regulations

• Our Disclosure of Credit Terms and Policies; or

• As required by us, at our discretion.

Margin maintenance requirements may change without prior notice.

We may issue a "margin call" (that is, a notification to deposit additional collateral) if your account equity falls below the margin maintenance requirement. This can happen for various reasons. The most common reasons are a decrease in the value of long securities held as collateral or an increase in the value of securities held short.

As a general guideline and when it is practicable to do so, we may (but is not required to) issue a margin call when the equity in your Margin and Short Account falls below a predetermined percentage of the market value of assets at risk (that is, the sum of the market values of the long and short equity security positions) in your Margin and Short Account. The amount of additional collateral Apex Clearing requires usually is an amount sufficient to raise your equity to minimum standards. For information on the current equity requirements, please contact your broker.

We retain absolute discretion to determine whether, when and in what amounts we will require additional collateral. In some situations, we may find it necessary to require a higher level of equity in your account. For example, we may require additional collateral if an account contains:

• Only one security or a large concentration of one or more securities; or

• Low-priced, thinly traded, or volatile securities; orif

• Some of your collateral is or becomes restricted or non-negotiable or non- marginable.

We also may consider market conditions and your financial resources.