Compliance

Market Securities is a broker-dealer registered with the U.S. Securities and Exchange Commission ("SEC") under Section 15(b) of the Securities Exchange Act of 1934. Market Securities is a member of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investor Protection Corporation ("SIPC").

Market Securities is also registered as a broker-dealer in all fifty U.S. states, the District of Columbia, and Puerto Rico, and as a futures commission merchant ("FCM") with the Commodity Futures Trading Commission ("CFTC") and the National Futures Association ("NFA") where applicable. Cryptocurrency services are provided by Market Securities, which is licensed as a money-services business and may hold state money-transmitter licenses where required.

You can review Market Securities's regulatory profile at FINRA BrokerCheck (brokercheck.finra.gov) and our SEC filings through the Investment Adviser Public Disclosure site (adviserinfo.sec.gov). Our SEC CRD number, FINRA registration, and state licenses are available on request from compliance@marketsecurities.com.

Market Securities maintains a written Anti-Money-Laundering ("AML") program reasonably designed to comply with the U.S. Bank Secrecy Act, the USA PATRIOT Act, FINRA Rule 3310, and applicable rules of the U.S. Treasury Department's Financial Crimes Enforcement Network ("FinCEN"). Our AML program is approved annually by senior management and reviewed for effectiveness.

As part of our Customer Identification Program ("CIP"), we collect and verify identifying information about each customer before opening an account. We screen customers against the U.S. Treasury Office of Foreign Assets Control ("OFAC") Specially Designated Nationals and Blocked Persons List and other applicable sanctions lists at onboarding and on an ongoing basis.

We monitor account activity for suspicious transactions. We may place holds on transactions, request additional information, decline to act on an instruction, or close an account where required by law or where we suspect illicit activity. Market Securities files Suspicious Activity Reports ("SARs") with FinCEN as required; SARs are confidential and customers are not notified when a SAR is filed.

Customers may not use the Services to evade U.S. or foreign sanctions, facilitate transactions for sanctioned parties, or engage in any conduct prohibited by the Bank Secrecy Act or applicable anti-corruption laws. Market Securities supports law-enforcement inquiries through proper legal process.

Market Securities screens customers, counterparties, and payment beneficiaries against OFAC's Specially Designated Nationals and Blocked Persons List, the U.S. Department of Commerce's Denied Persons List and Entity List, and other applicable U.S. and international sanctions lists. We also screen for transactions involving sanctioned jurisdictions such as Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions.

If we identify a potential sanctions match, we may block the transaction, freeze the related assets, and report to OFAC. We will not provide Services to any person or entity that is the target of U.S. sanctions or that is located in a sanctioned jurisdiction.

Market Securities supports the goals of U.S. sanctions policy and cooperates fully with OFAC and other agencies in investigations and enforcement actions.

Market Securities employees are trained to identify red flags of money laundering, terrorist financing, securities fraud, market manipulation, and elder financial exploitation. Suspected suspicious activity is escalated to Market Securities's AML Compliance Officer for review and, where appropriate, reported to FinCEN, the SEC, FINRA, or other authorities.

Where Market Securities suspects that a customer is the victim of financial exploitation (for example, an elderly customer being defrauded), we may place a temporary hold on the customer's account as permitted by state senior-saver laws and FINRA Rule 2165, and we may contact a trusted contact previously designated by the customer.

SARs and supporting documentation are confidential. Market Securities and its employees are prohibited from disclosing the existence or contents of a SAR to the subject of the report or to any unauthorized person, and are protected from liability for filing SARs in good faith.

Market Securities maintains a Personal Trading Policy for its employees, officers, and directors, designed to prevent misuse of material non-public information, front-running, and conflicts of interest. The policy requires pre-clearance of certain trades, holding periods for personal securities transactions, and prohibitions on trading in securities on Market Securities's restricted list.

Employees in possession of material non-public information about a customer, counterparty, or Market Securities itself are prohibited from trading in the affected securities and from disclosing the information to others. Market Securities enforces these rules through trade monitoring and disciplinary action.

Market Securities's Code of Ethics also addresses gifts and entertainment, outside business activities, political contributions, and other conduct that could create conflicts of interest. Violations may result in termination and referral to regulators.

Market Securities maintains books and records as required by SEC Rule 17a-3 and 17a-4, FINRA Rule 4511, and applicable CFTC and NFA rules. Records are retained for the periods prescribed by these rules (commonly three to six years, sometimes longer for specific record types) in a non-rewriteable, non-erasable ("WORM") format where required.

Records include account-opening documents, order tickets, trade confirmations, account statements, customer correspondence, advertising and communications, supervision records, AML records, and complaints. Customers may obtain copies of their own records by submitting a written request to compliance@marketsecurities.com.

Records may be inspected by the SEC, FINRA, NFA, CFTC, and other regulators in connection with examinations, investigations, or inquiries. Market Securities cooperates fully with all such regulatory inspections.

Market Securities is subject to periodic and for-cause examinations by the SEC, FINRA, and state securities regulators. Examinations review Market Securities's financial condition, supervisory systems, customer-protection practices, AML program, cybersecurity controls, and compliance with securities laws.

Market Securities maintains a system of written supervisory procedures ("WSPs") reasonably designed to achieve compliance with applicable laws and regulations. WSPs are reviewed and updated at least annually and following any material change to the business or applicable law.

Market Securities designates a Chief Compliance Officer and other principal officers who are responsible for the firm's compliance program. The firm's annual CEO/CCO certification under FINRA Rule 3130 confirms that the firm's supervisory and compliance procedures are reasonably designed and have been tested for effectiveness.

FINRA BrokerCheck — brokercheck.finra.org. BrokerCheck provides background information on Market Securities and its registered representatives, including registration history, exam qualifications, and any disclosures or events.

SEC Investment Adviser Public Disclosure (IAPD) — adviserinfo.sec.gov. IAPD provides information on registered investment advisers, including Market Securities's Form ADV where applicable.

Securities Investor Protection Corporation — www.sipc.org. SIPC provides information about SIPC coverage and the procedures for filing a claim in the event of a member firm failure.

Commodity Futures Trading Commission — www.cftc.gov. The CFTC provides information about futures, options on futures, and other derivatives.

National Futures Association — www.nfa.futures.org. NFA provides information about NFA members and the BASIC system for checking registration status and disciplinary history.

If you have a complaint about Market Securities or the Services, please contact our Customer Relations team at support@marketsecurities.com or +1 (212) 555-0142. We will acknowledge your complaint promptly and aim to resolve it within thirty (30) days. You may also submit a written complaint to Market Securities, Attn: Compliance Department, 1180 Avenue of the Americas, New York, NY 10036.

If we are unable to resolve your complaint, you may file a complaint with FINRA at finra.org/investors/need-help or with the SEC at sec.gov/complaint.shtml. You may also pursue arbitration through FINRA Dispute Resolution; see the Dispute Resolution section of our Terms of Service for details.

Market Securities tracks and reports customer complaints to its senior management and, where required, to regulators. We use complaint data to identify trends and improve our Services.