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Legal & Compliance

HOW YOUR MONEY IS PROTECTED

Pershing LLC, (“Pershing”) is the firm that provides clearing, execution and settlement services for your investment account(s).

Pershing LLC (Pershing), a BNY Mellon company, has been a leading global provider of financial business solutions for over 75 years and serves many of the world's most respected financial organizations. Pershing remains committed to the safekeeping, servicing, segregation and reporting of our global client assets.

Pershing's core financial strength provides the first measure of protection for our global client assets. Pershing's parent company, BNY Mellon, is a leading provider of financial services for institutions, corporations and high-net-worth individuals. While financial strength does not protect against loss due to market fluctuation, our internal controls and regulatory oversight help maintain our stability and focus.

EVALUATION AND SEGREGATION OF ASSETS

Pershing protects client assets through rigorous internal control measures. An annual audit by a major independent auditing firm and the audit team at Pershing's parent company, BNY Mellon, helps to monitor controls that are in place. In addition, an Annual Service Organizations report (as required) by a major independent auditing firm provides additional evaluation of the design and operating effectiveness of Pershing's internal controls related to account transfers, billing, clearance and settlement, confirmations and cash management functions, corporate actions, foreign exchange and primer brokerage controls, interest, margin monitoring, order and trade processing, physical custody, pricing and statements. Clients' fully paid-for assets are segregated from Pershing's own, with quarterly vault inspections conducted. Pershing maintains enough liquid assets, net of any liabilities, to protect client's fully paid-for assets in the unlikely event of Pershing's failure and liquidation. Pershing is a broker-dealer registered with the U.S. Securities and Exchange Commission, all 50 states as well as the District of Columbia and Commonwealth of Puerto Rico, and certain foreign jurisdictions.

SECURITIES INVESTOR PROTECTION CORPORATION (SIPC®) COVERAGE

Pershing is a member of the SIPC®, which protects securities customers of its members up to $500,000 (including $250,000 for claims for cash). Explanatory brochure available upon request or at sipc.org.

EXCESS OF SIPC® COVERAGE THROUGH UNDERWRITERS AT LLOYD'S AND OTHER COMMERCIAL INSURERS

In addition to SIPC® protection, Pershing provides coverage in excess of SIPC® limits from certain underwriters in Lloyd's insurance market and other commercial insurers. The excess of SIPC® coverage is valid through February 10, 2021 for Pershing LLC accounts. It provides the following protection for Pershing LLC's global client assets:

An excess of SIPC® claim would only arise if Pershing failed financially and client assets for covered accounts -- as defined by SIPC -- cannot be located due to theft, misplacement, destruction, burglary, robbery, embezzlement, abstraction, failure to obtain or maintain possession or control of client securities, or to maintain the special reserve bank account required by applicable rules. Lloyd's currently holds an A+ rating from Standard & Poor's® (S&P®), an A rating from A.M. Best and an AA-rating from Fitch. These ratings are based on the financial strength of the company and are subject to change by the rating agencies at any time. For more information about Lloyd's, please see www.lloyds.com.

Rule 606 Notice Disclosure of Order Routing Information

Rule 607 Payment for Order Flow Disclosure

SIPC Notice

Amendment to Markup/Markdown Disclosures

USA Patriot Act Notice 

Annual Customer Disclosure Document

Seelaus Asset Management, LLC Form ADV 2A: Investment Adviser Brochure