Privacy Policy

At Reliance Capital Markets II, LLC (“RCM”) we value our customers, and maintaining customer trust and confidence is our highest priority. While it is necessary that we obtain accurate and current information about our customers in order to provide the highest level of customer service, we are dedicated to protecting the privacy and confidentiality of our customers' information.

RCM will never sell your personal information to anyone. We will not use or distribute your personal information in any way without prior notification to you. We promise that we will uphold the privacy policies and procedures as set forth below.

Information we collect about our customers

The personal information we collect from you comes from information you supply to us in account opening applications (whether written or electronic), or in other forms you may provide to us. This information may include your name, address, social security number or tax identification number, and financial information about you.

Information regarding your transactions with us including your trading history at RCM, your history of meeting margin calls or your use of the various services and products that we provide.

Information about your credit history and information we may receive from our clearing firms or consumer reporting agencies.

"Cookies" are small text files consisting of encrypted information assigned to a computer's browser. Cookies do not collect or transmit your personal information. For users of the non-public areas of our or our clearing firm’s websites or electronic trading platforms that require a User ID or password, RCM may use cookies to identify you so that you do not have to input your password multiple times as you navigate our site. RCM may also use cookies for administrative purposes, such as to maintain security on our site.

Information we may share about our customers

RCM will not sell personal information regarding our current or former customers.

RCM may share personal information about our current and former customers with our affiliated companies and service providers around the world. (RCM affiliated companies includes any related companies) In either case, your personal information will remain subject to the strictest confidentiality protections.

To the extent that we may engage unaffiliated companies to assist in providing services on our website, such service providers will be subject to stringent contractual requirements to maintain the confidentiality of any personal information they may obtain in connection with the performance of their services for us. We will make every effort to make sure that they receive the minimum amount of personal information necessary and will be allowed to retain that information only for as long as necessary in order to provide such services. Such service providers will be allowed to use personal information only in the course of providing services to RCM and only for the purposes that we authorize.

Information we may disclose

We may disclose information about current or former customers in order to cooperate with legal or regulatory authorities or pursuant to a court order or subpoena.

We may also disclose personal information as necessary to perform credit checks, collect debts, enforce our legal rights or otherwise protect our interests and property.

Security

RCM is committed to protection of your personal information and of your privacy.

Only authorized RCM employees or agents will have access to your personal information. All of our employees, affiliates and service providers are held to the highest standards of privacy and security.

You will be notified either through the RCM website or in another appropriate way if this policy changes. If you have questions relating to this policy, please contact your RCM representative.

Exchange Traded Commodity Options Transactions

Who May Solicit or Deal In Commodity Options: Under CFTC, Exchange and NFA rules, only FCMs which are members of the exchange where a specific commodity option is traded or which are members of the NFA, and only registered introducing brokers ("IB's") which are NFA members or are "guaranteed" by an FCM, and the FCM’s or IB's CFTC registered associated persons ('AP's"), may solicit options business. The Compliance Department in the home office of RCM must be notified immediately by any branch office or introducing broker if the status of any of its associated persons changes by reason of expiration, suspension, revocation, withdrawal or abandonment of such AP registration. Notification shall be made by the fastest method, preferably by telephone or email and confirmed in writing.

Promotional Material: All "Promotional Material" as defined below prepared by any branch office or associated person registered with RCM, with respect to commodity option trading, must be submitted to the RCM Compliance Department prior to use. No "Promotional Material" may be used until the Firm’s Compliance Department notifies the preparer that the same is approved for use. The RCM Compliance Department will retain file copies of promotional material submitted pursuant to this section

Definition of Promotional Material: Under CFTC and NFA rules, "Promotional Material" is very broadly defined. It includes:

• Any text of a standardized oral presentation, or any communication for publication in any newspaper, magazine or similar medium, or for broadcast over television, radio or other electronic medium.
• Any standardized form of report, letter, circular, memorandum or publication; or
• Any other written material which is disseminated or directed to an option customer or prospective option customer concerning a commodity option transaction. "Promotional Material" also includes any disclosure statement required by the CFTC, NFA or Exchange rules.

Disclosure Statement: Before any commodity option account for a new customer or any commodity option transaction for an existing customer may be opened or entered into, the option customer must receive a copy of the current Risk Disclosure Statement and must sign, date and return to RCM the written acknowledgment of having received and understood the Disclosure Statement. If the option customer is a new account, all customer papers, including the Customer Agreement, must be completed, signed, dated and approved by the RCM Compliance Department before the account will be opened or any trading will be permitted.

Customer Information: In addition, the CFTC and NFA require that the information contained on the Customer Commodity Information Form (NFA Rule 2-30) be completed.

Sales Communications: Under no circumstances are sales communications which are misleading, inaccurate, fraudulent or "high pressure" to be made or countenanced. Examples of option-related communication that the NFA considers misleading include communications that use cash, futures-market or forex data to sell options, e.g.

• Option-related promotional material should generally not include futures or Forex price charts unless accompanied by option price charts and
• Members must ensure that the futures, options and Forex charts mirror the same time period;
• Imply that options prices move in tandem with cash, futures or Forex prices;
• Use price data for at-the-money options to sell out-of-the-money options; or
• Use price data that does not include commissions and fees comparable to those charged by the Member.

Other Disclosures to Customers: Prior to entering into any commodity options transactions, the associated person will provide the information required under the options disclosure statement including the commissions, costs, fees and other charges to be incurred in connection with the commodity option transaction and all costs to be incurred by the option customer if the commodity option is exercised. Additionally, each customer will, to the extent the following amounts are known, or can reasonably be approximated, be informed by the person accepting the order, of the amount of the strike price and the premium, and any markups related thereto. If any information provided to an option customer has become outdated or inaccurate, the associated person should provide the current information immediately.

Supervision of Position Accounts: All branch managers and office principals must review commodity option transactions, including but not limited to the solicitation of such transactions, handled by associated persons subject to their supervision on a regular basis. All questions, discrepancies and problems must be reported by telephone, email or facsimile to the RCM Compliance Department. (Also see supervision of Discretionary Option Accounts below).

Option Customer Complaints: All option customer complaints, whether written or oral, must be forwarded immediately to the RCM Compliance Department. The Compliance Department should be notified immediately, by telephone, email or facsimile, upon the receipt of the complaint and that the complaint in written form is being forwarded. If the complaint is oral, it must be reduced to writing for submission to the Compliance Department. A copy of the written complaint, or of the written transcript of the oral complaint, must be retained by the Branch Office. The date the complaint was received, the associated person who solicited and serviced the account, together with a general description of the matter complained of and what if any, action was taken will be recorded and retained by the Compliance Department. If the matter is resolved by the branch manager or office principal, a written record of the resolution should be forwarded to the RCM Compliance Department for its files.

Opening Discretionary (Managed) Option Accounts: Prior approval, in writing, of the discretionary authority must be given for each account by the Mr. Robert Schwartz, the Firm’s Principal and Compliance Officer.

Review of Discretionary Accounts: Each firm Principal or Branch Manager, if applicable, must frequently review all discretionary trading in commodity options by or through associated persons subject to his supervision and should keep written records of such reviews, which records are subject to inspection by the RCM Compliance Department. Discretionary option orders should be identified as discretionary at the time of entry and approved by the branch manager or office principal.

Time-Stamping: Pursuant to Rule 1.35 option orders will be time-stamped upon receipt from customer, upon transmittal for execution, upon receipt of the fill or unable.

Deep-out-of-the-money Options: RCM does not encourage the solicitation of deep-out-of-the-money options. In the event a customer chooses to place a deep-out-of-the-money option order, the CFTC required disclosure document which is acknowledged by the customer clearly states that the chance of such an option becoming profitable is ordinarily remote. On the other hand, the grantor of a deep-out-of-the-money option is informed that such grantor will receive a small premium while exposing the grantor to all of the potential losses described in the disclosure statement. In the event an associated person chooses to recommend a deep-out-of-the-money transaction, the associated person should plainly inform the customer of the information set forth in the disclosure document about deep-out-of-the-money options, with specific reference the deep-out-of-the-money definition for the specific contract recommended.

Random Option Exercise Allocation: RCM will allocate notices of exercise received by the various exchanges in a fair and non-preferential manner. Additionally, once the associated person or office principal receives notice of an option exercise for a customer the associated person or office principal must promptly notify the customer of the allocation.

Incorporation of Rules and Regulations: This manual incorporates by reference, the specific Rules and Regulations of the CFTC, NFA and the various exchanges relating to options transactions, as though they were set forth in full in this document. RCM and the RCM Compliance Department, upon request, would be pleased to provide assistance in order to help all personnel in understanding the mechanics of options trading, order entry procedures and the applicable rules and regulations. Above all, however, it is incumbent upon all supervisory personnel to assure that all communications with customers are informative, accurate and not fraudulent or characteristic of high pressure sales tactics.