Important Information Regarding your Account

Mirae Asset Securities (USA) Inc. (“Mirae” or the “Firm”) is a broker/dealer registered with the Securities and Exchange Commission (“SEC”) and is a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Mirae is a wholly owned subsidiary of Mirae Asset Securities Co., Ltd., a financial services institution based in Seoul, South Korea.

Please read the following information carefully in connection with your account(s) with Mirae.

Privacy Policy: Privacy is Important to Us

At Mirae, we understand that our relationship with you is based on trust. This is reflected in everything we do, including how we handle nonpublic information that comes into our possession, which may include personal information of the principals and employees of our institutional clients (we do not have natural persons as clients). The following disclosure explains what personal information we may receive from individuals acting on behalf of our institutional clients, what we do with that information and the steps we take to protect the nonpublic personal information that we may receive.

Information We May Receive

From time to time, we may receive personal information through any of the following means:

• Our interaction with individuals on the telephone, in person or through e-mail
• Account Applications or other forms individuals complete
• Transactions in accounts for which individuals have trading authority
• Our website or the websites of our affiliated companies
• Trading tools or other information tools we may make available
• Third parties with whom we deal to verify information we receive from individuals

It is the policy of Mirae’s businesses that collect U.S. Social Security numbers in the course of business to:

• Protect the confidentiality of such Social Security numbers;
• Prohibit the unlawful disclosure of such Social Security numbers; and
• Limit access to such Social Security number to those employees who need to know.

Protecting Information

It is Mirae’s policy not to disclose any nonpublic personal information to third parties without consent, unless those parties are providing services or support to us and have agreed to keep such nonpublic personal information confidential. Examples of these parties include the company we use to prepare and mail account statements or to perform our internal auditing. Mirae may, in certain circumstances, share nonpublic personal information with affiliates (including, without limitation, Mirae Asset Securities Co., Ltd) in order to better serve you. Unless and until you notify Mirae in writing to the contrary, you shall be deemed to have consented to the disclosure of nonpublic personal information between Mirae and its affiliates and their employees and representatives, to the extent permitted by law. These affiliates and their employees and representatives have agreed to hold your nonpublic personal information confidential and to comply with the privacy policy established by Mirae. Mirae also protects nonpublic personal information from access by third parties by maintaining physical, electronic and procedural safeguards. We limit access to information to those employees who are trained in the proper handling of nonpublic information and who need access to the information to perform their job functions.

Where we believe in good faith that disclosure is required under law to cooperate with regulators or law enforcement authorities, including but not limited to any obligations under the USA Patriot Act of 2001, we will disclose such nonpublic personal information only to the extent required. Even if you cease to transact business with Mirae, we will continue to apply the same protections to nonpublic personal information as we did when you represented an active Mirae client.

We trust that this clarifies Mirae’s position regarding confidentiality of nonpublic personal information and we look forward to being of service to you and your clients in the future.

For more information, to find out what personal information we have collected, or to update personal information, please contact our Compliance Officer at (212) 407-1000.

Regulation S-P Disclosure 

The Securities and Exchange Commission’s (“SEC”) Regulation S-P governs the treatment of non-public personal information about individual consumers by financial institutions, including broker-dealers such as Mirae. To the extent that Mirae maintains any accounts subject to Regulation S-P privacy notice, required disclosures will be addressed via our privacy notice disclosure, which can be found at the Mirae general website. Mirae has implemented specific policies and practices with respect to safeguarding the confidentiality and security of customer non-public financial information. Mirae’s employees are instructed to protect such information and are required to comply with these established policies and practices. Mirae considers its privacy responsibilities to be of paramount importance and will continue to vigorously protect the interests of account holders.

Anti-Money Laundering and Customer Identification Program 

Mirae is committed to complying with U.S. statutory and regulatory requirements designed to combat money laundering and terrorist financing. In particular, the USA Patriot Act of 2001 requires all financial institutions to obtain, verify, and record information that identifies each person or entity that opens an account or establishes a relationship with the Firm. What this means for you: when an entity opens an account with Mirae, for certain employees or principals of the entity we will ask for the legal name, address, date of birth (for individuals), identification number (i.e., social security number (for individuals) or EIN (for entities)) and any other information that will allow us to identify such individuals. We may also ask to see other identifying documents as necessary to enable Mirae to verify such identity. For example, we may require a legal entity to provide other information such as the address of its principal place of business and/or local office(s), employer identification number(s), certified articles of incorporation, government-issued business license(s), formational documents (such as a partnership agreement or a trust agreement), and other such information identifying the individuals or entities that exercise ownership or control over (directly or indirectly) of the legal entity. We may also ask for a copy of a driver’s license or government issued passport and/or seek additional personal documentation. Unless Mirae is required to disclose this information pursuant to applicable laws, rules or regulations, Mirae will otherwise retain this information and documentation in confidence according to our Privacy Policy. If all required documentation or information is not provided, Mirae may be unable to open an account or establish a relationship with you.

Section 311 Notice (Prohibited Accounts)

Pursuant to U.S. regulations issued under Section 311 of the USA Patriot Act, 31 CFR 103.193, Mirae is prohibited from establishing, maintaining, administering or managing correspondent account for, or on behalf of entities and/or in a jurisdiction designated as a primary money laundering concern through a rule issuance by FinCEN. As a matter of policy, Mirae will not conduct business related to such “311 entities” for which FinCEN has issued a notice of finding, notice of proposed rulemaking or final rule. For the most recent list of 311 Entities please refer to the FinCEN website: https://www.fincen.gov/

Large Trade Identification 

SEC Rule 13H (“Large Trader Rule”) requires that Mirae asks clients whether they qualify as a “large trader” and, if so, to provide their SEC-designated Large Trader Identification Number (“LTID”). For purposes of Rule 13h-1, the term “large trader” includes persons that directly or indirectly exercise investment discretion over one or more accounts and effect transactions for the purchase or sale of any NMS security by or through one or more registered broker-dealers, in an aggregate amount equal to or greater than:

(a) 2 million shares or shares with a fair market value of $20 million during any calendar day; or

(b) 20 million shares or shares with a fair market value of $200 million during any calendar month.

In connection with the foregoing, we kindly ask that you provide the following information via email to newaccounts@miraeasset.us.com

• The Legal Entity Name
• Your LTID or, if you are not required to have an LTID, confirm as such
• If there are any other large traders associated with your firm, the name and LTID of such other associated large trader

Extended Hours Trading Risk Disclosure – FINRA Rule 2265 

Mirae may execute a customer order outside of regular trading hours should the customer specifically request such facilitation. Clients should consider the following points before placing orders for execution during extended hours trading. “Extended hours trading” means trading outside of “regular trading hours.” “Regular trading hours” generally means the time between 9:30 a.m. and 4:00 p.m. Eastern Standard Time. Investors should be aware that the rules governing the various markets and venues that conduct extended-hours trading vary and may differ significantly from rules that apply during regular trading hours. While extended-hours trading may present investment opportunities, investors should consider the following risks before engaging in extended-hours trading:

• Risk of Lower Liquidity. 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 customers to buy and sell securities, and as a result, customers are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular market hours. As a result, your order may only be partially executed, or not at all.
• 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 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 than you would during regular market hours.
• Risk of Changing Prices. The prices of securities traded in extended hours trading may not reflect the prices either at the end of the regular market hours, or upon the opening the next morning. As a result, you may receive an inferior price in extended hours trading than you would during market hours.
• Risk of Unlinked Markets. Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended hours system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, you may receive an inferior price in one extended hours trading system than you would in another extended hours trading system.
• Risk of News Announcements. Normally, issuers make news announcements that may affect the price of their securities after regular market hours. Similarly, important financial information is frequently announced outside of regular market hours. In extended hours trading, these announcements may occur during trading, and if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of a security.
• Risk of Larger Spreads. The spread refers to the difference in price between what you can buy a security for and what you can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security.
• Risk of Lack of Calculation or Dissemination of Underlying Index Value or Intraday Indicative Value (“IIV”). For certain Derivative Securities Products, an updated underlying index value or IIV may not be calculated or publicly disseminated in extended trading hours. Since the underlying index value and IIV are not calculated or widely disseminated during the pre-market and post-market sessions an investor who is unable to calculate implied values for certain Derivative Securities Products in those sessions may be at a disadvantage to market professionals.
• Risk of Order Handling. Some rules that apply to the handling of orders during regular trading hours do not apply to orders in extended-hours trading. Investors should check with their brokerage firms to determine how orders placed during extended-hours trading are handled, including the markets to which the firm routes orders and whether or not the firm seeks to route each order to the best displayed price. In addition, consolidated quote and trade data for a stock that is available during regular trading hours may not be readily available during extended-hours trading.
• Risk of Requirements of Limit Orders. With respect to extended-hours trading, many brokerage firms currently accept only limit orders in order to protect investors from unexpectedly bad prices. Limit orders can be executed only at the limit price or better. If the market moves away from the limit price, the order will not be executed.
• Risk of Order Time Limit. Investors should check with their brokerage firms to see whether orders not executed during extended-hours trading will be cancelled or whether they will be automatically entered when regular trading hours begin. Similarly, investors should also check with their brokerage firms to see if orders placed during regular trading hours will carry over to extended-hours trading.
• Risk of Competition with Professional Traders. Investors should note that many of the extended-hours traders are professional traders who, by nature of their profession, generally have access to more information than individual investors.

Held and Not Held Orders 

Absent specific instructions to the contrary, Mirae understands that when an institutional customer places an order with us, it is directing that we handle the order on a “not held” basis. This means the client is giving us discretion to use our judgment on the time, price, and manner in which the order is executed, so that we may seek to obtain best execution that are reasonably available within market conditions.  “Not-held” orders give us the flexibility and discretion to act in your best interest by working your order to seek to obtain the best execution possible. Mirae believes that by exercising appropriate judgment and price and time discretion with respect to your order, it can achieve the best execution possible under the circumstances.  Institutional client orders transmitted via FIX or other protocol and not designated as “held” or “not held” will be handled as “not held.”

If the order is to be executed on a “held” basis, the client must identify it as such at the time of entry. We will immediately execute any market order at the then prevailing market price and any limit order at or better than your limit price if possible. In addition, where an order is executed in more than one transaction, our policy is for the confirmation of such transactions to indicate an “average price” instead of the price of each partial execution.

Market Access Disclosure – consistent with the obligation to maintain a fair and orderly market, Mirae reserves the right to reject an order based on its systemic controls required pursuant to SEC Rule 15c3-5. The Rule requires broker-dealers with market access or that provide market access to their customers to “appropriately control the risks associated with market access so as not to jeopardize their own financial condition, that of other market participants, the integrity of trading on the securities markets, and the stability of the financial system.

Investor Education and Protection Disclosure – FINRA Rule 2267 

The Financial Industry Regulatory Authority runs a public disclosure program known as BrokerCheck that provides information about brokerage firms and their registered persons. To obtain an investor brochure that includes information about BrokerCheck or to obtain additional information, contact the FINRA public disclosure hotline at (800) 289-9999 or visit the BrokerCheck website at http://brokercheck.finra.org/. FINRA’s general website is located at www.finra.org/.

Disclosure of Control Relationship with Issuer – FINRA Rule 2262  

Under Rule 2262, a member controlled by, controlling, or under common control with, the issuer of any security, shall disclose to a customer the existence of such control.  Mirae is under common control with Global X Management Company LLC, the registered investment adviser to Global X Funds, and is under common control with Horizon ETFs Management (Canada) Inc., the registered investment advisor to Horizon Exchange Traded Products.

Disclosure of Order Routing Information – Securities Exchange Act Rule 606  

The Rule requires broker-dealers that route customer orders in national market system (“NMS”) securities to make publicly available quarterly reports that disclose venues to which they routed “held” or “not held” orders on its website https://miraeassetsecuritiesus.com/ pursuant to and as described in SEC Rule 606(a)(1). Mirae will furnish, upon customer request, a written copy of the quarterly report. Mirae will also furnish, upon customer request and pursuant to SEC Rule 606(b)(2), a report on the order routing information described in SEC Rule 606(b)(1). The rule also requires broker-dealers to disclose the nature of any relationship they have with those venues, including payment for order flow arrangements.

Erroneous Executions – Bonafide errors can result from human error or system issues that affect the execution of an order. Such errors can occur at Mirae or can occur outside of Mirae at an exchange, ATS or at other market centers utilized by Mirae in connection with the execution of the order. Such errors can also result from general market volatility, communications or system breakdowns or other conditions over which Mirae has no control. Mirae reserves the right at its sole discretion to cancel or price adjust any trade that id deemed by Mirae to have been the result of an error, including the result of any of the above or an incorrect security symbol or name, size and/or prices that are unrelated to the market. Mirae also reserves the right at its sole discretion to cancel any execution that was effected based upon incorrect or unreliable market data. In the event that Mirae exercises this right, the Firm will use reasonable efforts to inform its clients in a timely manner.

Statement of Policy Regarding Payment for Order Flow – Securities Exchange Act Rule 607

Mirae is required by the SEC to disclose to new customers, and annually to all customers, its policies regarding the practice of receiving “payment for order flow,” the nature of order routing policies for orders subject to payment for order flow and the degree to which these orders can receive price improvement. The SEC generally defines “payment for order flow” to include any cash or non-cash compensation received by a broker or dealer from another broker or dealer, national securities exchange, registered securities association or exchange member in return for sending customer orders to such entities for execution.

Mirae may receive remuneration for directing orders to a particular broker-dealer and routes orders to market centers including national securities exchanges, alternative trading systems, electronic communications networks and other broker-dealers that offer credits for certain types of orders while assessing fees for other types of orders. Mirae’s routing decisions are based on a number of factors, including but not limited to, price, liquidity, venue reliability, cost of execution, likelihood of execution and potential for price improvement. In some cases, the credits offered by a market center will exceed the charges assessed such that a market center makes a payment to Mirae in relation to orders directed to such market center. Such remuneration is considered compensation to Mirae and the source and amount of any compensation will be disclosed upon written request.

Fail to Deliver Securities – SEC Rule 204 of Regulation SHO requires the delivery of equities sold long or short on settlement date. In compliance with the terms of the Rule, any fail-to-deliver position must be closed out by the opening of trading on the settlement day following the settlement date for short sales, and the third consecutive settlement day following the settlement date for long sales. While Mirae will use its best efforts to minimize the impact of any fails, we may be required to purchase shares from another source to cover your position should you not deliver the necessary shares by settlement. If we must effect a buy-in of the securities that were not delivered timely, you will be responsible for all losses and costs of the buy-in. By placing an order to sell a security you agree to be responsible for any cost or loss Mirae may incur in obtaining the securities. You appoint us, as agent, to complete all such transactions and authorize us to make advances and expend monies as are required. With respect to short positions maintained by you over a corporate action record date, we will, on the relevant payment date for such corporate action, if any, charge your account for money or property equal in value to the cost of such corporate action attributable to your short position, including the costs of any lost tax benefits for the lenders.

You are ultimately responsible for the delivery of securities on the settlement date, the consequences of a failure to deliver and the timely return of securities borrowed on your behalf and all costs associated with such borrowings, including costs relating to any corporate actions.

Transactions in Microcap Securities – Mirae has in place a Microcap Securities Policy that prohibits dealing in U.S. securities that fall into the four categories below. This prohibition applies to the execution, clearing, and custody services involving microcap securities. Mirae will not accept any orders or new positions in microcap securities, unless an exception is granted by Mirae’s Credit Risk and Compliance teams.

For purposes of this policy, “microcap securities” are defined as:

1. Securities that meet all the following three criteria:
   1. are not listed on a U.S. national exchange such as the NYSE or NASDAQ and instead are quoted on OTC systems, such as the OTCBB or OTC Link LLC;
   2. have a share price $5 or less; and
   3. have a market capitalization of $300MM or less; OR
2. Securities that are assigned the “Shell Company” designation*; OR
3. Securities that are assigned the “Expert Market**” designation*; OR
4. Securities that are assigned the “Caveat Emptor” designation*

*Note: The designations in the last three categories are assigned by www.otcmarkets.com

**Note: An Expert Market in the OTCBB is a market just for broker-dealers. Only broker-dealers and sophisticated investors can view quotations. It is similar to the Grey Market, except that the Expert Market allows for unsolicited quoting of companies not current in their filings.

Risks Associated with Investing in Low-Priced Exchange-Listed Securities – Customers should be aware that investing in low-priced securities (below $5.00) may present considerable economic risks even if the securities are listed on an exchange. Securities and Exchange Commission (“SEC”) rules require broker-dealers to provide specific risk disclosures to customers who invest in so-called “penny stocks” that trade over-the-counter (“OTC”) and are not listed on an exchange. These risk disclosures are not required for low-priced securities that are exchange-listed, even though the same risks—such as high volatility, low liquidity, information gaps, overvaluation, dilutive financings, insolvency (or limited assets/lack of capital), and potential fraud concerns—may apply to such stocks. In addition, customers should be aware that a company’s stock may continue to trade on an exchange long after the company fails to meet the exchange’s minimum listing standards.

Specifically, customers should be aware that depending on the exchange and its rules, its delisting process can take many months—and possibly longer— to complete, during which the company remains listed on the exchange even though it has fallen below the exchange’s minimum listing standards.

Moreover, some exchange-listed companies faced with delisting may use corporate actions to avoid or delay potential delisting by temporarily regaining compliance with the exchange’s listing standards. For example, some exchanges require companies to maintain a minimum bid or share price of $1.00 as part of the exchange’s continued listing standards. A company that approaches a $1.00 bid or share price (or lower) may engage in a reverse stock split (or multiple reverse stock splits if the company’s share price repeatedly drops below $1.00), raising its stock price above $1.00 and reducing the number of overall outstanding shares. These actions could allow a company to remain listed on the exchange even though its underlying financials have not improved.

Notably, FINRA has repeatedly cautioned investors about the potential risks associated with low-priced securities and reverse stock splits, observing that if “a reverse split is announced and actually occurs, proceed with caution.

Reverse splits tend to go hand in hand with low-priced, high-risk stocks. This is especially true with reverse splits that result in a post-split share price that is many times the price of the stock’s current price.”

If you have any questions about this disclosure or the risks of investing in low-priced securities, please contact us.

Prohibition Against Trading Ahead of Customer Orders – FINRA Rule 5320  

In the section above entitled Held and Not Held Orders, we note that Mirae presumes orders from our institutional customers are not held unless you specify otherwise. Please note that such not held orders are not subject to the protections of FINRA Rule 5320.

Rule 5320 generally prohibits Mirae from trading for its own account in an NMS stock or OTC equity security at a price that is equal to or better than an unexecuted held customer order, unless Mirae immediately thereafter executes the customer order up to the size and the price (or better) at which we executed our own order.

The Rule provides an exception for large-sized orders (orders of 10,000 shares or more with a total value of $100,000 or more) and/or orders for “institutional accounts.” For such orders, the Firm may trade a security on the same side of the market for its own account at a price that would satisfy the customer’s held order.

You may opt in to the protections of FINRA Rule 5320 with respect to all or any portion of your orders by notifying us of your objection to Mirae trading along with your orders by mail to Mirae Asset Securities (USA), Inc., 810 7th Avenue, New York, NY 10019 Attn: Compliance Department.

You may also notify us on a trade-by-trade basis that you object to our trading along with your order. If we do not receive any objection, we will presume that you consent to our trading activity.

Long/Short and Short Exempt Disclosure – When placing any order to sell securities short (“SS”) or short exempt (“SSX”) for your account, you are responsible for designating the order as such, and you hereby authorize Mirae to mark the order as SS or SSX as appropriate. Unless otherwise agreed to by Mirae, you are responsible to secure your own locate and agree to provide Mirae with information concerning any securities borrowing arrangements made by you and/or your prime broker in connection with any short sales. If you have designated a given prime broker as a locate source, we will document and rely on that source in our order records unless we receive specific instructions from you to the contrary.

Front Running of Block Transactions 

FINRA Rule 5270 – Rule 5270 prohibits a broker-dealer from trading for its own account while having material, non-public market information (“MNPI”) concerning an imminent block transaction in a security, a related financial instrument, or a security underlying the related financial instrument prior to the time information concerning the block transaction has been made publicly available or has otherwise become stale or obsolete. FINRA Rule 5270 permits certain exceptions to the foregoing prohibition, including transactions that are undertaken to fulfill or facilitate the execution of a client block order. For example, the Rule does not preclude a broker-dealer from trading for its own account for purpose of fulfilling or facilitating the execution of a client’s block transaction. In connection with the handling of a client’s block order, Mirae may engage in hedging or other risk-mitigating transactions that may occur at the same time or in advance of this order. This hedging activity may materially impact the market prices of the securities or financial instruments a client is buying or selling. Mirae conducts this trading in a manner designed to limit market impact and consistent with our best execution obligations to our clients and will refrain from conduct that could disadvantage or harm the execution of a client’s orders or that would place Mirae’s financial interests ahead of its client’s interests. Unless a client informs Mirae otherwise in writing (“opt out”), the Firm will conclude that the client understands that Mirae may engage in risk-mitigating transactions in connection with client orders and the Firm will conclude that the client has given its consent to Mirae to handle block transactions as described above. A client may choose to opt out by providing written notice to the Mirae Compliance Department at:

Mirae Asset Securities (USA) Inc.
810 7th Avenue, 37th Floor
New York, NY 10019
ATTN: Chief Compliance Officer

Fractional Share Trading Disclosure

Fractional share trading is generally available for exchange-listed National Market System (“NMS”) securities.  Fractional share trading functionality allows you to buy and sell fractional share quantities and dollar amounts of certain securities (“Fractional Trading”). Fractional Trading presents unique risks and has certain limitations that you should understand before placing your first trade.

Mirae may facilitate the holding or trading of a fraction of a share of a security (“Fractional Shares”) in your Account. You acknowledge and understand that Mirae rounds all trading of Fractional Shares to the sixth decimal place, the value of Fractional Shares to the nearest cent, and any dividends paid on Fractional Shares to the nearest cent. You understand that Mirae will not accept U.S. dollar-based purchases or sales of less than $0.01 and that you will receive proceeds from the sale of any whole or Fractional Shares rounded to the nearest cent.

All orders with a fractional share component will be marked “Not Held,” which gives Mirae the time and price discretion to execute the order without being held to the security’s current quote. In connection therewith, each time you submit an order to buy or sell a fractional share quantity or dollar amount of a particular security, you authorize Mirae to “work the order.” If you do not wish your order to be handled on a Not Held basis, you should not engage in Fractional Trading. You understand that when Mirae executes Fractional Orders utilizing inventory held in its principal account, the portions of such Fractional Orders that execute against inventory are executed in a principal capacity. To the extent that Mirae must purchase or sell whole shares in the market to fill any portion of your Fractional Order, that portion of the order may be executed under agency or principal capacity. To the extent that Mirae fills any portion of your Fractional Order out of inventory rather than by purchasing or selling shares in the market (“Inventory Fulfillment”), Mirae will attempt to price that portion of your Fractional Order at a price of the National Best Bid and the National Best Offer (“NBBO”) at the time of execution for orders executed. Due to rounding and price movements, the actual share amount received may differ from the estimated order quantity.

Trade Execution

For a variety of reasons, the actual amount of an executed dollar-value trade may be different from the requested amount. The actual amount of an executed order to buy or sell a dollar value of a security may also be lower than the amount requested due to the deduction of certain fees (e.g., the Additional Assessment) or taxes. Orders received in good form by Mirae will be accepted and transmitted for execution. You may attempt to cancel an order, but there is no ability to request that an order be “cancelled and replaced” (i.e., you cannot modify an order once it has been submitted). Instead, you will need to cancel your order and then submit a new one.

Your ability to buy or sell a security using Fractional Trading may be more restricted than if you were to buy or sell traditional whole share quantities of the same security.   Certain securities are not eligible for fractional trading. Mirae supports market and limit orders only for fractional share trading of a security that are good for that day’s trading session, or in the case of an order entered outside of market hours, that are good until the close of the next trading session.

You acknowledge that, subject to applicable requirements, Mirae may report transactions in your Account in terms of either U.S. Dollars, shares, or both.

Trading Halts

Trading on a particular security, or in the market as a whole can be halted for a variety of reasons. In the event of a trading halt of a security, or if the market overall is experiencing a trading halt, Fractional Trading of that security will also be halted, and your order will be held until trading resumes. You will have the option to cancel pending fractional orders, but the cancel requests won’t be processed until the halt is lifted.  Your order is good only for that day’s trading session, or in the case of an order entered outside of market hours, good until the close of the next trading session. If trading does not resume or your order is not executed by the close of that day’s Fractional Trading window, it will be cancelled.

Risks

Fractional Trading presents unique risks and has certain limitations that you should understand before placing your first trade. You should review and understand these risks and limitations before engaging in Fractional Trading. More information about order types is available at:  https://www.sec.gov/oiea/investor-alerts-and-bulletins/ib_ordertypes.

Suitability and Appropriateness 

Certain securities or financial instruments may not be suitable or appropriate for all investors or in all geographical areas. Depending on the needs, investment objectives and financial situation of your institution, your institution must make its own independent decisions regarding any securities or financial instruments purchased and sold. Moreover, the institutional customer exception to the suitability requirements focuses on two factors: (1) whether a broker “has a reasonable basis to believe the institutional customer is capable of evaluating investment risks independently, both in general and with regard to particular transactions and investment strategies involving a security or securities”, and (2) whether “the institutional customer affirmatively indicates that it is exercising independent judgment”.

The fact that Mirae has made available to you investment opinions and other information constitutes neither a recommendation that you enter into a particular transaction nor a representation that any financial instrument is suitable or appropriate for you. You should consider whether an investment strategy or the purchase or sale of any product is appropriate for your institution in the light of its particular investment needs, objectives and financial circumstances. You hereby acknowledge (i) that Mirae has a reasonable basis to believe that your entity is capable of evaluating investment risks independently, both in general and with regard to particular transactions and investment strategies involving a security or securities, and (ii) that your institution is exercising independent judgement about the instruments it transacts in and that your institution is a sophisticated investor that has sufficient knowledge and experience in financial and business matters and is capable of evaluating the merits and risks of any prospective investment or transaction.

Mirae may trade or make markets for its own account on a principal basis in any securities referenced herein. We may also engage in securities transactions that are inconsistent with this communication and may have long or short positions in such securities.

Margin Disclosure Statement – FINRA Rule 2264

Securities purchased on margin 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 or other assets in any of your accounts, 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.
• The Firm can force the sale of securities or other assets in your account(s).
• The Firm can sell your securities or other assets without contacting you.
• You are not entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call.
• The Firm can increase its “house” maintenance margin requirements at any time and is not required to provide you advance written notice.
• You are not entitled to an extension of time on a margin call.

Money Market Service, Support, and Operating Costs 

Money market funds typically bear ongoing fees and expenses to operate their business. These fees can include management fees, 12b-1 fees, shareholder services fees, and other expenses. These costs are deducted from a fund’s assets, reducing investment returns. Many money market funds, including Dreyfus, pay a 12b-1 fee that compensates third parties (including Mirae) for distribution activities and/or shareholder servicing. In addition, a financial institution, such as Mirae, may also provide shareholder services, processing of purchases, redemptions and exchanges, dividend reinvestment, consolidated account statements, and tax reporting and/or marketing services and support to its clients that are invested in the money market funds.

Mirae offers money market mutual funds distributed by Dreyfus. In general, money market funds are offered to meet the liquidity needs of clients, but, unlike bank deposits, money market funds are not insured or guaranteed by the Federal Deposit Insurance Corporation (FDIC) or any government agency. Although money market funds seek to preserve the value of your investment at $1.00 per share, it is possible to lose money by investing in a money market fund. In general, money market funds are designed and managed with the investment objective of preservation of capital, maintenance of liquidity, and generation of high current income.

U.S. Treasury Circular 230 Tax Notice 

Mirae does not render advice on tax and tax accounting matters to clients. This communication and any other communications between Mirae and you are not intended or written to be used, and it cannot be used by any taxpayer, for the purpose of avoiding penalties that may be imposed on the taxpayer under U.S. federal income tax laws. Investors should consult their own legal, tax investment or other advisors, at both the onset of any transaction and on an ongoing basis to determine the laws and analyze applicable to their specific circumstances.

SIPC Disclosure 

Mirae, as a member of SIPC and pursuant to FINRA Rule 2266, discloses to new customers, and annually to all customers, that they may obtain information about SIPC, including the SIPC brochure, by contacting SIPC at the following address or visiting their web site at WWW.SIPC.ORG.

Securities Investor Protection Corporation
805 Fifteenth Street NW, Suite 800
Washington, DC 20005-2215
Tel. (202) 371-8300

Information Concerning Mirae’s Business Continuity Plan 

Mirae has developed a business continuity plan to address how it will respond to events of varying scope that may significantly disrupt its business, in an effort to provide continuity of critical business functions. Such critical business functions include entering of client orders, completing securities transactions and providing clients with access to their cash and securities. Since the timing and impact of disasters and disruptions is unpredictable, Mirae will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our Business Continuity Plan, which is designed to describe the actions Mirae will take in the event of a significant business disruption.

Contact – If after a significant business disruption, you cannot contact us as you usually do, you should call our general number (212) 407-1000. If you cannot access Mirae through either of those means, you should visit Mirae’s website at https://miraeassetsecuritiesus.com/.

Mirae’s Business Continuity Plan – Mirae plans to quickly recover and resume business operations after a significant business disruption and respond by safeguarding it employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing its customers to transact business. In short, Mirae’s business continuity plan is designed to permit the firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Mirae’s Business Continuity Plan is designed to address the following: Data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counterparty impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business. Mirae backs up important records in a geographically diverse area from that of Mirae’s own servers. While every emergency situation poses unique challenges, based on external factors such as time of day and the nature or severity of the disruption, the objective of Mirae’s Business Continuity Plan is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within four (4) hours. Customer orders and requests for funds could be delayed during this period.

Varying disruptions – Significant business disruptions can vary in their scope and severity, such as those that may affect only the building housing Mirae’s operations, or the business district where Mirae is located, the city where Mirae is located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. Mirae’s recovery time objective for business resumption, including any necessary relocation of personnel or technology, is four (4) hours. This recovery objective may be negatively affected by the unavailability of external resources and circumstances beyond Mirae’s control. In particular, while Mirae’s business continuity plan has been reasonably designed to allow the firm to operate during emergency incidents of varying scope, these potential incidents are unpredictable. Mirae has no control over certain infrastructure such as utilities, communication networks, transportation, and third-party providers upon which Mirae may rely during an emergency. In the event of a significant disruption, we plan to notify you through our website, https://miraeassetsecuritiesus.com/. If the significant business disruption is so severe that it prevents Mirae from remaining in business, the firm will assure our customers prompt access to their funds and securities.

For more information – if you have questions about Mirae’s business continuity planning, please contact the firm at (212) 407-1000.

Customer Complaints – In accordance with SEA Rule 17a-3(a)(18)(ii), please be advised that any complaints may be directed to the following:

Mirae Asset Securities (USA) Inc.
810 7th Avenue, 37th Floor
New York, NY 10019
ATTN: Chief Compliance Officer
(212) 407-1000

Your California Privacy Rights 

California Civil Code Section 1798.83 permits users of the client website who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Under California law, California residents are entitled to ask us for a notice identifying the categories of personal customer information that we share with our affiliates and/or third parties for marketing purposes, and provide contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to:

Mirae Asset Securities (USA) Inc.
810 7th Avenue, 37th Floor
New York, NY 10019
ATTN: Mirae California Privacy Requests
newaccounts@miraeasset.us.com

Do Not Track 

While many current browsers permit you to send a signal to us about your Do Not Track (“DNT”) preferences, we do not respond to DNT signals sent from your browser.

International Users 

Mirae makes no claims that your content uploaded may be appropriately protected pursuant to privacy and data protection laws outside of the United States. Users from outside the United States, including the European Union, are advised that Mirae stores personal information on servers within the United States, and they are further advised that personal information uploaded to the website may not be protected in accordance with their local laws and regulations. If you upload personal information to the client website from outside the United States, you do so at your own risk. (co.) is not responsible for compliance with the laws of your jurisdiction and makes no representations, warranties or guarantees that it complies with privacy, data protection or cyber security laws or similar laws or regulations outside the United States.

YOU ARE ADVISED TO PROMPTLY REPORT ANY INACCURACY OR DISCREPANCY IN YOUR ACCOUNT (INCLUDING UNAUTHORIZED TRADING) TO MIRAE. PLEASE BE ADVISED THAT ANY ORAL COMMUNICATION SHOULD BE RECONFIRMED IN WRITING TO FURTHER PROTECT YOUR RIGHTS, INCLUDING YOUR RIGHTS UNDER THE SECURITIES INVESTOR PROTECTION ACT. MIRAE’S CONTACT INFORMATION IS AS FOLLOWS:

MIRAE ASSET SECURITIES (USA) INC.
810 SEVENTH AVENUE
37^th FLOOR
NEW YORK, NY 10019
TEL: (212) 407-1000

By accessing, browsing, and/or using this Website or linked websites and any pages hereof, you are indicating that you have read, acknowledged and agreed to be bound by this Disclaimers section and the Terms of Use section at (hyperlink). All persons and entities accessing the Website agree to do so on their own initiative and are responsible for compliance with applicable local laws and regulations.

This Website is for information purposes only and is not intended to be relied upon as a forecast, research or investment advice. The information on this Website does not constitute a recommendation, offer or solicitation to buy or sell any securities or to adopt any investment strategy. Although this material is based upon information that Mirae considers reliable and endeavors to keep current, Mirae does not assure that this material is accurate, current or complete, and it should not be relied upon as such. Any opinions expressed on this Website may change as subsequent conditions vary. Past performance is no guarantee of future results.

Nothing contained on this Website constitutes tax, accounting, regulatory, legal, insurance or investment advice. Neither the information, nor any opinion, contained on this Website constitutes a solicitation or offer by Mirae or its affiliates to buy or sell any securities, futures, options or other financial instruments, nor shall any such security be offered or sold to any person in any jurisdiction in which such offer, solicitation, purchase, or sale would be unlawful under the securities laws of such jurisdiction. Decisions to act or not act that may be based on information contained on this Website are the sole responsibility of the visitor.

The investments and strategies discussed in the Website may not be suitable for all investors and are not obligations of Mirae or its affiliates or guaranteed by Mirae or its affiliates. Mirae makes no representations that the contents are appropriate for use in all locations, or that the transactions, securities, products, instruments, or services discussed on this site are available or appropriate for sale or use in all jurisdictions or countries, or by all investors or counterparties. By making available information on the Website, Mirae does not represent that any investment vehicle is available or suitable for any particular user.

All investments involve risk and may lose value.

The value of your investment can go down depending upon market conditions. BEFORE ACQUIRING THE SHARES OF ANY INVESTMENT FUND BY PURCHASE OR EXCHANGE, IT IS YOUR RESPONSIBILITY TO READ THE FUND’S PROSPECTUS OR OFFERING MATERIALS.

You expressly acknowledge that you have checked and confirm that you; (i) are over eighteen (18) years of age and, are legally entitled to view this website; (ii) understand that any products mentioned on the website may no longer be available for investment or may not be available to you; and (iii) understand that the information on the website is not a promotion and that you will not treat it as such and that any information on the website is not addressed specifically to you.

Indemnification: As consideration for the provision of this website by Mirae, the visitor agrees to indemnify, defend and hold Mirae, its officers, directors, employees, affiliates, agents, licensors and suppliers harmless against any and all claims, losses, liability, costs and expenses (including but not limited to attorneys’ fees) arising from your use of this Website, from your violation of this Section or from any decisions that the visitor makes based on such information.​

Disclosure of Order Routing Information

Disclosure Statement made Pursuant to Rule 606 of the Securities Exchange Act of 1934

Mirae has prepared the following reports pursuant to Rule 606 of the Securities Exchange Act of 1934 and any other applicable rules (the “Rule” or the “Rules”). Mirae has made every reasonable attempt to prepare these reports in compliance with Rules. Although the information herein has been obtained from sources believed to be reliable, these reports have not been audited and may contain errors, inadvertent omissions, or the like. Accordingly, Mirae does not guarantee its accuracy, completeness, or fairness. From time to time, Mirae may become aware of systems or other errors that may affect the information provided in the reports but that cannot be corrected before publication. Mirae may, in its discretion, revise and republish this report and/or previous reports for prior periods. All reports, original and amended, are available upon request.

Further, Mirae disclaims all liability, including without limitation direct, indirect, punitive, special, consequential, or incidental damages on behalf of ourselves and our affiliates with regard to financial results or damages that may arise from the use of the information and data herein, any errors contained in the reports or any inability to access or use these reports. The information provided in the report may be impacted by market data system outages or errors, both internal and external, and it is dependent upon the integrity and accuracy of the data provided by outside sources. This information, including these disclaimers, applies to the current reports, previously published reports, and any revised reports in their entirety, irrespective of whether the reports are used or viewed collectively or individually, in whole or in part. The information and data provided in the reports is not intended to and do not reflect all factors relevant to an analysis of a broker-dealer’s best execution and order routing practices. These statistics capture only a small part of Mirae’s total order flow. The order routing decisions reflected by the statistics in the Report should not be construed as an endorsement of any particular security or market participant. Any decision about whether to open an account or to direct orders to Mirae should be based on analysis of the Firm’s full range of services and not solely based on these statistics.

Mirae does not route orders directly to any execution venues and relies instead on executing brokers to route orders to exchanges and third-party trading centers. Certain equities exchanges and third-party trading centers to which executing brokers route equities orders have implemented fee structures under which broker-dealer participants may receive rebates on certain orders. Under these fee structures, participants generally are charged a fee for orders that take liquidity from the venue and provided a rebate for orders that add liquidity to the venue. Some venues charge a fee for orders that add liquidity to the venue and provide a rebate for orders that remove liquidity from the venue. In either or both cases, rebates received from a venue by execution brokers and passed on to Mirae during any time period may or may not exceed the fees paid by Mirae to the executing brokers during that time period. This does not alter Mirae’s policy to route customer orders to the executing broker and via strategies where it believes clients will receive the best execution, taking into account, among other factors, price, transaction cost, volatility, market depth, quality of service, speed, and efficiency.

Mirae also may or may not enter into a routing arrangement with an executing broker whereby commissions may be reduced or rebates may be increased based on the volume of shares that Mirae routes to an executing broker. This does not alter Mirae’s policy to route customer orders to the executing broker where it believes clients will receive the best execution, taking into account, among other factors, price, transaction cost, volatility, market depth, quality of service, speed, and efficiency.

Fee rates and rebate amounts on any given venue or with any given broker may change periodically. We will provide you additional information regarding fees and rebates on your written request, including the amount per order or per share received by Mirae.

MARGIN LENDING PROGRAM

TRUTH-IN-LENDING DISCLOSURES

When you enter into certain securities transactions (for example, buying securities on margin or entering into short sales), you are borrowing money from Mirae for part of your transaction. Mirae is providing this document to you in conformity with Securities and Exchange Commission Rule 10b-16, which requires any broker or dealer who extends credit to a customer in connection with any securities transaction to furnish the customer with a written statement describing the terms and conditions under which interest will be charged.

Interest Charge Period

For any statement period during which your daily settlement date net debit balance is greater than zero ($0.00) Mirae will impose an interest charge. Interest will ordinarily be calculated from the first (1st) calendar day through the last calendar day of each month and will ordinarily be charged to your margin account on the last business day of each month. On such months where the last calendar day falls on a weekend day or holiday, the charges for those days will be included within the charges posted on the last business day of the month. The statement period may be before a fraction of the normal statement period based on the opening or closing date of your margin account.

Determination of Interest Rates

Unless otherwise disclosed, the margin interest rate charged to you will be an established “Firm Base Lending Rate” (FBLR). Mirae will set the FBLR based on publicly recognized interest rates, as well as an included incremental percentage imposed by Mirae.

Your statement of account will indicate the specific FBLR applied, the average daily net debit balance of your account, the number of days during which a debit balance was outstanding in your account and the actual interest charge made for the charge period. For each charge period in which there is a change in the FBLR, your statement of account will itemize information with respect to each rate of interest that was applied to your account during the charge period. You will be given prior notice of any changes in the terms and conditions under which interest is charged.

Adjustment of Rate Without Prior Notice

Your interest rate is subject to change without prior notice in accordance with changes in the FBLR. If there is a change in the FBLR during the charge period, the rate of interest applied to your account will be automatically increased or decreased accordingly for the remainder of the charge period or until another change in the FBLR occurs.

Calculation of Interest Charges

Any settlement date credit or debit balance in the respective cash account will be combined with the balance in the margin account for the purpose of computing interest. The interest charged to your account is calculated by multiplying any net debit balance each day by the applicable interest rate. A credit balance in any short account will not reduce the average daily debit balance in your margin account because such credit balance is normally used to collateralize the borrowing of stock to make delivery against the short sale. However, short sale positions will be marked to the market daily and such changes resulting therefrom will affect the debit balance in your margin account. Therefore, if such change results in a credit, such credit will be transferred to your margin account as a credit; conversely, if such change results in a debit, such debit will be transferred as a debit to your margin account.

Options

Options can be traded in a margin account and can be used to hedge a leveraged position; however, options cannot be purchased or sold on credit or borrowed against for purchases and credit cannot be extended on options held. Writers of options, other than certain covered call writers and certain writers of cash-secured puts, must comply with the applicable initial equity and maintenance requirements that are set by Mirae, subject to minimum requirements imposed by the Federal Reserve Board and by securities and option exchanges, and other self- regulatory organizations. These requirements vary depending on the underlying interest and the number of option contracts sold. Mirae, the Federal Reserve Board, the securities and option exchanges, and other self-regulatory organizations may increase these requirements at any time without prior notice.

In addition, certain position limits and additional initial equity and maintenance requirements may be imposed from time to time by Mirae after reasonable effort to provide notice. If these limits and additional requirements are not met, Mirae will close out sufficient option contracts to bring the account into compliance with them. All options trading must be pre-approved by Mirae and additional documents and disclosure may be necessary. Options transactions involve certain risks and are not appropriate for every investor. Please refer to your Mirae account opening documentation and disclosures for additional information.

Disclaimer: Options are not suitable for all investors, and trading in these instruments is considered risky and may be appropriate only for sophisticated investors. Past performance is not necessarily indicative of future results. Prior to buying or selling an option, and for a thorough description of risks relating to options, U.S. investors must receive a copy of the ‘Characteristics and Risks of Standardized Options’. You may read the  document  at:  https://www.theocc.com/Company-Information/Documents-and-Archives/Options-Disclosure-Document which includes documents regarding supplemental options information.

Collateral and Lien

Pursuant to agreements which you will have executed or will execute upon opening a margin account with Mirae (including, but not limited to the New Account Agreement) we have or will have a general lien on all monies, securities or other properties that we may at any time may be carrying for you or which may be in our possession for any purpose, including safekeeping, to secure the discharge of all your obligations to us. Notwithstanding the fact that you may have deposited monies, securities or other properties with us sufficient to satisfy the margin requirements under any applicable law, rule or regulation enacted or promulgated by any government regulatory body or authority, Mirae nevertheless expressly reserves the right to require you at any time, and from time to time, to deliver to Mirae such additional collateral as Mirae, in its sole and absolute discretion, may deem necessary to adequately secure Mirae in the discharge of all your obligations to Mirae. Defaults related to your securities borrowing activity will be subject to the relevant default provisions described in your New Account Agreement.

PORTFOLIO MARGIN RISK DISCLOSURE STATEMENT

OVERVIEW OF PORTFOLIO MARGIN

Portfolio margin is a margin methodology that sets margin requirements for an account based on the greatest projected net loss of all positions in a “security class” or “product group” as determined by a model using multiple pricing scenarios. Pricing scenarios for options are based on changes in inputs to a theoretical pricing model, including the underlying price and volatility.

The goal of portfolio margin is to set levels of margin that more precisely reflect actual net risk. The customer may benefit from portfolio margin in that margin requirements that are calculated based on net risk are generally lower than alternative “position” or “strategy” based methodologies for determining margin requirements. Lower margin requirements allow the customer more leverage in an account.

CUSTOMERS ELIGIBLE FOR PORTFOLIO MARGIN

To be eligible for portfolio margin, customers must be approved for writing uncovered options. Customers must have and maintain at all times account equity of not less than one million dollars ($1MM), aggregated across all accounts under identical ownership at Mirae. This identical ownership requirement excludes accounts held by the same customer in different capacities (e.g., as a trustee and as an individual) and accounts where ownership is overlapping but not identical (e.g., individual accounts and joint accounts).

POSITIONS ELIGIBLE FOR A PORTFOLIO MARGIN ACCOUNT

All margin equity securities (as defined in Section 220.2 of Regulation T of the Board of Governors of the Federal Reserve System) and, equity-based or equity-index based listed options, are eligible to be margined in a portfolio margin account at Mirae. Other securities like warrants, swaps, unlisted derivatives are not eligible to be margined in portfolio margin account.

SPECIAL RULES FOR PORTFOLIO MARGIN ACCOUNTS

A portfolio margin customer will have only one margin account with Mirae, and all the customers’ securities will be held in one account with the portfolio margin system applying portfolio margin methodology to only those securities that are deemed portfolio margin eligible. All non-PM, margin eligible assets will be treated in compliance with Regulation T and FINRA Rule 4210; all other collateral held that is not margin eligible will be required to be paid in full.

A portfolio margin account will be subject to a minimum margin requirement of $.375 for each listed option, multiplied by the contracts or instrument’s multiplier, carried long or short in the account. Other eligible products may be subject to a minimum margin requirement.

A margin deficiency in the portfolio margin account or sub-account, regardless of whether due to new commitments or the effect of adverse market movements on existing positions, must be met within one business day from the date the trade is placed (T+1). Failure to meet a portfolio margin deficiency by the end of the business day the call is issued may result in a prohibition on entering any new orders, with the exception of new orders that reduce the margin requirement. Failure to meet a portfolio margin deficiency by the end of the second business day (T+2) may result in liquidation of all positions in the account.

Any shortfall in aggregate equity across accounts, when required, must be met within one business day. Failure to meet a minimum equity deficiency by the end of one business day may result in a prohibition on entering any new orders, with the exception of new orders that reduce the margin requirement. Failure to meet minimum equity deficiency by the end of the second business day (T+2) may result in liquidation of all positions in the account.

SPECIAL RISKS OF PORTFOLIO MARGIN ACCOUNTS

Portfolio margin generally permits greater leverage in an account, and greater leverage creates greater losses in the event of adverse market movements. Because the maximum time limit for meeting a margin deficiency is shorter than in a standard margin account, there is an increased risk that a customer’s portfolio margin account will be liquidated involuntarily, possibly causing losses to the customer.

Because portfolio margin requirements are determined using sophisticated mathematical calculations and theoretical values that must be calculated from market data, it may be more difficult for customers to predict the size of future margin deficiencies in a portfolio margin account. This is particularly true in the case of customers who do not have access to specialized software necessary to make such calculations or who do not receive theoretical values calculated and distributed periodically by an approved vendor of theoretical values.

Trading of margin equity securities, warrants on margin equity securities or on eligible indices of equity securities, listed options, unlisted derivatives on margin equity securities or an eligible index of equity securities, and security futures products in a portfolio margin account is generally subject to all the risks of trading those same products in a standard securities margin account. Customers should be thoroughly familiar with the risk disclosure materials applicable to those products, including the booklets entitled “Characteristics and Risks of Standardized Options” available at the OCC site https://www.theocc.com/Company-Information/Documents-and-Archives/Options-Disclosure-Document. Because this disclosure statement does not disclose the risks and other significant aspects of trading in security futures and options, customers should review those materials carefully before trading these products in a portfolio margin account.

Customers should consult with their tax advisers to be certain that they are familiar with the tax treatment of transactions in margin equity securities, warrants on margin equity securities or on eligible indices of equity securities, listed options, unlisted derivatives on margin equity securities or an eligible index of equity securities, and security futures products, including tax consequences of trading strategies involving both security futures and option contracts.

The descriptions in this disclosure statement relating to eligibility requirements for portfolio margin accounts, and minimum equity and margin requirements for those accounts, are minimums per Mirae rules. Mirae reserves the right to increase requirements at any time.

Customers should bear in mind that the discrepancies in the cash flow characteristics of certain options are still present even when those products are carried together in a portfolio margin account. All positions in portfolio margin accounts are generally marked to the market at least once each business day. However, there may be incongruity between the marking to the market of each eligible product in that marks may take place with different frequency and at different times within the day. While a change in the value of a long option contract may increase or decrease the equity in the account, the gain or loss is not realized until the option is liquidated, exercised, or assigned. Accordingly, a customer may be required to deposit cash in the account in order to meet a variation payment even though the customer is in a hedged position and has experienced a corresponding (but yet unrealized) gain on an option. Alternatively, a customer who is in a hedged position and would otherwise be entitled to receive a variation payment may find that the cash is required to be held in the account as margin collateral on an offsetting option position.

The general provisions governing portfolio margin (including definitions used in this document) are set forth in FINRA

Rule 4210(g) which can be found at www.finra.org

OPTIONS DISCLOSURE STATEMENT

PLEASE NOTE – If you are completing any sections of the “New Account Application and Agreement” of Mirae that relate to trading in options, then this Options Disclosure Statement shall be deemed part of your account opening documentation and shall be legally and contractually binding.

DO NOT SIGN SECTIONS IN THE NEW ACCOUNT APPLICATION AND AGREEMENT THAT PERTAIN TO TRADING OPTIONS UNLESS AND UNTIL YOU HAVE READ THIS OPTIONS DISCLOSURE STATEMENT CAREFULLY.

With respect to any transaction effected by or on behalf of Mirae on my behalf for the purchase and/or sale of any options contract (puts, calls, etc.), listed on any exchange or traded in any market, I (we) agree and represent hereby as follows:

Options Trading and its Risks

You understand that purchasing or selling of options involves a high degree of risk and speculation. When purchasing options, there is the risk that the entire premium paid for the option can be lost if the option is not exercised or otherwise sold. When selling (“writing”) options, including uncovered (‘naked”) options, the risk of loss can be much greater and can exceed the amount of premium you received. You also understand you may not be able to close a position in the event that a secondary market in the market in the option ceases to exist or the listing exchange restricts or suspends trading in the option. You acknowledge that you have received and reviewed a copy of the options disclosure brochure and supplements entitled “Characteristics and Risk of Standardized Options,” which describes the risks associated with options trading in more detail and contains important information about this type of trading activity.

Buying and Selling Options

Whether acting alone or in agreement with others, you agree not to exceed the position limits set for your account by Mirae, any exchange or market or any other regulatory authority having jurisdiction. Unless you receive prior authorization from Mirae, you may not place trades that are not permitted under the option level for which you are approved. Mirae may, in its sole discretion and without notice, restrict or prohibit option trading or certain types of option transactions or specific option transactions in your account.

In order to buy or sell an option, your account must have cleared funds equal to or greater than the premium of the options contracts.

Uncovered Options

You must receive approval by Mirae to write an uncovered (“naked”) option. You understand that certain accounts are limited to long option purchases, cash secured puts and covered call writing are not eligible for uncovered options transactions (provided, however, that long option purchases may not be available for Custodian, Coverdell and certain types of retirement plan accounts and IRA’s).

You acknowledge and agree that the limitations described above are not intended to be exhaustive and that they may change from time to time.

Exercising Options

It is your sole responsibility to exercise, in a proper and timely manner, any right, privilege or obligation of any put, call or other option which Mirae may purchase, handle, endorse or carry for your account.

If your account has a long option position on the last trading day prior to expiration that closes $0.01 or more “in the money,” Mirae may (but is not required to) exercise the option for your account unless you contact Mirae with explicit contrary instructions by 4 p.m. ET.

Mirae reserves the right to require cash or securities in your account before exercising an option automatically or on your instruction, regardless of any historical patterns of action taken or not by Mirae.

You agree not to, during the life of the options in your account, sell the underlying securities collateralizing such options, including any cash or securities which may accrue on the underlying covered securities, until such options are closed, exercised or expire. You also agree that Mirae may refuse any order to sell such underlying securities received from you or by means of a “give up” basis through another firm unless, prior to such sale, you have met the collateral requirements established by Mirae for carrying uncovered options. Mirae has the right, in its sole discretion, to permit you to apply the proceeds of such sale to such collateral requirements.

You agree to immediately deliver any funds or securities required as the result of the exercise or assignment of options contracts in your account.

You are responsible for knowing the deliverables prior to engaging in an option transaction, as well as any changes in the deliverables while maintaining positions in your account.

Allocation of Exercise Notices

If you write an American-style option, the writer is subject to being assigned an exercise at any time after he/she has written the option until the option expires. Your entire position may be assigned, or you may be assigned in successive days. In contrast, the writer of a European-style option is subject to assignment only at expiration.

You understand that Mirae uses an automated, random method for allocation of exercise assignment notices for option contracts. This allocation method randomly selects from among all your short option positions, including positions established on the day of assignment. You agree to be bound by such allocation method and also agree that, if an exercise notice is assigned to your account, the underlying security (or sufficient cash in the case of stock index options) will be delivered to Mirae within the stated period of time in the case of a call, and sufficient cash to effect settlement of the assignment will be delivered to Mirae in the case of a put.

Steps Mirae May Take to Protect Itself

Mirae in its sole discretion and without notification to you, is authorized to take any and all steps necessary to protect Mirae from loss or damage arising out of or relating to your account or any options transaction in your account. If, without limitation, (1) Mirae determines in its sole discretion that it is necessary for its protection for any reason; (2) you die; (3) you exceed any applicable position or exercise limit; (4) you fail to meet a margin call promptly; and/or(5) your account fails to meet Mirae or New York Stock Exchange capital requirements, you authorize Mirae to: (a) buy, sell or sell short any option or security in any of your accounts held at Mirae; (b) close out any option position(s),( c) exercise any option(s);

(d) block any option(s); (e) additional margin deposits; (f) liquidate your account; and/or request (g) enter offsetting transactions in your account.

Any proceeds in excess of commission costs created by these actions will be credited to your account. You are responsible for all orders, including any orders Mirae executes to purchase or sell options in your account, even if the account does not contain sufficient cleared funds.

You agree that in connection with any uncovered options in your account, you will comply with the margin requirements Mirae has established got carrying uncovered options. Please review the Mirae Margin Agreement for future information on both your and Mirae rights and obligations governing your margin account. If the value of the underlying instrument moves against you as an uncovered options writer, we may request additional margin payments. If you do not make such margin payments in the time frame established by us, we may, in our sole discretion and without prior notice, liquidate stock or options positions in any one of your accounts or take other measures described in the Mirae Margin Agreement to satisfy the margin call. If any option position in your account becomes uncovered, we may, without prior notice to you, take immediate action to cover your position, and you shall be responsible for any resulting losses, and you further agree to reimburse any and all expenses Mirae incurs in connection with such transactions.

Accuracy of Your Information Provided to Mirae

You have carefully reviewed and completed your Options Application and confirm to Mirae the accuracy of all information contained therein, including those items concerning your income, liquid assets, net worth and options experience. If there is any change in your financial condition or other circumstances arise which may affect your ability to engage in option transactions, you will promptly provide written notice.

IRAs

You represent, warrant and covenant that any IRA which you may maintain at Mirae that holds options or conducts options strategies is not subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), as amended, and that you will not engage in any transaction in such IRA that involves any extension of credit by Mirae.

You understand that you are solely responsible for ensuring that sufficient assets are maintained in the IRA to cover all potential obligations arising from the holding of options and conducting any options strategies, including any potential assignment and exercise. You acknowledge responsibility for not conducting options transactions that can result in liabilities or obligations in excess of your IRA account balance. Mirae shall not be responsible for the dishonor of any transaction due to an insufficient balance in the IRA. If an assignment creates a short position or debit balance, Mirae is authorized to immediately cover any deficit in the IRA with other assets in the IRA account.

You understand that under Section 408(e)(4) of the Internal Revenue Code of 1986, as amended (the “IRC”), if you pledge any portion of the IRA as collateral for a loan, the amount pledged will be treated as a distribution, and may be included in your gross income for the taxable year in which you pledge the assets to the extent it represents earnings or may be subject to excise taxes. You understand that the extension of credit through margin, short selling positions, and uncovered options is not permitted in IRAs. If you or your beneficiary engages in a prohibited transaction with the IRA, as described in Section 4975 of the IRC, the IRA may lose its tax-deferred or tax-exempt status.

As a reminder, Mirae does not offer tax or legal advice. Please consult with a qualified tax professional should you have any additional questions related to the advisability of holding options or conducting options strategies in any IRA or other account which you hold at Mirae.

You have not and will not rely on Mirae for legal or tax advice in connection with engaging in options transactions in any such IRA or other account.

You will not hold Mirae responsible for any adverse tax consequences or penalties that you or such IRA or other account may incur in connection with options transactions.

Limits to Mirae Responsibilities

Generally

You agree to reimburse any and all expenses Mirae incurs in connection with any transaction or other action Mirae makes or takes pursuant to this Agreement.

You further agree to waive and to release Mirae and its directors, officers, employees and agents from any and all claims of damage or loss arising out of or relating to: (1) any such transactions made or taken by Mirae pursuant to this Agreement

(2) the exercise or non-exercise of an option contract, whether by Mirae or you; or (3) otherwise any execution, handling, selling, purchasing or endorsing of options for your account, whether by Mirae or you. Mirae does not warrant or guarantee the dependability of the Internet nor your ability to access services during periods of peak Internet activity or market volatility.

No Additional Disclosures

Mirae is not under any obligation to convey any information to you relating to the underlying securities or indexes covered by any option, or to any securities or indexes related thereto, and no information so conveyed shall be constructed as creating an implied agreement or course of dealing requiring Mirae to convey further information to you.

You are responsible for your account activity. You are solely responsible for reviewing and monitoring all activities in your account, including the expiration of options contacts. You understand that Mirae is not required and does not represent that it will monitor such activities for you.

If an investment advisor manages your account, you understand that Mirae may rely on the advisors Investment experience in conjunction with your qualifying information when determining your eligibility and approval to trade options.

Your Options trading may be limited to closing transactions if you terminate your professional relationship with your investment advisor. In such a case, you must re-apply for options approval to maintain options trading privileges in your account.

No Advice

You understand that Mirae will make no recommendations to you related to any investment or trading strategies in your account and you agree not to hold Mirae responsible for the suitability of trades or any subsequent losses in your account. The execution of any trades by Mirae will not be deemed to be an approval of such trades.

Force Majeure

You agree and acknowledge that Mirae shall not be liable for losses caused directly or indirectly by any events beyond its reasonable control, including without limitation, government restrictions, exchange or market rulings, suspension of trading or unusually heavy trading in any security, war, strikes, or a general change in economic, political or financial conditions.

Arbitration

You acknowledge that you have received, read and agree to abide by the terms of Mirae Customer Agreement which contains a pre-dispute arbitration clause. The parties agree as follows: (a) all parties to this Agreement are giving up the right to sue each other in court, including the right to a trial by jury, except as provided by the rules of the arbitration forum in which a claim is filed; (b) arbitration awards are generally final and binding. A party’s ability to have a court reverse to modify arbitration award is very limited; (c) the ability of the parties to obtain documents, witness statements and other discovery is generally more limited in arbitration than in court proceedings; (d) the arbitrators do not have to explain the reason(s) for their award; (e) the panel of arbitrators will typically include a minority of arbitrators who were or are affiliated with the securities industry; (f) the rules of some arbitration forums may impose time limits for bringing a claim in arbitration. In some cases, a claim that is ineligible for arbitration may be brought in court; and (g) the rules of the arbitration forum in which the claim is filed, and any amendments thereto, shall be incorporated into this Agreement.

You agree to arbitrate any controversy between you and Mirae (including any of Mirae’s officers, directors, employees, or agents) arising out of or relating in any way to our relationship, your account(s), any account that you may cause to be opened with us in the future, or any service provided by us, including but not limited to: (a) transactions of any kind made on your behalf, through or with us; or (b) the performance, construction or breach of this Agreement or any other agreement between you and us. If you are not a resident of the United States at the time a controversy subject to arbitration arises, you agree that any arbitration hearing shall be held in New York, NY, you consent to the personal jurisdiction of all courts located in the state of New York for purposes of enforcing this arbitration agreement and any arbitration award and you agree that any arbitration proceeding shall be conducted in the English language. If any party unsuccessfully resists confirmation or enforcement of an arbitration award rendered under this Agreement, then all costs, attorney’s fees, and expenses incurred by the other party or parties in confirming or enforcing the award shall be fully assessed against and paid by the party resisting confirmation or enforcement of the award. No person shall bring a putative or certified class action to arbitration, nor seek to enforce any pre-dispute arbitration agreement against any person who has initiated in court a putative class action or who is a member of putative class until: (a) the class certification is denied; (b) the class is decertified; or (c) the client is excluded from the class by the court. Such forbearance to enforce an agreement to arbitrate shall not constitute a waiver of any rights under this Agreement except to the extent stated herein.

 Miscellaneous

Other Mirae Agreements

The Mirae Customer Agreement and Agreement between Mirae and you and any margin agreement you may have with Mirae are incorporated into this Agreement by reference.

Governing Law

All transactions under this Agreement shall be subject to the rules, regulations, customs and practices of the exchange or market, and the Options Clearing Corporation, where such transactions are executed and/or cleared. All transactions are also subject to the rules and regulations of the Securities Exchange Commission, the Board of Governors to the Federal Reserve System, the Commodity Futures Trading Commission, the Financial Industry Regulatory agencies, state agencies and self-regulatory organizations. Notwithstanding the foregoing, this Agreement is governed by New York law. Whenever any statue shall be enacted or regulation made under any statute by any exchange, market or the Options Clearing Corporation that shall be applicable to and affect in any manner or be inconsistent with any of the provisions of this Agreement, the provisions of this Agreement so affected shall be deemed modified or superseded by such statute or regulation.

Notices

Communications may be sent to you at your address of record, and all communications sent, whether by first-class postage-paid mail, overnight courier or otherwise, shall be deemed given to you personally, whether received or not. Communications sent to you by first-class postage-paid mail shall be deemed received three business days thereafter. Communications sent to you by overnight courier or similar method shall be deemed received one business day thereafter.

Severability

If any provision of this Agreement is held to be unenforceable, it shall not affect any other provisions of this Agreement.

Assignment

You may not assign this Agreement without the express written consent of Mirae. This Agreement will inure to the benefit of your successors and permitted assigns.

Disclaimer: Options are not suitable for all investors, and trading in these instruments is considered risky and may be appropriate only for sophisticated investors. Past performance is not necessarily indicative of future results. Prior to buying or selling an option, and for a thorough description of risks relating to options, U.S. investors must receive a copy of ‘The Characteristics and Risks of Standardized Options.’ You may read the document at: https://www.theocc.com/Company-Information/Documents-and-Archives/Options-Disclosure-Document which includes documents regarding supplemental options information.

Financial Disclosures

Focus Report April 2026

Statement of Financial Condition – Audited 2025

Statement of Financial Condition – Unaudited June 2025