Important Information Regarding your Account

Mirae Asset Securities (USA) Inc. (“Mirae”) 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 Daewoo Co., Ltd., a financial institution based in Seoul, South Korea, with financial services activities in the USA. In connection with your account maintained with Mirae, please read the following information carefully.

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 the way we handle nonpublic personal information that comes into our possession. We do not have individuals 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 have put in place 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 Daewoo 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.

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 you open an account with Mirae, we will ask for your 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 you. We may also ask to see other identifying documents, as necessary to enable Mirae to verify your identity. A legal entity may need to provide other information such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, and a partnership agreement or a trust agreement. We may also ask for a copy of your driver’s license or government issued passport and/or seek additional 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.

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.

  • 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 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 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 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 Wider 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.

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. 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.

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  

Mirae makes publicly available on its website a quarterly report on order routing statistics pursuant to and as described in SEA 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 SEA Rule 606(b)(2), a report on the order routing information described in SEA Rule 606(b)(1).

Statement of Policy Regarding Payment for Order Flow-SEC 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.

Many venues offer cash credits or rebates for orders that provide liquidity to their books and charge explicit fees for orders that extract liquidity from their books, and some other “inverted venues” offer cash credits or rebates for orders that extract liquidity from their books and charge explicit fees for orders that provide liquidity to their books. Liquidity rebates are considered payments for order flow.  Although Mirae does not receive outright payment for order flow, Mirae may from time to time receive rebates for providing liquidity or extracting liquidity pursuant to agreements we have with certain executing brokers. 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.

Trading Along with 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.

FINRA Rule 5270 prohibits a broker-dealer from trading for its own account while having material, non-public market information 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. The Rule provides exceptions for certain transactions. 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. A broker-dealer is also permitted to engage in hedging or pre-hedging when the purpose of the trading is to fulfill the client order and the broker-dealer has disclosed such trading activity to the client. This hedging or pre-hedging activity may materially impact the market prices of the securities or financial instruments a client is buying or selling. Of course, Mirae conducts this trading in a manner designed to limit market impact and consistent with our best execution obligations to our clients.

Suitability and Appropriateness 

Certain securities or financial instruments may not be suitable or appropriate for all investors or in all geographical areas. Because your needs, investment objectives and financial situation were not taken into account, you must make your own independent decisions regarding any securities or financial instruments. 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 you in the light of your particular investment needs, objectives and financial circumstances. You hereby acknowledge that you are a sophisticated investor and have sufficient knowledge and experience in financial and business matters and are 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.

Voice Recording 

In accordance with applicable laws and regulations, Mirae records certain telephone conversations with outside parties. By communicating with Mirae you consent to the voice recording of conversations with personnel of Mirae.

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
37th FLOOR
NEW YORK, NY 10019
TEL: (212) 407-1000

Disclaimers

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 Asset Securities (USA) Inc. (“Mirae” hereafter) 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.​_