Hapi_statement_sept-2023

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DISCLOSURE

ANNUAL DISCLOSURE STATEMENT

ANTI-MONEY LAUNDERING

To help the government fight the funding of terrorism and money laundering activities, Federal law
requires all financial institutions to obtain, verify and record information that identifies each person who
opens an account. This notice answers some questions about your firm's Customer Identification Program
(CIP).

What types of information will I need to provide?

When you open an account, your firm is required to collect information such as the following from you:
your name, address, date of birth, identification number: (a) US Citizen: taxpayer identification number
(social security number or employee identification number), or (b) Non-US Citizen: taxpayer identification
number, passport number and country of issuance, alien identification card number, or government-
issued identification showing nationality, residence, and a photograph of you. You may also need to show
your driver's license or other identifying documents. A corporation, partnership, trust, or other 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, a
partnership agreement, or a trust agreement. In addition, the United States Department of the Treasury,
the United States Securities and Exchange Commission (“SEC”), and the Financial Industry Regulatory
Authority (“FINRA”) currently require you to provide additional information, such as net worth, annual
income, occupation, employment information, investment experience and objectives, and risk tolerance.

What happens if I don't provide the information requested or my identity can't be verified?

Your firm may not be able to open an account or process transactions for you. If your firm has already
opened an account for you, it may be closed.

PRIVACY POLICY

For information on what personal information Apex Clearing Corporation and the Apex Fintech Solutions
group of companies collects about you, how we use it, who we share it with and what rights you have in
relation to your personal information, please visit www.apexfintechsolutions.com/privacy.

Disclosure – Annual Disclosure Statement


Page 1 of 12
Rev. 09/13/2023
ADS
MARGIN DISCLOSURE STATEMENT

 FINRA Rule 2264

Apex is furnishing this document to provide you with basic facts about purchasing securities on margin,
and to alert you to the risks involved with trading securities in a margin account. Before trading in a margin
account, you should carefully review the margin agreement provided by your broker. Consult your broker
and/or registered investment advisor regarding any questions or concerns you may have with your margin
accounts.

When you purchase securities, you may pay for the securities in full or you may borrow part of the
purchase price from your brokerage firm. If you choose to borrow funds from your firm, you will open a
margin account with the firm. The securities purchased 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 in your account, 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
A decline in the value of securities that are purchased on margin may require you to
provide additional funds to the firm that has made the loan to avoid the forced sale of
those securities or other securities in your account.

 The firm can force the sale of securities in your account


If the equity in your account falls below the maintenance margin requirements under the
law, or the firm's higher "house" requirements, the firm can sell the securities in your
account to cover the margin deficiency. You also will be responsible for any shortfall in
the account after such a sale.

 The firm can sell your securities without contacting you


Some investors mistakenly believe that a firm must contact them for a margin call to be
valid, and that the firm cannot liquidate securities in their accounts to meet the call unless
the firm has contacted them first. This is not the case. Most firms will attempt to notify
their customers of margin calls, but they are not required to do so. However, even if a
firm has contacted a customer and provided a specific date by which the customer can
meet a margin call, the firm can still take necessary steps to protect its financial interest,
including immediately selling the securities without notice to the customer.

 You are not entitled to choose which security in your margin account is liquidated or
sold to meet a margin call
Because the securities are collateral for the margin loan, the firm has the right to decide
which security to sell in order to protect its interests.

 The firm can increase its "house" maintenance margin requirement at any time and is
not required to provide you advance written notice

Disclosure – Annual Disclosure Statement


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Rev. 09/13/2023
These changes in firm policy often take effect immediately and may result in the issuance
of a maintenance margin call. Your failure to satisfy the call may cause the member to
liquidate or sell securities in your account.

 You are not entitled to an extension of time on a margin call


While an extension of time to meet margin requirements may be available to customers
under certain conditions, a customer does not have a right to the extension.

 The IRS requires Broker Dealers to treat dividend payments on loaned securities
positions as a “substitute payment” in lieu of a dividend
A substitute payment is not, a “qualified dividend” and is not taxed as ordinary income.

 Industry regulations may limit, in whole or in part, your ability to exercise voting rights
of securities that have been lent or pledged to others
You may receive proxy materials indicating voting rights for a fewer number of shares
than are in your account, or you may not receive any proxy materials.

DAY-TRADING RISK DISCLOSURE STATEMENT

 FINRA Rule 2270

You should consider the following points before engaging in a day-trading strategy. For purpose of this
notice, a “day trading strategy” means an overall trading strategy characterized by the regular
transmission by a customer of intra-day orders to effect both purchase and sale transactions in the same
security or securities.

 Day trading can be extremely risky


Day trading, generally, is not appropriate for someone of limited resources and limited
investment or trading experience and low risk tolerance. You should be prepared to lose
all of the funds that you use for day trading. In particular, you should not fund day-trading
activities with retirement savings, student loans, second mortgages, emergency funds,
funds set aside for purposes such as education or home ownership or funds required to
meet your living expenses. Further, certain evidence indicates that an investment of less
than $50,000 will significantly impair the ability of a day trader to make a profit. Of course,
an investment of $50,000 or more in no way guarantees success.

 Be cautious of claims of large profits from day trading


You should be wary of advertisements or other statements that emphasize the potential
for large profits as a result of day trading. Day trading can lead to large and immediate
financial losses.

 Day trading requires knowledge of securities markets


Day trading requires in-depth knowledge of the securities markets and trading techniques
and strategies. In attempting to profit through day trading, you must compete with
professional, licensed traders employed by securities firms. You should have appropriate
experience before engaging in day trading.

Disclosure – Annual Disclosure Statement


Page 3 of 12
Rev. 09/13/2023
 Day trading requires knowledge of a firm's operations
You should be familiar with a securities firm's business practices, including the operation
of the firm's order execution systems and procedures. Under certain market conditions,
you may find it difficult or impossible to liquidate a position quickly at a reasonable price.
This can occur, for example, when the market for a stock suddenly drops, or if trading is
halted due to recent news events or unusual trading activity. The more volatile a stock is,
the greater the likelihood that problems may be encountered in executing a transaction.
In addition to normal market risks, you may experience losses due to system failures.

 Day trading will generate substantial commissions, even if the per trade cost is low
Day trading involves aggressive trading, and generally you will pay commissions on each
trade. The total daily commissions that you pay on your trades will add to your losses or
significantly reduce your earnings. For instance, if a trade costs $16 and an average of 29
transactions are conducted per day, an investor would need to generate an annual profit
of $111,360 just to cover commission expenses.

 Day trading on margin or short selling may result in losses beyond your initial
investment.
When you day trade with funds borrowed from a firm or someone else, you can lose more
than the funds you originally placed at risk. A decline in the value of the securities that
are purchased may require you to provide additional funds to the firm to avoid the forced
sale of those securities or other securities in your account. Short selling as part of your
day trading strategy also may lead to extraordinary losses, because you may have to
purchase a stock at a very high price in order to cover a short position.

 Potential Registration Requirements


Persons providing investment advice for others or managing securities accounts for
others may need to register as either an “Investment Advisor” under the Investment
Advisors Act of 1940 or as a “Broker” or “Dealer” under the Securities Exchange Act of
1934. Such activities may also trigger state registration requirements.

BUSINESS CONTINUITY PLAN

 FINRA Rule 4370

As a fully disclosed and omnibus clearing firm, Apex has developed a Disaster Recovery Plan to ensure
business continuity. In Apex’s capacity as clearing firm, Apex provides a variety of services that require
the provision of continual technological and operational support to your broker and to your registered
investment advisor as the broker dealer on record in connection with accomplishing business continuity,
we have established a remote independent Disaster Recovery Site as a major component of Apex’s
Disaster Recovery Plan. This Site has resources in place to operate and maintain business critical processes
in the event that Apex’s primary location cannot be occupied due to anything from a natural disaster to a
terrorist attack, whether or not such an event affects only Apex or is more regional in scope. The Disaster
Recovery Plan contemplates restoration of critical processes within 24 hours. Please note that the
specifics of Apex’s Disaster Recovery Plan are subject to modification. You may obtain a copy of Apex’s

Disclosure – Annual Disclosure Statement


Page 4 of 12
Rev. 09/13/2023
most current Disaster Recovery Plan at www.apexclearing.com.

DISCLOSURE OF PAYMENT FOR ORDER FLOW


AND ORDER ROUTING INFORMATION

 SEC Rules 606 and 607

Pursuant to SEC Rule 606, Apex is required to make publicly available a quarterly report about its routing
of non-directed orders. For the purpose of this Rule, Apex has entered into an agreement with S3
Matching Technologies LP, to disclose all required information pertaining to this rule. This information
can be accessed at www.apexclearing.com.

SEC Rule 606(b) requires a broker-dealer to disclose to its customers, upon request, “the identity of the
venue to which the customer’s orders were routed for execution in the six months prior to the request,
whether the orders were directed orders or non-directed orders, and the time of the transactions, if any,
that resulted from such orders.”

Pursuant to SEC Rule 607, Apex is required to disclose its payment for Order Flow practices. Apex sends
certain equity orders to exchanges, electronic communication networks, or broker-dealers during normal
business hours and during extended trading sessions. Some of those market centers provide payments to
Apex, or charge access fees depending upon the characteristics of the order and any subsequent
execution. In addition, Apex may execute certain equity orders as principal. The details of these payments
and fees are available upon written request. Apex receives payments for directing listed options order
flow to certain option exchanges. Compensation is generally in the form of a per-option contract cash
payment. This disclosure only applies to orders directed to Apex by your firm.

SEC RULE 10b-10

SEC Rule 10b-10 requires that you are provided with prior written notification if certain transactions are
not reported immediately through a trade confirmation. You will not receive an immediate trade
confirmation for automatic reinvestments of money market dividends if there are no other transactions
in your brokerage account on the day the automatic reinvestment occurs. A summary of these
transactions will instead be reported in your quarterly brokerage account statement.

SIPC INFORMATION

 FINRA Rule 2266

As a member of the Securities Investor Protection Corporation (“SIPC”), funds are available to meet
customer claims up to a ceiling of $500,000, including a maximum of $250,000 for cash claims. For
additional information regarding SIPC coverage, including a brochure, please contact SIPC at (202) 371-
8300 or visit www.sipc.org.

Disclosure – Annual Disclosure Statement


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Rev. 09/13/2023
Additionally, Apex has arranged for coverage above the SIPC limits. For more information, please contact
your firm directly.

INVESTOR EDUCATION AND PROTECTION

 FINRA Rule 2267

FINRA Rule 2267 requires Apex to provide information about FINRA’s BrokerCheck program. An investor
brochure that includes information describing the BrokerCheck program may be obtained from FINRA.
The FINRA BrokerCheck hotline number is (800) 289-9999. The FINRA web site address is www.FINRA.org.

MUTUAL FUNDS – CHARGES, BREAKPOINTS, AND FEES

Before investing in mutual funds, it is important that you understand the sales charges, expenses, and
management fees that you will be charged, as well as the breakpoint discounts to which you may be
entitled. Understanding these charges and breakpoint discounts will assist you in identifying the best
investment for your particular needs and may help you to reduce the cost of your investment. Information
about charges, discounts, sales charges, expenses, management fees and breakpoint discounts vary from
mutual fund to mutual fund. Therefore, you should discuss these matters with your firm and review each
mutual fund’s prospectus and statement of additional information to obtain the specific information
regarding the charges and breakpoint discounts associated with a particular mutual fund.

In addition, most mutual funds offer different share classes. Although each share class represents a similar
interest in a mutual fund’s portfolio, the mutual fund will charge you different fees and expenses
depending upon the share class selected. As a general rule, Class A shares carry a “front-end” sales charge
or “load” that is deducted from your investment at the time you buy shares. This sales charge is a
percentage of your total purchase. Further, many mutual funds offer volume discounts to the front-end
sales charge assessed on Class A shares at certain pre-determined levels of investment, which are called
“breakpoint discounts.” Conversely, Class B and C shares usually do not carry any front-end sales charges.
Instead, investors that purchase Class B or C shares pay asset-based sales charges, which may be higher
than the charges associated with Class A shares, and investors that purchase Class B and C shares may be
required to pay a sales charges known as a contingent deferred sales charge when they sell their shares,
depending upon the rules of the particular mutual fund. To learn more about mutual fund share classes,
charges, breakpoints, and fees, you may want to consider reviewing the following FINRA investor alerts:

http://www.finra.org/investors/alerts/understanding-mutual-fund-classes
http://www.finra.org/investors/alerts/mutual-fund-breakpoints-break-worth-taking

CARRYING AGREEMENTS

 FINRA Rule 4311

In the event that your account has been introduced to Apex by a broker-dealer, the broker-dealer with

Disclosure – Annual Disclosure Statement


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Rev. 09/13/2023
which you have opened your securities account has retained Apex to provide certain record keeping or
operational services. These services, such as the execution and settlement of securities transactions,
custody of securities and cash balances, and extension of credit on margin transactions, are provided
under a Fully Disclosed Clearing Agreement between Apex and your broker-dealer. As a member of FINRA,
Apex is required (under FINRA Rule 4311) to disclose to you the details of its Fully Disclosed Clearing
Agreement with your broker-dealer, which are summarized below.

Responsibilities of Your Broker-Dealer

Your broker-dealer has the responsibility to:

 Approve the opening of your account


 Obtain necessary documentation to help fight the funding of terrorism and money
laundering activities
 Service and supervise your account through its own personnel in accordance with its
own policies, procedures, applicable laws, and regulators
 Know you and your stated investment objectives
 Provide appropriate investment advice, recommendations, or management services
based on your investment objectives
 Determine whether particular kinds of transactions such as margin, option, and short
sale are appropriate for you
 Obtain the initial margin as required by Regulation T if a margin account is opened for
you
 Accept and, in certain instances, execute securities orders
 Know the facts about any orders for the purpose or sales of securities in your account
 Comply with fair pricing and disclosure responsibilities (if your firm is a market maker in
any securities or otherwise trades as principal with you)
 Correctly identify and promptly forward funds or securities intended for your account to
Apex
 Supervise the activities of any individual who services your account, resolve any
complaints regarding the handling of your account and manage the ongoing relationship
that it has with you

Apex has no involvement and assumes no responsibility in all of the above matters relating to the
servicing of your account.

Responsibilities of Apex

In general, Apex is only responsible to perform the services within the scope of the Fully Disclosed Clearing
Agreement that your broker-dealer specifically requests Apex to perform. For example, Apex may fulfill
the following responsibilities on behalf of your account at your broker-dealer’s instruction:

 Create computer-based account records


 Process orders for the purchase, sale, or transfer of securities (Apex is not obligated to
accept orders directly from you and will do so only at Apex ’s discretion in exceptional
circumstances)

Disclosure – Annual Disclosure Statement


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Rev. 09/13/2023
 Receive and deliver funds and securities
 Record such receipts and deliveries according to information provided either by your
firm or directly, in writing, by you
 Hold securities and cash in custody (after it comes into Apex’s physical possession or
control)
 Collect and disburse dividends and interest
 Process reorganization and voting instructions with respect to securities held in custody
 Prepare and transmit confirmations of trades to you with the exception of the following
transactions which will alternatively appear on account statements:
o Systemic investments or withdrawals of investment company products
o Transactions in money market funds that have no purchase or redemption fees
o Dividend reinvestments
 Prepare and transmit periodic account statements summarizing transactions
 Provide your firm with written reports of all transactions processed for your account to
enable your firm to carry out its responsibilities under the Fully Disclosed Clearing
Agreement
 Assist you and your firm with any discrepancies or errors that may occur in the
processing of transactions.

If your broker-dealer opened a margin account for you, Apex may:

 Loan money to you for the purpose of purchasing or holding securities (subject to the
terms of Apex’s, margin agreement, margin policies and applicable margin regulations)
 Calculate the amount of maintenance margin required and advise you of those
requirements (usually through your firm)
 Calculate any interest charged on your debit balance

Apex maintains the books and records required by law and business practice. The Fully Disclosed Clearing
Agreement does not encompass transactions in investments other than marketable securities, which Apex
normally processes on recognized exchanges and over-the-counter (“OTC”) markets. In furnishing services
under the Fully Disclosed Clearing Agreement, Apex may use and rely upon the services of clearing agencies,
automatic data processing vendors, proxy processing, transfer agents, securities pricing services and other
similar organizations. This document addresses the basic allocation of functions regarding the handling of
your account. It is not meant as a definite enumeration of every possible circumstance, but only as a
general disclosure.

Further, regardless of whether our account has been introduced by a broker-dealer or registered
investment advisor, Apex does not control, audit, or otherwise supervise the activities of your firm or its
employees. Apex does not verify information provided by your firm regarding your account or
transactions processed for your account. Apex does not undertake responsibilities for reviewing the
appropriateness of transactions entered by your firm on your behalf.

Disclosure – Annual Disclosure Statement


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Rev. 09/13/2023
EXTENDED HOURS TRADING RISK DISCLOSURE

 FINRA Rule 2265

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 investors to buy or sell securities, and as a result, investors are more likely to pay or receive
a competitive price for securities purchased or sold. There may be lower levels of 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 levels of 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 to what you might receive 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
regular market hours, or upon the opening of the next morning. As a result, you may receive an inferior
price in extended hours trading to what you might receive during regular 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 hour’s system may not reflect the prices on other concurrently operating extended hours
trading systems dealing in the same securities. Accordingly, you may receive an inferior price on one
extended hours trading system than you might receive on another extended hours trading system.

Risk of News Announcements


Normally, issuers release 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 IndicativeValue


(“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

Disclosure – Annual Disclosure Statement


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Rev. 09/13/2023
who is unable to calculate implied values for certain Derivative Securities Products in those sessions may
be at a disadvantage to market professionals.

LIENS AND LEVIES

If, for any reason, your account(s) is/are subject to a lien or levy directed to Apex, Apex will abide by the
directions of the federal, state, or other levying authority unless it receives:

 A court order staying or quashing the lien or levy


 Some other form of release from the levying authority

If Apex receives a lien or levy on your account, you may be assessed a reasonable processing fee.
Questions concerning liens or levies may be directed to Compliance at (214) 765-1055.
REGULATION E

Regulation E of the Board of Governors of the Federal Reserve System requires disclosure regarding
electronic transfers. Electronic transfers include:

 Authorized Debits
A client provides their checking account information to a company (such as mortgage,
utility) and the company electronically sends debits directly to the client’s checking
account, which debits the brokerage account.

 Debit Card Transactions


Any merchant purchase, automatic teller machine (ATM) withdrawal or cash advance
done with the debit card issued from the account.

 Check Conversion
A client provides checks for deposit into their Apex accounts which Apex scans and
converts them into either an image replacement document (IRD) or ACH file.

Questions concerning electronic transfers may be directed to your firm.

CALLABLE SECURITIES

 FINRA Rule 4340

Once a security is deemed callable (callable security) by the issuer, DTC or the custodian will notify Apex
of the call and Apex will implement a random lottery call process, based on account eligibility. Eligibility
for the random lottery process is based on the securities call classification of ‘favorable redemption call’
or ‘unfavorable redemption call’. The term favorable or unfavorable is based on a comparison between
the call price and the market price. When the comparison between the call price and market price are
beneficial to the account, the call is deemed favorable. Favorable redemption calls will exclude any
account in which Apex or its associated persons have an interest until all other customers' positions in
such securities have been satisfied.

Disclosure – Annual Disclosure Statement


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Rev. 09/13/2023
An unfavorable redemption call is when the comparison between the call price and market price are not
as beneficial to the account and therefore deemed unfavorable. Apex will not exclude its positions or
those of its associated persons (including those persons performing solely clerical and ministerial
functions) from the pool of any securities deemed unfavorable and eligible to be called.

A determination will be made as to which redemption call the security is subject to (favorable or
unfavorable) prior to commencement of the lottery process.

Once the terms of the call have been determined and eligible accounts have been selected, the random
lottery process will occur to select accounts for the partial call redemption. A random start and jump
number is executed at the beginning of the lottery to ensure the process is impartial, fair and consistent
with the call allocation. When the redemption call has ended for each security, Apex is notified of the
called account by its vendor and will inform your firm who will notify you of your account status, if
applicable.

MSRB DISCLOSURE REQUIREMENT

Rule G-10 of the MSRB requires annual notification of the following information:

 Apex Clearing Corporation is registered with the U.S. Securities and Exchange
Commission and the Municipal Securities Rulemaking Board
 To stay informed on the new rules and changes to rules, visit: http://www.msrb.org/
 For more information regarding protections that may be provided by the Municipal
Securities Rulemaking Board rules and how to file a complaint with an appropriate
regulatory authority, see the MSRB Investor Brochure:
http://msrb.org/msrb1/pdfs/MSRB-Investor-Brochure.pdf

COMPLAINTS

 FINRA Rule 4513

The FINRA has jurisdiction over virtually every brokerage firm and its employees. To request an
informational brochure, inquire about your broker-dealer firm or file a complaint, visit their website at
www.finra.org or call (301) 590-6500.

FINANCIAL EXPLOITATION OF SPECIFIED ADULTS AND


TRUSTED CONTACT PERSON

 FINRA Rule 4512

Under FINRA Rule 4512, Apex is required to disclose to you (the customer) that Apex or an associated
person of Apex is authorized to contact the trusted contact person you may have identified in your
account opening documents and disclose information about your account to address possible financial

Disclosure – Annual Disclosure Statement


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Rev. 09/13/2023
exploitation, to confirm the specifics of your current contact information, health status, or the identity of
any legal guardian, executor, trustee or holder of a power of attorney, or as otherwise permitted by FINRA
Rule 2165.

Disclosure – Annual Disclosure Statement


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Rev. 09/13/2023
Apex Clearing Corporation
350 N. St. Paul Street 1300
Dallas, TX 75201
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September 1, 2023 - September 30, 2023


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M

PAGE 1 OF 7

ACCOUNT NUMBER 2IU-26827-13 RR HHA


E
T

EDWARD M
A
T

EDWARD M
Y o u r Re gi st e r e d R e p r e s en t a ti ve
S

CALLE 20 2B 13
HAPI
CALLE
250020 FUNZA
COLOMBIA
T

Y o u r A c co un t I ns t r u c ti o ns
Hold Securities in Account
N

Hold Proceeds
U
O
C
C

OPENING BALANCE CLOSING BALANCE


A

Cash account $0.96 $1.27


NET ACCOUNT BALANCE 0.96 1.27 Cash
0.528%
Securities 252.31 239.43
TOTAL PRICED PORTFOLIO 252.31 239.43

Total Equity Holdings $253.27 $240.70

THIS PERIOD YEAR TO DATE

Taxable dividends $0.31 $0.99


Non-resident tax paid $0.00 $-0.12
Foreign tax paid 0.00 -0.03
Equities
99.472%

See Reverse Side for Important Tax Information. This statement shall be conclusive if not objected to in
writing within ten days. Errors and omissions excepted. Please address all communications to the firm and not to individuals.
Address changes or other material changes on your account should be directed to the office servicing your account. Kindly
mention your account number. This statement should be retained for income tax purposes.
September 1, 2023 - September 30, 2023
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PAGE 2 OF 7
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ACCOUNT NUMBER 2IU-26827-13 RR HHA


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EDWARD M
E
T
A
T
S

SYMBOL/ ACCOUNT MARKET LAST PERIOD'S EST. ANNUAL % OF TOTAL


DESCRIPTION CUSIP TYPE QUANTITY PRICE VALUE MARKET VALUE % CHANGE INCOME PORTFOLIO

E QU I T I E S / OP T I O N S
T

VANGUARD S&P 500 ETF VOO C 0.6097 $392.70 $239.43 $252.31 -5% $4 99.472%
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Total Equities $239.43 $4 99.472%


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Total Cash (Net Portfolio Balance) $1.27 0.528%


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TOTAL PRICED PORTFOLIO $240.70 $4


C
C

ACCOUNT
A

TRANSACTION DATE TYPE DESCRIPTION QUANTITY PRICE DEBIT CREDIT

DI V I DE ND S A N D I N T E RE ST
DIVIDEND 09/27/23 C PETROLEO BRASILEIRO SA $0.3897536 $0.31
PETROBRAS
SPONSORED ADR
CASH DIV ON
0.80000 SHS
REC 06/14/23 PAY 09/27/23
CUSIP: 71654V408
Total Dividends And Interest $0.31
September 1, 2023 - September 30, 2023
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PAGE 3 OF 7
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ACCOUNT NUMBER 2IU-26827-13 RR HHA


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EDWARD M
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A
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IMPORTANT INFORMATION
S

Statement of Financial Condition


A copy of Apex Clearing Corporation's Unaudited Statement of Financial Condition as of June 30, 2023 is available on the website at https://apexfintechsolutions.com/legal/disclosures/. A
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copy may also be obtained at no cost by calling Apex Clearing Corporation. As of June 30, 2023, Apex Clearing Corporation had a net capital of $425,879,816 and was $394,823,096 in
excess of its required net capital of $31,056,720. As of July 31, 2023, Apex Clearing Corporation had a net capital of $417,093,251 and was $386,104,362 in excess of its required net
N

capital of $30,988,889.
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Apex's Policy for Dividends and Interest


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Apex's policy is to pay all dividends and interest in US Dollars. Apex will allow the following countries to be paid in their foreign currency (Canadian Dollars, British Pounds, Euros, Argentine
Peso, Chinese Renminbi, Korean Won, Philippine Peso and Brazilian Real).
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Participation in Fully Paid Lending Program


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Customers participating in the Fully-Paid Securities Lending Program should be aware that shares on loan are not covered by FDIC or SIPC. Cash securities collateralizing shares are held at JP
Morgan Chase & Co. and not subject to FDIC or SIPC protections. Please consult the Master Securities Lending Agreement for additional information.
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Information Regarding Cost Basis for Foreign Account Statements


Foreign Currency: Cost basis is required to be reported in U.S. dollars for tax purposes. It is the responsibility of the account holder to convert sales proceeds paid in foreign currency to U.S.
dollars to avoid inaccurate cost basis calculations. When reporting the purchase or sale, you must determine the U.S. dollar amounts to be reported as of the settlement date, at the spot rate
or by following a reasonable spot rate convention. See Regulations section 1.6045-1(d)(8).

Payment of Interest to holders of Municipal Securities - you may be subject to a substitute interest payment if the transfer of ownership of your municipal security has not been
completed prior to the next interest payment. Please contact a tax professional for more specific details.

IMPORTANT INFORMATIO N

To our valued customers:


FINRA Rule 2231 requires that we advise you to promptly report any inaccuracy or discrepancy in your account (within 10 days after available) to your brokerage firm and clearing firm (where
these are different firms) and to re-confirm any oral communications in writing.
https://www.finra.org/rules-guidance/notices/06-72
"IMPORTANT - Part of your distribution includes a return of capital. Any distribution that represents a return of capital reduces the estimated per share value shown on your account
statement."
The preceding notice is required when reporting distributions on Direct Participation Programs and/or REITs and is subject to the DPP or REIT sponsor's final capital return determination as
detailed in the IRS Form 1099 or K-1, as applicable.
Alternative or Other Investments, DPP, and Unlisted securities are not listed on a national securities exchange, are generally illiquid and that, even if a customer is able to sell the securities,
the price received may be less than the per share estimated value provided in the account. The evaluation method used for any particular DPP or REIT will be provided to clients upon request.
Certain positions are not held on Apex's books or custodied by Apex and are not Protected by SIPC.
September 1, 2023 - September 30, 2023
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Pursuant to SEC Rule 606, Apex Clearing Corporation is required to make publicly available a quarterly report with regard to its routing of non-directed orders. For the purpose of this Rule, we
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have entered into an agreement with Quantum5 Market Surveillance (a Division of S3 Matching Technologies) to disclose all required information pertaining to this rule. This information can
be accessed on the internet at: http://public.s3.com/rule606/apex/, or a written copy will be furnished at no cost upon request via telephone to (214) 765-1009.
SEC Rule 606 (b) requires a broker-dealer to disclose to its customers, upon request, "the identity of the venue to which the customer's orders were routed for execution in the six months prior
to the request, whether the orders were directed orders or non-directed orders, and the time of the transactions, if any, that resulted from such orders."
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In accordance with the Emergency Economic Stabilization Act of 2008 broker-dealers are required to track and report cost basis to the IRS in three phases over the next three years.
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jEquity securities acquired on or after January 1, 2011


jMutual fund and dividend reinvestment plan (DRIP) shares acquired on or after January 1, 2012:
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jDebit securities, options, and all other financial instruments acquired on or after January 1, 2014. (The IRS has extended this date from the previously announced date of January 1, 2013.)
Beginning this upcoming tax reporting season the cost basis of any covered equity security transaction (purchased after 12/31/10) that is required to be reported on a 1099-B will include its
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associated cost basis. If you have any questions about this important change to the IRS mandated reporting requirements, please contact your broker-dealer or registered advisor.
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IMPORTANT INFORMATION CONTINUED


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Please take note of the following description of Apex Clearing Corporation's excess SIPC coverage, which reflects certain changes made to the coverage effective August 8, 2013. The
Securities Investor Protection Corporation (×SIPCÖ) protects certain customer funds up to a ceiling of $500,000, including a maximum of $250,000 for cash claims. Please note SIPC does
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not cover commodity contracts and options on futures. For additional information regarding SIPC coverage, including a brochure, please contact SIPC at (202) 371-8300 or visit
www.sipc.org.
Apex has purchased an additional insurance policy to supplement SIPC protection. This additional insurance policy, widely known as ×excess SIPC,Ö becomes available to customers in the
event that SIPC limits are exhausted. This additional insurance provides protection for securities and cash up to an aggregate limit of $150 million, subject to sub-limits for any one
customer of $37.5 million for securities and $900,000 for cash. Similar to SIPC protection, this additional insurance does not protect against a loss in the market value of securities. For
additional information, please contact your broker.

FDIC SWEEP PROGRAM

For customers with balances in a bank deposit account as part of the Apex FDIC-Insured Sweep Program or shares of a money market mutual fund in which you have a beneficial interest,
those balances or shares may be liquidated on your order and the proceeds returned to your account or remitted to you in accordance with the applicable prospectus and/or Terms and
Conditions of the program.

For customers participating in the Apex FDIC-Insured Sweep Program, the Apex FDIC-Insured Sweep Program allows your cash balance to be eligible for insurance protection through the FDIC
up to the maximum applicable insurance limits. Customers may obtain information about FDIC, by contacting the FDIC at 1-877-275-3342, 1-800-925-4618 (TDD) or by visiting www.fdic.gov.
Deposit Account balances in the Apex FDIC-Insured Sweep Program are not protected by SIPC or any other excess coverage by Apex Clearing Corporation. Deposit Account balances are
protected as established by current applicable laws regulated by the FDIC.

NOTE: Occasionally, Apex FDIC-Insured Sweep Program's banks ("Program Banks") may be added or removed from the Participating Bank List, which is available on Apex's website. Apex will,
to the extent possible, update the Participating Bank List, with any added Program Banks at least 30 calendar days before making deposits. If a Program Bank is removed from Apex
FDIC-Insured Sweep Program (the "Program"), it will no longer be able to receive sweeps of your excess cash balance. If any of your excess cash balance is at a Program Bank that is removed
September 1, 2023 - September 30, 2023
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from the Program, Apex will transfer those funds into another Program Bank still in the Program or into your Apex Account, at Apex's discretion. You may contact your broker to specify any
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Program Banks into which you do not wish your excess cash balance to be swept. Please note that if there are insufficient Program Banks available in the Program, taking into account any
from which you have opted out, such that not all of your excess cash balance can be spread among Program Banks to ensure FDIC coverage, then some or all of your excess cash balance may
remain dormant in your Apex Account or may be deposited at a Program Bank but not covered by FDIC insurance. You may obtain additional information on each Program Bank at
www.fdic.gov.
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You are solely responsible for monitoring the total amount of your assets on deposit with each Program Bank (including non-Program funds and accounts) in order to determine the extent of
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FDIC insurance coverage available to you on those deposits, including Program deposits. Apex shall not take into account any money you have on deposit at a Program Bank outside of the
Program.
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A current Apex FDIC-Insured Sweep Program Bank List and Apex FDIC-Insured Sweep Program Terms and Conditions may be found at https:/apexclearing.com/disclosures/
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IMPORTANT INFORMATION
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APEX CLEARING CORPORATION DISCLOSURE STATEMENT

Apex Clearing Corporation ("Apex") recognizes the importance of providing information on an ongoing basis to the customers whose accounts are cleared through Apex. Your broker/dealer has
designated Apex as its clearing firm. In accordance with industry rules and regulations, Apex is required to disclose on an annual basis certain important regulatory notices and disclosures. To
comply with these requirements, Apex has published an Annual Disclosure Statement which is available on the Apex corporate web site, www.apexclearing.com. For customers who do not
have access to the internet please call Apex at 214-765-1009 and request a complete copy of the Annual Disclosure Statement be mailed to your address of record.
A brief summary of the content of the Annual Disclosure Statement is as follows:
j Anti-Money Laundering - Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account.
j Privacy Policy - The privacy of customers is a responsibility which Apex respects and protects for former customers as well as current customers.
j Margin Disclosure Statement: FINRA Rule 2264 - The Information furnished provides basic facts about purchasing securities on margin and alerts customers of certain risks
involved in trading securities in a margin account.
j Day-Trading Risk Disclosure Statement: FINRA Rule 2270 - Information to be considered before engaging in a day-trading strategy.
j Business Continuity Plan: FINRA Rule 4370 - A further summary of Apex's Disaster Recovery Plan to reasonable ensure business continuity.
j SEC Rule 606 and 607 (Payment for Order Flow and Order Routing information) - (Rule 606) Requires Apex to make public a quarterly report with regard to routing of
non-directed orders and (Rule 607) Requires Apex to disclose its payment for order flow practices.
j SEC Rule 10b-10 - Requires customers are provided with prior written notification of certain transactions that are not reported immediately through a trade confirmation.
j SIPC Information: FINRA Rule 2266 - The Securities Investor Protection Corporation ("SIPC") requires that funds are available to meet customer claims up to a ceiling of
$500,000, including a maximum of $250,000 for cash claims. For more information about SIPC coverage or to receive a brochure, please visit the SIPC website at www.sipc.org
or, call (202) 371-8300.
j Investor Education and Protection: FINRA Rule 2267 - Requires Apex to provide information about FINRA's BrokerCheck program. The investor brochure may be obtained from
FINRA BrokerCHeck hotline number (800) 289-9999 or the FINRA web site address www.FINRA.org.
j Joint NASD Industry Breakpoint Task Force - A further summary of a July 2003 report which recommends written disclosure regarding mutual fund breakpoints.
September 1, 2023 - September 30, 2023
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j Carrying Agreements: FINRA Rule 4311 - The firm with which you have opened your securities account has retained Apex to provide certain record keeping, clearance, and
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settlement functions. A further summary of details is disclosed.


j Extended Hours Trading Risk Disclosure: FINRA Rule 2265 - Risks to consider include lower liquidity, higher volatility, changing prices, unlinked markets, news announcements,
wider spreads, and lack of calculation.
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j Liens and Levies - Apex will abide by the directions of federal, state, or other levying authorities.
j Regulation E - Disclosure regarding certain electronic transfers is required under the provisions of this regulation as issued by the Board of Governors of the Federal Reserve
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System.
j Municipal Securities Rulemaking Board ("MSRB") Rule G-10 requires an annual notification that 1) Apex Clearing Corporation is registered with the U.S. Securities and Exchange
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Commission and the Municipal Securities Rulemaking Board, 2) the MSRB publishes an investor brochure that is published on their website that describes the protections that may be
provided by the MSRB and how to file a complaint with the regulatory authorities and 3) a copy of the MSRB Investor Brochure as well as information regarding prospective, new and
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existing MSRB rules may be found on the MSRB website by going to the following link: http://www.msrb.org/,
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IMPORTANT INFORMATION - Privacy Policy


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Apex Clearing Corporation ("Apex") carries your account as a clearing broker by arrangement with your broker-dealer or registered investment advisor as Apex's introducing client. At Apex, we
understand that privacy is an important issue for customers of our introducing firms. It is our policy to respect the privacy of all accounts that we maintain as clearing broker and to protect the
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security and confidentiality of non-public personal information relating to those accounts. Please note that this policy generally applies to former customers of Apex as well as current
customers.

Personal Information Collected


In order to service your account as a clearing broker, information is provided to Apex by your introducing firm who collects information from you in order to provide the financial services that
you have requested. The information collected by your introducing firm and provided to Apex or otherwise obtained by Apex may come from the following sources and is not limited to:
j Information included in your applications or forms, such as your name, address, telephone number, social security number, occupation, and income;
j Information relating to your transactions, including account balances, positions, and activity;
j Information which may be received from consumer reporting agencies, such as credit bureau reports;
j information relating to your creditworthiness;
j Information which may be received from other sources with your consent or with the consent of your introducing firm.

In addition to servicing your account, Apex may make use of your personal information for analysis purposes, for example, to draw conclusions, detect patterns or determine preferences.

Sharing of Nonpublic Personal Information


Apex does not disclose non-public personal information relating to current or former customers of introducing firms to any third parties, except as required or permitted by law, including but
not limited to any obligations of Apex under the USA PATRIOT Act, and in order to facilitate the clearing of customer transactions in the ordinary course of business.

Apex has multiple affiliates and relationships with third party companies. Examples of these companies include financial and non-financial companies that perform services such as data
processing and companies that perform securities executions on your behalf. We may share information among our affiliates and third parties, as permitted by law, in order to better service
your financial needs and to pursue legitimate business interests, including to carry out, monitor and analyze our business, systems and operations.
September 1, 2023 - September 30, 2023
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Security
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Apex strives to ensure that our systems are secure and that they meet industry standards. We seek to protect non- public personal information that is provided to Apex by your introducing firm
or otherwise obtained by Apex by implementing physical and electronic safeguards. Where we believe appropriate, we employ firewalls, encryption technology, user authentication systems
(i.e. passwords and personal identification numbers) and access control mechanisms to control access to systems and data. Apex endeavors to ensure that third party service providers who
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may have access to non-public personal information are following appropriate standards of security and confidentiality. Further, we instruct our employees to use strict standards of care in
handling the personal financial information of customers. As a general policy, our staff will not discuss or disclose information regarding an account except; 1) with authorized personnel of
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your introducing firm, 2) as required by law or pursuant to regulatory request, or 3) as authorized by Apex to a third party or affiliate providing services to your account or pursuing Apex's
legitimate business interests.
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Access to Your Information


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You may access your account information through a variety of media offered by your introducing firm and Apex (i.e. statements or online services). Please contact your introducing firm if you
require any additional information.
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IMPORTANT INFORMATION - Privacy Policy - CONTINUED


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Apex may use "cookies" in order to provide better service, to facilitate its customers' use of the website, to track usage of the website, and to address security hazards. A cookie is a small
piece of information that a website stores on a personal computer, and which it can later retrieve.
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Changes to Apex's Privacy Policy


Apex reserves the right to make changes to this policy.

CONTACT APEX CLEARING


For general inquiries, please submit your questions to our Individual Investor Contact Page on the Apex website. Our Customer Support team will assist in providing the necessary answers to
your questions.

Individual Investor Contact Page: https://go.apexfintechsolutions.com/individual-investor-contact-form

Physical mail may be sent to:


Apex Clearing Corporation
Attn: Customer Support
350 N. St. Paul St., Suite 130
Dallas, Texas 75201

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