Important Information Regarding Trading Digital Assets with Paxos Trust Company

BFT offers customers with FX trading accounts at BFT the ability to access digital asset trading and custody services (the “Paxos Services”) in an account in the customer’s name (the “Paxos Account”) at Paxos Trust Company, LLC (“Paxos”) through BFT’s electronic trading platform and interface. The digital assets in your Paxos Account are maintained at Paxos, while all other assets are carried in your BFT account.

You should carefully consider the risks below before making a decision to utilize the Paxos Services.

Trading Digital Assets is Risky

Digital asset prices are highly volatile and can rise or fall dramatically and quickly. If you hold a position in digital assets and the value of the asset falls, you can lose money.

The use of digital currencies may result in a financial loss at the time such currencies are exchanged for fiat currency due to an unfavorable exchange rate.

You should carefully consider your financial circumstances and your risk tolerance before trading digital assets with Paxos, and you should not trade digital assets unless you have the financial capability to sustain losses if they occur.

The use of any investment strategies and techniques is at your sole discretion, and there may be additional unforeseen risks when trading digital assets.

You should be aware that you may sustain a total loss of the assets in your Paxos Account.

No Investment Advice, Recommendations, or Tax Advice

BFT does not provide investment, legal, tax, or trading advice or recommendations. By making digital assets available to you, neither BFT nor Paxos makes any assessment, representation, or warranty concerning the appropriateness or suitability of digital assets for your financial circumstances.

The Paxos Services are “execution only.” BFT and Paxos will not advise you on any transaction, and you take full responsibility for your trading actions.

Neither BFT nor Paxos will assess whether your transactions are suitable for you or help you avoid losses. You should obtain your own financial, legal, taxation, and other professional advice as to whether digital assets are appropriate investments for you.

Digital Asset Holdings Are Not Covered by FDIC or SIPC

By offering customers the ability to trade digital assets through a cryptocurrency broker/custodian that is suitably licensed, customers have separate accounts in their own name.

These cryptocurrency broker/custodians are not broker-dealers, and digital assets are not securities; therefore, SIPC coverage does not apply to accounts at cryptocurrency broker/custodians.

Likewise, most cryptocurrency broker/custodians are not insured banks, and digital assets are not cash; therefore, FDIC coverage does not apply to accounts at cryptocurrency broker/custodians.

BFT has selected Paxos as the cryptocurrency broker/custodian with which to work. By requesting trading permissions for digital assets through BFT’s platform, you are opening an account in your name at Paxos (the previously mentioned Paxos Account).

All trading you do in digital assets through BFT’s platform will be executed in your Paxos Account (and not an account at BFT), and Paxos will be your custodian and counterparty for those trades, which means that Paxos holds your digital assets for you and represents your ownership of them on their internal ledger.

As explained above, the holdings in your Paxos Account are not protected by FDIC or SIPC insurance in the event of Paxos’ or BFT’s insolvency.

NFA Disclosure

Because BFT is a member of the National Futures Association (“NFA”), BFT is required to provide you with the following disclosure in connection with trading digital assets, or “virtual currencies”:

BFT IS A MEMBER OF NFA AND IS SUBJECT TO THE NFA’S REGULATORY OVERSIGHT AND EXAMINATIONS. HOWEVER, YOU SHOULD BE AWARE THAT NFA DOES NOT HAVE REGULATORY OVERSIGHT AUTHORITY OVER UNDERLYING OR SPOT VIRTUAL CURRENCY PRODUCTS OR TRANSACTIONS OR VIRTUAL CURRENCY EXCHANGES, CUSTODIANS OR MARKETS.

Paxos is not an NFA Member.
Paxos is not an NFA member and is not subject to the NFA’s regulatory oversight and examinations.

Trading Hours May Be Limited

Digital assets generally trade 24/7, and their prices may change dramatically over the weekend.

However, your ability to access your Paxos Account through BFT’s platform, including purchasing or selling digital assets over the weekend, may be limited, most notably due to planned maintenance hours.

Please visit BFT’s website for additional details on trading hour limitations.

Market Volatility

The market for digital assets can be extremely volatile. The price of digital assets may be influenced by, among other things:

• Volatile market price swings or flash crashes
• Market manipulation and cybersecurity risks
• The performance of the global economy
• New or amended government regulation
• Supply and demand relationships for digital assets
• Governmental, commercial, and trade policies
• Interest rates and inflation
• Technological developments
• Political and economic events
• Social media sentiment and public perception

Margin and Liquidity Risks

• No Margin Value:
  The digital assets custodied in your Paxos Account will not be assigned any margin value and will not count toward your FX margin requirements in your BFT account.
  If you have insufficient equity in your BFT account to meet FX margin requirements, your FX assets may be liquidated per our standard margin closeout process.
• Liquidity Risk:
  Paxos is not obligated to provide quotes for digital assets at any time.
  Neither Paxos nor BFT guarantees the continuous availability of quotations or trading for digital assets on Paxos’ or any other exchange.

Fees and Commissions

Paxos will charge commissions on your digital asset trades.
For more details on commissions, please see BFT’s website.

Paxos Account Terms

Your Paxos Account is governed by the Paxos Terms & Conditions (“Paxos T&Cs”).
You should read the Paxos T&Cs carefully to fully understand the terms of your relationship with Paxos.

Short Selling Is Not Permitted

Short sales of digital assets in your Paxos Account are prohibited.
This limitation may negatively impact your ability to protect against trading losses.

Limited Availability of Digital Assets

The digital assets available for trading in your Paxos Account are limited and subject to change.
Either Paxos or BFT may further limit which digital assets can be traded without prior notice.

A complete list of available assets is published on BFT’s website.

Disruption or Interruption Risks

Both BFT and Paxos rely on computer software, hardware, and telecommunications infrastructure to deliver services.

These systems are inherently vulnerable to disruption, delay, or failure, which could:

• Prevent access to your Paxos Account
• Interrupt digital asset quotations or trading
• Negatively impact the services provided by BFT or Paxos

Under BFT’s Customer Agreement, you accept the BFT systems and services “as is” and agree that BFT’s liability is limited.

Potential Conflicts of Interest

By partnering with Paxos to offer digital asset trading, BFT may benefit financially through fees collected from customer transactions.

BFT is not a party to any transactions in digital assets that occur through Paxos.