Ally Ventures

• 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
• 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 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

Apex Clearing Corp CREDIT TERMS AND POLICIES The following Disclosure of Credit Terms and Policies is required by the Securities and Exchange Commission and is part of your Apex Clearing Corp Account–Customer Account Agreement It describes the terms under which we extend credit and charge interest and how your obligations are secured by property in your Account

Interest Charges We will charge interest on a daily basis on the credit we extend to you The daily interest charges are calculated by multiplying your "daily adjusted debit balance" by the "daily margin interest rate " Generally speaking, your daily adjusted debit balance is the actual settled debit balance in your Margin and Short Account, increased by the value of securities held short and reduced by the amount of any settled credit balance carried in your Cash Account

We calculate your daily-adjusted debit balance each day by adjusting your previous day's balance by any debits and credits to your account and by changes in the value of short positions If your daily-adjusted debit balance is reduced because you deposit a check or other item that is later returned to us unpaid, we may adjust your account to reflect interest charges you have incurred

We reserve the right to charge interest on debit balances in the Cash Account Periodically, we will send you a comprehensive statement showing the activity in your account, including applicable interest charges, interest rates and adjusted daily debit balances

Daily Margin Interest Rate The "daily margin interest rate" is based on a 360-day year It is calculated for each day by dividing the base margin interest rate by 360 Note that the use of a 360-day year results in a higher effective rate of interest than if a year of 365 days were used

The applicable margin interest rate is the base rate for all daily adjusted debit balances Your margin interest rate will be adjusted automatically and without notice to reflect any change in the Base Rate If your interest rate increases for any reason other than a change in the Base Rate, we will give you written notice at least 30 days' prior to that change

Compounding Interest Charges We compound interest on a daily basis Interest charges will accrue to your account each day We will include the charges in the next day's opening debit balance and charge interest accordingly The interest rates described above do not reflect compounding of unpaid interest charges; the effective interest rate, taking into effect such compounding, will be higher

Initial Margin Requirements The Federal Reserve Board and various stock exchanges determine margin loan rules and regulations When you purchase securities on margin, you agree to deposit the required initial equity by the settlement date and to maintain your equity at the required levels The maximum amount we currently may loan for common stock (equity) securities is 50% of the value of marginable securities purchased in your Margin and Short Account; different requirements apply to non-equity securities, such as bonds or options If the market value of stock held as collateral increases after you have met the initial margin requirements, your available credit may increase proportionately Conversely, if the market value decreases, your available credit may proportionately decrease

Initial margin requirements may change without prior notice We may impose anytime and without prior notice more stringent requirements on positions that in our sole discretion involve higher levels of risk; for example, higher limits may apply for thinly traded, speculative or volatile securities, or concentrated positions of securities

You may purchase only certain securities on margin or use them as collateral in your Margin and Short Account Most stocks traded on national securities exchanges, and some over-the-counter (OTC) securities are marginable At our discretion, we reserve the right not to extend credit on any security

Equity securities with a market value of less than $3 per share may not be purchased on margin or deposited as margin collateral If the market value of a security drops below $3 per share, the security will not be assigned any value as collateral to secure your margin obligations

Margin Maintenance Requirements You must maintain a minimum amount of equity in your account to collateralize your outstanding loans and other obligations Margin maintenance requirements are set:

• By the rules and regulations of the New York Stock Exchange, the American Stock Exchange and other regulatory agencies to the jurisdiction of which we are subject; and
• According to our sole discretion and judgment

You agree to maintain in your Margin and Short Account collateral of the type and amount required by:

• Applicable exchange rules and federal regulations; and
• Our Disclosure of Credit Terms and Policies; or
• As required by us, at our discretion

Margin maintenance requirements may change without prior notice

We may issue a "margin call" (that is, a notification to deposit additional collateral) if your account equity falls below the margin maintenance requirement This can happen for various reasons The most common reasons are a decrease in the value of long securities held as collateral or an increase in the value of securities held short

As a general guideline and when it is practicable to do so, we may (but are not required to) issue a margin call when the equity in your Margin and Short Account falls below a predetermined percentage of the market value of assets at risk (that is, the sum of the market values of the long and short equity security positions) in your Margin and Short Account The amount of additional collateral we require usually is an amount sufficient to raise your equity to minimum standards For information on the current equity requirements, please contact your broker

We retain absolute discretion to determine whether, when and in what amounts we will require additional collateral In some situations, we may find it necessary to require a higher level of equity in your account For example, we may require additional collateral if an account contains:

• Only one security or a large concentration of one or more securities; or