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Clearpool Disclosure Statement

Privacy Policy and Opt Out Option

Clearpool Execution Services LLC (“CES”) 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”). CES recognizes the importance of protecting the privacy of our customers and as such, we have policies in place to maintain the confidentiality and security of customer information. It is CES’s general policy to restrict access to nonpublic client information to only those employees who have a need to know the information. CES may, in certain circumstances, share customer information with affiliates in order to better serve you.

CES collects information from you to service your account, process transactions, and to comply with applicable laws and regulations. CES gathers information about you in several ways: 1) Information on account opening documents and other forms needed to service your account and comply with applicable rule and regulations, including tax ID number, and specific information about your business; 2) Information about the transactions you execute through CES and its affiliates; 3) Information we receive from affiliates or reporting agencies.

CES protects your information by limiting access to those employees and affiliates who need access for appropriate business purposes including to service your account, and perform required reviews. CES may also disclose customer information to companies that provide services for CES with whom we have a non-disclosure agreement. CES maintains electronic and procedural safeguards to protect the information we collect from you.

CES must obtain your consent before it can share nonpublic customer information with, or obtain certain information from its affiliates. Unless and until you notify CES in writing to the contrary, you shall be deemed to have consented to the disclosure of nonpublic information between CES and its affiliates, to the extent permitted by law.

Important AML Information for Opening a New Account

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. What this means for you: When you open an account with CES, we will ask for your name, address, and any other information that will allow us to identify you. We may also ask to see other identifying documents.

Statement of Policy Regarding Payment for Order Flow

CES 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 SEC 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 exchange for sending customer orders to such entities for execution. CES does receive payment for order flow.

Technology

CES is not responsible for any performance or communication issues relating to any third party technology including but not limited to order management or portfolio management systems.

Customer Complaints

To file a complaint regarding Clearpool Execution Services, LLC (“CES”), employee of CES, or services provided to you by CES contact:

Compliance
Clearpool Execution Services, LLC
17 State Street, 38th Floor
New York, NY 10004
212-531-8518

Information Concerning FINRA Broker Check

FINRA requires that CES, as a member firm, notify our customers about the availability of information through the FINRA Broker Check program. To obtain a brochure or to log onto FINRA Broker Check you may use the following information: the FINRA Broker Check Hotline Number is 1-800-289-9999; the FINRA Web Site address is www.finra.org.

SIPC Disclosure

CES, 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:

Securities Investor Protection Corporation 805 Fifteenth Street NW, Suite 800
Washington, DC 20005-2215
Tel. (202) 371-8300
Web Site: http://www.sipc.org/

Information Concerning CES’s Business Continuity Plan

Clearpool Execution Services, LLC (“CES”) is committed to taking commercially reasonable steps to provide protection for essential activities and critical support services should significant business disruption result from events such as power outages, natural disasters, pandemics or other situations. CES has established a Business Continuity Plan intended to protect customer data while enabling continued operation of critical functions during or immediately following a disruption.

Since the timing and impact of disasters and disruptions is unpredictable, we 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.

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

The Continuity Plan is reviewed and tested annually and has been approved by senior management.

Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternative physical location of employees; critical supplier, contractor, bank and counter-party impact; and regulatory reporting. A copy of the CES Business Continuity Plan can be obtained by contacting CES compliance at 212-531-8518. We constantly re-evaluate and improve our response to disruptive events, therefore the CES Business Continuity Plan is subject to modification without notification.

Annual 606 Disclosure