Account Opening Disclosures

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1 Account Opening Disclosures Arbitration of Disputes Your agreement contains a pre-dispute arbitration clause. By signing an arbitration agreement the parties agree as follows: a) All parties to this agreement are giving up the right to sue each other in court, including the right to a trial by jury, except as provided by the rules of the arbitration forum in which a claim is filed. b) Arbitration awards are generally final and binding; a party s ability to have a court reverse or modify an arbitration award is very limited. c) The ability of the parties to obtain documents, witness statements and other discovery is generally more limited in arbitration than in court proceedings. d) The arbitrators do not have to explain the reason(s) for their award. e) The Panel of Arbitrators will typically include a minority of arbitrators who were or are affiliated with the securities industry. f) The rules of some arbitration forums may impose time limits for bringing a claim in arbitration. In some cases, a claim that is ineligible for arbitration may be brought in court. g) The rules of the arbitration forum in which the claim is filed, and any amendments thereto, shall be incorporated into this agreement. In consideration of opening one or more accounts for you, you agree that any controversy between you and Stonnington Group, LLC and/or your Representative arising out of or relating to your account, transactions with or for you, or the construction, performance, or breach of this agreement whether entered into prior, on or subsequent to the date hereof, shall be settled by arbitration in accordance with the rules, then in effect, of the Financial Industry Regulatory Authority ( FINRA ). Any arbitration award hereunder shall be final, and judgment upon the award rendered may be entered in any court, state or federal, having jurisdiction. You understand that you cannot be required to arbitrate any dispute or controversy that, under federal law, is not subject to arbitration. Investment Risk Disclosure In consideration of Stonnington Group, LLC agreeing to open one or more accounts on your behalf, you hereby understand, acknowledge and agree: You understand that investing in securities involves risks and that many variables, including, but not limited to market and economic fluctuations, may have a substantial negative effect on the value of your securities positions. Furthermore, you represent to Stonnington Group, LLC that you are willing to assume these risks and that you are

2 in fact financially able to bear these risks. You agree to notify Stonnington Group, LLC in writing should your financial condition materially change, or should your investment objective change from when the account was opened. For each purchase of mutual fund shares you agree to disclose information regarding your current holdings within the same fund family, either individually or in related accounts. You also agree to advise Stonnington Group, LLC at the time of each mutual fund purchase whether or not you have recently liquidated mutual funds shares within the same fund family or a different fund family. This will enable us to provide you with any commission discounts to which you may be entitled. It may not be advisable to exchange from one variable product or mutual fund to another of like objective if such a transfer involves payment of an additional up front sales charge or surrender charges. However, there may be circumstances in which it is reasonable to do so. Exchanges within the same mutual fund family may be available at no commission and at reduced processing costs. Stonnington Group, LLC is an introducing broker dealer, FINRA member and registered investment advisor with the SEC and does execute trades for client accounts. While there is a best execution policy in place, all transactions in your account are subject to the rules, customs and usages of the exchanges, markets or clearing houses where the transactions are executed and to all applicable federal and state laws and regulations. Notice to Customers re Identity Verification Important Information About Procedures for Opening a New Account To assist the government in fighting the funding of global 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 account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask you to provide a copy of a government issued photo identification or other identifying documents that establish your identify.

3 SEC Rule 10b-10(a)(2)(i)(D) and Rule 11Ac1-3; Payment for Order Flow This section provides information about the payment and order routing policies of Stonnington Group, LLC. First and foremost, the firm s order routing decisions are based on the overriding principle of best execution. Currently, Stonnington Group, LLC, has deemed it appropriate not to accept remuneration for directing orders to designated broker-dealers of market centers for execution. The firm routes most of its orders for listed equities to established market participants and clears all trades through its clearing firm, Pershing, LLC on a fully disclosed basis. Trades executed through the firm, both on listed and unlisted stocks may have the opportunity for price improvements (execution at prices superior to the displayed national best bid or offer). Market Volatility During times of extreme volatile market conditions, Stonnington Group, LLC, makes every attempt to execute customer orders in the most equitable fashion possible. As recommended in FINRA Notice to Members 99-11, Stonnington Group, LLC is making the following disclosures to all of its customers. High volumes of trading at the market opening or intra-day may cause delays in execution and executions at prices significantly away from the market price quoted or displayed at the time the order was entered. Customers should be aware of the difference between market and limit orders and the benefits and risks of each. Broker-dealers are required to execute a market order fully and promptly without regard to price and that, while a customer may receive a prompt execution of a market order, the execution may be at a price significantly different from the current quoted price of that security. Limit orders will be executed only at a specified price or better and that, while the customer receives price protection, there is the possibility that the orders will not be executed. Customers should recognize the risk of placing market orders for initial public offerings (IPO) securities trading in the secondary market, particularly those that trade at a much higher price than their offering price, or in hot stocks (especially those that trade for a period of time under what is known as fast market conditions, in which the price of the security changes so quickly that quotes for a stock do not keep pace with the trading price of the stock). In such cases customer s risk of receiving an execution substantially away from the market price at the time they place the order may be significantly reduced if they also include a cap (or floor) with the order above (or below) which the order is not to be executed, by placing a limit order. Customers may suffer market losses during periods of volatility in the price and volume of a particular stock when system problems, including those of other broker-dealers, result in

4 inability to place buy or sell orders. To view the entire FINRA Notice to Members 99-11, please go ite to: Privacy Policy Stonnington Group, LLC has developed a privacy policy in response to SEC Regulation S-P, the Privacy Policy. The firm will provide the policy to: a) New customers at the time an account is opened, including an opt out option; b) Customers before information is provided to any nonaffiliated third party; and, c) Existing customers on an annual basis. Securities Investor Protection Corporation Customers m a y o b t a i n i n f o r m a t i o n about the Securities Investor Protection Corporation ( SIPC ), including the SIPC brochure, by contacting SIPC at: SIPC th Street N.W., Suite 800 Washington, D.C Phone: (202) Fax: (202) Business Continuity/Disaster Recovery Plan Stonnington Group, LLC is committed to best practices in all areas of our firm including business continuity and disaster recovery in the event of any disruptions to our business operations. A copy of our Plan is available upon request at account opening or any time thereafter and can also be downloaded at your convenience from our website (). Brokerage Account vs. Advisory Account If this account is a brokerage account and not an advisory account or an advisory account held on our introducing broker dealer platform at Pershing, LLC, and our interests may not always be the same as yours. Please don t hesitate to contact us to make sure you understand your rights and our obligations to you, including the extent of our obligations to disclose conflicts of interest and to act in your best interest. We are paid both by you, and, sometimes, by people who compensate us based on what investments you purchase. Therefore, our profits and compensation may vary by product and over time. Please call us at (818) if you have any questions about the difference between brokerage and advisory services.

5 Complaints Kindly direct any complaints, concerns regarding the handling of your account to: Denise Evans Chief Compliance Officer T: (818) We will respond as promptly as possible.

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