CFD TRADING GUIDE 10/2005 Authorised and regulated by FSA UK; NFA USA; ASIC Australia; CBRC China; SFC Hong Kong; BAFIN Germany; OSC Canada.



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CFD TRADING GUIDE 10/2005 Authorised and regulated by FSA UK; NFA USA; ASIC Australia; CBRC China; SFC Hong Kong; BAFIN Germany; OSC Canada. Copyright 2005 CMC Markets, 66 Prescot Street, London, England, E1 8HG. All Rights Reserved.

NOTICE AND RISK WARNING Notice Whilst every effort has been made to ensure the accuracy of the other parts of this Trading Guide, the information given is subject to change and is for guidance only. Risk Warning Investing in Derivatives carries high degree of risk to the investor, which due to fluctuations in value, the investor may not get back the amount of their original investment, and in certain circumstances be liable to pay a far greater sum. The inherent concept of Derivatives means that they are not suitable for the investor seeking income from such investments, and are only suitable for those who have the required experience and understand the market risks. It is advisable to seek independent advice if necessary. Copyright 2005 CMC Markets, London, England. All rights reserved. No part of this document may be reproduced by any means without the prior written consent of CMC Markets. Any unauthorised copying or distribution in whole or part will constitute an infringement of copyright.

INTRODUCTION TO CMC MARKETS Unique Service The service we provide is unique. We obtain very competitive prices and pass on the benefit this presents directly to our clients. Our clients also benefit from free use of our highly acclaimed MarketMaker R trading software, which won the Millennium Product Award from the UK Government for outstanding innovation. Our software enables real time dealing prices in over 1000 financial instruments including Shares, Indices and Sectors to be delivered directly to our clients enabling them to trade in seconds, 24 hours a day. Our, 24-hour, service includes a full on-line back office function complete with statements, position summaries, order/trade histories, news, analysis and charting. Our clients are also able to chat live direct to our Dealers or Helpdesk via our software. Our aim is to provide our clients with the most efficient and professional service with the ability to trade at the most competitive prices, permanently commission free and real-time via the Internet or telephone. Execution Only We pride our service on an execution-only basis and clients will only be accepted for execution-only business. As such we shall not advise or exercise any judgement on your behalf nor can you request any such advice or judgement as to the suitability of trades. Risk Warning Do not invest in derivatives with money you cannot afford to lose. Past performance does not guarantee future performance. An investment in derivatives carries a high degree of risk to the investor, and which due to fluctuations in value, the investor may not get back the amount s/he has invested. 3

This guide is designed to help you understand trading with CMC Markets. If you have any additional questions you can contact a member of our staff. Please read this guide thoroughly so you fully understand our service. Good luck with your trading. CONTENTS AND INDEX SECTION 1: GENERAL DEALING / ADMINISTRATION 1. DEALING 1.1 Introduction to the Trading Guide 1.2 Internet Based Dealing 1.3 Telephone Based Dealing 1.4 CFD means Contract For Difference 2. OPENING THE POSITION 2.1 How to Open a Position 2.1.1 Buying / Placing a long position 2.1.2 Selling / Placing a short position 2.1.3 Minimum trade Size 3. CLOSING THE POSITION 3.1 How to Close a Position 3.1.1 Selling / Placing a short position 3.1.2 Buying / Placing a long position 3.1.3 Partial Closing of positions 4. ORDER TYPES 4.1 Conditional Orders 4.1.1 Day Orders 4.1.2 Good Till Cancelled (GTC) 4.2 Limit Orders 4.2.1 Limit order to close an open position 4.2.2 Limit order used to open a new position 4.3 Stop Orders 4.3.1 Stop order to close an open position 4.3.2 Stop order used to open a new position 4.4 One Cancels the Other (OCO) 4.5 If Done 4.6 Guaranteed Stop Order (GSO) 5. CONFIRMATIONS/ POSITIONS/ STATEMENTS 5.1 Confirmations 5.2 Positions 5.3 Statements 6. ROLLOVERS 6.1 Financing 6.1.1 Shares and Indices 7. INITIAL MARGIN 7.1 What is Margin 7.1.1 Initial Margin 7.1.2 Variation Margin 7.2 Margin Requirements 7.3 Equity Balances 7.4 Shortage of Equity 7.5 Margin Calls 7.6 Liquidation / Stop Out Level 7.7 Trading Profits / Losses 8. PAYMENTS 8.1 Depositing Funds 8.2 Withdrawing Funds 8.3 Interest on Equity Balances 9. ADMINSTRATION 9.1 General 9.2 Trade Confirmation 9.3 Position Summary 9.4 Ledger Activity 9.5 Margin Requirements 9.6 Ledger Reval 9.7 Equity Summary 9.8 Delivery of Statements and Confirmation 9.8.1 On-line Users 9.8.2 E-mail Services APPENDIX A: FREQUENTLY ASKED QUESTIONS APPENDIX B: CONTACT US SECTION 2: INSTRUMENT TABLE AND RATES 1. GUARANTEED STOP ORDER 1.1 Placing a GSO 1.2 Premium Calculation 1.3 Placing Levels 2. FINANCING AND MARGIN 2.1 Financing 2.1.1 Shares and Indices 2.2 Initial Margin 3. SHARE TRADING 3.1 Normal Trading Hours 3.2 Extended Trading Hours 3.3 Placing a Trade 3.4 Initial margin 4

3.5 Dividends 3.6 Corporate Actions 3.7 Share Pricing 3.8 Mark to Market 3.9 Liquidations 3.10 Share Tables 4. INDEX TRADING 4.1 Trading Hours 4.2 Placing an Index Trade 4.3 Initial Margin 4.4 Index Pricing 4.5 Dividends 4.6 Mark to Market 4.7 Liquidations 4.8 Maximum Position Limits 4.9 Indices Tables 5. SECTOR TRADING 5.1 Trading Hours 5.2 Placing a Sector Trade 5.3 Initial Margin 5.4 Sector Pricing 5.5 Dividends 5.6 Mark to Market 5.7 Liquidation 5.8 Expiry and Rollover Days 5.9 Sector Tables 6. TREASURY TRADING 6.1 Markets Covered 6.2 Trading Hours 6.3 Placing a Treasury CFD 6.4 Initial Margin / NTR 6.5 Treasury Pricing 6.6 Mark to Market 6.7 Liquidations 6.8 MOC Settlement Prices 6.9 MOC Restrictions 6.10 Treasury Tables 7. COMMODITY TRADING 7.1 Markets Covered 7.2 Trading Hours 7.3 Placing a Commodity Trade 7.4 Initial Margin / NTR 7.5 Pricing 7.6 Mark to Market 7.7 Liquidations 7.8 Commodity Table 5

SECTION 1: GENERAL DEALING / ADMINISTRATION 1. DEALING 1.1 Introduction to the Trading Guide This Trading guide has been developed to assist clients of CMC Markets CFD trading service. It provides explanations of how to open and close positions, the types of trades we offer, technical terms, and financing requirements, as well as practical examples of trades and an explanation of your trading statement. The Trading Guide is aimed to provide you with all relevant information you require to open, run and maintain a CFD account with CMC Markets. We recommend that you pay particular attention to the nature and types of trades available through CMC Markets, which may vary in detail from firms. Our Frequently asked Questions Section may also help you in this respect (see Appendix A). 1.2 Internet Based Dealing Our Internet service provides clients with the capability to execute CFD trades in seconds simply by clicking on our latest dealing price. There is also a full on-line back office and position keeping service. Typically it will be quicker for clients to deal via the Internet as opposed to the telephone because the Internet service will be automatically publishing our latest dealing prices in real time. To open a trade via the Internet, simply click on the latest real time price for the product you want to deal in. A deal ticket appears and you simply enter the trade details. Click place order and the deal is done when confirmed back by CMC Markets. This usually happens within seconds of the order being placed. Please Note: we recommend you take time to read the full CFD/FX Software User Guide for the On-line dealing system. This is available to all our clients as they log on. 1.3 Telephone Based Dealing If it becomes nesscessary to deal over the telephone, there are various factors you must adhere to in order to avoid confusion or errors and minimise delay, especially in a fast moving market. Before calling the dealing room you must: Know the Instrument (e.g. Vodafone or UK100) of the trade you wish to place; Decide in advance whether you want to buy (place a long position ) or sell place a short position (see paragraphs 2.1.1 & 2.1.2 below); Decide in advance on the size/amount of the trade (see paragraph 2.1.3 below); Have your account number to hand; Ideally have a good idea of where the market is trading i.e. the level or price of a particular share or index. This can be checked on our website, through the trading software or by requesting it from our dealers. Example: Hello, can I have a dealing quote for Vodafone Group for 2000 CFD s please? You do not at this point have to declare whether you want to buy (place a long trade) or sell (place a short trade). 6

Continuing with this example and with the assumption that you think that Vodafone will weaken (or go down) - on hearing the dealers quote, if the price is acceptable, you would say: sell 2000 CFD s. The dealer will then confirm the trade to you: At 140 - you sell 2000 CFD s of Vodafone. Please Note: It is important that you give your order immediately. Prices in the markets are changing all the time, and a price quotation has to be accepted or refused within seconds. You may refuse the quote by saying: nothing there. In a fast moving market, once the dealer has quoted a price, you may hear: out or change, which means that the price has changed and you can no longer deal at the original price. You may then request a new quote. Please Note: You must always wait for the dealer to confirm your trade and not assume that you have executed your trade on giving your instructions to buy or sell. By instigating the trade in the above example, you now have an open position. You are now short 2000 CFD s of Vodafone at 140. If you bought Vodafone then you would commonly be known as being long Vodafone. If you wished to close this open position you simply follow the same procedure outlined above this time placing an equal and opposite trade as previously opened (see Section 1, paragraph 3.1 below). In the above example you would now need to instruct the dealer to buy 2000 CFD s of Vodafone to close your open position. Please Note: You must place an equal and opposite trade to close your position (see Section 1, paragraph, 3. below). On closing an open position you do not need to inform the dealer that you are closing an open position, as this is your responsibility and will be shown automatically in your statement once you have performed your equal and opposite trade (see paragraph 3. below). Once a trade is executed, no cancellations, adjustments or waiving of trades will be allowed. 1.4 CFD means Contract for difference A CFD offers you all the benefits of trading shares without having to physically own them. Simply put, it is a contract that mirrors the performance of a share or index. It is traded on margin, and just like physical shares your profit or loss is determined by the difference between the price you buy at and the price you sell at. 2. OPENING THE POSITION 2.1 How to Open a Position A position is opened by either buying (placing a long trade) or selling (placing a short trade) on a share, index, currency or other financial instrument offered by us. 2.1.1 Buying / Placing a long trade. You can open a trade by buying or placing a long trade on the share, index. To make a profit, you want the price of that instrument to rise. 2.1.2 Selling / Placing a Short trade You can open a trade by selling or placing a Short trade on the share, index. To make a profit, you want the price of that instrument to fall. 7

2.1.3 Minimum Trade Size 3. CLOSING A POSITION The minimum trade size is 1 CFD on all products apart from the Japanese index (100 CFDs) and the HongKong 100 index (Hangseng) (10 CFDs). 3.1 How to Close a Position You can close your open position by placing a trade of an equal and opposite amount of the same instrument as you previously opened. Please Note: Please also remember to cancel any related conditional orders you have placed as failure to do so may result in that order remaining in the market at risk of execution (see Section 1, para. 4.1.2 below). 3.1.1 Selling / Placing a Short trade You can close an open long position by selling or placing a short trade of an equal and opposite amount of the same instrument as you previously opened with us. Closing your position will result in a profit or loss being realised on your account. 3.1.2 Buying / Placing a Long trade You can close an open Short position by buying or placing a long trade of an equal and opposite amount of the same instrument as you previously opened with us. Closing your position will result in a profit or loss being realised on your account. 3.1.3 Partial Closing of Positions You may close part of an open position by selling or placing a Short trade or buying or placing a Long trade of the same instrument (as above) for a lesser or greater amount. The difference between the two amounts (opening and closing trades) will result in the creation of a new open position. This will mean that you will either have a remaining position in your original position or you have created a new long trade or Short trade as the case may be (stopped and reversed). 4. ORDER TYPES 4.1 Conditional Orders We offer you the ability to place Conditional Orders such as Limits, Stops, Guaranteed Stop Orders (GSOs), If done and OCOs to help you manage your risk. By using these additional order types you have the ability to effectively control potential profits as well as potential losses on your open positions. Conditional Orders can be placed either as Day Orders or Good Til Cancelled (GTC). Please Note: Unless you are using GSOs (Guaranteed Stop Orders), CMC Markets does not guarantee to execute your Stop loss order at the price at which you placed it. Once your Stop loss level has been reached or breached, we will fill your order at the next available market price (which we cannot guarantee will be the same price). 4.1.1 Day Orders Conditional Orders can be placed as Day Orders. A Day order means that the order you place will either be executed or cancelled at the end of that trading day. Should you want to maintain that order in the market the next day, you will have to resubmit that order on the next trading day. 8

CMC Markets defines the trading day, as the normal and extended trading session for that instrument on each given trading day. Trading hours by instrument are defined later and can be found at our website (www.cmcmarkets.co.uk/help). 4.1.2 Good Til Cancelled (GTC) 4.2 Limit Orders Conditional Orders can also be placed as Good Til Cancelled. A Good Til Cancelled (GTC) order means that your order will remain in the market until it is either executed according to the terms of that order, or is cancelled by you. Please Note: Please remember to cancel any conditional orders you have placed that you no longer require, as failure to do so will result in that order remaining in the market at risk of execution (and the possibly the creation of a new open position). A Limit Order can be used to either open a new position or close an existing open position (partially or to stop and reverse, see Section 1, para. 3.1.3) at a predefined price set by you, which may be more favorable than the then current price for that instrument. Limit orders are executed at the price you specify. 4.2.1 Limit order to close an open position. Example: You have an existing open position of long 2000 Vodafone CFD s. Whilst the market is showing Vodafone trading at 140/ 140.25, you believe Vodafone will strengthen further to 145. You place a Limit order to sell 2000 Vodafone CFD s at 145. This Limit order will remain in the market until it is executed at 145 or cancelled. 4.2.2 Limit order used to open a new position. 4.3 Stop Orders Example: Whilst the market is showing Vodafone trading at 140/140.25, you believe Vodafone will fall to 134, you place a Day Limit order to buy 2000 CFDs at 134. This Limit order will remain in the market until it is executed at 134 level or cancelled at the end of its trading day. A Stop or stop loss order is an order normally placed to limit the loss on an open position. It is therefore good practice to place this type of Conditional order to control any potential losses of your open position(s) should the market move against you. A Stop Order can also be used to enter the market at an inferior rate, allowing you to enter the market on a breakout of the current trading range. 4.3.1 Stop order to close an open position. Example: You have an existing open position of short 2000 Vodafone CFD s. Whilst the market is showing Vodafone trading at 140/ 140.25, you believe Vodafone will strengthen further to 155. You place a GTC Stop order to buy 2000 Vodafone CFD s at 155. This Stop order will remain in the market until it is executed at 155 or cancelled. 4.3.2 Stop order used to open a new position. Example: 9

Whilst the market is showing Vodafone trading at 140/140.25, you believe Vodafone will rise through 155, you place a Day Stop order to buy 2000 CFDs at 145. This Stop order will remain in the market until it is executed at 145 or cancelled at the end of its trading day. Please Note: We do not guarantee execution of any Stop order(s) at the price the order is set unless it is a Guaranteed Stop Order (GSO, see Section 1, para. 4.6). The placing of a Stop order indicates the level at which you wish to execute that order. Once this level has been reached or breached, we will fill your order at the next available market price (which may or may not be at the price placed). 4.4 One Cancels the Other (OCO) This is the combination of both a Limit and a Stop Order. It is an order that can be used to take a profit if the market moves favorably to the open position or to limit the loss if the market moves against the open position. The execution of one order will automatically cancel the other order. 4.5 If Done Example: Using the above CFD Limit and Stop orders as examples. You are long 2000 Vodafone CFDs at 140.25, and place an O.C.O with a Limit Sell Order at 148, and a Stop Loss Sell at 134. If either the Limit or the Stop Loss order is executed, the other order is automatically cancelled. This is again a combination of both a Stop and Limit Order. It is an order that will allow you to enter a new position at the desired price and once triggered, activating a Stop or Limit, to protect your position. Example: Using the above CFD Limit and Stop orders as examples. Whilst the market is showing Vodafone trading at 140/140.25, you want to buy 2000 Vodafone CFDs if the price falls to 134, You place a Limit Order to buy at 134, and an if done Stop Loss to sell at 125. When the Limit is triggered the Stop Loss becomes an active pending order. 4.6 Guaranteed Stop Order (GSO) Guaranteed Stop Order A Guaranteed Stop Order can be placed on all the instruments quoted by the CFD desk. A GSO can be treated similar to a normal stop order in that it can be used to close or reduce a position. Please note a GSO order cannot be used to open/reverse a position. The main advantage is you know the price you are prepared to be stopped out, because you are not susceptible to price jumps and fills away from the original placement. A GSO enables you to have a known 'worse case scenario' should the market move against you. Because we guarantee the stop out price there are conditions to this type of order, specifically there is a premium charge when placing the order, as well as a criteria to the minimum amount of points / percentage away from the current market price. (See below) Please note a Guaranteed stop can only be placed once the stock is open and trading. They CANNOT be placed out of hours or within the last half an hour of trading. Should you want to amend an order e.g. Price, amount. You will have to cancel the GSO existing order and place a new GSO, thus encountering a new premium. 10

Example scenario using a GSO Time Action 12:00 Client goes long Stock ABC at market @260 13:00 Client decides that he would like to place a Guaranteed Stop Loss @242. Market price of Stock ABC at time of placing GSL 255 260. Premium charged = 2 points i.e. Dealer will place purchase order at 252 immediately followed by trade to sell at 250. 14:00 Guaranteed Stop loss order is triggered @242 5. CONFIRMATIONS / POSITIONS / STATEMENTS 5.1 Confirmations All telephone trades are confirmed back to the client verbally on execution, and executed transactions are listed on the statement that is sent daily. For users of the dealing software clients will have an electronic ticket confirming execution of all orders. In addition you will also receive a statement with the day s trades. Please refer to the CFD/FX Software User Guide for system-based confirmations and Section 1, paragraph 9 of this Trading Guide for further details. 5.2 Positions Clients are able to view their positions at any point in real-time, as well as all trades, orders, and pending orders. Please refer to the CFD/FX Software User Guide for system-based confirmations (see section 1 para. 9 for further details). 5.3 Statements 6. ROLLOVERS Clients may view their statements on-line at any time throughout the day. Please refer to the CFD/FX Software User Guide for system-based confirmations. 6.1 Financing 6.1.1 Shares and Indices At CMC Markets we believe a fairer way to charge for a rollover of a share or index position is the same way we would be charged, and that is a calculation based on an interest rate on the total value of the outstanding position. That way if you roll over a short position with us we may even pay you interest on the total value of the outstanding position as you are technically lending to us. The thing is we are actually giving you no more than you should expect anyway. This charge is actually referred to as the cost of carry and is actually the calculation used when calculating the price of a forward trade. But why pay for three months cost of carriage if you re only going to hold it for one day. Example: Take an example of the 2000 long position of VOD. The Mark to market price (closing price) was 140.25. The notional total value of the position is 2000 X 1.4025 = 2,805 (2000 X 1.4025 = 2805). If you were to borrow 2805 from a 11

bank for one night, you would be charged one nights interest, which is effectively what we will do. We base our rollover interest rates on an applicable rate, depending on the trade s currency. LIBOR, London Interbank Offer Rate GBP FFER, Federal Funds Effective rate USD EONIA, European Overnight Index rate EUR TOIS, Swiss Tom/Next Indexed Swap CHF RBA36, Reserve Bank of Australia rate AUD NZOCR, New Zealand Official rate NZD TONAR, Tokyo Overnight Average rate JPY HIBOR, Hong Kong Interbank Offered rate HKD SIBOR, Singapore Interbank Offered rate - SGD At this point we will either add (for a long position) or subtract (for a short position) a percentage of 3 to the applicable rate. Therefore if we assume that LIBOR (London Interbank Rate) is 4.25%, then the interest payable overnight will be 0.56p, (2,805 * 7.25% / 365 days). This charge will be shown in your statement under the heading CFD Position Summary and is shown on the row, Interest. The actual interest rates used will be displayed on the same row. This way you can compare the cost of rolling over any of our trades. A further benefit of this method is that if you placed a short trade on Vodafone you would receive the benefit of the rollover, i.e. you would receive daily interest. This is because technically you are lending the funds to us, and therefore we owe interest to you for this transaction. This interest is credited to your account whenever the position is rolled over and is displayed on the daily statement. 7. INITIAL MARGIN 7.1 What is Margin Margin is a term derived from the futures market, and provides for leveraged trading in financial products. In its most simple format, if you offered the trading of an instrument at 5% margin, you are in fact saying that you need to only deposit 5% of the total purchase cost of that deal to open that position. Example: You purchase 100 of shares in Company A at 1, but only deposit 5%, or 5 towards this transaction. This is attractive to people who do not want to hold the position for the long term, and provides for leverage when trading. In this case the client has only paid 5, if the stock they purchased goes up 5p the next day, and they sell, they will have made a 5 profit on a 5 investment, or 100% return (less roll-over costs). If they had been cash buyers of the shares they would have made a 5% return. A 5% margin provides a trading leverage of twenty times the initial deposit or 1:20. Initial Margin for share CFD s is calculated on a percentage basis. 7.1.1 Initial Margin Initial Margin is the initial deposit required to open a position on an instrument with us once you have opened your account. There is a minimum account opening Margin deposit of 2,000 (3000 USD, 5000 AUD) or equivalent with CMC Markets. Our margin rate on stocks is 5% and in indices and sectors is 1%. 12

7.1.2 Variation Margin Variation Margin is the difference in margin requirement once you have opened a position, and provides for trading profits and losses. Example: You buy 2000 Vodafone CFD s, at 140.25. This provides a notional position of 2000 x 140.25p = 2,805. Vodafone is margined at 5% so you would need at least 140.25 Initial Margin to hold this position. If Vodafone s price goes down to 138, you would now show a loss on your account of 45 (2.25p lost at 2000 CFDs). This loss (known as variation margin) is subtracted from the Initial Margin of 140.25, leaving a deposit of 95.25 However, you still hold Vodafone at a position of 2000 CFDs now at 138. This gives a notional value of 2,760 (i.e. 2000 X 1.38). Knowing that Vodafone has a 5% margin requirement, you would need a minimum of 138 Initial Margin to cover this position. As your Initial Margin is now only 95.25, you are in deficit margin by 42.75. This shortfall or deficit is known as Shortage in Equity (refer to Paragraph 7.4), and you will be required to add additional funds to maintain the position. 7.2 Margin Requirements Different products have different Initial Margin requirements. Within the individual instrument areas of this Trading Guide you can see the different Initial Margin applicable by instrument. 7.3 Equity Balances The equity (or balance) on your account will fluctuate according to the money you have deposited in your account, according to the trading conducted on your account and positions held. During the trading day your account balance(s), including all open positions, are valued against the prevailing market mid rate. Therefore your equity balance is constantly calculated in-line with market movements. This equity balance is calculated at the end of the day using the mid-closing rates (or the last traded price). This equity balance is used to assess your available margin against current positions, and potential new positions you may wish to take. The balance is used to establish if there is a requirement for additional margin deposits on your account. Once a position is opened both Initial Margin and Variation Margin requirements must always be maintained for the open position(s). It is your responsibility to ensure that your account is sufficiently margined at all times, especially during volatile trading periods. To assist you to monitor your equity we summarise your equity together with your margin requirements in your daily confirmation and our Help Desk can provide you with your open position and equity report on-line. Please Note: You will only be allowed to trade and maintain open positions on the basis of cleared funds on your account, not on promised funds or funds in transit. 7.4 Shortage of Equity A shortage in equity occurs when the Equity Balance falls below the required Initial Margin deposit. If your account has a shortage in equity you should only reduce your open positions, at least until the Equity Balance in your account is in excess of the required Initial Margin deposit. 13

7.5 Margin Calls If the market moves against you and your Equity Balance falls below your Initial Margin requirement you have the option to: i) close one or more of your open position(s), in order to reduce your Initial Margin requirement to the required level; and/or ii) remit further funds to your account as deposit in order to maintain the Initial Margin requirements. We may or may not make a margin call in these circumstances, (which is a request for you to deposit additional cleared funds on your account to maintain your open positions). In any event if you fail to maintain sufficient margin on your account or sufficient funds on your account to meet the margin requirement then we may close your open position(s) or take any action that we deem necessary. Please refer to clause 4,5 and 32 of the Terms of Business. Once your equity falls below your initial margin requirement, it is advisable that you place a stop loss order with us to try and avoid a deficit balance on your account. Our policy is not to provide credit facilities on any accounts. Details of Stop Orders and GSOs (these are guaranteed Stop orders) can be found in paragraph 4.3 of this section 1 of this guide. 7.6 Liquidation / Stop Out Level We may place Stop loss orders for your open position(s), at a level where the total Equity Balance falls below our minimum required Initial Margin requirement. This level is referred to as the stop-out level, below which your open positions may be automatically closed out or liquidated. All liquidations on your account will be undertaken at a reasonable and fair valuation. You will be liable for any loss in the account as a result of any such liquidation. Definitions of liquidation price calculations can be found within the individual instrument areas in Section 2 of this Trading Guide. Once the stop-out level has been triggered, you will not be allowed to trade on your account until the Equity Balance is restored to the required Initial Margin level. Margin calls can be made at any time during the day and alternative payment arrangements must be made if you cannot be contacted or if you are travelling. Please refer to our Terms of Business, which addresses the non-payment of margin calls and change in margin requirements. 7.7 Trading Profits / Losses 8 PAYMENTS Profits made on your trading activities increase the Equity Balance on your account. Any surplus equity may be withdrawn from your account, on request. Losses made on your trading activities decrease the Equity Balance on your account, and therefore the margin available for trading or holding positions. 8.1 Depositing Funds Clients may deposit funds through approved Credit Card and approved Debit Card payment, Funds Transfer, Telex Transfer or by cheque. All funds must be cleared funds on your account before they are made available for your equity balance. Please ensure that any cheque or transfer that you effect is made from a bank account in your name and not from that of another party. Any remittances from third party accounts may be returned in certain circumstances and we would advise you to contact the Help Desk before remitting funds if you are considering this. 14

8.2 Withdrawing Funds Funds may normally be withdrawn from your account at any time, by giving 24 hours notice, provided however that they are not being utilised for Margin purposes. CMC Markets will not transfer funds to a bank account other than that of the account holder(s). 8.3 Interest on Equity Balances Interest will be paid on equity balances above the interest qualification level after all respective margins have been deducted at such rates as CMC Markets may determine from time to time. The rate of interest receivable is available from CMC Markets on request. 9. ADMINISTRATION 9.1 General Every day, provided you have dealt or have an open position, we shall send you a daily confirmation of your trading and positions. The confirmation is made up of four main sections: 1. Trade Confirmations 2. Position Summary 3. Ledger Activity 4. Margin Requirements 5. Equity Summary At the end of each month, we shall send you your monthly statement detailing all of the above plus: 1. Trade Confirmations 2. Open Positions 3. Ledger Activity 4. Ledger Reval 5. Equity Summary Please Note: It is very important that you check all the contents in detail and contact us immediately if you disagree with any of its contents. Also if you view your statements online, at the bottom you will see a link that opens a Statement Explanied web page, which you may find very useful. 9.2 Trade confirmation This section of the statement confirms all of the trades transacted within the business day. Deal Time: This is the time in GMT that the trade was executed on your account. Trade ID: This is the unique trade identification number generated by Marketmaker for every executed trade. Order ID: This is the unique trade identification number generated by Marketmaker. This is a very important number, which you should quote whenever you wish to query a particular trade. Stock Index: This column displays the instrument that was traded. You Bought (Sold): This shows the total size of the position that you bought or sold. All sold positions will be shown in brackets ( ). Price: This is the price that the trade was executed at. 9.3 Position Summary 15

This section displays the profit and loss for each executed trade up until the close of business on the day that the statement was issued. Name of instrument traded: This shows each trade by order ID so that all profit and loss information can be seen listed by each other. Ticket of instrument traded: This column confirms the size of the trade and whether you are long or short (short positions will be shown in brackets). Price: This column confirms the price that the trade was executed at. GBP: This column shows the overall value of the executed trade, therefore it is the multiple of the adjoining price and quantity columns. After Trading: This shows the overall net position of the instrument traded. It also shows whether you are long or short at the end of the business day, the average price and the total value of the position. Mark to Market: This shows the overall position that you are carrying forward into the next business day. This also shows the price that your position is being marked off against. Trading Profit/(Loss): This is the difference between the 'After Trading' position valuation and the 'Mark to Market' valuation. Interest: This is the amount of interest charged/credited for overnight positions. Margin: This shows the margin requirement for each product held. 9.4 Ledger Activity This section shows all debits/credits to the balance of the account, for example corporate actions adjustment or credits and debits, including payments. In addition to this, the different currency balances that the client may have on their account are displayed in this area. B/Fwd: This is the amount of a given currency that you carried forward from the previous trading day. Total Mark to Market: This is the profit and loss in each currency on the business day credited and debited to your ledger balance. Please note that if you trade an instrument in a given currency the profit and loss will be denominated in that given currency. Total Financing: This shows the overall debit or credit of all financing costs relating to positions held overnight. CFwd: This shows the overall balance that will be carried forward to the next working day after all debits and credits have been made. Reval Rate: This is the rate used to re-value the ledger positions back into their base currency. 9.5 Margin Requirements This section displays the margin required to hold open CFD positions. The Grand Total is the cumulative margin required for all open CFD positions in the reporting/base currency. 9.6 Ledger Reval This section displays the balance of the currency s that you have traded in and the rate that it uses to convert back to your base currency. You will only have a different currency from your base currency if you have traded in products that are from that country. Balance: Of the currencies that you may have on your account. Rate: The rate used to give you your base currency equivalent. Base currency Equiv: This figure represents the equity balance on the account in your reporting currency. 9.7 Equity Summary This section shows the Total Equity in the account denominated in the reporting currency and the Free Margin that the client has on the account in order to open up further positions. Total Cash: This is your new account balance shown in your base currency after the day s profit & loss has been taken into account. 16

Open Equity: This should always read Zero and is for administration. Total Equity: This figure represents the equity balance on the account in your reporting currency should all positions be closed. Total Margin required: This is the amount of Margin required to sustain your open positions. Total Free Equity: This is the Total Equity less the margin required to hold your positions open. The Total free Equity is also the amount that you have available to open further positions. A deficit balance here shows what your margin call was at the close of business. Please Note:It is very important that you are aware of your daily equity balance, your margin requirement for your open position(s), and any free equity available. This report will provide you with your margin position, and will indicate to you whether you are approaching your maximum facility (Initial Margin) level, or your margin requirement level. It will also highlight excess funds available that you may either utilise to increase your open positions. 9.8 Delivery of Statements and Confirmations 9.8.1 On-line Users Clients who use the on-line / Internet trading system have direct electronic delivery and/or access to their; Orders for trading day Trades for trading day Positions Deal confirmations Statements 9.8.2 E-mail Services CMC Markets will send all communications, including contract confirmations, daily and monthly statements, margin call etc. in electronic form to all customers. Please Note: You must ensure that you notify CMC Markets promptly of any changes to the contact details that you initially provide which affect your e- mail, telephone number or address. Our primary point of contact with clients is via e-mail. As stated in our Terms of Business, it is your responsibility to ensure that CMC Markets has your correct e-mail address at all times. Failures of delivery, by e-mail, due to poor quality service providers may result in you not receiving important notifications or information, which require remedial action to be taken by you. 17

APPENDIX A - FREQUENTLY ASKED QUESTIONS Q. How do I open an account with CMC Markets? A. All you need to do is complete an application form and an Intermediate Customer Notice form, either online or in hard copy format, the original being required to be signed and sent to us. In order to open your account you will need to deposit an initial 2,000 or equivalent and we shall then send you your logon details and account number. At the present time CMC Markets does not allow its customers to open a credit account nor does it offer any type of credit facility. Q. Can CMC Markets give me trading advice? A. No. CMC Markets will not offer trading advice to its clients. Clients are responsible for all their own trading decisions and positions. Q. Does CMC Markets charge commission? A. No. Furthermore with CMC Markets there are no additional charges added to your dealing spread when you open a trade. Q. If I open a position can I roll this position over for another day? A. Yes, in fact this is done automatically for you with CMC Markets. The roll over charge that is applicable is cheaper than closing the original position and opening another at a spread. Q. How can I view my open positions and statement of account balance? A. CMC Markets will e-mail clients their daily statement. Alternatively all open positions can be viewed from our award-winning MarketMaker R software. Clients also have direct telephone access to our Helpdesk. Q. What is the minimum amount I can trade on each instrument in each financial market? A. The minimum size for any trade is 1 CFD. This applies to all Equity, Sectors, Indices and Equity Index transactions. Q. How are dividends treated? A. Adjustments for dividends are clearly stated on the statements that you will receive daily. Dividends are applied to the clients cash positions the day after the ex-dividend date. If you ever wish to query any dividends or corporate actions on your account then please call the dealers. Q. What are the advantages of trading CFDs? A. The advantages of trading CFDs include the ability to go long and short, the ability to place long and short term trades, instant execution, no commissions, leverage and tight spreads. Q. Why Trade with CMC Markets? A. CMC Markets provides extremely tight spreads, the ability to roll trades on around 1100 stocks and indices at very competitive rates. The service is open 24 hours a day, offering dealing in a range of markets, with extended hours trading offered on selected products. This is coupled with our award-winning MarketMaker R software providing instant execution, online BackOffice, news and technical analysis. Q. Are my risks limited? A. CMC Markets offers a Guaranteed Stop Order facility whereby clients can guarantee the level of a stop loss. In this way clients are able to limit the risks on any of their positions. However, if you do not use the GSO facility losses may not be limited, all clients are provided with a full risk warning prior to trading. 18

Q. How are the margin requirements calculated? A. Simply multiply the price by the amount of your stake. Multiply this by the initial margin and this is the amount of margin required to hold your position. The margin requirement for single stock trades is calculated on a percentage basis of the notional value of the position. On Stocks the margin requirement is no more than 10% of the value of your trade, most commonly 5%. Please see section 1 chaper 7 for more information. Q. What is the difference between a deposit requirement and a margin requirement? A. A deposit requirement and a margin requirement is essentially the same thing the amount of equity you need to open or hold a position. Q. Will CMC Markets contact me for margin calls? A. CMC Markets will endeavor to contact its clients by e-mail for more margin when the need arises, however, it is always the responsibility of the client to make sure they have enough free equity to hold their open positions. Should a clients position prove unatenable then liquidation or stop loss orders may be placed on the account to close positions automatically and in some cases prior to. Q. What markets can I trade on? A. CMC Markets provides trades on a huge variety of products from all major financial centers of the world, including stocks, indices, sectors, treasuries. A full list of all the instruments we offer can be found in Section 2 of this Trading Guide. Q. Can I trade outside market hours? A. Yes certain products are offered outside of the normal market hours. A list of these products can be found in Section 2 of this Trading Guide. Q. Do CMC Markets execute my deals in the market? A. CMC Markets is a market maker and is counterpart to your deals, we may not immediately execute all deals into the market since it is more practical and effective to control the position as a whole. Q. Where do CMC Markets get their prices from? A. CMC Markets has dealing relationships with several major global banks and access to electronic dealing systems providing us with constant real-time Interbank prices in all traded currencies. Index, stock and sector prices are based on CMC Markets CFD prices. Q. Can CMC Markets dealers advise me on positions? A. CMC Markets will only accept execution only business and as such we shall not advise or exercise any judgement on your behalf, nor can you request any such advice or judgement as to the suitability of trades. Q. Can I view my position on line? A. Yes, MarketMaker R allows client access through its Client position keeping facility. Q. Can I retrieve my Statement on-line? A. Yes, using the MarketMaker R software it is possible to access all orders and trades on the system, as well as positions, and statements. Other questions may be directed in the first instance to either our Sales team for account opening information, or our helpdesk Department for all other queries. Q. Do I need to cancel stop and limit orders after I close out of my positions? A. Yes, if you have closed out of your positions and do not wish to enter into any new ones by the means of stop or limit entry orders it is your responsibility, the client, to make sure all pending orders are cancelled. 19

APPENDIX B - CONTACT US Registered Office: 66 Prescot Street London E1 8HG England Registered in England 2589529 Telephone Numbers CMC Markets 020 7170 8200 CFD Dealing Line 020 7170 8203 Sales 020 7170 8201 Help desk 020 7170 8205 Fax Numbers Fax General Number 020 7170 8497 Email Addresses Sales Helpdesk sales@cmcmarkets.co.uk helpdesk@cmcmarkets.co.uk 20

TRADING GUIDE SECTION 2 21

SECTION 2: INSTRUMENT TABLES AND RATES Guaranteed Stop Order 1.1 Placing a GSO A Guaranteed Stop Order can be placed on all the instruments quoted by the CFD desk. A GSO can be treated similar to a normal stop order in that it can be used to close or reduce a position. Please note a GSO order cannot be used to open/reverse a position. The main advantage is you know the price you are prepared to be stopped out, because you are not susceptible to price jumps and fills away from the original placement. A GSO enables you to have a known 'worse case scenario' should the market move against you. Because we guarantee the stop out price there are conditions to this type of order, specifically there is a premium charge when placing the order, as well as a criteria to the minimum amount of points / percentage away from the current market price. (See below) Please note a Guaranteed stop can only be placed once the stock is open and trading. They CANNOT be placed out of hours. Should you want to amend an order e.g. Price, amount. You will have to cancel the GSO existing order and place a new GSO, thus encountering a new premium. Example scenario using a GSO Time Action 12:00 Client goes long Stock ABC at market @260 13:00 Client decides that he would like to place a Guaranteed Stop Loss @242. Market price of Stock ABC at time of placing GSL 255 260. Premium charged = 2 points i.e. Dealer will place purchase order at 252 immediately followed by trade to sell at 250. 14:00 Guaranteed Stop loss order is triggered @242 Table 1.2 : Premium Calculation GBP, USD, EUR, Swiss, HK, NZ AUS Stocks Premium JPY Premium 0-99 1 1 4.99 2 0-499 5 5.00 9.99 3 500-1999 10 10.00 14.99 4 2000-9999 15 15.00 19.99 5 10000 + 500 20.00 24.99 6 25.00 34.99 8 35.00 + 10 22

1.3 Placing Levels Guaranteed Stops (GS) must be placed a minimum of 5% away on stocks and in accordance with current spread rules. The table below lists the minimum required distance a guaranteed stop on indices can be placed from the current market rate. Index Points away Premium FTSE 30 2 CAC 30 2 DAX 30 2 SMI 30 2 BEL20 30 2 AEX 30 2 Ireland 30 2 MIB30 120 20 IBEX 80 2 NDX 20 2 DOW 50 5 S&P 3 0.5 Nasdaq 30 4 Nikkei 120 20 Hang Sang 120 5 ASX 30 2 NZD 30 1 STI 30 2 2. FINANCING AND MARGIN 2.1 Financing We refer to our charge as Financing as it is analogous to the cost financing the total value of your open position and is displayed on your Daily Statement. Furthermore as it is analogous to financing your open position when you hold a short position we may pay you the Financing. Our Financing is only applied to positions, which are left open overnight to roll over to the next trading day. 2.1.1 Shares and Indices Financing is charged or credited on positions that are carried or held overnight. On Short positions you will be credited, whereas on long positions you will debited. The Financing Adjustment for Shares and Index positions are based on a calculation of the daily applicable rate of interest for the notional value of your position. For CFDs the rate will vary depending on the notional value of the position and is calculated as follows: UK Stocks / Index: Total Contract Value x LIBOR +/- 3% /365 US Stocks / Index: Total Contract Value x FFER (Federal Funds Effective Rate) +/- 3% /360 EU Stocks / Index: Total Contract Value x EONIA (European Overnight Index Average) +/- 3% /360 23

2.2 Initial Margin To calculate your Margin for a particular instrument you will need to do the following: (Please note that the Margin requirement for Share CFDs is 5% and for all Indices 1% Price x Number of Contracts = Total Contract Value Then Total Contract Value x 5%or 1% = Margin Requirement 3. SHARES CMC Markets provides access for clients wishing to place trades in a range of domestic and international shares through one common service. All trades are placed on the basis of a minimum 1 contract. Please see Table 3.0 below for markets covered which we offer. Table 3.0: Markets Covered (as at 1 st Jul 2004) Market Underlying Markets Available No. of Shares UK FTSE100 100 FTSE 250 250 US NASDAQ 100 100 Dow Jones 30 30 S&P 500 200 France CAC40 40 Germany HDAX 110 Ireland ISEQ 5 Italy MIB30 10 Netherlands AEX25 15 Spain IBEX35 10 Switzerland SMI30 10 Sweden OMX30 6 Finland HEX25 2 Japan NIKKEI225 30 Australia ASX200 200 New Zealand 10 3.1 Normal Trading Hours We will normally accept on the markets as tabulated below and accordingly in-line with the opening times of the respective underlying market(s). Please see Table 3.1 below for normal trading hours of markets covered. Please Note: We reserve the right not to quote any instrument even if the underlying market is deemed to be open. Trading hours may vary due to the implementation of daylight savings time throughout the world. 24