For purposes of managing risk and minimizing transaction costs, we may offset or negate market risk and act as the direct counterparty to certain trades initiated in the Account. Such trades are executed at prices provided by the Broker. This

framework is intended to ensure you receive real market execution on your trades while simultaneously allowing us to manage risk dynamically by routing existing positions or future orders to third parties for execution as we deem appropriate. We believe that such real market execution and dynamic risk management would not be possible or as cost-effective if trades were executed in simulated accounts. Regardless of whether we act as a counterparty to your trades, the gain or loss on your Simulated Funded Account is not calculated differently. However, when we act as the counterparty to your

trades, there is an inherent potential conflict of interest because your trades do not result in net gain or loss to us, as your trades would if we were not the direct counterparty.