TRUTH IN LENDING STATEMENT

When you buy securities on margin, or enter into short sales or short options, you are borrowing money from Newedge USA, LLC for part of your transaction. Securities and Exchange Commission Rule 10b-16 requires a broker or dealer who extends credit to a customer in connection with any securities transaction to furnish the customer with a written statement describing the terms and conditions under which interest will be charged. This document is being provided to you in conformity with this rule.

1. Interest Charges - Margin interest is charged to your account daily on the credit we extend to you. The daily interest charges are calculated by multiplying your settled debit balance by the margin interest rate. Your settled debit balance is calculated by adjusting your previous day's balance by debits or credits to your account and by changes in the value of short positions. We will pay interest on settled credit balances held in your account. The credit balance interest rate is set at our discretion with reference to commercially recognized interest rates, industry conditions, and general credit conditions. The credit interest rate may be changed without notice at our discretion.

2. Daily Margin Interest Rate - The daily margin interest rate is calculated based on a 360-day year. It is calculated for each day by dividing the margin interest rate by 360. The Margin interest rate is set at Newedge USA's discretion with reference to commercially recognized interest rates. The margin interest rate will be changed without notice.

3. Compounding Interest - Margin interest is compounded on a daily basis. Interest charges will accrue to your account each day. We will include the charges on the next day's opening debit balance and charge interest accordingly. On weekends and holidays we will calculate and post interest to your account on the previous business day. This means that interest charged over the weekend is calculated based on Friday's settled debit balance, and charged to your account on Friday. Credit balance interest is compounded daily as well. Your monthly statement will reflect the dollar amount of interest charged or paid, and the rate of interest.

4. Marking to Market - The credit balance in the short account will be decreased or increased in accordance with the corresponding market values of all short positions. Corresponding debits or credits will be posted to the margin account. These entries in the margin account will affect the margin debit balance upon which interest is computed. Credits in your short account, other than marking to market, will not be used to offset your margin account balance for interest computation.

5. Liens and Liquidation - At our election, all debit balances in your account, including those resulting from extensions of margin credit, will be immediately due and payable. We reserve the right to require additional collateral at any time, or to initiate immediate liquidation procedures without notice under conditions described in the Newedge USA Margin Agreement. By signing the Margin Agreement you acknowledge that you have read and agreed to these term and conditions.