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Disclosure of Futures Commission Merchant Material Conflicts of Interest

The purpose of this document is to provide you with information about some of the material conflicts of interest that may arise between you and NinjaTrader in connection with NinjaTrader performing services for you with respect to futures or other commodity derivatives. Per U.S. Commodity Futures Trading Commission’s regulations, conflicts of interests can arise when NinjaTrader has an economic or other incentive to act, or persuade you to act, in a way that favors NinjaTrader or its affiliates.

Potential Conflict of Interest Relating to NinjaTrader

NinjaTrader receives a portion of the commissions and fees charged to client’s accounts. Although NinjaTrader is not in a position to direct the frequency and type of trading for client’s accounts (NinjaTrader and affiliates do not provide discretionary trading services to customers), these commission and fees are for the benefit of NinjaTrader.

In addition, NinjaTrader, its directors, officers, employees, or affiliates may unknowingly act on the other side of your order or transaction by purchase or sale for an account, or the execution of a transaction with a counterparty, in which NinjaTrader, or a person affiliated with NinjaTrader has a direct or indirect interest. This unusual occurrence may take place since all orders go through a regulated exchange and NinjaTrader not its directors, officers, employees, or affiliates have nay ability to match orders against any other orders.