Form 7-R Firm Application Instructions

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READ THESE INSTRUCTIONS CAREFULLY BEFORE COMPLETING OR REVIEWING THE

APPLICATION. THE FAILURE TO ANSWER ALL QUESTIONS COMPLETELY AND ACCURATELY OR

THE OMISSION OF REQUIRED INFORMATION MAY RESULT IN THE DENIAL OR REVOCATION OF

REGISTRATION.

THE FAILURE TO DISCLOSE A DISCIPLINARY MATTER EITHER IN AN APPLICATION OR AN

UPDATE WILL RESULT IN THE IMPOSITION OF A LATE DISCLOSURE FEE IN ACCORDANCE WITH

NFA REGISTRATION RULE 210(c).

Not every section applies to every applicant. Certain sections apply depending on the registration category or

categories being applied for. e text above these sections explains who must complete the section.

DEFINED TERMS

Words that are underlined in this form are dened terms and have the meanings contained in the Denition of

Terms section or links to the text of Commodity Exchange Act provisions, CFTC Regulations or NFA Rules.

GENERAL

Read the Instructions and Questions Carefully

A question that is answered incorrectly because it was misread or misinterpreted can result in severe

consequences, including denial or revocation of registration. Although this applies to all questions in the

application, it is particularly important to the questions in the Disciplinary Information Section.

Rely Only on Advice from NFA Sta

A question that is answered incorrectly because of advice received from a lawyer, employer, a judge or anyone

else (other than a member of NFA’s Registration Investigations or Legal (RIL) sta) can result in severe

consequences, including denial or revocation of registration. is also applies to all questions in the form, but

is particularly important regarding the Disciplinary Information Section. If the language of a question in the

Disciplinary Information Section requires disclosure of a matter, a “Yes” answer to the question is required no

matter what other advice has been received from anyone other than NFA’s RIL sta. Additionally, the applicant

or registrant remains responsible for failures to disclose even if someone completes the form on the applicant’s or

registrant’s behalf.

Update the Information on the Application

If information provided on the application changes or a matter that would have required disclosure on the

application occurs aer the application is led, the new information must be promptly led. APs and Principals

should advise their Sponsors of the new information, and the Sponsor must le the update on their behalf. e

failure to promptly update information can result in severe consequences, including denial or revocation of

Instructions for Using the Firm Application Template

TEMPLATE: DO NOT SEND TO NFA

FIRM APPLICATION (FORM 7-R)

COMMODITY FUTURES TRADING COMMISSION

NATIONAL FUTURES ASSOCIATION

Rev. 9/22/2023

Instructions for Using the Firm Application Template (cont.)

registration.

Compliance with Disclosure Requirements of Another Regulatory Body is not Su

cient

With some exceptions, which are described below in the Regulatory and Financial Disclosures sections, if any

question requires the provision of information, that information must be provided. In particular, if a question

in the Disciplinary Information Section requires disclosure of a matter, the question must be answered “Yes” and

additional documents must be provided even if the matter has been disclosed to another regulatory body such as

FINRA, an exchange or a state regulator. Similarly, disclosure is required even if another regulatory body does

NOT require disclosure of the same matter.

Call NFA with Questions

If there is any question about whether particular information must be provided, whether a particular matter

must be disclosed or whether a particular question requires a “Yes” answer, call the NFA Information Center

at (800) 621-3570 or (312) 781-1410. Representatives are available from 8:00 a.m. to 5:00 p.m., Central Time,

Monday through Friday. If the advice of NFA sta is sought, a written record containing the date of the

conversation, the name of the NFA sta person giving the advice and a description of the advice should be made

during the conversation and kept in the event an issue concerning disclosure of the matter arises later.

DISCIPLINARY INFORMATION SECTION

Criminal Disclosures

Some common mistakes in answering the criminal disclosure questions involve expungements, diversion

programs and similar processes. e Commodity Futures Trading Commission requires a “Yes” answer even if

the matter has been expunged or the records sealed, there was no adjudication or nding of guilt, the guilty plea

was vacated or set aside or the matter was dismissed upon completion of the diversion program.

Another common error regarding criminal matters concerns matters that do not involve the derivatives industry.

All criminal matters must be disclosed, even if a matter is unrelated to the derivatives industry, unless the case

was decided in a juvenile court or under a Youth Oender law.

Regulatory Disclosures

Regulatory actions taken by the Commodity Futures Trading Commission, NFA or U.S. futures exchanges do

not need to be disclosed since NFA is already aware of them once they are entered into NFA’s BASIC system.

Financial Disclosures

It is not necessary to disclose arbitration awards or CFTC reparations matters unless the applicant or registrant

has failed to pay an award related to a CFTC-related product or an order entered in a reparations matter.

Only adversary actions that a U.S. bankruptcy trustee les must be disclosed. Adversary actions that creditors le

are not disclosable. A person named as a party to an adversary action in a bankruptcy proceeding must disclose

the action, even if the person is not the bankrupt person.

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• either the futures activity conducted in the non-OSJ that is subject to the Designated Supervisor's

supervision is limited to activity not requiring the Series 3 Examination and both the Designated

Supervisor and the Branch Manager of the Oce of Supervisory Jurisdiction to which the non-OSJ reports

have otherwise satised NFA's Prociency Requirements appropriate to their supervisory activities; or

• the activity that is conducted in the non-OSJ that requires the Series 3 Examination is supervised by the

Branch Manager of the Oce of Supervisory Jurisdiction to which the non-OSJ reports and both the

Designated Supervisor and Branch Oce Manager have passed the Series 3 Examination.

Instructions for Using the Firm Application Template (cont.)

ADDITIONAL DOCUMENTS

For each matter that caused a “Yes” answer, a Disclosure Matter Page (DMP), which is accessible using NFA’s

DMP Filing System, must be led. In addition to the required DMP, other documents about the matter must be

provided to NFA. If court documents are unavailable, a certied letter from the court verifying that must be sent

to NFA. If documents other than court documents are unavailable, a written explanation for their unavailability

must be provided. Electronic copies of the documents can be uploaded using NFA’s DMP Filing System or

documents may be sent to NFA by email to [email protected], fax to (312) 559-3411 or mail to NFA

Registration Department, 320 South Canal, Suite 2400, Chicago, IL 60606.

Providing all documents to NFA is important. Failure to do so will delay the registration process and may result

in a denial of the application.

DEFINITION OF TERMS

(e following terms are dened solely for the purpose of using NFA’s Online Registration System.)

10% OR MORE INTEREST: direct or indirect ownership of 10% or more of an entity’s stock; entitlement to

vote or empowered to sell 10% or more of an entity’s voting securities; contribution of 10% or more of an entity’s

capital; or entitlement to 10% or more of an entity’s net prots.

ADJUDICATION: in a criminal case, a determination by the court that the defendant is guilty or not guilty.

ADVERSARY ACTION: a lawsuit arising in or related to a bankruptcy case commenced by a bankruptcy

trustee by ling a complaint with a bankruptcy court or a district court.

ALIAS: another name utilized by an individual or previously used by an entity.

CHARGE: a formal complaint, information, indictment or equivalent instrument containing an accusation of a

crime.

DBA: abbreviation for Doing Business As. e rm is doing its futures, retail o-exchange forex or swaps

business by this name.

DESIGNATED SUPERVISOR: solely for the purpose of determining whether the Branch Manager Examination

(Series 30) is required, Designated Supervisor means a person who is registered with FINRA (formerly known as

NASD) as a General Securities Representative and has been designated to act as the supervisor of an oce that is

not an Oce of Supervisory Jurisdiction ("non-OSJ"), provided that:

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ENJOINED: subject to an injunction.

ENTITY: any person other than an individual.

ENTITY FLOOR TRADER: an applicant that les or registrant that led a Form 7-R to apply for registration as

a oor trader.

FELONY: any crime classied as a felony and for states and countries that do not dierentiate between a felony

or misdemeanor, an oense that could result in imprisonment for any period of more than one year. e term

also includes a general court martial.

FINANCIAL SERVICES INDUSTRY: the commodities, securities, accounting, banking, nance, insurance, law

or real estate industries.

FLOOR TRADER ORDER ENTERER: an individual responsible for entry of orders from an Entity Floor

Trader's own account.

FOUND: subject to a determination that conduct or a rule violation has occurred. e term applies to

dispositions of any type, including but not limited to consent decrees or settlements in which the ndings are

neither admitted nor denied or in which the ndings are for settlement or record purposes only.

INDIRECT OWNER: an individual who through agreement, holding companies, nominees, trusts or otherwise:

• is the owner of 10% or more of the outstanding shares of any class of an entity's equity securities, other

than non-voting securities;

• is entitled to vote 10% or more of the outstanding shares of any class of an entity's equity securities, other

than non-voting securities;

• has the power to sell or direct the sale of 10% or more of the outstanding shares of any class of an entity's

equity securites, other than non-voting securities;

• is entitled to receive 10% or more of an entity's net prots; or

• has the power to exercise a controlling inuence over an entity's activities that are subject to regulation by

the Commission.

INTERNAL REVENUE CODE:

Section 7203: Willful Failure to File Return, Supply Information or Pay Tax

Section 7204: Fraudulent Statement or Failure to Make Statement

Section 7205: Fraudulent Withholding Exemption Certicate or Failure to Supply Information

Section 7207: Fraudulent Returns, Statements or Other Documents

INVESTMENT RELATED STATUTES:

• e Commodity Exchange Act

• e Securities Act of 1933

• e Securities Exchange Act of 1934

• e Public Utility Holding Company Act of 1935

• e Trust Indenture Act of 1939

• e Investment Advisers Act of 1940

• e Investment Company Act of 1940

• e Securities Investors Protection Act of 1970

• e Foreign Corrupt Practices Act of 1977

Instructions for Using the Firm Application Template (cont.)

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• Chapter 96 of Title 18 of the United States Code

• Any similar statute of a State or foreign jurisdiction

• Any rule, regulation or order under any such statutes; and

• e rules of the Municipal Securities Rulemaking Board

MISDEMEANOR: any crime classied as a misdemeanor and for states and countries that do not dierentiate

between a felony or misdemeanor, an oense that could result in imprisonment for any period of at least six days

but not more than one year. By way of example, an oense for which the maximum period of imprisonment is 60

days would be considered a misdemeanor. e term also includes a special court martial.

NON-U.S. NATURAL PERSON: an individual who has not resided in the U.S. since reaching the age of 18

years.

OTHER NAME: For rms, including sole proprietors, any other name that the rm uses or has used in the

past but not the name of any other legal entity that the rm has an aliation or association with (see DBA). For

individuals, this is any name the person is or has been known by. For example, a maiden name, an alias name

that you use or are known by, or a previous name if you have changed your legal name.

OUTSIDE DIRECTOR: an individual who is director of an applicant or registrant and who

• is not an ocer or employee of the applicant or registrant;

• is not engaged in or have direct supervisory responsibility over persons engaged in the solicitation of

• or acceptance of customers' orders or retail forex customers' orders;

• funds, securities or property for participation in a commodity pool;

• a client's or prospective client's discretionary account;

• leverage customers' orders for leverage transactions;

• or acceptance of a swap agreement; or

• does not regularly have access to the keeping, handling or processing of:

• transactions involving "commodity interests", as that term is dened in CFTC Regulation 1.3;

• customer funds, retail forex customer funds, leverage customer funds, foreign futures or foreign

options secured amount, or adjusted net capital.

PERSON: an individual, association, partnership, corporation, limited liability company, limited liability

partnership, trust, or other form of business organization.

PRINCIPAL: means, with respect to an applicant, a registrant, or a person required to be registered under the

Act:

(1) an individual who is:

• a sole proprietor of a sole proprietorship;

• a general partner of a partnership;

• a director, president, chief executive ocer, chief operating ocer, chief nancial ocer, or a person in

charge of a business unit, division or function subject to regulation by the Commission of a corporation,

limited liability company or limited liability partnership;

• a manager, managing member or a member vested with the management authority for a limited liability

company or limited liability partnership; or

• a chief compliance ocer; or

Instructions for Using the Firm Application Template (cont.)

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(2) an individual who directly or indirectly, through agreement, holding companies, nominees, trusts or

otherwise:

• is the owner of 10% or more of the outstanding shares of any class of an applicant or registrant’s equity

securities, other than non-voting securities;

• is entitled to vote 10% or more of the outstanding shares of any class of an applicant or registrant’s equity

securities, other than non-voting securities;

• has the power to sell or direct the sale of 10% or more of the outstanding shares of any class of an applicant

or registrant’s equity securities, other than non-voting securities;

• is entitled to receive 10% or more of an applicant or registrant’s net prots; or

• has the power to exercise a controlling inuence over an applicant or registrant’s activities that are subject

to regulation by the Commission; or

(3) an entity that:

• is a general partner of a partnership; or

• is the direct owner of 10% or more of the outstanding shares of any class of an applicant or registrant’s

equity securities, other than non-voting securities; or

(4) an individual who or an entity that:

• has contributed 10% or more of an applicant or registrant’s capital unless such capital contribution consists

of subordinated debt contributed by:

• an unaliated bank insured by the Federal Deposit Insurance Corporation;

• an unaliated ‘‘foreign bank,’’ as dened in 12 CFR 211.21(n) that currently operates an ‘‘oce of a

foreign bank,’’ as dened in 12 CFR 211.21(t), which is licensed under 12 CFR 211.24(a);

• such oce of an unaliated, licensed foreign bank; or

• an insurance company subject to regulation by any State, provided such debt is not guaranteed by an

individual who or entity that is not a principal of the applicant or registrant.

SELF-REGULATORY ORGANIZATION (SRO): a private, non-governmental organization authorized to set

and enforce standards of conduct for an industry. NFA, FINRA (formerly known as NASD) and the securities

and futures exchanges in the U.S. are examples of domestic SROs.

UNITED STATES CRIMINAL CODE:

Section 152: Concealment of assets, making false claims or bribery in connection with a bankruptcy

Section 1341, 1342 or 1343: Mail fraud

Chapter 25: Counterfeiting and forgery

Chapter 47: Fraud or false statements in a matter within the jurisdiction of a United States department or

agency

Chapter 95 or 96: Racketeering and Racketeering Inuence

Instructions for Using the Firm Application Template (cont.)

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Principals

Firms must le electronic applications for each individual who is a principal of the rm, including the sole

proprietor of a sole proprietorship. A rm must have at least one individual principal aliated with it in order

to obtain registration. NFA Members that are registered or applying for registration as an FCM, RFED, IB, CPO

and/or CTA must have at least one individual principal who is also registered as an AP of the rm or a oor

broker.

Additional Assistance

Additional information regarding registration requirements and specic topics can be found on the Registration

page of NFA’s website at www.nfa.futures.org. NFA’s Information Center, (800-621-3570 or 312-781-1410), is

also available to provide assistance. Its normal hours are Monday through Friday, from 8:00 AM to 5:00 PM CT.

Instructions for Using the Firm Application Template (cont.)

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*Required to le application

Name

Indicate the full legal name that appears on the rm’s corporate lings or if Sole Proprietor, indicate the full legal

name of the individual who is the Sole Proprietor. e name should not be a “doing business as” name the Firm

or Sole Proprietor may be doing business under. Do not use nicknames or abbreviations. For example, if the

individual’s rst name is Charles, enter Charles, not Chuck.

Firm Name*________________________________________________________________________________

First & Middle Name* _____________________Last Name* (Surname)________________________Sux____

NFA ID#__________________________________________________________________________________

Categories*

Check category(ies).*



NFA Member



Commodity Trading Advisor



Swap Dealer



Futures Commission Merchant



Commodity Pool Operator



Major Swap Participant



Introducing Broker



Retail Foreign Exchange Dealer



Floor Trader Firm

Business Information



Sole Proprietorship (Individual)



Limited Liability Company



U.S. Federally Chartered Bank



Partnership



Limited Liability Partnership



Other



Corporation



Trust

Where is the entity incorporated, organized or established? (Sole proprietors and U.S. Federally Chartered Banks

do not answer this question.)*

State________________________________________________

Country_____________________________________________

Federal EIN__________________________________________

Form of Organization*

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Business Address

Enter information. A sole proprietor may use a P.O. Box address if the business is located in the sole proprietor's

residence and a complete residential address is provided on the individual application.

For all others, a P.O. Box address is not acceptable.

Street Address 1*___________________________________________________________________________

Street Address 2____________________________________________________________________________

Street Address 3____________________________________________________________________________

City**_____________________________________ State* (U.S. Only)________________________________

Province__________________________________ Zip/Postal Code**_________________________________

Country*__________________________________________________________________________________

Phone Number*_____________________________________________________________________________

Fax Number _______________________________________________________________________________

Email_____________________________________________________________________________________

Website/URL______________________________________________________________________________

CRD/IARD ID_____________________________________________________________________________

Other Names

Enter any other name the rm uses or has used in the past. e name should not be the name of any other legal

entity. For example, the name should not be the name of an aliate, subsidiary or any other legal entity the rm

may have an aliation/association with.

Name______________________________________________________



In Use



Not In Use

Name______________________________________________________



In Use



Not In Use

Name______________________________________________________



In Use



Not In Use

Name______________________________________________________



In Use



Not In Use

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LOCATION OF BUSINESS RECORDS

Enter the location of the rm’s business records and those records required to be kept by regulation under the

Commodity Exchange Act. A P.O. Box address is not acceptable. If the rm is a CTA, this address must be the

same as the business address, unless the CFTC has granted an exemption to the rm. If the rm is a CPO, the

rm can maintain its books and records at a location other than the business address, as long as the rm les a

notice of exemption pursuant to CFTC Regulation 4.23(c).

Street Address 1*___________________________________________________________________________

Street Address 2____________________________________________________________________________

Street Address 3____________________________________________________________________________

City**_____________________________________ State* (U.S. Only)________________________________

Province__________________________________ Zip/Postal Code**_________________________________

Country*__________________________________________________________________________________

Only non-U.S. applicants complete this section.

Enter the location in the U.S. where the rm’s books and records will be produced for inspection by the CFTC

and NFA.

Select one.



e oce of NFA located in New York, NY



e oce of NFA located in Chicago, IL



e following address (P.O. Box address is not acceptable):

Oce of*_________________________________________________________________________________

Street Address 1*___________________________________________________________________________

Street Address 2____________________________________________________________________________

Street Address 3____________________________________________________________________________

City*_____________________________________ State*__________________________________________

Zip/Postal Code*______________________________________

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HOLDING COMPANY INFORMATION

Enter the full legal name, Federal EIN and location where incorporated, organized or established for any entity

that is a principal of the rm. It is important that the full legal name of the entity is entered. NFA will assign an

NFA ID number to the entity if one has not already been assigned. An incorrect name could cause a delay in the

application process. If more space is needed, please add in another document and attach it to this document. If

none, continue to the next section.

Full Name________________________________________________________ 10% or More Interest:



Yes



Federal EIN____________________________________ State___________________Country______________

Full Name__________________________________________________________ 10% or More Interest:



Yes



Federal EIN____________________________________ State___________________Country______________

BRANCH OFFICE INFORMATION

Swap Dealers, Major Swap Participants and Floor Trader Firms do not complete this section.

If the rm has more than one branch oce, please add in another document and attach it to this document. If

none, continue to the next section.

Branch ID________________________________________________________________________________

Street Address 1*___________________________________________________________________________

Street Address 2____________________________________________________________________________

Street Address 3____________________________________________________________________________

City**_____________________________________ State* (U.S. Only)_________________________________

Province__________________________________ Zip/Postal Code**_________________________________

Country*__________________________________________________________________________________

Phone Number_____________________________________________________________________________

Fax Number _______________________________________________________________________________

Email_____________________________________________________________________________________

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Disciplinary Information – Criminal Disclosures

For additional assistance and information on completing this page, refer to the Instructions and Denition of

Terms at the beginning of this document.

THE QUESTIONS ON THIS PAGE MUST BE ANSWERED “YES” EVEN IF:

• ADJUDICATION OF GUILT WAS WITHHELD OR THERE WAS NO CONVICTION; OR

• THERE WAS A CONDITIONAL DISCHARGE OR POST-CONVICTION DISMISSAL AFTER

SUCCESSFUL COMPLETION OF A SENTENCE; OR

• A STATE CERTIFICATE OF RELIEF FROM DISABILITIES OR SIMILAR DOCUMENT WAS

ISSUED RELIEVING THE HOLDER OF FORFEITURES, DISABILITIES OR BARS RESULTING

FROM A CONVICTION; OR

• THE RECORD WAS EXPUNGED OR SEALED; OR

• A PARDON WAS GRANTED.

THE QUESTIONS MAY BE ANSWERED “NO” IF THE CASE WAS DECIDED IN A JUVENILE COURT

OR UNDER A YOUTH OFFENDER LAW.

For each matter that requires a “Yes” answer to Questions A, B or C below, a Criminal Disclosure Matter Page

(DMP) must be led using NFA’s DMP Filing System that requests:

• who was involved;

• when it occurred;

• what the allegations were;

• what the nal determination was, if any; and

• the date of the determination.



In addition, documents must be provided for each matter requiring a “Yes” answer that show:

• the charges;

NON-U.S. REGULATOR INFORMATION

Enter the name and location of each non-U.S. nancial services industry regulatory authority or self-regulatory

organization that has regulated the rm during the past ve (5) years. Do not enter NFA, FINRA or the name of

any U.S. exchange.

List of Non-U.S. Regulators:

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*Required to le application

Disciplinary Information – Criminal Disclosures (cont.)

• the classication of the oense, i.e., felony or misdemeanor;

• the plea, sentencing and probation information, as applicable;

• the nal disposition; and

• a summary of the circumstances surrounding the criminal matter.

e documents may be provided electronically using the upload function in the DMP Filing System or by

sending them to NFA (See Instructions).

Answer the following questions.

Question A.*

Has the rm ever pled guilty or nolo contendere (“no contest”) to or been convicted or found guilty of any felony

in any U.S., non-U.S. or military court?



Yes



Question B.*

Has the rm ever pled guilty to or been convicted or found guilty of any misdemeanor in any U.S., non-U.S. or

military court which involves:

• embezzlement, the, extortion, fraud, fraudulent conversion, forgery, counterfeiting, false pretenses,

bribery, gambling, racketeering or misappropriation of funds, securities or property; or

• violation of sections 7203, 7204, 7205 or 7207 of the Internal Revenue Code of 1986; or

• violation of sections 152, 1341, 1342, or 1343 or chapters 25, 47, 95 or 96 of the U.S. Criminal Code; or

• any transaction in or advice concerning futures, options, leverage transactions or securities?



Yes



Question C.*

Is there a charge pending, the resolution of which could result in a “Yes” answer to the above questions?



Yes



Applicants with all “No” answers above answer this question.

Even though you answered “No” to all of the above questions, would you like to provide a Criminal DMP?*



Yes



Applicants with “Yes” answers above answer this question.

Will you be ling a Criminal DMP with respect to a new matter?*



Yes



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*Required to le application

Disciplinary Information – Regulatory Disclosures

For additional assistance and information on completing this page refer to the Instructions and Denition of

Terms at the beginning of this document.

For each matter that requires a “Yes” answer to Questions D, E, F, G, H or I below, a Regulatory DMP must be

led using NFA’s DMP Filing System that requests:

• who was involved;

• when it occurred;

• what the allegations were;

• what the nal determination was, if any;

• the date of the determination; and

• a summary of the circumstances surrounding the regulatory matter.

In addition, documents must be provided for each matter requiring a “Yes” answer that show:

• the allegations; and

• the nal disposition.

e documents may be provided electronically using the upload function in the DMP Filing System or by

sending them to NFA (See Instructions).

Answer the following questions.

Question D.*

In any case brought by a U.S. or non-U.S. governmental body (other than the CFTC), has a court ever

permanently or temporarily enjoined the rm aer a hearing or default or as the result of a settlement, consent

decree or other agreement, from engaging in or continuing any activity involving:

• any transaction in or advice concerning futures, options, leverage transactions or securities; or

• embezzlement, the, extortion, fraud, fraudulent conversion, forgery, counterfeiting, false pretenses,

bribery, gambling, racketeering or misappropriation of funds, securities or property?



Yes



Question E.*

In any case brought by a U.S. or non-U.S. governmental body (other than the CFTC), has the rm ever been

found, aer a hearing or default or as the result of a settlement, consent decree or other agreement, to:

• have violated any provision of any investment-related statute or regulation thereunder; or

• have violated any statute, rule, regulation or order which involves embezzlement, the, extortion,

fraud, fraudulent conversion, forgery, counterfeiting, false pretenses, bribery, gambling, racketeering or

misappropriation of funds, securities or property; or

• have willfully aided, abetted, counseled, commanded, induced or procured such violation by any other

person; or

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*Required to le application

Disciplinary Information – Regulatory Disclosures (cont.)

• have failed to supervise another person’s activities under any investment-related statute or regulation

thereunder?



Yes



Question F.*

Has the rm ever been debarred by any agency of the U.S. from contracting with the U.S.?



Yes



Question G.*

Has the rm ever been the subject of any order issued by or a party to any agreement with a U.S. or non-U.S.

regulatory authority (other than the CFTC), including but not limited to a licensing authority, or self-regulatory

organization (other than NFA or a U.S. futures exchange) that prevented or restricted the rm’s ability to engage

in any business in the nancial services industry?



Yes



Question H.*

Are any of the orders or other agreements described in Question G currently in eect against the rm?



Yes



Question I.*

Is the rm a party to any action, the resolution of which could result in a “Yes” answer to the above questions?



Yes



Applicants with all “No” answers above answer this question.

Even though you answered “No” to all of the above questions, would you like to provide a Regulatory DMP?*



Yes



Applicants with “Yes” answers above answer this question.

Will you be ling a Regulatory DMP with respect to a new matter?*



Yes



Page 16 | OMB Numbers 3038-0023 (exp. April 30, 2026) & 3038-0072 (exp. August 31, 2026)

*Required to le application

Disciplinary Information – Financial Disclosures

For additional assistance and information on completing this page refer to the Instructions and Denition of

Terms at the beginning of this document.

For each matter that requires a “Yes” answer to Question J below, a Financial DMP must be led using NFA’s

DMP Filing System that requests:

• who was involved;

• when it occurred;

• what the allegations were;

• what the nal determination was, if any;

• the date of the determination; and

• a summary of the circumstances surrounding the nancial matter.

In addition, documents must be provided for each matter requiring a “Yes” answer that show:

• the allegations; and

• the nal disposition.

e documents may be provided electronically using the upload function in the DMP Filing System or by

sending them to NFA (See Instructions).

Answer the following question.

Question J.*

Has the rm ever been the subject of an adversary action brought by a U.S. bankruptcy trustee?



Yes



Applicants with a “No” answer above answer this question.

Even though you answered “No” to the above question, would you like to provide a Financial DMP?*



Yes



Applicants with a “Yes” answer above answer this question.

Will you be ling a Financial DMP with respect to a new matter?*



Yes



Contact Information

REGISTRATION CONTACT

Enter the individual to whom all registration inquiries are to be directed.

First Name*________________________________________________________________________________

Last Name*________________________________________________________________________________

Title______________________________________________________________________________________

Street Address 1*___________________________________________________________________________

Street Address 2____________________________________________________________________________

Street Address 3____________________________________________________________________________

City**_____________________________________

State* (U.S. Only)_________________________________

Province__________________________________ Zip/Postal Code**_________________________________

Country*__________________________________________________________________________________

Phone Number*_____________________________________________________________________________

Fax Number _______________________________________________________________________________

Email*_____________________________________________________________________________________

*Required to file application | **Required to file application for United States address

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Page 18 | OMB Numbers 3038-0023 (exp. April 30, 2026) & 3038-0072 (exp. August 31, 2026)

Enter the individual(s) to whom all enforcement and compliance communications and inquiries from the CFTC

are to be directed. NFA may also send communications to this individual. Firms may list multiple enforcement/

compliance contacts. If the rm would like to list more than one individual, please add in another document

and attach it to this document.