Conditions of Use


These terms and conditions govern your use of Windy City Trader; by using Windy City Trader, you accept these terms and conditions in full. If you disagree with these terms and conditions or any part of these terms and conditions, you must not use Windy City Trader.

You must be at least [18] years of age to use Windy City Trader. By using Windy City Trader [and by agreeing to these terms and conditions] you warrant and represent that you are at least [18] years of age.

Windy City Trader uses cookies. By using Windy City Trader and agreeing to these terms and conditions, you consent to our use of cookies.


Unless otherwise stated, Windy City Trader and/or its licensors own the intellectual property rights in the website and material on the website. Subject to the license below, all these intellectual property rights are reserved.

You may view, download for caching purposes only, and print pages from the website for your own personal use, subject to the restrictions set out below and elsewhere in these terms and conditions.

You must not:

republish material from Windy City Trader (including republication on another website);

sell, rent or sub-license material from the website;

show any material from the website in public;

reproduce, duplicate, copy or otherwise exploit material on Windy City Trader for a commercial purpose;

edit or otherwise modify any material on the website; or

redistribute material from Windy City Trader.


You must not use Windy City Trader in any way that causes, or may cause, damage to the website or impairment of the availability or accessibility of the website; or in any way which is unlawful, illegal, fraudulent or harmful, or in connection with any unlawful, illegal, fraudulent or harmful purpose or activity.

You must not use Windy City Trader to copy, store, host, transmit, send, use, publish or distribute any material which consists of (or is linked to) any spyware, computer virus, Trojan horse, worm, keystroke logger, rootkit or other malicious computer software.

You must not conduct any systematic or automated data collection activities (including without limitation scraping, data mining, data extraction and data harvesting) on or in relation to Windy City Trader without Windy City Trader’s express written consent.

You must not use Windy City Trader for any purposes related to marketing without Windy City Trader’s express written consent.


Access to certain areas of Windy City Trader are restricted. Windy City Trader reserves the right to restrict access to other areas of Windy City Trader, or indeed this entire website, at Windy City Trader’s discretion.

If Windy City Trader provides you with a user ID and password to enable you to access restricted areas of Windy City Trader or other content or services, you must ensure that the user ID and password are kept confidential.

Windy City Trader may disable your user ID and password in Windy City Trader’s sole discretion without notice or explanation.


In these terms and conditions, “your user content” means material (including without limitation text, images, audio material, video material and audio-visual material) that you submit to Windy City Trader, for whatever purpose.

You grant to Windy City Trader a worldwide, irrevocable, non-exclusive, royalty-free license to use, reproduce, adapt, publish, translate and distribute your user content in any existing or future media. You also grant to Windy City Trader the right to sub-license these rights, and the right to bring an action for infringement of these rights.

Your user content must not be illegal or unlawful, must not infringe any third party’s legal rights, and must not be capable of giving rise to legal action whether against you or Windy City Trader or a third party (in each case under any applicable law).

You must not submit any user content to the website that is or has ever been the subject of any threatened or actual legal proceedings or other similar complaint.

Windy City Trader reserves the right to edit or remove any material submitted to Windy City Trader, or stored on Windy City Trader’s servers, or hosted or published upon Windy City Trader.


Your subscription to our services, which may start with a free trial or promotional subscription, will continue unless and until you cancel or we terminate it. You must provide us with a current, valid, accepted method of payment (as such may be updated from time to time, “Payment Method”) to use our services. We will bill the applicable subscription fee to your Payment Method. You must cancel your subscription before it renews in order to avoid billing of the next period’s subscription fees to your Payment Method.

We may offer a number of subscription plans, including special promotional plans or subscriptions with differing conditions and limitations. Any materially different terms from those described in these Terms & Conditions will be disclosed at your sign-up or in other communications made available to you. You can find specific details regarding your subscription with us by verifying the email receipt issued upon your sign-up. Some promotional subscriptions may be offered by third parties in conjunction with the provision of their own products and services. We are not responsible for the products and services provided by such third parties. We reserve the right to modify, terminate or otherwise amend our offered subscription plans.


Your subscription to our services may start with a free trial or promotional subscription. The free trial period of your subscription lasts for seven days, or as otherwise specified during sign-up. For combinations with other offers, restrictions may apply. Free trials or promotional subscriptions are for new and certain former subscribers only. We reserve the right, in our absolute discretion, to determine your eligibility for free trial or promotional subscription.

We will begin billing your Payment Method for monthly subscription fees at the end of the free trial period of your subscription or at the end of your promotional subscription unless you cancel prior to the end of the applicable period. To view the specific details of your subscription, including monthly subscription price and end date of your free trial period or promotional subscription, please verify the email receipt issued upon your sign-up or contact us. We may authorize your Payment Method through various methods, including authorizing it up to an amount equal to or similar to the amount of the monthly subscription fee as soon as you register. In some instances, your available balance or credit limit may be reduced to reflect the authorization during your free trial period. However, you will not be charged during your free trial period for the subscription fee.

You will not receive a notice from us that your free trial period has ended or that the paying portion of your subscription has begun. We will continue to bill your Payment Method on a monthly basis for your subscription fee until you cancel.


By starting your subscription and providing or designating a Payment Method, you authorize us to charge you a recurring subscription fee at the then current rate, and any other charges you may incur in connection with your use of our Service to your Payment Method. You acknowledge that the amount billed each period may vary (but not materially) from term to term and you authorize us to charge your Payment Method for such varying amounts, which may be billed monthly in one or more charges.

We reserve the right to adjust pricing for our service or any components thereof in any manner and at any time as we may determine in our sole and absolute discretion. Except as otherwise expressly provided for in these Terms & Conditions, any material price increases to your service will take effect following notice to you.

The subscription fee for our service will be billed at the beginning of the paying portion of your subscription and each period thereafter unless and until you cancel your subscription. We automatically bill your Payment Method each period on or near the calendar day corresponding to the commencement of your paying subscription. Subscription fees are fully earned upon payment. We reserve the right to change the timing of our billing, in particular, as indicated below, if your Payment Method has not successfully been processed. In the event that your paying subscription began on a day not contained in a given month, we may bill your Payment Method on a day in the applicable month or such other day as we deem appropriate. Your renewal date may change due to changes in your subscription. We may authorize your Payment Method in anticipation of subscription or service-related charges. In the event that your Payment Method does not successfully process a charge for a subscription fee, you authorize us to charge you an administration fee up to $9.99 in order to keep your subscription temporarily active until the full subscription fee can be processed successfully and your full term renewed.

As used in these Terms & Conditions, “billing” shall indicate a charge, debit or other payment clearance, as applicable, against your Payment Method. Unless otherwise stated differently, month or monthly refers to your billing cycle.

Windy City Trading, Alpha Designed, or others (depending on your geographical location) may appear on your credit card, bank statement, or phone bill for all applicable charges. If multiple websites are joined utilizing any Payment Method, your statement will list each individual purchase comprising the transaction. Billing may include other information on your statement based on requirements of credit card association, telephone regulation, National Automated Clearinghouse Association or any other mandated rules and regulations. If you elect to use a checking account to purchase a subscription to the Website, a debit will be executed on your checking account.


PAYMENTS ARE NONREFUNDABLE AND THERE ARE NO REFUNDS OR CREDITS FOR PARTIALLY USED PERIODS. In the event we terminate your rights to use the Website because of a breach of these Terms & Conditions, you shall not be entitled to the refund of any unused portion of subscription fees. Following any cancellation by you, however, you will continue to have access to the service through the end of your current billing period. Note however, that using the online form to cancel your subscription, as opposed to contacting us may result in an immediate loss of access to the Website. At any time, and for any reason, we may provide a refund, discount, or other consideration to some or all of our subscribers (“credits”). The amount and form of such credits, and the decision to provide them, are at our sole and absolute discretion. The provision of credits in one instance does not entitle you to credits in the future for similar instances, nor does it obligate us to provide credits in the future, under any circumstance.


All chargebacks are thoroughly investigated and may prevent future purchases with us given the circumstances. Fraud claims may result in contacting your issuer to protect you and prevent future fraudulent charges to your Payment Method.


You may edit your Payment Method information by visiting the Website and clicking on the “Login” link, available at the top of the pages of the Website. If a payment is not successfully processed, due to expiration, insufficient funds, or otherwise, and you do not edit your Payment Method information or cancel your account, you remain responsible for any uncollected amounts and authorize us to continue billing the Payment Method, as it may be updated. This may result in a change to your payment billing dates. For certain Payment Methods, the issuer of your Payment Method may charge you a transaction fee or other charges.


You will receive an email receipt to the email provided upon initial subscription. You may request a copy of the account of charges of your subscription to the Website but we cannot guarantee the availability of such records more than 365 days after the subscription date.


You may cancel your subscription at any time by notifying us by electronic mail or by telephone. You are liable for charges incurred until the date of the termination and you will continue to have access to our service through the end of your monthly billing period. WE DO NOT PROVIDE REFUNDS OR CREDITS FOR ANY PARTIAL-MONTH SUBSCRIPTION PERIODS. If you cancel your subscription, your account will automatically close at the end of your current billing period. Using the online form to cancel your subscription, as opposed to contacting us, may result in an immediate loss of access to the Website.


Windy City Trader is provided “as is” without any representations or warranties, express or implied. Windy City Trader makes no representations or warranties in relation to Windy City Trader or the information and materials provided on Windy City Trader.

Without prejudice to the generality of the foregoing paragraph, Windy City Trader does not warrant that:

Windy City Trader will be constantly available, or available at all; or

the information on Windy City Trader is complete, true, accurate or non-misleading.

Nothing on Windy City Trader constitutes, or is meant to constitute, advice of any kind. If you require advice in relation to any financial matter you should consult an appropriate professional.


Windy City Trader will not be liable to you (whether under the law of contact, the law of torts or otherwise) in relation to the contents of, or use of, or otherwise in connection with, Windy City Trader:

for any indirect, special or consequential loss; or

for any business losses, loss of revenue, income, profits or anticipated savings, loss of contracts or business relationships, loss of reputation or goodwill, or loss or corruption of information or data.

These limitations of liability apply even if Windy City Trader has been expressly advised of the potential loss.


You accept that, as a limited liability entity, Windy City Trader has an interest in limiting the personal liability of its officers and employees. You agree that you will not bring any claim personally against Windy City Trader’s officers or employees in respect of any losses you suffer in connection with the website.

warranties and liability set out in Windy City Trader disclaimer will protect Windy City Trader’s officers, employees, agents, subsidiaries, successors, assigns and sub-contractors as well as Windy City Trader.


If any provision of Windy City Trader disclaimer is, or is found to be, unenforceable under applicable law, that will not affect the enforceability of the other provisions of Windy City Trader disclaimer.


You hereby indemnify Windy City Trader and undertake to keep Windy City Trader indemnified against any losses, damages, costs, liabilities and expenses (including without limitation legal expenses and any amounts paid by Windy City Trader to a third party in settlement of a claim or dispute on the advice of Windy City Trader’s legal advisers) incurred or suffered by Windy City Trader arising out of any breach by you of any provision of these terms and conditions, or arising out of any claim that you have breached any provision of these terms and conditions.


Without prejudice to Windy City Trader’s other rights under these terms and conditions, if you breach these terms and conditions in any way, Windy City Trader may take such action as Windy City Trader deems appropriate to deal with the breach, including suspending your access to the website, prohibiting you from accessing the website, blocking computers using your IP address from accessing the website, contacting your internet service provider to request that they block your access to the website and/or bringing court proceedings against you.


Windy City Trader may revise these terms and conditions from time-to-time. Revised terms and conditions will apply to the use of Windy City Trader from the date of the publication of the revised terms and conditions on Windy City Trader. Please check this page regularly to ensure you are familiar with the current version.


Windy City Trader may transfer, sub-contract or otherwise deal with Windy City Trader’s rights and/or obligations under these terms and conditions without notifying you or obtaining your consent.

You may not transfer, sub-contract or otherwise deal with your rights and/or obligations under these terms and conditions.


If a provision of these terms and conditions is determined by any court or other competent authority to be unlawful and/or unenforceable, the other provisions will continue in effect. If any unlawful and/or unenforceable provision would be lawful or enforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect.


These terms and conditions constitute the entire agreement between you and Windy City Trader in relation to your use of Windy City Trader, and supersede all previous agreements in respect of your use of Windy City Trader.


This document was created using a Contractology template available at

Privacy Policy


Windy City Trader may collect and use the following kinds of personal information:

information about your use of this website;

information that you provide using for the purpose of registering with the website;

information about transactions carried out over this website;

information that you provide for the purpose of subscribing to the website services;

any other information that you send to Windy City Trader.


Windy City Trader may use your personal information to:

administer this website;

personalize the website for you;

enable your access to and use of the website services;

send to you products that you purchase;

supply to you services that you purchase;

send to you statements and invoices;

collect payments from you; and

send you marketing communications.

Where Windy City Trader discloses your personal information to its agents or sub-contractors for these purposes, the agent or sub-contractor in question will be obligated to use that personal information in accordance with the terms of this privacy statement. In addition to the disclosures reasonably necessary for the purposes identified elsewhere above, Windy City Trader may disclose your personal information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights.


Windy City Trader will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. Windy City Trader will store all the personal information you provide on its secure servers. Information relating to electronic transactions entered into via this website will be protected by encryption technology.


Information that Windy City Trader collects may be stored and processed in and transferred between any of the countries in which Windy City Trader operates to enable the use of the information in accordance with this privacy policy. In addition, personal information that you submit for publication on the website will be published on the internet and may be available around the world. You agree to such cross-border transfers of personal information.


We will retain your information for as long as your account is active, your information is needed to provide you services, or as required to fulfill our legal obligations. If you wish to delete your account or request that we no longer use your information to provide you services contact us at We will respond to your request within 30 days. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.


Help remember and process the items in the shopping cart.
Help remember a user’s login session.
Understand and save user’s preferences for future visits.
Keep track of advertisements.
Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browsers are all a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.


Windy City Trader may update this privacy policy by posting a new version on this website. You should check this page occasionally to ensure you are familiar with any changes.


This website contains links to other websites. Windy City Trader is not responsible for the privacy policies or practices of any third party.


If you have any questions about this privacy policy or Windy City Trader’s treatment of your personal information, please write:

by email to

This document was created using a Contractology template available at

Risk Disclosure


Options are not suitable for all investors. Options involve risk. It is possible to lose your entire investment. Prior to buying or selling an option, a person must receive a copy of this brochure. It includes a discussion on basic option terminology, types of options available for trading, general provisions for exercise and settlement, unique tax considerations, risks, and other supplemental material. This publication refers solely to options issued by OCC.


This information is not to be construed as an offer to sell or a solicitation or an offer to buy the commodities herein named. The factual information of this report has been obtained from sources believed to be reliable, but is not necessarily all-inclusive and is not guaranteed as to the accuracy, and is not to be construed as representation by TJM. The risk of trading futures and options can be substantial. Each investor must consider whether this is a suitable investment. Past performance is not indicative of future results.


You may sustain a total loss of the funds that you deposit with your broker to establish or maintain a position in the commodity futures market, and you may incur losses beyond these amounts. If the market moves against your position, you may be called upon by your broker to deposit a substantial amount of additional margin funds, on short notice, in order to maintain your position. If you do not provide the required funds within the time required by your broker, your position may be liquidated at a loss, and you will be liable for any resulting deficit in your account.

Under certain market conditions, you may find it difficult or impossible to liquidate a position. This can occur, for example, when the market reaches a daily price fluctuation limit (“limit move”).

Placing contingent orders, such as “stop-loss” or “stop-limit” orders, will not necessarily limit your losses to the intended amounts, since market conditions on the exchange where the order is placed may make it impossible to execute such orders.

All futures positions involve risk, and a “spread” position may not be less risky than an outright “long” or “short” position.

The high degree of leverage (gearing) that is often obtainable in futures trading because of the small margin requirements can work against you as well as for you. Leverage (gearing) can lead to large losses as well as gains.

You should consult your broker concerning the nature of the protections available to safeguard funds or property deposited for your account.


Foreign futures transactions involve executing and clearing trades on a foreign exchange. This is the case even if the foreign exchange is formally “linked” to a domestic exchange, whereby a trade executed on one exchange liquidates or establishes a position on the other exchange. No domestic organization regulates the activities of a foreign exchange, including the execution, delivery, and clearing of transactions on such an exchange, and no domestic regulator has the power to compel enforcement of the rules of the foreign exchange or the laws of the foreign country. Moreover, such laws or regulations will vary depending on the foreign country in which the transaction occurs. For these reasons, customers who trade on foreign exchanges may not be afforded certain of the protections which apply to domestic transactions, including the right to use domestic alternative dispute resolution procedures. In particular, funds received from customers to margin foreign futures transactions may not be provided the same protections as funds received to margin futures transactions on domestic exchanges. Before you trade, you should familiarize yourself with the foreign rules, which will apply, to your particular transaction.

Finally, you should be aware that the price of any foreign futures or option contract and, therefore, the potential profit and loss resulting therefrom, may be affected by any fluctuation in the foreign exchange rate between the time the order is placed and the foreign futures contract is liquidated or the foreign option contract is liquidated or exercised.


Account documents are not an offer of solicitation for the purchase or sale of any Security or Commodity. Before trading one should be aware that with potential profits there is also potential for losses that may be very large. Futures and options  involve risk and are not suitable for everyone. Those acting on this information are responsible for their own actions.


The services provided by TJM may not be available in all jurisdictions. It is possible that the country in which you are a resident prohibits us from opening and maintaining an account for you. If in doubt, please contact an TJM account representative.



The purpose of this Disclosure of FX Intermediary Material Incentives, Conflicts of Interest and Other Matters (“Standard Conflicts Disclosure”) is to provide you with information about material conflicts of interest that may arise between you and us when we act as your agent pursuant to that certain Derivatives/FX Prime Brokerage FX Intermediary Business Conduct Agency Agreement (the “Agency Agreement”).Unless otherwise specified, capitalized terms used herein are defined in the Agency Agreement and the Annex thereto.

Our agency role is in connection with providing FX intermediation services for you pursuant to our separate contractual relationship with you. These FX intermediation services include the negotiation and agreement to the material terms and conditions of a Covered Transaction with one or more Executing Dealers based on our market knowledge and access to liquidity through market expertise and relationships with Executing Dealers, other liquidity providers, Trading Facilities (as defined below) and non-registered electronic trading platforms.

In our agency role, conflicts of interests can arise in particular when we have an economic or other incentive to act, or persuade you to act, in a way that favors us or our affiliates. Conflicts of interests can arise in the fees and costs we charge you, the use of our services as opposed to another market participant or trading facility, the decisions we make regarding the execution of your orders, the decisions we make regarding multiple and aggregated orders, our role as an agent to another market participant, the market information we provide or do not provide to you, our ownership or other interests in non-registered electronic trading platforms, and our research and other services we provide in the market. We have provided greater detail on conflicts of interest below.

In addition, we may from time to time provide you with additional disclosure to supplement the information provided herein. This Standard Conflicts Disclosure should be read in conjunction with any such additional disclosures.

In this Standard Conflicts Disclosure and any supplemental disclosure statement that expressly refers to this Standard Conflicts Disclosure, any reference to us includes our affiliates, and we refer to any transaction that we may intermediate for you as a Covered Transaction.

This Standard Conflicts Disclosure is limited to those Covered Transactions for which we are your agent pursuant to the Agency Agreement.

Material Incentives and Conflicts of Interest

Fees and Costs: We generally intermediate Covered Transactions to earn a profit. Our profits may derive from explicit fees and commissions, or may be implicit in the difference between payments and deliveries made to or by us (or our Prime Broker) under Covered Transactions and our costs (or gains) in offsetting the resulting exposures. It is possible that we may earn a substantial return from offsetting positions related to a Covered Transaction while the value of the Covered Transaction to you declines or fails to increase by a commensurate amount. Before you enter into a Covered Transaction, you should review and understand all commissions, fees and other charges for which you will be liable, including all amounts payable or due to us. These charges will affect your net profit (if any) or increase your loss.

We will incur a variety of costs and expenses in connection with intermediating Covered Transactions on your behalf. These may include, without limitation, fees, commissions and other charges that we may become obligated to pay to third parties from time to time in connection with Covered Transactions, including brokerage fees, referral fees, and execution, clearing and/or reporting fees associated with our compliance with applicable law. Unless otherwise agreed, you will not be obligated to reimburse us for these fees, commissions or other charges, but as with any of our other costs and expenses, you should assume they are reflected in the price or other economics of your Covered Transactions. In this regard, we generally do not disclose our costs and expenses except as required by applicable law.

Use of an FX Intermediary’s Services: Under applicable law, including regulations of the Commodity Futures Trading Commission (“CFTC”), not all Covered Transactions are required to be executed on an exchange or swap execution facility (each, a “Trading Facility”), even if a Trading Facility lists the Covered Transactions for trading. In such circumstances, it may be financially advantageous for us to intermediate a Covered Transaction on your behalf bilaterally in the over-the-counter market (including on a non-registered electronic trading platform) pursuant to a Covered PB Arrangement with one or more Executing Dealers rather than on a Trading Facility. We may thus have an incentive to persuade you to execute your Covered Transaction bilaterally in the over-the-counter market pursuant to a Covered PB Arrangement. Additionally, we may have an incentive to persuade you to intermediate a Covered Transaction with us, instead of directly with an Executing Dealer or your Prime Broker, either bilaterally between you and such Executing Dealer or your Prime Broker or on a non-registered electronic trading platform provided by the Executing Dealer or your Prime Broker (often referred to as a single-dealer platform).

Decisions Regarding Order Execution : As your agent for the execution of Covered Transactions, subject to applicable law, we may have discretion to decide where and how to direct your orders, to solicit (or not solicit) persons to trade opposite those orders, or to enter into Covered Transactions opposite those orders for the account of other counterparties. We may derive financial and other benefits (such as the right to receive payment for order flow or other fees) from such decisions.

When we provide intermediation services to you, we may direct orders to affiliated or unaffiliated Swap Dealers, Executing Dealers, market-makers, other executing firms, Trading Facilities, non-registered electronic trading platforms, individual brokers or brokerage groups for execution.We may also choose one Executing Dealer instead of another Executing Dealer, or choose an Executing Dealer instead of a non-registered electronic trading platform (if available), or seek pricing for a Covered Transaction from only one Executing Dealer or selected Executing Dealers, or seek price improvements or not seek price improvements with one or more Executing Dealers. Unless otherwise agreed, any price improvements we obtain may accrue solely to our benefit. We may derive financial and other benefits (such as the right to receive payment for order flow or other fees) from such decisions.

Multiple Orders and Order Aggregation

When we provide intermediation services to you, we may concurrently handle multiple orders for other counterparties who may receive pricing and terms that are different from the pricing and terms we provide to you. In addition, we may aggregate the trades from multiple Executing Dealers and allocate such trades to you and other counterparties. Our intermediation services may result in different fee structures or fees for the same or a similar transaction than the fee structure or fees charged to you. We may derive financial and other benefits (such as the right to receive payment for order flow, reporting or other fees) from such order handling and decisions related to order handling. In addition, differences in fees or fee structures among the counterparties for whom we provide intermediation services or otherwise handle orders may create potential conflicts of interest with regard to our order handling decisions.

Agent to Other Counterparties: When we provide intermediation services to you, we may act as agent to other counterparties in Covered Transactions that have trading, investment, or hedging objectives that are similar to yours. This may create potential conflicts where there is limited availability or limited liquidity for those Covered Transactions. We may also act as agent to other counterparties in Covered Transactions that have trading, investment, or hedging objectives adverse to yours. We are under no duty to inform you of the nature or identity of these other counterparties or their respective  Covered Transactions.

Further where we act as agent to other counterparties, we may solicit a counterparty or Executing Dealer to trade opposite your order or enter into transactions for its own account or the account of other counterparties or Executing Dealers that may, at times, be adverse to your interests in a Covered Transaction. In such circumstances, that counterparty or Executing Dealer may make payments and/or pay a commission or fee to us in connection with that transaction. The results of your Covered Transactions may differ significantly from the results achieved by us for other counterparties.

Covered Transactions by multiple counterparties may have the effect of diluting or otherwise negatively affecting the values, prices or levels of Covered Transactions, or your trading, investment or hedging strategies or results. The results of your Covered Transactions may differ significantly from the results achieved by other counterparties.

Market Information.  Acting as an FX intermediary may give us broad access to the current status of certain markets, investments and products. As a result, we may be in possession of information, which, if known to you, might cause you to seek to dispose of, retain or increase interests in one or more Covered Transactions. Unless otherwise agreed, we will be under no duty to make any such information available to you, except to the extent that disclosure may be required under applicable law.

Ownership and Other Interests in Electronic Trading Platforms.  You also should be aware that we may own stock in, or have some other form of ownership interest in, one or more U.S. or foreign electronic trading platforms where your Covered Transactions may be executed. As a result, we may receive financial or other benefits related to our ownership interest when Covered Transactions are executed on a given electronic trading platform, and we would, in such circumstances, have an incentive to persuade you to have Covered Transactions executed on that electronic trading platform rather than bilaterally in the over-the-counter market. In addition, our employees and officers may also serve on the board of directors or on one or more committees of an electronic trading platform.

Research and Other Market Roles.

We may act as, among other things, an investor, research provider, placement agent, underwriter, distributor, remarketing agent, structurer, securitizer, lender, investment manager, investment adviser, commodity trading advisor, municipal advisor, market maker, trader, prime broker or clearing broker. In those and other capacities, we may take or hold positions in, or advise other counterparties concerning, or publish research or express a view with respect to, a Covered Transaction or a related financial instrument that may be the subject of advice from us to you. Any such positions and other advice may not be consistent with, or may be contrary to, your interests or to positions which are the subject of advice previously provided by us to you, and unless otherwise disclosed in writing, we are not necessarily acting in your best interest and are not assessing the suitability for you of any Covered Transaction or related financial instrument. Acting in one or more of the capacities noted above may give us access to information relating to markets, investments and products. As a result, we may be in possession of information which, if known to you, might cause you to seek to dispose of, retain or increase your position in one or more Covered Transactions or other financial instruments. We will be under no duty to make any such information available to you, except to the extent we have agreed in writing or as may be required under applicable law.

Material Economic Terms and Price of Covered Transaction

Pursuant to the Agency Agreement, we have agreed to receive from the Executing Dealer certain Rule 23.431 Disclosure related to Covered Transactions, and to provide certain Rule 23.431 Disclosure to you via an Approved Method (as defined in the Agency Agreement) prior to an agreement to the material economic terms of a Covered Transaction. The Rule 23.431 Disclosure includes the price and other material economic terms of the Covered Transaction (including notional amount and termination date) and the mid-market mark of the Covered Transaction (such mid-market mark shall not include amounts for profit, credit reserve, hedging, funding, liquidity, or any other costs or adjustments). Such Rule 23.431 Disclosure will be provided to you via an Approved Method prior to an agreement to the material economic terms of a Covered Transaction. Certain Rule 23.431 Disclosures related to Covered Transactions disclosed by the Executing Dealer to us may be material to your decision to enter into a Covered Transaction and to yourevaluation of the effectiveness and the price of the Covered Transactionobtained by the FX Intermediary for you. Accordingly, it is important for you to review carefully the terms of the Agency Agreement, including particularly the terms governing the manner and timing of transmittal of Executing Dealer disclosure to you and your use of the Rule 23.431 Disclosure provided by us to you.

What Investors Need to Know (NFA) –

Trading Futures, Options on Futures, and Forex FAQ (NFA) –

Fixed Income Disclosure Document

Investments in fixed income securities involve a variety of risks, including credit risk, inflation risk, interest rate risk, liquidity risk and call risk, among others.

Bonds issued by the U.S. government have significantly less risk of default than those issued by corporations and municipalities. However, the overall return on government bonds tends to be less than other types of fixed income securities. Investments in debt securities rated below investment grade (commonly referred to as “junk bonds”) may be subject to greater levels of credit and liquidity risk than investments in investment grade securities. Sovereign debt instruments are subject to the risk that a governmental entity may delay or refuse to pay interest or repay principal on its sovereign debt.

Investors who own fixed income securities should be aware of the relationship between interest rates and the price of those securities. As a general rule, the price of a bond moves inversely to changes in interest rates.

Diversification does not ensure a profit or protect against a loss. There are risks associated with fixed income investing, even though many investors consider bonds to be “risk free” investment vehicles.

Investors should pay careful attention to the types of fixed income securities which comprise their portfolios and remember that, as with all investments, there is the risk of loss of capital. The value of fixed income securities fluctuates and investors may receive more or less than their original investments if sold prior to maturity. Bonds are subject to price change and availability.

International Investment Disclosure

Investors should consider various factors when assessing potential investments, whether domestic or international.

International investment returns may move in a different direction, or at a different pace, than U.S. investment returns. In that case, including exposure to both domestic and foreign securities in a portfolio may reduce the risk that an investor will lose money if there is a drop in U.S. investment returns and a portfolio’s overall investment returns over time may have less volatility. Keep in mind, though, that this is not always true and that with globalization, markets are increasingly intertwined across borders.

While investing in any security requires careful consideration, international investing raises some special issues and risks. These include:

Access to different investment information. In some jurisdictions, the information provided by foreign companies is different than information provided by U.S. companies. The nature, amount and frequency of disclosures required under foreign law may also be different from that required of U.S. companies. In addition, foreign companies’ financial statements may be prepared using a different set of accounting standards than companies use in the United States. Information foreign companies publish may not be in English.

Moreover, the financial statements of publicly listed companies in the United States, whether based in the United States or abroad, must be audited by an independent public accounting firm subject to oversight by the Public Company Accounting Oversight Board (PCAOB). The financial statements of a foreign company that is not publicly listed in the United States may or may not be subject to analogous auditing and auditor oversight arrangements.

Costs of international investments. International investing can be more expensive than investing in U.S. companies. In some countries there may be unexpected taxes, such as withholding taxes on dividends. In addition, transaction costs such as fees, broker’s commissions and taxes may be higher than in U.S. markets. Investors also should be aware of the potential risks and effects of currency conversion costs on an investment. U.S.-registered mutual funds and ETFs that invest abroad may have higher fees and expenses than funds and ETFs that invest in U.S. securities, in part because of the extra expense of trading in foreign markets.

Working with a broker or investment adviser. If investors are working with a broker or investment adviser, they should make sure the investment professional is registered with the SEC or (for some investment advisers) with the appropriate state regulatory entity.

It is generally against the law for a broker, foreign or domestic, to contact a U.S. investor and solicit an investment unless the broker is registered with the SEC. If U.S. investors directly contact and work with a foreign broker not registered with the SEC, they may not have the same protections as they would if the broker were registered with the SEC and subject to the laws of the United States. Investment advisers advising U.S. persons on investments in securities must register in the U.S. or must be eligible for an exemption to registration.

Details on a U.S.-registered broker’s or investment adviser’s background and qualifications are available on the SEC’s Investment Adviser Public Disclosure (IAPD) website which is also available through the SEC’s website for individual investors, If investors have any questions about checking the background of an investment professional, they can call the SEC’s toll-free investor assistance line at (800) 732-0330 for help.

Changes in currency exchange rates and currency controls. A foreign investment also has foreign currency exchange risks. When the exchange rate between the foreign currency and the U.S. dollar changes, it can increase or reduce an investment return in a foreign security. In fact, it is possible that a foreign investment may increase in value in its home market but, because of changing exchange rates, the value of that investment in U.S. dollars is actually lower. In addition to exchange rates, investors should be aware that some countries may impose foreign currency controls that restrict or delay investors or the company invested in from moving currency out of a country. These controls could affect the value and liquidity of an investment.

Changes in market value. All securities markets can experience dramatic changes in market value. One way to attempt to reduce the impact of these price changes is to be prepared to hold investments through adverse times and sharp downturns in domestic or foreign markets, which may be long lasting.

Political, economic and social events. Depending on the country or region, it can be more difficult for individual investors to obtain information about and comprehensively analyze all the political, economic and social factors that influence a particular foreign market. These factors may provide diversification from a domestically-focused portfolio, but they may also contribute to the risk of international investing.

Different levels of liquidity. Some foreign markets may have lower trading volumes for securities or fewer listed companies than U.S. markets. Some foreign markets are open for shorter periods than U.S. markets. In addition, some countries may restrict the amount or type of securities that foreign investors may purchase. Where these factors exist, a market may have less liquidity, which may make it more difficult to find a buyer when investors want to sell their securities.

Legal remedies. Where investors purchase a security can affect whether they have, and where they can pursue, legal remedies against the foreign company or any other foreign-based entities involved in a transaction. Investors should be mindful of this when either buying or selling securities on foreign securities exchanges or otherwise outside the United States or entering into securities transactions with parties located outside the United States. In these situations, investors may not have the ability to seek certain legal remedies in U.S. courts as private plaintiffs. Moreover, even if investors sue successfully in a U.S. court, they may not be able to collect on a U.S. judgment against a foreign company, entity or person. Investors may have to rely on legal remedies that are available in the home country, if any.

The SEC’s law enforcement authority with respect to fraudulent conduct protects investors and markets within the United States and protects against fraudulent conduct outside the United States that has a foreseeable substantial effect within the United States.  SEC action, however, may or may not lead to the investor receiving funds to redress any fraud.  In addition, the SEC may face legal and other obstacles to obtaining information that it would need for investigations or litigation if the information is located in a foreign country.

Investors who would like to provide information about fraud or wrongdoing involving potential violations of the U.S. securities laws may contact the SEC using the SEC’s Tips, Complaints and Referrals Portal.

Different market operations. Foreign markets may operate differently from the major U.S. trading markets. For example, there may be different time periods for clearance and settlement of securities transactions. Some foreign markets may not report securities trades within the same period as U.S. markets. Rules providing for the safekeeping of shares held by foreign custodian banks or depositories may differ from those in the United States. If a foreign custodian has credit problems or fails, shares purchased in a foreign market may have different levels of protection than provided under the laws of the United States.


FINRA Rules 2267 requires that members firms provide customers with the FINRA BrokerCheck Hotline Number 800-289-9999, FINRA web site information and notify each customer that a brochure describing BrokerCheck is available from FINRA by contacting FINRA. Information regarding the BrokerCheck system may also be found at


NFA rules require that members provide customers with the NFA’s Background Affiliation Status Information Center (BASIC) web site


TJM Investments, LLC is a member of the Securities Investor Protections Corporation (SIPC).  You may obtain information about SIPC, including the SIPC brochure by contacting SIPC at or (202)371-8300.

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The prize: A “The Cow Guy” t-shirt. No cash or other prize substitution permitted. The prize is nontransferable. Any and all prize related expenses, including without limitation any and all federal, state, and/or local taxes shall be the sole responsibility of the winner.

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Sweepstakes entries are limited to the United States and District of Columbia and is void where prohibited. All federal, state and local laws and regulations apply. Subject to any governmental approval that may be required, Sponsor reserves the right to, without prior notice and at any time, terminate the Sweepstakes, in whole or in part, or modify Sweepstakes in any way, should any factor interfere with its proper conduct as contemplated by these Official Rules. Sponsor reserves the right in its sole discretion, to cancel the sweepstakes in its entirety, or only the online portion, if it becomes technically corrupted or because of non-authorized human intervention.

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