PETITION FOR RULEMAKING SUBMITTED TO THE SECRETARY OF THE SEC

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PETITION BY DONALD EASTERLIN RE: REDEFINING

FIDUCIARY STANDARDS AND MODERNIZING MARGIN NOTICE PRACTICES

AMONG RETAIL BROKER-DEALERS (FINRA RULES 2264 AND 4210)

Date: September 26, 2025

Zachary M. Kravat, Esq.

KRAVAT LAW

445 Broadhollow Road, Suite 419

Melville, NY 11747

zkravat@kravatlaw.com

(516) 399-0465

TABLE OF CONTENTS

INTRODUCTION .......................................................................................................................... 1

CURRENT REGULATIONS AND BROKER-DEALER PRACTICES.......................... 3

Current United States Margin Rules and Broker-Dealer Discretion................... 3

Examination of Standard Margin Agreements and Their Explicit Clauses ........ 7

II.

HISTORY BEHIND CURRENT REGULATORY SCHEME .......................................... 8

III.

THE FORCED SALE OF MR. EASTERLIN’S SECURITIES ......................................11

Background and Schwab’s Sale of Mr. Easterlin’s Securities ...........................11

The FINRA Arbitration ..................................................................................... 13

IV.

WHY UPDATING MARGIN NOTICE REQUIREMENTS IS NECESSARY ............. 14

RECOMMENDATIONS ................................................................................................. 17

Undersigned counsel presents this submission to the United States Securities and

Exchange Commission (“SEC”) on behalf of Donald Easterlin. Mr. Easterlin respectfully

requests assessment of SEC and Financial Industry Regulatory Authority (“FINRA”) regulations

permitting registered broker-dealers to sell their clients’ securities on margin without providing

actual or constructive notice. As discussed below, these regulations are outdated and

disproportionately harm retail investors. Mr. Easterlin further requests an opportunity to present

these matters in person before the SEC.

INTRODUCTION

In May 2022, Mr. Easterlin lost his complete investment account of approximately

$20,000 when his broker, Charles Schwab, Inc. (“Schwab”) d/b/a TD Ameritrade, authorized a

sale of securities in Mr. Easterlin’s account without providing him with notice to allow him to

sufficiently collateralize the account. Mr. Easterlin, a seasoned retail investor, had been actively

following the market regarding the spin-off and IPO of Bausch + Lomb (BLCO), an eye-health

business, from parent company Bausch Health (BHC). BHC had been under fire from short

sellers who, in the opinion of acknowledged professional brokers, as well as in the opinion of

Mr. Easterlin and others in the market, had improperly targeted the stock and negatively

manipulated its price. This manipulation was particularly acute in before- and after-market

trading. As a result of this manipulation, and through actions beyond his control, on May 10,

2022, Schwab sold shares of BHC Mr. Easterlin had previously purchased either in cash or on

margin. These sales were effectuated by Schwab before the official opening time of the New

York Stock Exchange, without any notice to Mr. Easterlin, and without any ability by Mr.

Easterlin to contact Schwab’s margin department. As such, before the market even opened on

May 10, 2022, Schwab had instantly wiped out Mr. Easterlin’s equity position and negated any

chance of redemption, instead putting his account in a deficit of approximately one-hundred and

eighty dollars. Relevant statutes and regulations, including the Trust Indenture Act of 1939 and

Regulation Best Interest, outline the fiduciary responsibilities in the context of debt securities;

Schwab flouted those responsibilities to Mr. Easterlin with its concealed fire sale in the dead of

night.

Mr. Easterlin presented his case to FINRA through arbitration, which was resolved by

order of the arbitrator on November 20, 2024 in favor of Schwab.1 In those proceedings,

Schwab alternately claimed: (1) it provided Mr. Easterlin with notice, despite the fact that Mr.

Easterlin was never contacted to learn about the pre-market-open trading, which is contrary to

Schwab’s policy; and (2) that it was not required to give Mr. Easterlin notice at all.

To be clear, Mr. Easterlin is not relitigating his case. He raises Schwab’s positions

because those arguments, and the arbitrator’s decision in favor of Schwab, highlight the

unfairness of the current regulatory scheme and its bias towards broker-dealers to the detriment

of retail investors. As noted by Charles Cain, chief of the SEC Enforcement Division’s FCPA

unit, “[i]nvestors must have confidence that the operations and performance of public companies

reflect merit and legitimate considerations[.] Bribery and corruption turn that dynamic on its

head, distorting the orderly operation of the markets and undermining investor confidence.”

As such, Mr. Easterlin submits this memorandum, which will: (1) describe current

regulations and broker-dealer practices; (2) explain the history behind the current regulatory

scheme; (3) describe Mr. Easterlin’s case, which serves as an example of the unfairness of the

current regulatory scheme, which allows broker-dealers like Schwab to place its interests above

See Exhibit A (Nov. 20, 2024 Award), also available at

https://www.finra.org/sites/default/files/aao_documents/24-00513.pdf.

retail investors; (4) argue why current regulations are outdated, inconsistent, and are harmful to

retail investors; and (5) provide actionable recommendations for the SEC to remedy these harms.

CURRENT REGULATIONS AND BROKER-DEALER PRACTICES

A. Current United States Margin Rules and Broker-Dealer Discretion

The current United States regulatory landscape for margin accounts is characterized by a

significant degree of discretion afforded to broker-dealers regarding liquidation without prior

notice. This framework is a composite of rules from FINRA, the Securities and Exchange

Commission (SEC), and the Federal Reserve Board (FRB).

1. FINRA Rule 42102

FINRA Rule 4210 establishes comprehensive margin requirements for broker-dealers,

setting standards for the extension of credit in customer margin accounts.3 This rule serves

several critical objectives within the securities industry. First, Rule 4210 helps mitigate

significant losses for traders and prevents destabilization of brokerage firms and the broader

market.4 Second, Rule 4210 claims to enhance investor protection and risk awareness by

mandating firms to issue margin calls when account balances fall below maintenance

requirements, preventing unaffordable losses, and requiring clear disclosures about margin

trading risks to inform retail investors.5 As discussed below, however, these provisions are in

opposition to Rule 4210’s explicit grant of discretion to brokers. The rule specifies that brokers,

Fin. Indus. Regul. Auth. Rule 4210, https://www.finra.org/rules-guidance/rulebooks/finra-rules/4210

(hereinafter “FINRA Rule 4210”).

See Inst. for Innov. Regul., FINRA Rule 4210 Margin Requirements,

https://www.innreg.com/resources/finra-rules/4210-margin-requirements; https://www.finra.org/rules-guidance/keytopics/margin-accounts.

Inst. for Innov. Regul., FINRA Rule 4210 Margin Requirements, https://www.innreg.com/resources/finrarules/4210-margin-requirements.

Id.

at their discretion, “may liquidate an account at any time to eliminate a margin deficiency.”6

This grants broker-dealers broad and unilateral authority to execute forced sales without explicit

prior notification to the investor. This broad discretionary power forms a foundational element

of the current framework, allowing broker-dealers immense, practically unchecked latitude in

managing their perceived credit risk.

FINRA Rule 2264

FINRA Rule 2264 (formerly Rule 2341) is a cornerstone of the current regulatory

scheme’s attempts to increase investor awareness regarding the risks inherent in margin trading.

This rule mandates that brokerage firms provide a “Margin Disclosure Statement” to noninstitutional customers.7 The rule explicitly requires the disclosure of several key risks,

including the potential for customers to lose more funds than they initially deposited in the

margin account; the firm’s unequivocal right to force the sale of securities or other assets in any

of the customer’s accounts to cover a margin deficiency; and, critically, the firm’s right to sell

securities or other assets without contacting the customer.8 Other important disclosures include

the fact that the customer is not entitled to choose which securities or assets are liquidated, as the

firm retains sole discretion over this decision.9 Additionally, firms can increase their “house”

maintenance margin requirements at any time without advance written notice, including changes

taking immediate effect and potentially triggering a margin call.10

FINRA Rule 4210.

Fin. Indus. Regul. Auth. Rule 2264, https://www.finra.org/rules-guidance/rulebooks/finra-rules/2264

(hereinafter “FINRA Rule 2264”).

Id.

Federal Reserve Board Regulation T

Regulation T (Reg T), promulgated by the FRB and codified under 12 CFR § 220,

governs the extension of credit by securities brokers and dealers in the United States. Its primary

function is to control initial margin requirements for stocks purchased on margin; since 1974,

this initial margin requirement has been consistently set at 50% of the purchase price of equity

securities.11 Reg T only sets initial margin requirements; ongoing “maintenance margin”

requirements are typically regulated by FINRA (e.g., Rule 4210) or by the individual brokerage

firms’ “house” rules.12 This distributed regulatory authority, where initial margin is set by the

FRB and maintenance margin and liquidation rules fall under FINRA and individual brokerdealer discretion, creates a fragmented landscape for investor safeguards.

SEC Investor Alerts and Guidance on Margin Account Risks

The SEC issues investor alerts and guidance to highlight the significant risks associated

with margin trading, including the alert titled “Investor Bulletin: Margin Accounts,” dated June

10, 2021.13 The alert specifically notes:

Some investors have been shocked to find out that the brokerage firm has

the right to sell their securities that were bought on margin – without any

notification and potentially at a substantial loss to the investor. If your

broker sells your stock after the price has plummeted, then you’ve lost out

on the chance to recoup your losses if the market bounces back.14

As such, both FINRA rules and SEC investor alerts explicitly acknowledge the potential

for “shock” and “substantial loss” to retail investors due to no-notice liquidations.

See Interactive Brokers, Reg T Margin, https://www.interactivebrokers.com/campus/glossary-terms/reg-t-

margin/.

See, e.g., id.

U.S. Sec. & Exch. Comm’n, Investor Bulletin: Margin Rules, https://www.investor.gov/introductioninvesting/general-resources/news-alerts/alerts-bulletins/investor-bulletins-29 (hereinafter “Investor Bullet: Margin

Rules”).

Id.

5. Regulation Best Interest

Regulation Best Interest, adopted by the SEC in 2019 and codified under the Exchange

Act at 7 C.F.R. § 240.15l-1, requires broker-dealers, when making a recommendation to a retail

customer about any securities transaction or investment strategy, to act in the customer’s best

interest and not place the firm’s interests ahead of the customer’s.15 The SEC has explicitly

stated that Regulation Best Interest applies to “account recommendations,” including margin

accounts.16 To satisfy the best-interest obligation, a broker-dealer must comply with four

component obligations: (1) disclosure; (2) care; (3) conflict of interest; and (4) compliance.17 In

particular, the “conflict of interest” provision of Regulation Best Interest requires broker-dealers

to “[i]dentify and mitigate any conflicts of interest associated with such recommendations that

create an incentive for the broker-dealer’s associated persons to place their interest or the interest

of the broker-dealer ahead of the retail customer’s interest[.]”18 Further, the “care” provision

obligates broker-dealers to avoid “[m]aking recommendations without developing a sufficient

understanding of the features and risks of the recommended security or investment strategy

involving a security, such as when recommending leveraged . . . products without understanding

holding-period risk . . . .”19

Regulation Best Interest: The Broker-Dealer Standard of Conduct, Exchange Act Release No. 34-86031,

84 Fed. Reg. 33,318 (July 12, 2019), https://www.sec.gov/files/rules/final/2019/34-86031.pdf.

Id. at PDF 86 n.174.

See id.; U.S. Sec. & Exch. Comm’n, Regulation Best Interest: Small Entity Compliance Guide,

https://www.sec.gov/resources-small-businesses/small-business-compliance-guides/regulation-best-interest.

U.S. Sec. & Exch. Comm’n, Regulation Best Interest: Small Entity Compliance Guide,

https://www.sec.gov/resources-small-businesses/small-business-compliance-guides/regulation-best-interest.

Fin. Indus. Regul. Auth., 2025 Annual Regulatory Oversight Report, Reg BI and Form CRS,

https://www.finra.org/rules-guidance/guidance/reports/2025-finra-annual-regulatory-oversight-report/reg-bi-formcrs#_ednref2.

Examination of Standard Margin Agreements and Their Explicit Clauses

Standard margin agreements used by major United States brokerage firms consistently

include explicit clauses that grant broker-dealers extensive authority over margin accounts,

particularly concerning liquidation. These clauses are designed to protect the firms’ financial

interests over the interest of the individual investor and are presented to customers on a nonnegotiable basis.

Mr. Easterlin, for his part, signed a Cash & Margin Agreement with TD Ameritrade on

August 20, 2003. That Agreement that did not explicitly discuss the broker’s discretion over Mr.

Easterlin’s margin account, instead incorporating the terms and conditions by reference.20 Those

terms, providing in 9 pages of the proverbial “small print” that Mr. Easterlin was not required to

explicitly sign, included the following key provisions mirroring the FINRA regulations and SEC

guidance discussed above: (1) the broker’s right to liquidate without providing any prior notice;21

(2) no right by Mr. Easterlin to choose which securities the broker may liquidate or sold to meet

a margin call; (3) the broker’s right to change its “house” margin requirements without any

notice; (4) no right by Mr. Easterlin for an extension of time on a margin call.22

TD Ameritrade was purchased by Schwab in October 2020 and was “absorbed” by

Schwab by May 2024.23 Schwab’s current Brokerage Account Agreement and Margin

See Exhibit B.

Exhibit C at 7 (“You can sell my securities or other assets without contacting me. Some investors

mistakenly believe that a firm must contact them for a margin call to be valid, and that the firm cannot liquidate

securities or other assets in their accounts to meet the call unless the firm has contacted them first. This is not the

case. Although you may attempt to notify me of margin calls, you are not required to do so, and even if you have

contacted me and provided a specific date by which I can meet a margin call, you can still take necessary steps to

protect your financial interests, including immediately selling securities without notice to me.”).

Id.

Press Release, Charles Schwab, Charles Schwab Completes Acquisition of TD Ameritrade (Oct. 6,

2020), https://pressroom.aboutschwab.com/press-releases/press-release/2020/Charles-Schwab-CompletesAcquisition-of-TD-Ameritrade/default.aspx; Charles Schwab Corp., Annual Report (Form 10-K) 1 (Feb. 22, 2024),

https://content.schwab.com/web/retail/public/about-schwab/SEC_Form10k_2024.pdf at 1.

Disclosure Statement mirrors the TD Ameritrade terms.24 A survey similar agreements provided

by popular brokers for retail investors indicates they too provide the same or similar nonnegotiable terms:

TABLE 1: Comparison of Key Margin Agreement Clauses (Notice &

Liquidation Authority)

Brokerage

Firm

Schwab25

Fidelity26

Merrill

Edge27

Robinhood28

Right to Liquidate

Without Prior

Notice

Yes

No Right to Choose

Securities for

Liquidation

Yes

Right to Change “House”

Requirements Without

Advance Notice

Yes

The current regulatory scheme provides brokers with no incentive to offer more investorfriendly terms, and leaves retail investors with no option but to submit to the brokers’

“discretion” in operating their margin accounts.

II.

HISTORY BEHIND CURRENT REGULATORY SCHEME

As discussed above, regulatory bodies are clearly aware of the “shock” felt by many

retail investors’ in finding out that their broker has the unfettered ability to sell off or liquidate

their margin positions. This raises a fundamental question: if regulatory bodies are clearly aware

of this specific harm, why do the underlying rules continue to permit it without mandating

modern, feasible mitigation strategies?

See Charles Schwab, Schwab Brokerage Account Agreement, https://www.schwab.com/legal/schwabbrokerage-account-agreement; Charles Schwab, Margin Disclosure Statement,

https://www.schwab.com/legal/margin-disclosure-statement (hereinafter “Schwab Margin Disclosure Statement”).

Schwab Margin Disclosure Statement.

idelity Brokerage Servs. LLC, Fidelity Account Customer Agreement,https://www.fidelity.com/binpublic/060_www_fidelity_com/documents/customer-service/updated-agreements/Updated-Fidelity-AccountCustomer-Agreement.pdf.

Merrill Edge, Trade Violations, https://www.merrilledge.com/trade/violations,

Robinhood, Margin Calls, https://robinhood.com/us/en/support/articles/margin-calls/; Robinhood,

Margin Maintenance, https://robinhood.com/gb/en/support/articles/margin-maintenance/.

The current regulatory scheme was born nearly 100 years ago in the aftermath of the

stock market crash of 1929. That crash, and the subsequent Great Depression, were significantly

exacerbated by excessive margin borrowing; an extraordinarily high volume of margin calls and

ensuing forced liquidations overwhelmed the financial system’s infrastructure, creating a “selffulfilling downward spiral” where declining prices triggered more margin calls, leading to further

forced selling and even deeper price depression.29

In direct response to the financial abuses and market instability of 1929, Congress

enacted the Securities Exchange Act of 1934 (the “Act”).30 A cornerstone of this legislation was

Section 7, which granted the FRB the authority to regulate margin lending with the stated

purpose of “preventing the excessive use of credit for the purchase or carrying of securities.”31

This regulatory intervention was primarily seen as a mechanism to minimize market fluctuations

and safeguard the national business system from the volatility of the securities market.

The “no-notice liquidation” right, which is a central feature of current margin rules, can

be understood as a direct historical artifact of this period. The immediate regulatory response to

such a catastrophic event logically prioritized preventing a recurrence of systemic collapse and

safeguarding the solvency of financial intermediaries, namely broker-dealers and banks. This

historical context is vital for understanding the current rules.

However, while stability of the financial system was the highlighted goal of the Act,

legislative history demonstrates that protection of the investor was also of paramount importance

to Congress. Representative Rayburn, Speaker of the House and Chairman of the House

Jesper Rangvid, The Great Margin Call, Univ. of S. Denmark (2020), https://www.sdu.dk//media/files/om_sdu/institutter/ivoe/econ/the+great+margin+call.pdf.

EBSCO Research Starters, Securities and Exchange Commission Established,

https://www.ebsco.com/research-starters/politics-and-government/securities-and-exchange-commission-established.

15 U.S.C. § 78g.

Committee, declared that a purpose of the House bill that led to the passage of the Act was to

protect investors from speculating on insufficient margin, stating that a “[r]easonably high

margin is essential so that a person cannot get in the market on a shoe string one day and be one

of the sheared lambs when he wakes up the next morning.”32 Another member of the House,

Representative Sabath, stressed his opinion that “it is our duty to see that the investing public, or

rather the ‘lambs,’ be protected by this Government so that their investments shall not be wiped

out even before the receipt of the stock certificates issued to them.”33

The concerns of these Congressmen, however, have been severely undermined by the

modern regulatory scheme and the leeway provided to brokers, allowing for “lambs” like Mr.

Easterlin and other retail investors to be “sheared” by their brokers without any warning or

ability to increase their margin/decrease their exposure. This is particularly salient today, where

modern technology offers brokers and their investor clients with many options for instantaneous

communication and far more flexibility to allow investors to avoid harm before the liquidity of

the broker is significantly threatened.

The SEC’s adoption of Regulation Best Interest in 2019 was a step in the right direction

in terms of prioritizing the interests of retail investors over the more powerful broker-dealers. In

particular, it requires broker-dealers, “when providing personalized investment advice about

securities to retail customers,” to “act in the best interest of the customer without regard to the

financial or other interest of the broker, dealer, or investment adviser providing the advice.”34 In

Daniel J. Morrissey, Securities Regulation at the Crossroads: The Law and Politics of the 1934 Act, 18

N.C. J. INT’L L. & COM. REG. 1, 26 (1992),

https://scholarship.law.unc.edu/cgi/viewcontent.cgi?article=1197&context=ncilj (quoting 78 CONG. REC. 7,700

(1934)).

Id. (quoting 78 CONG. REC. 8,011 (1934)).

Credit Card Accountability Responsibility and Disclosure Act of 2009, Pub. L. No. 111-203, 124 Stat.

1376, https://www.congress.gov/111/plaws/publ203/PLAW-111publ203.pdf.

particular, the SEC has advised that “heightened scrutiny” should be applied to “investments

traded on margin[.]”35 However, FINRA and SEC enforcement of Regulation Best Interest

appears to be limited to particular brokers’ recommendations of risky investments, not to the

brokers’ decisions to liquidate or sell a margin position with limited or no notice.36

III.

THE FORCED SALE OF MR. EASTERLIN’S SECURITIES

Given this regulatory framework, the petitioner’s case serves as a compelling example of

how the current system systematically disadvantages retail investors.

Background and Schwab’s Sale of Mr. Easterlin’s Securities

Mr. Easterlin, 88, is a retiree and active member of his church community in Brooklyn,

New York. Prior to his retirement, Mr. Easterlin worked for the Transit Authority as a subway

train operator and dispatcher and served four years as a Staff Sergeant in the United States Army,

Infantry Division. As discussed above, Mr. Easterlin became a retail client of TD Ameritrade in

2003 and had a successful and mutually beneficial relationship with TD Ameritrade for over

twenty years. During that time, Mr. Easterlin regularly engaged in frequent margin purchases

and was routinely given the opportunity to add equity in response to margin calls, thereby

avoiding the immediate sale of securities.

In early May 2022, Bausch Health (BHC) completed the long-planned spin-off of its eyecare unit, Bausch + Lomb. The spin-off unit priced its IPO on May 5, 2022 at $18 per share, and

the stock began trading on the NYSE under ticker BLCO on May 6, 2022.37 The stock was

U.S. Sec. & Exch. Comm’n, Staff Bulletin: Standards of Conduct for Broker-Dealers and Investment

Advisers, https://www.sec.gov/about/divisions-offices/division-trading-markets/broker-dealers/staff-bulletinstandards-conduct-broker-dealers-investment-advisers-care-obligations.

See, e,g., Gibson, Dunn & Crutcher LLP, Securities Enforcement 2025 Mid-Year Update,

https://www.gibsondunn.com/securities-enforcement-2025-mid-year-update/.

Michael Bloom, Bausch & Lomb Begins Trading in One of the Biggest IPOs of 2022, CNBC (May 6,

2022), https://www.cnbc.com/2022/05/06/bausch-lomb-begins-trading-in-one-of-the-biggest-ipos-of-2022.html.

immediately targeted by short sellers.38 Mr. Easterlin, an avid watcher of Mad Money with Jim

Cramer, was alerted to this fact in an early May 2022 broadcast, in which Mr. Cramer noted that

“[t]here are shorts taking [BHC] stock all the way down” and his view that this attempted

manipulation was “quite ridiculous,” and that he wanted to purchase more BHC himself.39

On April 28, 2022, Mr. Easterlin acquired roughly 1,595 shares of BHC on margin at

prices between $18.75 and $21.15 per share, committing over $32,000 of funds. On May 6,

2022, TD Ameritrade (now owned and operated by Schwab) sold 800 shares at $16.08 per share;

on May 10, 2022, TD Ameritrade/Schwab sold the remaining 1,395 shares in multiple tranches

between $9.26 and $9.66 per share. These forced sales liquidated Mr. Easterlin’s account,

leaving him with no securities, a residual margin debit of negative $381, and cumulative

portfolio losses of approximately $19,600.40

Troublingly, Schwab never notified Mr. Easterlin of its decision on May 10, 2022 to

engage in a fire sale of the securities, liquidate his account, and place him in a deficit.41 Nor was

he given the opportunity, as he had for the nearly two decades prior, to add collateral to his

account to prevent the sale of the BHC position. Indeed, on May 6, 2022, Mr. Easterlin sold

shares in a different position, Palisade Bio (PALI), in order to increase the collateral in his

account to prevent further sales of BHC.42 Despite this, Schwab, in contravention to its own

stated policies and Regulation Best Interest, liquidated his remaining position in BHC without

MarketBeat, Bausch Health Companies Short Interest,

https://www.marketbeat.com/stocks/NYSE/BHC/short-interest/.

Jim Cramer, Lightning Round, CNBC (May 4, 2022), https://www.cnbc.com/2022/05/04/cramerslightning-round-marvell-technology-and-bausch-health-are-buys.html.

See Exhibit D.

At the arbitration hearing, Schwab introduced evidence tending to show that Mr. Easterlin was provided

with a phone call on May 6, 2022, but further stipulated that Mr. Easterlin did not receive any advance notification

before the liquidation of the remaining positions in his account on May 10, 2022.

See Exhibit D.

consulting Mr. Easterlin. Furthermore, Schwab’s records demonstrate that its forced sale of BHC

on May 10, 2022 occurred prior to the market opening when it was impossible for Mr. Easterlin

to supplement the collateral in his account.

The FINRA Arbitration

Mr. Easterlin commenced arbitration proceedings against TD Ameritrade on or about

March 7, 2024. Mr. Easterlin, representing himself, faced a process marred by procedural and

other concerns.

First, at Mr. Easterlin’s request, the initial arbitrator assigned by FINRA was forced to

recuse herself because of her interest in an IRA account managed by Schwab. Second, FINRA

violated its own Rule 12202 when it failed to notify Mr. Easterlin that TD Ameritrade had

become an inactive member of FINRA. When Mr. Easterlin filed his initial claim with FINRA

on March 7, 2024, TD Ameritrade was still an active member of FINRA. However, as a result of

Schwab “absorbing” TD Ameritrade and winding down the TD Ameritrade-branded business, on

May 30, 2024, while the arbitration was pending, TD Ameritrade ceased doing business and

withdrew its FINRA registration.43 According to FINRA Rule 12202, “[i]f a member or an

associated person becomes inactive during a pending arbitration, FINRA will notify the customer

about the status change. Within 60 days of receiving notice of a member or an associated

person’s status change to inactive, a customer may withdraw the claim(s) against such inactive

member or inactive associated person with or without prejudice.”44 But Mr. Easterlin was never

notified that he was, in fact, arbitrating against an inactive member; to the contrary, Mr. Easterlin

had to raise the issue himself on June 23, 2024, by raising the issue to the arbitrator’s attention.

See Fin. Indus. Regul. Auth., BrokerCheck Report for Charles Schwab & Co., Inc. 2 (2024),

https://files.brokercheck.finra.org/firm/firm_7870.pdf at 2 (PDF page 4).

Fin. Indus. Regul. Auth. Rule 12202, https://www.finra.org/rules-guidance/rulebooks/finra-rules/12202.

Only by order on Mr. Easterlin’s motion was Schwab added as a respondent, and despite Mr.

Easterlin’s repeated requests to remove TD Ameritrade as a respondent, that now-defunct entity

still remained on the caption in the arbitrator’s order.45

On November 20, 2024, after a hearing, the arbitrator issued an order denying Mr.

Easterlin’s claims.46

IV.

WHY UPDATING MARGIN NOTICE REQUIREMENTS IS NECESSARY

The complete wipeout of Mr. Easterlin’s margin position serves as a case study in the real

risk of harm faced by retail investors trading on margin resulting from the current regulatory

scheme. As a result of new technology, in particular the proliferation online trading platforms

(OTPs), more and more retail investors have access to trading on margin. U.S. households’

margin debt reached a historical peak of nearly 4% of GDP in 2022, underscoring the widespread

engagement of individual investors in leveraged positions.47

While margin trading offers the potential to amplify gains, it inherently magnifies losses,

making the terms and conditions governing these accounts critically important for investor

welfare. Indeed, when a broker sells an investor’s stock after a significant price decline, without

prior notice, the investor is deprived of any opportunity to recoup losses should the market

subsequently rebound. This means that even if the market recovers, the investor's position has

been prematurely closed out at the lowest point, locking in maximum losses. As Mr. Easterlin’s

case illustrates, investors can lose more money than their initial investment, and may even

Exhibit A (Nov. 20, 2024 Award).

Id.

Zhiwu Chen, Margin Trading and Stock Market Volatility 15 (Univ. of Notre Dame Working Paper

2002), https://www3.nd.edu/~zda/margin.pdf.

remain indebted to the brokerage firm after the liquidation if the proceeds do not cover the

margin loan and associated costs.

As discussed in Section II, supra, the current framework, deeply rooted in post-1929

crisis responses, prioritizes the solvency of financial institutions and systemic stability. As such,

the current regulatory scheme’s main “protection” of investors is a simple attempt to increase

investors’ awareness of risk. In practice, serves primarily as a legal shield for broker-dealers,

allowing them to assert that investors were “informed” of the risks, thereby limiting the firms’

liability. This harm is further compounded by the fact that retail investors are presented with the

broker-dealers’ terms on a “take-it-or-leave-it” basis,48 having no ability to trade on margin

without accepting that the broker-dealer may trade away the investors’ position without any

notice or ability for recourse. This places the onus entirely on the investor to understand and

anticipate extreme, fast-moving market events, despite the inherent power imbalance and

complexity of margin trading. As noted above, the SEC has already long realized that this is an

unrealistic expectation for many retail investors, who, like Mr. Easterlin, are “shocked” 49 to find

that their broker-dealer has acted contrary to their interests. This is particularly salient when

those same broker-dealers are bound by Regulation Best Interest to place the investors’ interest

above their own. The current regulatory scheme that overly protects broker-dealers, in particular

FINRA Rules 4210 and 2264, are at odds with that overarching duty placed on broker-dealers by

Regulation Best Interest.

Importantly, in today’s world—where virtually every retail investor carries a smartphone

and broker-dealers already push account alerts in real time—these rules are anachronistic. The

See, e.g., James J. Park, When Retail Investors Sue: Securities Class Actions in the 21st Century, 23

CARDOZO J. CONFLICT RESOL. 1 (2021), https://larc.cardozo.yu.edu/cgi/viewcontent.cgi?article=1246&context=cjcr

Investor Bulletin: Margin Rules.

SEC has long authorized electronic delivery of required disclosures by intermediaries (including

broker-dealers).50 FINRA likewise formalized policies for electronic delivery to customers as far

back as 1998 and issued detailed supervisory guidance for electronic communications (email,

portals, social/app) in 2007.51 91% of U.S. adults own a smartphone; 98% own a cellphone. 52 A

meaningful slice are smartphone dependent for internet access, so mobile is the default way

many investors receive urgent information.53 Retail broker platforms advertise configurable

push, SMS, and email alerts in their mobile apps and portals;54 Schwab itself has publicly stated

that it has access and may choose to use multi-channel notice methods (phone/email/online

message center) for margin calls.55

In other words, the technology that allows brokers to contact their client to respond to a

margin notice and provide that investor with the immediate or near-immediate opportunity to

respond before their positions are liquidated is not hypothetical—it exists and is currently in use.

The relevant regulations, however, have yet to catch up, unnecessarily placing investors in

harms’ way when such risks can easily be avoided.

Use of Electronic Media, 65 Fed. Reg. 25,843 (May 4, 2000),

https://www.federalregister.gov/documents/2000/05/04/00-11079/use-of-electronic-media.

Fin. Indus. Regul. Auth., Notice to Members 98-03, https://www.finra.org/rules-guidance/notices/98-03;

Fin. Indus. Regul. Auth., Regulatory Notice 07-59 (Dec. 2007),

https://www.finra.org/sites/default/files/NoticeDocument/p037553.pdf.

Pew Rsch. Ctr., Mobile Fact Sheet, https://www.pewresearch.org/internet/fact-sheet/mobile/.

Pew Rsch. Ctr., Americans’ Use of Mobile Technology and Home Broadband (Jan. 31, 2024),

https://www.pewresearch.org/internet/2024/01/31/americans-use-of-mobile-technology-and-home-broadband/.

See Robinhood, Notifications and Messages, https://robinhood.com/us/en/support/articles/notificationsand-messages; Fidelity, 4 Ways to Use Alerts, https://www.fidelity.com/viewpoints/active-investor/4-ways-to-usealerts.

Charles Schwab, Margin Rates and Requirements, https://www.schwab.com/margin/margin-rates-andrequirements.

RECOMMENDATIONS

Based on the findings above, and to avoid harms to other retail investors like those that

befell Mr. Easterlin, the following recommendations are proposed for updates to FINRA and

SEC rules governing the liquidation of margin accounts:

1. Mandate a Real-Time Margin Deficiency Notice: FINRA and the SEC should

replace the permissive “firms may sell without contacting you” language in

FINRA Rule 2264 and elsewhere with a real-time margin deficiency notice

requirement. Specifically, firms should be required to send a margin deficiency

notice before liquidating securities, unless limited exceptions apply. This notice

should be delivered via multiple, verifiable digital channels, including text

messages, email, and in-app notifications, to ensure prompt and effective

communication. Exceptions should be narrowly defined and limited to extreme,

systemic risk scenarios where immediate action is demonstrably necessary to

prevent broader market instability.

2. Standardize Notice Content and Actionable Options: The content of the preliquidation notice should be standardized to include clear, actionable information.

This must specify the exact margin deficiency amount, the precise liquidation

threshold, the remaining time until liquidation, and explicitly outline the

investor’s available options to meet the call (e.g., depositing additional funds,

selling specific securities, or transferring assets).

3. Mandate a Minimum Pre-Liquidation Notice Period: FINRA and the SEC

should establish a clear, minimum timeframe during which broker-dealers must

provide notice to a retail investor before initiating the forced liquidation of

securities in a margin account. For example, standard margin calls may require a

pre-liquidation notice of 1-2 business days, consistent with current practices at

certain firms,56 while emergency margin calls that threaten the financial viability

of the broker-dealer can be shorter.

4. Grant Investor Choice in Liquidation: Within the mandated notice period, and

provided the investor takes timely action, the rules should ideally allow retail

investors to designate which specific securities they prefer to sell to meet the

margin call.

5. Require Advance Notice for Changes in “House” Margin Requirements:

Broker-dealers should be required to provide advance notice (e.g., 1-2 business

days) to retail investors of any significant increases in their “house” margin

requirements. This would allow investors to proactively adjust their positions or

deposit additional collateral before a new, higher threshold triggers an immediate

margin call.

These recommendations represent a pragmatic evolution of existing regulations,

leveraging modern technology to enhance retail investor protection and foster a more transparent

and fair market environment, without undermining the fundamental stability objectives of margin

rules.

Mr. Easterlin respectfully requests an in-person audience to discuss these matters in

further detail.

See, e.g., Vanguard, Margin Calls, https://investor.vanguard.com/investor-resources-education/onlinetrading/margin-calls.

Dated: Melville, New York

September 26, 2025

Respectfully submitted,

By: Zachary M. Kravat, Esq.

445 Broadhollow Road, Suite 419

Melville, NY 11747

Telephone: (516) 399-0465

Email:

zkravat@kravatlaw.com

Attorney for Donald Easterlin

EXHIBIT A

Award

FINRA Dispute Resolution Services

In the Matter of the Arbitration Between:

Claimant

Donald Easterlin

Case Number: 24-00513

vs.

Respondent

Charles Schwab & Co., Inc.

TD Ameritrade, Inc.

Hearing Site: New York, New York

Awards are rendered by independent arbitrators who are chosen by the parties to issue final,

binding decisions. FINRA makes available an arbitration forum—pursuant to rules approved by

the SEC—but has no part in deciding the award.

Nature of the Dispute: Customer vs. Members

The evidentiary hearing was conducted by videoconference.

REPRESENTATION OF PARTIES

Claimant Donald Easterlin (“Claimant”) appeared pro se.

For Respondents Charles Schwab & Co., Inc. (“Charles Schwab”), and TD Ameritrade, Inc. (“TD

Ameritrade”) (collectively “Respondents”) : Garrett R. Wynne, Esq., Charles Schwab & Co., Inc.,

Lone Tree, Colorado.

CASE INFORMATION

Statement of Claim filed on or about: March 7, 2024.

Claimant signed the Submission Agreement: March 7, 2024.

Statement of Answer filed by Respondent TD Ameritrade on or about: April 26, 2024.

TD Ameritrade signed the Submission Agreement: April 26, 2024.

Charles Schwab signed the Submission Agreement: August 9, 2024.

CASE SUMMARY

In the Statement of Claim, Claimant asserted the following cause of action: breach of fiduciary

duty. The cause of action relates to sale of BHC shares.

Unless specifically admitted in the Statement of Answer, Respondent TD Ameritrade denied the

allegations made in the Statement of Claim and asserted various affirmative defenses.

FINRA Dispute Resolution Services

Arbitration No. 24-00513

Award Page 2 of 5

RELIEF REQUESTED

In the Statement of Claim, Claimant requested: compensatory damages of $50,000.00; costs;

interest; and other monetary relief.

In the Statement of Answer, Respondent TD Ameritrade requested: dismissal of Claimant’s

Statement of Claim in its entirety; forum fees and costs; and such further relief deemed just and

proper.

OTHER ISSUES CONSIDERED AND DECIDED

The Arbitrator acknowledges having read the pleadings and other materials filed by the parties.

On August 8, 2024, Claimant made an oral Motion to Amend the Statement of Claim to add

Charles Schwab & Co., Inc. as a Respondent. TD Ameritrade did not oppose the Motion. By

Order dated August 8, 2024, Claimant’s Motion was granted.

On October 2, 2024, Respondents filed a Motion for Zoom Hearing. On October 2, 2024,

Claimant opposed the Motion. By Order dated October 10, 2024, the Arbitrator granted the

Motion.

On October 8, 2024, Claimant requested that Respondent TD Ameritrade be removed as a party in

this matter and Respondents did not object. Accordingly, Charles Schwab became the sole

Respondent.

The Arbitrator has provided an explanation of the decision in this award. The explanation is for

the parties’ information only and is not precedential in nature.

AWARD

After considering the pleadings, the testimony and evidence presented at the hearing, and any

post-hearing submissions, the Arbitrator has decided in full and final resolution of the issues

submitted for determination as follows:

1. Claimant’s claims are denied in their entirety.

2. Any and all claims for relief not specifically addressed herein, are denied.

ARBITRATOR’S EXPLANATION OF DECISION

Claimant alleged violation of the Fiduciary Act of 1952 and the Investors Advisors Act of 1940

§215(b) stating a contract made in violation is void. Respondent states said acts are not

applicable here. I find said acts inapplicable.

Claimant states he was not given notice of margin call. Respondent states notice was given and

in any event, Respondent was not required to give notice under paragraph 9 or 11 of the

Customer Agreement which Claimant signed. Claimant alleges said provision is "illegal" under

SEC investment brokers' manual stating "client's interest comes first" and states liquidation was

FINRA Dispute Resolution Services

Arbitration No. 24-00513

Award Page 3 of 5

made prior to opening bell; that he is a 20+ year customer who had purportedly never missed a

margin call. This claim of illegality was denied without prejudice.

Claimant further alleged liquidation was made prior to opening bell, which was not sufficiently

clear from evidence submitted. Respondent's witness, Mr. Woerman, margin desk manager,

testified that to wait longer to liquidate might have cost the Claimant more of a loss, (the alleged

loss here being over $500K). I find Claimant was afforded sufficient time and opportunity to

question and cross-examine Respondent's witness regarding the instant margin call event and

other events which Claimant complained of in the course of their 20-year dealings, including but

not limited to, the accessibility of the margin department in relation to other departments.

Claimant also cites R. 2264, SEC 34-86031, Reg BI, which Respondent states is inapplicable.

Claimant’s claim is denied.

Respondent states Claimant’s account was self-directed and Claimant was aware of risk

involved.

FEES

Pursuant to the Code of Arbitration Procedure (“Code”), the following fees are assessed:

Filing Fees

FINRA Dispute Resolution Services assessed a filing fee* for each claim:

Initial Claim Filing Fee

=$ 600.00

*The filing fee is made up of a non-refundable and a refundable portion.

Member Fees

Member fees are assessed to each member firm that is a party in these proceedings or to the

member firm that employed the associated person at the time of the events giving rise to the

dispute. Accordingly, as a party, Respondent TD Ameritrade is assessed the following:

Member Surcharge

Member Process Fee

=$ 750.00

=$ 1,750.00

Hearing Session Fees and Assessments

The Arbitrator has assessed hearing session fees for each session conducted. A session is any

meeting between the parties and the Arbitrator, including a pre-hearing conference with the

Arbitrator, which lasts four (4) hours or less. Fees associated with these proceedings are:

One (1) pre-hearing session with a single Arbitrator @ $450.00/session

Pre-Hearing Conference: August 8, 2024

1 session

450.00

Two (2) hearing sessions @ $450.00/session

Hearing:

November 8, 2024

900.00

Total Hearing Session Fees

2 sessions

=$ 1,350.00

FINRA Dispute Resolution Services

Arbitration No. 24-00513

Award Page 4 of 5

The Arbitrator has assessed the total hearing session fees to Claimant.

All balances are payable to FINRA Dispute Resolution Services and are due upon receipt.

FINRA Dispute Resolution Services

Arbitration No. 24-00513

Award Page 5 of 5

ARBITRATOR

Anna M. Fanelli

Sole Public Arbitrator

I, the undersigned Arbitrator, do hereby affirm, pursuant to Article 7507 of the Civil Practice Law

and Rules, that I am the individual described herein and who executed this instrument, which is

my award.

Arbitrator's Signature

Anna M. Fanelli

Sole Public Arbitrator

11/20/2024

Signature Date

Awards are rendered by independent arbitrators who are chosen by the parties to issue final,

binding decisions. FINRA makes available an arbitration forum—pursuant to rules approved by

the SEC—but has no part in deciding the award.

November 21, 2024

Date of Service (For FINRA Dispute Resolution Services use only)

EXHIBIT B

(Page 1

(Page 2

(Page 3

(Page 4

(Page 5

EXHIBIT C

Client Agreement

PO Box 2760  Omaha, NE 68103-2760

Fax: 866-468-6268

1. INTRODUCTION

This Agreement governs all brokerage accounts that I open with you, all

transactions in my Account, the use of your websites, the Brokerage Services,

the TD Ameritrade Content, and the Third-Party Content; is binding on my

heirs, executors, administrators, successors, and assigns; and will inure to the

benefit of your successors. By opening an Account with you, I acknowledge

that I have received, read, and understand this Agreement and agree to be

bound by its terms. Accounts opened with the TD Ameritrade Institutional

Division are governed by a separate agreement.

“I,” “me,” “my,” or “account owner” means each account owner who signs the

Account Application. “You,” “Your,” or “TD Ameritrade” means TD Ameritrade,

Inc., and, when applicable, TD Ameritrade Clearing, Inc. (“Clearing”),

TD Ameritrade’s clearing broker-dealer.

2. DEFINITIONS

“Account” means each brokerage account I open with you or have an interest in.

“Agreement” means these terms and conditions as well as any supplemental

agreements and disclosures that apply to my Account, as amended from time

to time.

b. Fees and Commissions. I will pay commissions, charges, taxes, and other

fees applicable to my Account. Current commission pricing and other fees are

on the websites. You may change your fees and commissions at any time by

posting changes on the websites or by other means.

You reserve the right to vary commissions among clients in connection with

special offers or combinations of services or in other circumstances. You or

Clearing may pay a portion of the revenues or fees derived from servicing my

Account to third parties that provide services to you or Clearing. If my Account

is an IRA or other retirement plan account, my Account may be charged fees

that the particular plan has authorized to be paid to service providers other

than you or Clearing.

c. Statements and Confirmations. It is my obligation to review trade

confirmations and Account statements promptly upon receipt. These

documents will be considered binding on me unless I notify you of any

objections within five days from the date confirmations are sent and within 10

days after Account statements are sent.

d. Instructions.

“Applicable Rules” means all applicable federal and state laws, rules and

regulations, rules of any self-regulatory organization, and the constitution and

applicable rules, regulations, customs, and usages of the exchange or market

and its clearinghouse.

“Brokerage Services” means your website and related services that you

provide other than TD Ameritrade Content, which I need to place trades in

my Account.

“Business Day” means Monday through Friday, excluding market holidays.

“Services” means, collectively, the websites, the Brokerage Services, the

TD Ameritrade Content, and the Third-Party Content. This Agreement applies

to the Services provided by you regardless of how I access them (for example,

in person, phone, Internet, or by mobile device).

“TD Ameritrade Content” means all information, tools, and services available

on your website, other than Brokerage Services provided by you, and not by

a third party.

“Third-Party Content” means all information, tools, and services available

on your website that are provided by a third party (“Third-Party Provider”),

including financial and investment tools, market data, reports, alerts,

calculators, access to online conferences, telecasts, bulletin boards, tax

preparation, or account management tools.

“websites” means the Internet sites of TD Ameritrade, whose domain name

is registered as http://www.tdameritrade.com, and others, and through which

you offer Services.

3. MY ACCOUNT AND RELATIONSHIP WITH YOU

a. Self-Directed Account. I understand that Accounts opened with you are

self-directed. I am responsible for all purchase and sell orders, decisions

to continue with an investment strategy or to hold an investment, and

instructions placed in my Account. Unless you provide advice to me that is

clearly identified by you as an individualized recommendation for me, any

investment decision that I make or investment strategy that I utilize, including

the decision to hold any and all of the securities or derivatives in the Account,

is based on my own investment decisions or those of my agent and is at my

own risk. All investments involve risk, and unless you provide individualized

recommendations to me, I or my agent are responsible for determining the

suitability of any trade, investment, investment strategy, and risk associated

with my investments. TD Ameritrade Content or Third-Party Content I access

through you does not constitute a recommendation to invest in any security or

derivative, or to utilize any investment strategy.

Page 1 of 9

1. General. You may accept and act on instructions from me, my agent, or

any person authorized on my Account. You may refuse any order, or delay

placing any order, if you determine that an order requires clarification from

me. I will not hold you responsible for any losses caused by the rejection

or delay. You will not receive any order or instruction transmitted by my

agent or me until you have actual knowledge of the order or instruction.

You do not determine the validity of my agent’s status or capacity, the

appropriateness of, or the authority or actions by such person.

2. Wire Transfers. By initiating a wire transfer from my Account with or

without a letter of instruction, I agree that you may use security procedures

for accepting and acting upon wire transfer instructions. I agree that

such security procedures may include one, some, or all of the following,

depending on the type, amount, and frequency of the wire transfer request:

requestor and/or account owner identification and verification; requestor

and/or account owner signature comparison or verification; confirmation

of receiving bank and/or account designation; notice provided via email,

message center, or phone to account owner and/or authorized agent;

account surveillance and/or trending analysis. In some circumstances, you

may place limits on the portability of funds and additional documentation

may be required.

I agree that the above security procedures are commercially reasonable

under the circumstances. I agree to be bound by instructions to initiate

a wire transfer, with or without a letter of instruction, whether in fact

authorized or unauthorized, which you implement in compliance with these

procedures, unless I have given you prior notice of possible unauthorized

activity in my Account and you have a reasonable opportunity to act on

such notice.

3. ACH Transactions. From time to time, originators that I authorize may

send ACH credits or debits to my account. For each ACH transaction, I

agree it is subject to the NACHA Operating Rules and Guidelines or other

funds transfer system rules as applicable, and that the following additional

terms shall apply: (1) TD Ameritrade’s payment of a funds transfer to my

account will be provisional until TD Ameritrade receives final settlement or

payment, and I agree that TD Ameritrade may reverse the provisional credit

and/or obtain reimbursement from me if you do not receive final settlement

or payment; (2) A payment by the beneficiary’s bank of a funds transfer

from my account to the beneficiary will be provisional until final settlement

has been made or until payment is considered received under applicable

law, and I agree that the beneficiary’s bank may reverse its provisional

credit and obtain a refund from the beneficiary and I, as the originator

of the payment, will not be considered to have paid the beneficiary; (3) I

hereby authorize any Originating Depository Financial Institution (ODFI) to

initiate, pursuant to ACH operating rules, ACH debit entries to my account

AMTD 182 F 07/21

for electronic presentation or re-presentment of items written or authorized

by me; and (4) If I receive an unauthorized debit, I will need to file a

written unauthorized debit statement with TD Ameritrade by contacting

TD Ameritrade at 1-800-669-3900

e. No Endorsement of Day Trading Strategy; Representations. You do not

recommend, endorse, or promote a “day trading” strategy, which may involve

significant financial risk to me. If I accumulate a position in a security through

multiple purchase transactions in one day and subsequently liquidate and/or

close out that position on the same day through a single sale transaction, I

represent that it is my intent to execute a single day-trade, unless I notify you

to the contrary.

f. Clearing Agreement. You and Clearing have entered into a clearing

agreement in which Clearing is the clearing agent for securities transactions

for your clients. You transmit client instructions to Clearing which causes such

instructions to be executed. Clearing carries my Account on a fully disclosed

basis. All securities, dividends, and proceeds will be held at Clearing unless

otherwise instructed.

g. Trading in Affiliate Securities. If I transact in securities that are issued

by The Charles Schwab Corporation (“CSC”) or an entity controlled by CSC, I

acknowledge and understand that You are controlled by CSC, and/or You and

the issuer are under the common control of CSC.

h. Account Protection. You are a member of the Securities Investor Protection

Corporation (“SIPC”), which protects securities customers of its members up

to $500,000 (including $250,000 for claims for cash). An explanatory brochure

is available on request at sipc.org. Additionally, you provide each client $149.5

million worth of protection for securities and $2 million of protection for cash

through supplemental coverage provided by London insurers. In the event of

a brokerage insolvency, a client may receive amounts due from the trustee

in bankruptcy and then SIPC. Supplemental coverage is paid out after the

trustee and SIPC payouts and under such coverage each client is limited to a

combined return of $152 million from a trustee, SIPC, and London insurers. The

TD Ameritrade supplemental coverage has an aggregate limit of $500 million

over all customers. This policy provides coverage following brokerage insolvency

and does not protect against loss in market value of the securities.

To obtain information about the SIPC, including the SIPC brochure, I can

contact the SIPC at:

Securities Investor Protection Corporation

805 15th St, N.W., Suite 800

Washington, D.C. 20005-2215

Tel: 202-371-8300

Fax: 202-371-6728

Email: asksipc@sipc.org

Website: sipc.org

i. Beneficiary Designation. Changes in the relationship between the account

owner and designated beneficiary (such as, marriage, divorce, or adoption)

will not automatically add or revoke beneficiary designations. For example, if

an account owner designated a spouse as beneficiary and they subsequently

divorced, the former spouse will remain beneficiary on the Account unless the

account owner submits a new beneficiary designation to you.

j. Compliance with Laws. I agree to comply with all laws, rules, and

regulations applicable to my Account.

4. ABOUT ME

a. Legal Capacity. I am of legal age in the jurisdiction in which I reside and

have the capacity and authority to enter into this Agreement.

b. Accuracy of Information. All the information I provide you is true and

correct. I will promptly notify you in writing within 10 Business Days after any

change in such information. You may rely upon all information I provide you.

c. Interest in Account. I represent that no one except me (us) has an

interest in any of my (our) Account(s) (unless I am opening the Account as

a fiduciary).

d. Multiple Owners. If there is more than one Account owner, then the

provisions of the Agreement apply to each owner. Accounts of husbands and

wives in community property states will be held in the name of husband and

wife as community property unless we instruct you otherwise; any other Joint

Account will be held jointly with rights of survivorship unless I notify you of a

different form of ownership and provide such documentation as you require.

You will have no liability for any loss that may arise due to taking instructions

from one owner or requiring instructions from all owners. If I am married, I

may establish an account with my spouse as tenants by entirety. I will notify

you if I become legally divorced.

e. Rights, Terms, and Obligations of Securities in Account. Except as

required by Applicable Rules, you are not obligated to notify me of any events

involving my securities positions, nor do you have the responsibility to take any

actions on my behalf with respect to such events without specific instructions

from me. I am responsible for knowing the rights, terms, and obligations of

securities in my Account and for monitoring the occurrence of any events

involving my securities positions or securities for which I intend to place an

order.

5. PRIVACY AND CONFIDENTIALITY

a. Privacy. You will take reasonable measures to protect the privacy and

confidentiality of information in your possession about my Account and me.

Your Privacy Statement explains how you collect and protect my information.

The Privacy Statement is incorporated into this Agreement by reference.

b. Account Number, PIN, or Password. I will receive a password and/or

access number (collectively “PINs”) that provides electronic access to my

Account. Account numbers, User IDs, and PINs are confidential, and I am

responsible for the confidentiality, protection, and use of them. Subject to

the TD Ameritrade Asset Protection Guarantee, I agree to be responsible

for all activities in my Account. You may be assured that I have authorized

any orders or instructions that are received under my Account number and

PIN or by initiating an electronic transfer of funds, with or without a letter of

instruction.

c. TD Ameritrade Asset Protection Guarantee. If I lose cash or securities

from my Account due to unauthorized activity, you will reimburse me for the

cash or securities I lose. You promise me this protection if unauthorized

activity causes losses and you determine it was through no fault of my own.

You promise this protection if I do five things: (1) keep my personal identifying

information and Account information secure and confidential because sharing

my password, PIN, secret question answers, or other standard means of

authentication with other people means I authorize them to take action in my

Account; (2) use the standard security features you require for access to my

account as they change over time, including using multi-factor authentication.

(3) keep my contact information up-to-date with you, including my email

address and phone number, so that you can contact me in case of suspected

fraud; (4) review my Account frequently and my statements promptly

and report any suspicious or unauthorized activity to you immediately in

accordance with this Agreement; and (5) take the actions you request if

my account is ever compromised and cooperate with any investigation. I

agree that unauthorized activity does not include any actions or transactions

undertaken by or at the request of me, my investment advisors or family

members, or anyone else whom I have allowed access to my Account or to

my Account information for any purpose, such as trading securities, writing

checks, or making withdrawals or transfers.

d. Phone Conversations and Electronic Communications. You may record

and monitor any telephone, video, or electronic communications with me.

e. Credit Reports. I authorize you to request my credit reports to verify my

creditworthiness and to provide information to credit agencies. Upon request,

you will inform me whether a report was requested and provide me with the

name and address of the credit-reporting agency that furnished the report.

Negative credit information may be submitted to a credit-reporting agency if I

fail to fulfill the terms of my credit obligations.

f. Disclosure of Account Information to Third Parties. Consistent with your

Privacy Statement, you and your agents are specifically authorized to disclose

information about my Accounts and me to third parties.

g. Trusted Contact Authorization. If I elect to provide Trusted Contact

information to you, you are authorized to communicate, verbally and in writing,

with the Trusted Contact Person(s) named on the applicable Trusted Contact

Authorization Form, or by other such means as I may provide Trusted Contact

information to you. I understand that any communication with the Trusted

Contact Person(s) may include information about any of the Account Owners,

the account for which the Trusted Contact information was provided, any

other accounts at TD Ameritrade in which any of the Account Owners has an

Page 2 of 9

AMTD 182 F 07/21

interest, or any other information the Account Owners may have provided to

TD Ameritrade.

I understand that you may contact the Trusted Contact Person(s) for

the following reasons: (1) if there are questions or concerns about my

whereabouts or health status; (2) if you suspect that I may be a victim of

fraud or financial exploitation; (3) if you suspect that I might no longer be able

to handle my financial affairs; (4) to confirm the identity of any legal guardian,

executor, trustee, authorized trader, or holder of a power of attorney; or (5) if

you have any other concerns or are unable to contact me about my Account(s)

held with you. If my Account is an Entity or other Non-natural person Account,

you may also contact any Authorized Agent named on the Account for the

foregoing reasons.

I further agree that: (1) the Trusted Contact Authorization does not impose

any obligation that you communicate with my Trusted Contact Person(s); (2)

the Trusted Contact Authorization does not authorize the Trusted Contact

Person(s) to make any investment decisions or transact any business with

you on my behalf; (3) the Trusted Contact Authorization is optional and I may

change or withdraw it at any time by notifying you in writing; (4) all named

Trusted Contact Person(s) are 18 years of age or older; (5) if there are

multiple Account Owners, you are authorized to follow the instructions of any

one or more Account Owners in adding a Trusted Contact, and you will not

be held liable for information shared with a Trusted Contact, without regard

to which Account Owner(s) authorized the addition of the Trusted Contact;

and (6) you are released and discharged from all claims, causes of action,

damages, losses, expenses, costs, and liabilities of any kind that may arise

out of, relate to, or are in connection with the release of, or failure to release,

personal and/or account information to the Trusted Contact Person(s).

6. CLIENT COMMUNICATIONS

a. Addresses. You may send communications to the mailing address, email,

telephone number, or facsimile number that I provide. You also may deliver

information verbally or via the Secure Message Center on your website.

Communications shall be deemed delivered to me whether or not I actually

receive them.

b. Electronic Signatures. My use of electronic signatures to sign your

documents legally binds me in the same manner as if I had manually signed.

The use of an electronic version of these documents fully satisfies any

requirement that they be provided to me in writing. If I sign electronically,

I represent that I have the ability to access and retain a record of the

documents. I am responsible for understanding these documents and agree

to conduct business with you by electronic means. I am obliged to review

periodically the websites for changes or modifications.

c. Consent. By consenting to the electronic delivery of all information relating

to my Account, I authorize you to deliver all communications to me by the

following means: (1) by email at the email address specified by me; (2) by

posting the communication on the websites or other sites on the Internet

where the communication can be read and printed; (3) by sending me an

email that includes a hyperlink to the websites or an address on the Internet

where the information is posted, and can be read and printed; and (4) by

sending me a notice that directs me to an address on the Internet or a place

within the websites where the communication is posted and from which it

can be read and printed. Such delivery will be an effective delivery to me for

the purpose of any Applicable Rules whether or not I access or review the

communication. Although I consent to electronic delivery, you may elect to

deliver communications by other means which shall not affect my consent. I will

notify you of any change in my address. I may revoke my consent to electronic

delivery of communications and receive documents on paper. You have a

reasonable period to effect such a change and may charge a reasonable fee

for sending paper copies.

d. Equipment. If I agree to electronic delivery, I must have a computer with

Internet access, an email address, and the ability to download and save or

print communications to retain for my records. I am responsible for obtaining

and maintaining all equipment and services required for online access of my

Account.

7. ELECTRONIC SERVICES

a. Availability. You do not guarantee that any media will be available to me at

a particular time. Access to the websites may be limited or unavailable during

periods of peak demand, market volatility, system upgrades, or other reasons.

You reserve the right to suspend and deny access to the Services, without

prior notice or for any reason. I recognize that Account activity may be

conducted through several different media (for example, Interactive Voice

Response phone system [IVR] and phone); and if a certain medium is not

available, I will use another medium to conduct Account activity. You will not

be liable for the unavailability, delay, or failure of any of the media at any

particular time or for the accessibility of, transmission quality, outages to, or

malfunction of any telephone circuits, computer system, or software.

b. Use of Services. I will use the Services for lawful purposes, for my

personal and noncommercial use, and as permitted by this Agreement. I

will not transmit through the websites any material that violates or infringes

in any way upon the rights of others or would encourage conduct that may

give rise to civil or criminal liability. I will not modify, copy, publish, transmit,

license, participate in the transfer or sale of, reproduce, create derivative

works from, distribute, redistribute, display, or in any way exploit the Services.

I will not upload, post, decompile, reverse engineer, disassemble, modify, copy,

distribute, transmit, reproduce, republish, license, display, sell or transfer, or

create derivative products from the Services. Software accessed on the

websites is subject to U.S. export controls and may not be downloaded by any

person prohibited from doing so by Applicable Rules.

I may download software on a single computer for personal, noncommercial

use, provided I keep intact all copyright and other proprietary notices. You

and Third-Party Providers reserve the right to revise, modify, change, upgrade,

suspend, impose limitations or restrictions on, deny access to, remove,

or discontinue the Services at any time without prior notice. Third-Party

Providers may enforce this Agreement against me and take action against me

for my breach of this Agreement. I further acknowledge that I am subject to

any agreements for the receipt and use of real time market data as distributed

by the Securities Information Processors, such as those agreements

governing subscriber use published at CTAplan.com.

c. Limitation of Liability. The Services are provided “as is” and “as available.”

You, your affiliates, the Third-Party Providers and their respective licensors,

employees, distributors, or agents make no representations with respect

to the system and expressly disclaim all warranties. Subject to Applicable

Rules, in no event will you, your affiliates, the Third-Party Providers or their

respective licensors, employees, distributors, or agents be liable to me or any

third party for any direct, indirect, incidental, special, punitive, or consequential

losses or damages of any kind with respect to the Services.

I am solely responsible for my investment research, and neither you nor

any Third-Party Provider make any representations, warranties, or other

guarantees as to the accuracy or timeliness of any market data; nor do you

or any Third-Party Provider make any representations, warranties, or other

guarantees as to the present or future value or suitability of any sale, trade,

or other transaction involving any particular security or any other investment.

d. Intellectual Property. My use of the Services will not confer any title,

ownership interest, or intellectual property rights to me. The Services

are protected under U.S. patent, copyright laws, international treaties or

conventions and other laws, and will remain the exclusive property of you or

Third-Party Providers. Company names, logos, and all related product and

service names, design marks, and slogans of you or your affiliates or any

Third-Party Provider are the property of the respective company. I am not

authorized to use any such name or mark in any advertising, for publicity, or in

any other commercial manner.

e. Cookies. You use cookies on websites and my browser will need to accept

all cookies for it to perform fully. Certain features of the websites may also

require the acceptance of cookies.

f. Hyperlinks. The websites may include hyperlinks to websites, owned or

operated by affiliated or unaffiliated third parties. Neither you nor Third-Party

Providers are responsible for the content or availability of such other websites,

and shall not be responsible or liable for any loss in connection with reliance

on such sites.

8. BROKERAGE SERVICES

a. Order Routing and Executions. Unless I specify the market for execution,

you decide where to route my orders for execution. You consider a wide

variety of factors in determining where to direct my orders, such as execution

price, opportunities for price improvement (which is when an order is executed

at a price that is more favorable than the displayed national best bid or offer),

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AMTD 182 F 07/21

market depth, order size and trading characteristics of the security, efficient

and reliable order handling systems and market center service levels, speed,

efficiency, accuracy of executions, and the cost of executing orders at a

market. If I instruct you to route my order to a particular market for execution

(“Direct Routing”), and you accept my order and instruction, you are not

required to make a best execution determination beyond executing the order

promptly and in accordance with the terms of my order. Instructions to direct

my order to certain market centers could incur additional fees.

b. Deposit and Order Refusal; Account Restrictions. You reserve the right

not to accept the deposit of funds or particular securities into my Account

and may refuse any of my orders. You also reserve the right to place trading,

disbursement, and other restrictions on my Account. You may restrict my

Account from withdrawals or trading if there is a reasonable suspicion of

fraud, diminished capacity, inappropriate activity, or if you receive reasonable

notice that the ownership of some or all of the assets in my Account is in

dispute. I will not hold you liable for any loss I may incur due to your refusal to

permit any deposit, withdrawal, or transaction.

c. Trade Execution and Price. You route orders to markets for prompt

execution in view of prevailing market conditions, but there can be delays in

the processing of orders. I understand and agree with the following:

• The quoted price may not reflect the trading activity from all markets.

• High volumes of trading at the market open or intraday may cause delays

in executions and result in prices significantly different from the price

quoted at the time the order was entered.

• Markets may handle orders manually and may reduce size guarantees during

periods of volatility, resulting in possible delays in order execution, and losses.

• The execution price I receive may be impacted by numerous factors

beyond your control and responsibility, including the type of security,

liquidity, and the size of my order. For example, large or “block” orders or

orders involving illiquid securities may take additional time to execute and

may execute at prices significantly different from the quoted price.

• The execution of market and stop-market orders may be at a price

significantly different from the quoted price of that security. Limit orders will

be executed only at a specified price or better, but there is the possibility

that the order will not be executed.

• Securities traded in over-the-counter bulletin board and pink sheet

securities and other thinly traded securities present particular trading risks

in that they are often more volatile and generally less liquid than securities

traded on exchanges. You reserve the right to place restrictions on the

trading of such securities without prior notice.

• I may suffer market losses during periods of volatility in the price and

volume of a particular stock when systems issues result in an inability to

place buy or sell orders.

d. Payment for Order Flow. You may receive remuneration from markets

for directing orders to them. The source and amount of these payments are

available upon written request. Markets may act as principals to buy, sell

or hold securities for their own accounts, and they may make money when

executing your trade.

Rule 607 of Regulation NMS requires broker-dealers to disclose, upon

opening a new customer account and on an annual basis thereafter: (i) its

policies regarding receipt of payment for order flow, including a statement as

to whether any payment for order flow is received for routing customer orders

and a detailed description of the nature of the compensation received; and

(ii) its policies for determining where to route customer orders that are the

subject of payment for order flow absent specific instructions.

The firm receives compensation for directing listed and OTC securities,

and options order flow to selected market centers (e.g., broker dealers,

exchanges and alternative trading systems) for execution. Compensation

generally is in the form of a per share or per contract cash payment. The

potential for receipt of order flow payment is not a factor in the routing

determination. TD Ameritrade also may receive compensation related to the

foreign currency exchange component of transactions in foreign securities

from market centers executing such trades. In accordance with SEC Rule

606, TD Ameritrade posts quarterly reports that detail the material market

centers to which TD Ameritrade routes orders in NMS Securities and

TD Ameritrade’s material relationships with those market centers. This report

is made available at www.tdameritrade.com/historical-606-disclosure.page

or in written form upon request. As required under SEC Rule 606(b)(1), on

request, TD Ameritrade will provide the identity of the market center to which

your orders were routed for execution in the six months prior to the request,

whether the orders were directed orders or non-directed orders, and the time

of the executions, if any, that resulted from such orders. This applies to both

held and not held order flow.

TD Ameritrade regularly assesses the execution quality provided by the

market centers to which we route order flow in seeking best execution for

our clients. For non-directed client orders, it is our policy to route orders to

market centers based on a number of factors that are more fully discussed in

the Supplemental Materials of FINRA Rule 5310, including where applicable,

but not necessarily limited to, speed of execution, price improvement

opportunities, differences in price disimprovement, likelihood of executions,

the marketability of the order, size guarantees, service levels and support,

the reliability of order handling systems, customer needs and expectations,

transaction costs and whether the firm will receive remuneration for routing

order flow to such market centers. Price improvement occurs when an order

is executed at a price that is more favorable than the displayed national best

bid or offer.

e. Payment for Transactions. All orders that I authorize will be processed

with the understanding that I will pay for any purchase and deliver certificates

to cover all sales on or before the settlement date. All sell orders that I place

will be for securities that I own (“long”) and in deliverable form at the time I

place the order, unless I inform you otherwise.

You reserve the right to require full payment, or an acceptable equity deposit,

prior to the acceptance of any order. I will have the required cash, available

funds, or equity in my Account prior to the execution and/or settlement of a

purchase or short sale transaction, and the required securities in my Account

prior to the execution and/or settlement of a long sale. If I do not have

sufficient funds or securities in my Account, you have the right to liquidate or

buy in securities at my expense, and I will be responsible for any cost or loss.

f. Payment of Indebtedness Upon Demand. If I incur and indebtedness in

an account held with one of your affiliates, such as TD Ameritrade Futures

& Forex LLC, I understand and acknowledge that you and your affiliates may

decide to transfer my indebtedness to my Account. Subject to Applicable Law,

I will be liable for the payment upon your demand of any obligations owing

in my Account, including the reasonable costs incurred in collecting such

amounts.

g. Security for Indebtedness. I consent to you having a continuing security

interest in, right of set-off to and lien on all securities, cash, investment

property, and other property in my Account (“Collateral”). Subject to

Applicable Rules, and without prior notice to me, you may sell or transfer the

Collateral to satisfy my obligations. You also have the discretion to determine

which securities and other properties are to be sold and which contracts are

to be closed. You have all the rights of a secured party under the Uniform

Commercial Code.

h. Short Sales. I will designate any sell order as a “short” sale if at the time

I place the order I do not own the security I intend to sell or am unable to

deliver the security before settlement. All short sales will be executed in a

Margin Account.

i. Mutual Funds and ETFs. I authorize you to custody mutual fund holdings

that I purchase directly through you. When purchasing a mutual fund, I

acknowledge that I have received and read the fund prospectus. Mutual

fund purchases may be subject to investment minimums, eligibility and other

restrictions, as well as charges and expenses. Certain money market funds

may impose liquidity fees and redemption gates in certain circumstances.

Some mutual funds sold through you impose a charge on the purchase of

shares, called a “sales load.” I may be able to purchase mutual fund shares

through you without paying a front-end sales load, but I may be charged a fee,

called a “contingent deferred sales charge,” when I sell or redeem my shares.

You may receive part or the entire sales load.

As discussed in the prospectus, some mutual funds agree to waive or reduce

front-end sales loads for purchases over certain amounts. I am responsible

for determining and obtaining any waivers, breakpoints, or providing you with

sufficient information to assist me in obtaining such.

Page 4 of 9

AMTD 182 F 07/21

You may receive remuneration from fund companies, including, those

participating in your no-load, no-transaction-fee program, for record-keeping,

shareholder services, and other administrative and distribution services.

The amount of your remuneration for these services is based in part on the

amount of investments in such funds by your clients. Some mutual funds

impose a distribution or service fee known as a “12b-1 fee.” You may receive

the 12b-1 fees in connection with my investment in such fund’s shares. If

I invest online in no-transaction-fee mutual funds (“NTF funds”) directly

through you, I will not pay a transaction fee. I also may be able to purchase

mutual funds directly from the fund’s distributor or underwriter without

incurring a transaction fee. You receive remuneration from fund companies

participating in the NTF fund program. NTF funds have other fees and

expenses that apply to continued investment in the fund that are described

in the prospectus. TD Ameritrade receives remuneration from certain ETFs

(exchange-traded funds) that participate in commission-free ETF program for

shareholder, administrative, and other services.

j. Cash Features Program. The Cash Features Program is a service

you provide that permits uninvested funds, or “free credit balances,” in my

Account to earn income until I decide how to invest the funds in a longerterm investment. My uninvested funds may earn interest through available

alternatives, which are referred to as “Features.” The Feature I select, or

where applicable the Feature assigned to my Account, is referred to as

the “Designated Feature.” I understand that I may not be eligible for some

Features.

The Features available in the Cash Features Program include “sweep”

vehicles (“Sweep Vehicles”) into which my funds are automatically deposited

or invested (i.e., swept). Currently, the Sweep Vehicles available are the

TD Ameritrade FDIC Insured Deposit Account (“IDA”) Feature and the money

market fund Feature. Certain eligibility requirements currently apply to each

of the IDA Feature and the money market fund Feature.

My Account may not be eligible for the IDA Feature. I must maintain assets

in my Account with a minimum market value of $50,000 (“Minimum Account

Value”) to be eligible for the IDA Feature. The Minimum Account Value

requirement will be applied separately to each of my Accounts. If my

Designated Feature is the IDA Feature, you may at any time determine that

the value of assets in my Account is below the Minimum Account Value

and you may provide me with written notice that my Designated Feature will

be changed to the TD Ameritrade Cash Feature. I will be provided with an

opportunity to meet the Minimum Account Value by a date specified in the

written notice to retain the IDA Feature for my Account. If I no longer qualify

for the IDA Feature, my funds will be withdrawn from the Program Banks

(as defined below) in the IDA Feature and will be held in my Account in the

TD Ameritrade Cash Feature. I understand and acknowledge that there may

be benefits to TD Ameritrade, the Program Banks, or both, from withdrawing

my funds from the IDA Feature and holding them through the TD Ameritrade

Cash Feature.

At any time, you may impose new eligibility criteria, change existing

eligibility criteria, or replace the Sweep Vehicles available to me. You may,

in your discretion, grant exceptions to your eligibility criteria to one or more

customers without granting such exceptions to me. You may also change

the terms and conditions of any Sweep Vehicle at any time. You will give

me advance notice of any such change in the Sweep Vehicles. I understand

that if I am no longer eligible for my then-current Sweep Vehicle, upon prior

notice, you may withdraw or redeem my funds or shares from that Sweep

Vehicle and invest or deposit the proceeds in the replacement Designated

Feature described in the notice. My Account will be subject to the terms and

conditions of my new Designated Feature.

Through the Cash Features Program, you also provide the TD Ameritrade

Cash Feature, in which uninvested funds in my Account will remain in

my Account and earn interest paid by TD Ameritrade. My funds in the

TD Ameritrade Cash Feature are covered by the SIPC within applicable limits,

as further described in the Client Agreement.

The TD Ameritrade Cash Feature is the only Feature available to customers

who reside outside the United States of America and its Territories. If my

Designated Feature is the IDA Feature and I either reside or move outside the

United States of America and its Territories, I understand that TD Ameritrade

will, upon 30-days written notice, change my Designated Feature to

TD Ameritrade Cash and my funds in the Deposit Accounts at the Program

Banks in the IDA Feature will be withdrawn and placed in my Account in the

TD Ameritrade Cash Feature.

If I am eligible for more than one Feature, I may instruct you to change my

Designated Feature at any time to another of the Features for which I am

eligible, and acknowledge that upon such instruction you may withdraw or

redeem my funds or shares from my Designated Feature, as applicable, and

transfer such balances to the new Designated Feature.

Proceeds from the sale of securities in my Account will be placed in my

Designated Feature following settlement. The proceeds of any checks that

I deposit to my Account will be placed in my Designated Feature on the

Business Day after receipt by you and will begin earning dividends or interest

on that day. Access may be withheld for up to four Business Days to assure

that such checks have not been returned unpaid.

I acknowledge that you will automatically withdraw or redeem my funds or

shares maintained in a Designated Feature to satisfy my obligations in my

Account. I authorize you to select and use agents as you deem appropriate.

Fees relating to each Feature will vary depending on the Feature. No portion

of these fees will reduce or offset the fees otherwise due to you unless

required by Applicable Rules.

If my Designated Feature is a Sweep Vehicle, and my Account is flagged

as a “Pattern Day Trader,” you may change my Designated Feature to

TD Ameritrade Cash.

Each of the three Features is described below.

1.TD Ameritrade FDIC Insured Deposit Account. Through the IDA Feature,

the available cash in my Account will be automatically deposited into an

interest-bearing money market deposit account (“Deposit Account”) at one

or more banks (“Program Banks”), whose deposits are insured by the FDIC.

Certain of the Program Banks include Charles Schwab Bank, SSB; Charles

Schwab Premier Bank, SSB; and Charles Schwab Trust Bank, each of which

is an affiliate of you. You will maintain a list of the current Program Banks at

the following link on your website: tdameritrade.com/idaprogrambanks.

The Deposit Accounts at the Program Banks are held in the name of Clearing

as agent for its customers. My funds at each Program Bank will be eligible

for FDIC insurance in an amount equal to $250,000 for principal and accrued

interest per depositor in each recognized legal capacity. The IDA has been

structured to provide me with access to at least two Program Banks, which

may be affiliated or unaffiliated with you, resulting in up to $500,000 in FDIC

insurance per depositor in each recognized legal capacity. Subject to deposit

limits pursuant to agreements with the Program Banks, to the extent that my

cash is being deposited into more than two Program Banks, it is possible for

me to obtain total FDIC insurance in excess of $500,000 per depositor in

each recognized legal capacity.

In addition, you will determine the order of the Program Banks in the IDA for

the purposes of accepting deposits based on several factors including, but

not limited to, minimum and maximum deposit balances agreed to with a

particular Program Bank and the contractual arrangement between you and

a particular Program Bank. My deposits swept to Deposit Accounts through

the IDA Feature, aggregated with any other of my deposits held at each

Program Bank in the same legal capacity, are eligible for FDIC insurance

coverage.

Questions about FDIC insurance coverage may be directed to you.

Information also may be obtained by contacting the FDIC, by letter (550 17th

Street NW, Washington, D.C. 20429), by phone (877-275-3342, 800-9254618 ([TTY]), by email using the FDIC’s online Customer Assistance Form, or

by accessing the FDIC website at fdic.gov. Learn more about FDIC coverage

by using the FDIC’s Electronic Deposit Insurance Estimator at edie.fdic.gov/.

My uninvested funds in each of my Accounts will be deposited into a Deposit

Account at one or more Program Banks in an amount up to $247,500 in a

Deposit Account at any Program Bank, except for “the Excess Bank” which

will receive deposits without limit, even if the amount in the Deposit Account

at the Excess Bank exceeds the FDIC insurance available to me. The

complete list of Program Banks including “the Excess Bank” is included on

your website at tdameritrade.com/idaprogrambanks. I may contact you to

determine the list of Program Banks assigned to my Account.

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AMTD 182 F 07/21

Any deposits (including certificates of deposit) that I maintain in the same

insurable capacity directly with a Program Bank, or through an intermediary

(such as you or another broker), will be aggregated with deposits in my IDA

at such Program Bank for purposes of determining my maximum FDIC

insurance amount. I am responsible for monitoring the total amount of

deposits that I maintain at the Program Banks to determine the extent of FDIC

coverage available to me. I acknowledge that Deposit Accounts constitute

obligations of the Program Banks and are not your obligations.

I can obtain publicly available financial information concerning each Program

Bank at www.fdic.gov/news/publications/pichardcopies.html or by contacting

the FDIC Public Information center by mail at L. William Seidman Center,

Virginia Square, 3501 North Fairfax Drive, Arlington, VA 22226 or by phone at

703-562-2200. You do not guarantee in any way the financial condition of the

Program Banks or the accuracy of any publicly available financial information

concerning the Program Banks. You will not be responsible for any insured

or uninsured portion of the IDAs. Funds in my Account will be automatically

swept daily to Deposit Accounts at the Program Banks. As required by federal

regulations, the Program Banks have the right to require seven days’ prior

notice before permitting a withdrawal out of a savings account. Currently,

the Program Banks do not intend to exercise this right. In addition, savings

accounts you hold as agent for me at a Program Bank may have transfer limits

that prevent using such accounts as a transaction account. The following

applies to the Deposit Accounts:

• When funds in my Account are first available for deposit into the Deposit

Account at a Program Bank, you, as my agent, will open the Deposit

Account on my behalf at the Program Bank and you will deposit the

available funds from my Account into the Deposit Account at the Program

Bank. Once the deposit limit at the first Program Bank is reached, funds

will be deposited in the next Program Bank up to the deposit limit. Once my

deposits reach the deposit limit at each Program Bank available to me, all

remaining uninvested funds will be deposited in the Excess Bank, without

limit and without regard to the FDIC insurance limit. You will periodically

rebalance my Deposit Accounts so the total amount of my funds in the

Deposit Accounts at Program Banks remains below applicable FDIC

insurance limits (except for the Excess Bank, which has no limit).

• All withdrawals necessary to satisfy debits in my Account will be made by

Clearing, as my agent. A debit will be created when I purchase securities or

request a withdrawal of funds from my Account.

• My Account statement will display the name of each Program Bank with

which I have deposits, the balance of deposits at each Program Bank,

any deposits and withdrawals made during the month, and the applicable

interest rate and amount of interest earned on my deposits. You, not

the Program Banks, are responsible for the accuracy of my Account

statements, including transactions in the Deposit Accounts maintained

through the IDA Feature. I may contact you at 1-800-669-3900 for

information about my balances or if I have questions about my Account

statement.

• The deposit limit at the Program Banks is set slightly below FDIC-insurance

thresholds to allow for accrued interest on deposits. The deposit limit

at the Program Banks is set at $247,500 ($495,000 for Joint Accounts),

which may be reset from time to time based on FDIC-insurance limits and

the interest rate environment. If interest paid on my funds in the Deposit

Account at one of the Program Banks results in my total funds in the

Deposit Account exceeding the deposit limit at that Program Bank, the

Deposit Accounts will be rebalanced the next day and the amounts in

excess of the deposit limit will be transferred to another Program Bank.

• I may not change the Program Banks, the order in which funds are

deposited into the Program Banks, or the maximum deposit amount at any

Program Bank. I may withdraw from the IDA Feature at any time and use

another Feature.

• I will earn interest on my deposits in the Deposit Accounts in accordance

with the rates or tiered rates available to me as determined by you. I

understand that rates may vary based on the offering or the level of my

assets held with you. Interest rates earned in the Deposit Accounts will vary

over time but will be paid consistent with the rate or tiered rate you make

available to me regardless of which Program Bank holds my cash. The

interest rates paid with respect to the IDA Feature may be higher or lower

than the interest rates available to depositors making deposits directly with

the Program Banks or other depository institutions in comparable accounts.

The current interest rate will be available on https://www.tdameritrade.

com/pricing/margin-and-interest-rates.html, or I may contact you to obtain

the current rate. Interest will accrue on balances from the day they are

deposited into the Deposit Account through the Business Day preceding the

date of withdrawal from the Deposit Account. Interest will be accrued daily

and credited on the last Business Day of each month. You use the daily

balance method to calculate interest on my Account.

• My Relationship with you and the Program Banks

- Clearing will act as my agent in depositing funds into the Deposit

Accounts and withdrawing funds from the Deposit Accounts. No evidence

of the Deposit Accounts, such as a passbook or certificate, will be issued

to me. Ownership of the Deposit Accounts at the Program Banks will be

evidenced by a book entry on the records of the Program Banks, and

by records maintained by Clearing. I will contact you if I believe there

has been any unauthorized activity between my Account and Deposit

Accounts at the Program Banks, or if I have any complaints regarding the

Deposit Accounts at the Program Banks.

- You may terminate my use of the IDA Feature. If you terminate my

use of the IDA Feature, or do not wish to continue to act as my agent

with respect to a Deposit Account, I may deal directly with the Program

Banks, subject to their rules, with respect to establishing and maintaining

Deposit Accounts. In the event you terminate my use of the IDA Feature,

you will inform me of the replacement Feature or Features available to

me. Similarly, if I decide to terminate my use of the IDA Feature, or that

I no longer wish to have Clearing act as my agent with respect to the

Deposit Accounts, I may establish a direct depository relationship with

the Program Banks, subject to the Program Banks’ rules. Establishing

a direct depository relationship with the Program Banks will result in the

separation of my balances in my Deposit Accounts at the Program Banks

from my Account.

- Unless I establish the Deposit Accounts directly with a Program Bank as

described above, any instructions regarding the movement of my funds

in the IDA Feature must be provided by you to the Program Banks, and

information concerning the Features may only be obtained from you. The

Program Banks will not accept instructions directly from me with respect

to my Deposit Accounts held through the IDA Feature, nor provide me

directly with information concerning this Feature.

• I understand and acknowledge that the Program Banks benefit from having

my funds placed through the IDA Feature because they use IDA balances

to fund current and new investment and lending activity. The Program

Banks seek to make a profit by achieving a positive spread between their

cost of funds and the return on their assets, net of expenses. You receive

a volume- based fee from the Program Banks that are not affiliated with

TD Ameritrade that ranges from 0.70 to 1.00%. In the case of Program

Banks that are affiliates, you will receive a fee of up to $100 per account.

You have the right to waive all or part of this fee. The rate of the fee that you

receive may exceed the interest rate or effective yield that I receive in my

balances in the Deposit Accounts. Other than the applicable fees charged

on brokerage accounts, there will be no charges, fees, or commissions

imposed on my Account for this Feature. The current IDA interest rate will

be disclosed on your website and may be changed without prior notice.

• My deposit into Deposit Accounts at the Program Banks may need to be

limited if one or more Program Banks stop accepting deposits. You will

provide advance notification via your website, or other reasonable means,

if any Program Bank is removed from the IDA Feature, and if advance

notice is not practicable, you will notify me as soon as is reasonably

practicable. If a Program Bank ceases to make its Deposit Accounts

available through the IDA Feature, I will be given an opportunity to establish

a direct relationship with that Program Bank outside of the IDA Feature, or

else my funds will be transferred to another Program Bank participating in

the IDA Feature, if available.

• In the event that FDIC insurance payments become necessary, the FDIC

is required to pay principal plus unpaid and accrued interest to the date

of the closing of the relevant Program Bank, as prescribed by applicable

laws and regulations. Because there is no specific time period during which

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AMTD 182 F 07/21

the FDIC must make available such insurable payments, there may be

a delay in obtaining insurable payments. In addition, I may be required

to provide documentation to the FDIC and you, before any insurance

payouts are released to me. If the Deposit Account balances are held by

me as trustee for the benefit of trust participants, I may be required to

furnish an affidavit to that effect.

• You may change the IDA Feature terms and conditions by providing me

advance notice.

2. TD Ameritrade Cash. If TD Ameritrade Cash is my Designated Feature,

you will pay interest on available cash in my Account, the rate of which may

be changed without prior notice. Interest will be accrued daily and credited

on the last Business Day of each month. You may vary interest rates among

clients in connection with special offers or combinations of services or in

other circumstances. TD Ameritrade Cash represents balances pending

investment and is not maintained solely for receiving credit interest. You

segregate customer cash consistent with the Securities and Exchange

Commission rules and regulations. I understand and acknowledge that you

may earn income from holding my funds in the TD Ameritrade Cash Feature.

Interest rates are set at our discretion and can change daily. Interest

accrues daily and is credited to my Account on or before the last Business

Day of each month. To participate in the TD Ameritrade Cash Feature, I

must maintain the uninvested funds in my Account for the purpose of

investing in securities. The TD Ameritrade Cash Feature is not a bank

account or other bank obligation, is not guaranteed by any bank, and is not

insured by the FDIC.

3. Money Market Funds. Investments in money market funds are subject

to eligibility and other restrictions, as well as charges, and expenses, all as

further described in the prospectus. Money market funds are securities that

may increase or decrease in value. They are not insured or guaranteed

by the FDIC, any other government agency, or you, and there can be

no assurance that such funds will be able to maintain a stable net asset

value of $1 per share. I understand that I will receive period statements

for sweep transactions involving money market funds in lieu of immediate

confirmations.

I understand and acknowledge that you may receive fees for providing

marketing and shareholder services to money market funds. In addition,

Clearing may act as transfer agent for certain funds and may receive

payment for such services provided to such funds. I understand and

acknowledge that the fees you and Clearing receive are disclosed in the

prospectus for the fund.

k. Callable Securities. I consent to your lottery system for allocation of

partial redemption or calls. A description of your procedures for callable

securities is available on your website, or hard copies are available upon

request.

9. MARGIN TRADING

a. Margin Account. When I purchase securities on margin, I am

borrowing money from you and pledging all securities and other property

in my Account as collateral for these loans. I agree to evaluate my own

financial situation, resources, investment objectives, and other relevant

circumstances to determine whether margin transactions are appropriate

for me. You will not make this determination. Even if I determine that margin

is appropriate for me, you determine whether to make such loans to me. I

also understand that trading securities on margin involves a variety of risks,

including the following:

1. I can lose more funds than I deposit in the margin Account. A

decline in the value of securities that I purchase on margin may require

me to provide additional funds to you to avoid the forced sale of those

securities or other securities or assets in my Account. I could lose more

than the amount I deposit in my Account.

2. You can force the sale of securities or other assets in my

Account. If the equity in my Account falls below the maintenance

margin requirement, or any higher “house” requirements, you can sell

the securities or other assets in any of my Accounts to cover the margin

deficiency. I also will be responsible for any shortfall in the Account after

such a sale.

Page 7 of 9

3. You can sell my securities or other assets without contacting

me. Some investors mistakenly believe that a firm must contact them

for a margin call to be valid, and that the firm cannot liquidate securities

or other assets in their accounts to meet the call unless the firm has

contacted them first. This is not the case. Although you may attempt to

notify me of margin calls, you are not required to do so, and even if you

have contacted me and provided a specific date by which I can meet a

margin call, you can still take necessary steps to protect your financial

interests, including immediately selling securities without notice to me.

4. I am not entitled to choose which securities or other assets in

my Account are liquidated or sold to meet a margin call. Because

the securities are collateral for my margin loan, you have the right to

decide which securities to sell in order to protect your interests.

5. You can increase your “house” maintenance margin

requirements at any time, and you are not required to provide

me advance written notice of the change. These changes to your

policy often take effect immediately and may result in the issuance of a

maintenance margin call. My failure to satisfy the call may cause you to

liquidate or sell securities in my Account.

6. I am not entitled to an extension of time on a margin call. While

an extension of time to meet margin requirements may be available to

clients under certain conditions, I do not have a right to any extension.

You will determine whether to provide an extension.

b. Initial Margin and Margin Maintenance Requirements. There are

rules and regulations covering margin loans, including the initial and margin

maintenance requirements for margin Accounts. You may impose more

stringent margin requirements, which may change without notice to me.

To trade on margin, my Account must maintain at least $2,000 in minimum

equity. I will meet the margin requirement in my margin Account before

entering any order and will satisfy any additional requirements you may

require. You may apply all premiums received from options writing against

my margin requirements. I have the obligation to monitor the balances in my

margin Account to ensure that I maintain sufficient amounts to meet margin

requirements at all times. I agree to read carefully the TD Ameritrade Margin

Handbook before purchasing securities on margin.

You may decline to extend credit to me for any reason, subject to Applicable

Rules. There may be times when you have extended credit on certain

securities, but due to market or other conditions, you may require additional

cash or securities.

c. Margin Interest. I will pay interest on any credit provided to me for the

purpose of purchasing, carrying, or trading in any security.

d. Margin Interest Rates. You utilize a base rate (“Base Rate”) to set

margin interest rates. My margin interest rate will vary based on the Base

Rate and the margin balance (“Balance”) in my margin Account during the

interest period. The Base Rate may be changed without prior notice to me.

You will post on the websites any changes to the Base Rate.

e. Interest Calculation. For each day there is a debit balance in my Account,

the interest charged for that day is calculated by multiplying the applicable

interest rate by my debit balance, with the result divided by 360. The sum of

the daily interest charges is totaled at the end of each Account statement

period and is posted to my Account on the last Business Day of the Account

statement period. I will not earn interest on credit balances in my short

Account.

f. Short Sales. Sales designated as “short” are done in my margin

Account, and are subject to different margin maintenance requirements

than securities purchased on margin. Short sales are subject to certain

regulatory rules and cannot be executed under certain market conditions.

You may not always have the securities available to facilitate my short

sale. You may, without notice, “buy-in” securities to cover any short security

position in my Account. I will reimburse you for any losses that you may incur.

You may require me to deposit Collateral if the Collateral in my Account

becomes insufficient. Short sale proceeds are part of the Collateral that

secures your loan to me. I am also liable for all dividends paid, and all other

distributions of cash or property, on securities that I have sold short.

AMTD 182 F 07/21

g. Pledge of Securities and Other Property. You may pledge, repledge,

hypothecate, or re-hypothecate, without notice to me, all securities and

other property that you hold, carry, or maintain or for any of my margin

or short Accounts. You may do so without retaining in your possession or

under your control for delivery the same amount of similar securities or other

property. The value of the securities and other property that you may pledge,

repledge, hypothecate, or re-hypothecate may be greater than the amount

I owe you, and any losses, gains, or compensation that result from these

activities will not accrue to my Account.

h. Loan of Securities/Dividend “Payments in Lieu”. You are authorized

to lend to yourself or others any securities you hold in my Account and to

carry all securities lent as general loans. In connection with such loans,

you may receive compensation and retain certain benefits that I will not be

entitled to, such as interest on Collateral posted for such loans. In certain

circumstances, such loans may limit my ability to exercise voting rights

with respect to the securities lent. I may request that fully paid securities

not be used in connection with short sales. I understand that in certain

situations including when you have borrowed my securities or when trades

or securities loans are in the process of settling, I may receive a “payment in

lieu” of the dividend issued (see Margin Handbook for more details).

10. OPTIONS TRADING

If I elect to engage in options transactions, I will be bound by the following

additional terms:

a. Suitability. Options are not suitable for all investors. Options trading has

inherent risks and I am prepared financially to undertake such risks and to

withstand the losses that may be incurred. I acknowledge I have received or

have been given access to the “Characteristics and Risks of Standardized

Options” by the Options Clearing Corporation (OCC).

b. General Terms.

• I am responsible for knowing the rights and terms of all options in my

Account. I agree to be bound by the FINRA, OCC, and exchange rules

applicable to the trading of options contracts.

• If my options trading occurs in a margin Account, it is subject to the terms

and conditions applicable to margin trading.

• Settlement on options cleared through the OCC is the Business Day after

the trade date. I shall not exceed the position and exercise limits imposed

by the rules of the OCC.

• I am responsible for instructing you as to my intention to exercise

options contracts before the expiration date. Absent proper and timely

exercise instructions from me, you have no obligation to exercise any

right, privilege or obligation of any option for my Account. I agree that

my failure to provide you with proper and timely instructions may result in

the option expiring worthless, even though it may have a monetary value

on the expiration date. I agree to read carefully the Margin Handbook for

additional terms and important information regarding options exercise.

• You collect information only to establish option trading permission and

not for the purpose of monitoring Account holdings or option positions.

• You and Clearing are authorized to take steps to protect their position and

any obligation they have assumed at my request without notifying me.

• If I write (short) a call options contract that requires the delivery of

securities to be sold, I may be required to keep the securities in my

Account until the expiration of the options period and may not be allowed

to sell or withdraw the securities.

• If I write (short) a put options contract that requires payment for securities

to be purchased, I may be required to keep sufficient funds in my Account

to make the payment until the expiration of the options period, and may

not be allowed to withdraw the funds or use them for any other purpose.

If I am assigned on the options, Clearing may use the funds for the

purchase of the securities without prior notice to me.

• All short equity and some index options positions are available for

assignment. Exercise assignment notices for equity or index options are

randomly allocated among all clients’ short positions.

11. INITIAL PUBLIC AND FOLLOW-UP OFFERINGS

You may participate as underwriter or a member of the selling group of, and

provide access to, Initial Public Offerings (IPOs) and follow-up offerings. If I

participate in such, I will be bound by additional terms.

12. ARBITRATION

This Agreement contains a predispute arbitration clause. By signing

an arbitration clause, the parties agree as follows:

• All parties to this Agreement are giving up their right to sue each

other in court, including the right to jury trial, except as provided by

the rules of the arbitration forum in which a claim is filed.

• Arbitration awards are generally final and binding; a party’s ability

to have a court reverse or modify an arbitration award is very

limited.

• The ability of the parties to obtain documents, witness statements,

and other discovery is generally more limited in arbitration than in

court proceedings.

• The arbitrators do not have to explain the reason(s) for their award

unless, in an eligible case, a joint request for an explained decision

has been submitted by all parties to the panel at least 20 days prior

to the first scheduled hearing date.

• The panel of arbitrators may include a minority of arbitrators who

were or are affiliated with the securities industry.

• The rules of some arbitration forums may impose time limits

for bringing a claim in arbitration. In some cases, a claim that is

ineligible for arbitration may be brought in court.

• The rules of the arbitration forum in which the claim is filed, and any

amendments thereto, shall be incorporated into this Agreement.

• No person will bring a putative or certified class action to arbitration,

nor seek to enforce any predispute arbitration agreement against

any person who has initiated in court a putative class action; or

who is a member of a putative class who has not opted out of the

class with respect to any claims encompassed by the putative class

action until: (1) the class certification is denied; (2) the class is

decertified; or (3) the client is excluded from the class by the court.

Such forbearance to enforce an agreement to arbitrate will not

constitute a waiver of any rights under this Agreement except to the

extent stated herein.

I agree that any controversy between you and your affiliates, any of their

respective officers, directors, employees, or agents and me (including

any of my officers, directors, employees, or agents) arising out of or

relating to this Agreement, our relationship, any Services provided

by you, or the use of the Services, and whether arising before or after

the date of this Agreement, shall be arbitrated and conducted under

the provisions of the Code of Arbitration of the FINRA. If any party

unsuccessfully resists confirmation or enforcement of an arbitration

award rendered under this Agreement, then that party shall pay all costs,

attorneys’ fees, and expenses incurred by the other party or parties

in confirming or enforcing the award. Arbitration must be initiated

by service upon the other party of a written demand for arbitration or

notice of intention to arbitrate. Judgment, upon any award rendered by

the arbitrator, may be entered in any court having jurisdiction.

13. ADVICE

a. Unless otherwise noted by you in writing, you will act only as broker-dealer

and not as an investment advisor governed by the Investment Advisers Act

of 1940.

b. When I act as a self-directed investor, I am responsible for determining

the suitability of any particular investment strategy, transaction, or security.

You have no responsibility for any such determination unless you otherwise

agree in writing, or you or your representative gives advice directly to

me that is identified clearly as a recommendation by you to enter into a

particular transaction or to buy, sell, or hold a particular security or securities.

Page 8 of 9

AMTD 182 F 07/21

c. From time to time, in connection with my Account, you may provide

investment-related guidance or recommendations to me. In the event that

a recommendation is made, you and/or your representative shall have my

informed consent to deliver the Form CRS Customer Relationship Summary

for TD Ameritrade or its affiliates, as required (“Form CRS”) - as well as any

other notices, disclosures, or communications - to any mailing address,

email address or facsimile number that I provide in connection with either the

Account, or any other accounts that I open or otherwise maintain with you.

I understand that I can also access the Form CRS by visiting tdameritrade.

com/regbi. I understand and acknowledge that it is incumbent on me to

provide you with current and accurate contact information for the delivery of

these documents. I acknowledge that I shall read and understand the Form

CRS - as well as any other notices, disclosures, or communications - prior

to acting upon any such recommendation. I agree that when you make a

recommendation to me, you determine whether it is suitable and in my best

interest at the time of the recommendation. If the recommended transaction

is not effected contemporaneously with your recommendation, I agree

you will have no liability if I choose to effect such transaction in the future.

Furthermore, when you are acting as broker-dealer for my Account, I agree

that you have no ongoing duty to ensure a recommendation continues to

be suitable for me. Rather, I have an affirmative duty to monitor profits and

losses in my Account, along with my investment goals and risk tolerance

and to modify my trading decisions accordingly.

d. Unless otherwise agreed to in writing, you do not have discretionary

authority over my Account or an obligation to monitor, review or make

recommendations for the investment of securities or cash in my Account.

e. Any research, analysis, news, or other information made available by you

does not constitute an individualized recommendation by you to buy, sell, or

hold a particular security.

f. You do not provide legal, tax, or estate planning advice.

14. MISCELLANEOUS

a. Severability. If any provision of this Agreement is held to be illegal, invalid,

or unenforceable under present or future laws, such provisions shall be fully

severable. In such event: (1) this Agreement shall be construed and enforced

as if such illegal, invalid, or unenforceable provision has never comprised a

part of this Agreement or was modified to be legal, valid, and enforceable;

and (2) the remaining provisions of this Agreement shall remain in full force

and effect and shall not be affected by the illegal, invalid, or unenforceable

provisions or by its severance from this Agreement, to the extent permitted by

Applicable Rules.

b. Account Handbook. The Account Handbook provided to me upon

account opening, and available on your websites, contains important

information about my Account. I will refer to the Account Handbook to learn

additional information about the handling of trade orders, the receipt and

delivery of funds, account policies, and other general account information.

c. Entirety of Agreement. This Agreement, any attachments hereto, the

addenda and other agreements referred to in this Agreement and the terms

and conditions contained in the Account statements and confirmations

contain the entire agreement between you and me; and it supersedes

all prior or contemporaneous communications and proposals, whether

electronic, oral, or written, between me and you, provided, however, any

and all other agreements if any, between me and you and your affiliates,

not inconsistent with this Agreement will remain in full force and effect, and

if there are any conflicts between this Agreement and any attachments or

other agreements, this Agreement shall prevail.

d. Assignment and Escheatment. I may not assign this Agreement or

any rights or obligations under this Agreement without first obtaining your

prior written consent. You may assign, sell, or transfer my Account and this

Agreement, or any portion thereof, at any time, without my prior consent.

The assets in my Account may be transferred to the appropriate state if no

activity occurs in my Account within the time period specified by state law.

e. Amendment. You reserve the right to amend this Agreement without

prior notice to me or as required by Applicable Rules. The current version

of the Agreement will be posted on the websites and my continued Account

activity after such amendment constitutes my agreement to be bound by

all amendments to the Agreement, regardless of whether I have actually

reviewed them. You are not bound by any verbal statements that seek to

amend the Agreement.

f. Termination. You may terminate this Agreement, or close, deactivate, or

block access to my Account. If you decide to close my Account and I fail to

transfer it to another broker, you may liquidate my Account and send me the

proceeds. I will remain responsible for the payment of all obligations incurred

in my Account or otherwise. I may terminate this Agreement after paying any

obligations owed upon written notice. The Agreement survives termination of

the Account.

g. Force Majeure. You will not be liable for loss caused directly or indirectly

by conditions beyond your reasonable control, including but not limited

to Force Majeure events. “Force Majeure” means events that are beyond

the reasonable control of a party, including but not limited to the following:

disasters, extraordinary weather conditions, earthquakes or other acts

of God, war, insurrection, riot, labor strikes, terrorist acts, government

restrictions, exchange or market rulings, suspension of trading, computer

or communication line failure, or failure of market centers or transmission

facilities.

h. Indemnification. I agree to indemnify and hold harmless you, your

affiliates, and Third-Party Providers and your and their respective officers,

directors, employees, agents, and representatives from any and all liabilities,

losses, costs, judgments, penalties, claims, actions, damages, expenses, or

attorney’s fees (collectively “Losses”) resulting or arising directly or indirectly

from use of the Services or transactions in my Account, except to the extent

that such Losses are the direct result of your gross negligence or willful

misconduct.

i. Waiver. Your failure to insist on compliance with this Agreement will not

constitute a waiver of any of its rights.

j. Admissibility of Documents in Proceedings. All documents in any

format are considered to be true, complete, valid, authentic, and enforceable

records of the applicable document, admissible in judicial or administrative

proceedings to the same extent as if the documents and records were

originally generated and maintained in printed form. I will not contest the

admissibility or enforceability of your copy of the documents in any proceeding

arising out of this Agreement.

k. Governing Law, Jurisdiction, and Venue. This Agreement will be

governed by the laws of the State of Nebraska, but not its conflicts of law

provisions. I hereby consent to the jurisdiction of and venue within the State

of Nebraska for all disputes arising out of or relating to this Agreement.

l. NJ State Law. New Jersey law prohibits contractual provisions that violate

the legal rights of a NJ consumer or responsibility of a seller. No provision in

this Agreement shall apply to any NJ consumer if it violates any such right

or responsibility, including grounds for redress based on: (i) your tortious

actions; (ii) the NJ Punitive Damages Act; (iii) the NJ Uniform Commercial

Code; or (iv) your failure to protect reasonably against criminal acts of third

parties.

m. Worthless Securities. You may remove a worthless security from my

account including, and without limitation to, the following circumstance:

your primary custodian, the Depository Trust Company, has deemed the

security eligible for removal and you have reviewed and determined, to the

best of your ability, that the security has no market value. I agree to waive

any claim to any future distribution from the security and agree to indemnify

and hold you harmless from any claims, liability, or damages resulting from

the removal of such security. If I provide you with evidence of the value of

the security from an independent third party within 60 days of receiving

your account statement noting the removal, you will review and, if able to,

reinstate my position.

Investment Products: Not FDIC Insured * No Bank Guarantee * May Lose Value

TD Ameritrade, Inc. and TD Ameritrade Clearing, Inc., members FINRA/SIPC, are subsidiaries of The Charles Schwab Corporation.

TD Ameritrade is a trademark jointly owned by TD Ameritrade IP Company, Inc. and The Toronto-Dominion Bank.

Page 9 of 9

AMTD 182 F 07/21

EXHIBIT D

PO BOX 2577

OMAHA NE 68103-2577

DONALD EASTERLIN

Terms and Conditions

TD Ameritrade provides monthly statements for accounts with activity and quarterly statements for

inactive accounts with assets. 1

The balance in your bank deposit account or shares of your money market mutual fund can be

liquidated on your order, and the proceeds returned to your securities account or remitted to you.

Portfolio Summary: Tracks the current value of your portfolio as of the report date and compares it

to the prior month.2 The asset allocation indicates your portfolio diversification by investment type.

Tax Reporting: The portfolio report is not a tax document. You will receive Form 1099 for annual

tax reporting in compliance with IRS requirements (includes taxable interest, dividends, capital

gains, taxes withheld, and sales proceeds). Some payments are subject to reclassification which

will be reflected on subsequent tax reports.

Multiple allocations under 5% will be grouped into the category of "Other" in the pie chart. Margin Equity

= Total Account Equity/ (Total Long Marginable Value + Total Short Value)

Activity Summary: The opening and closing cash balances are reconciled here for quick reference.

All account activity is summarized for the current period and year-to-date.

Income & Expense Summary (non-IRAs only): This section details the income and expense totals

from the Activity Summary and classifies the tax treatment.

Retirement Account Summary (IRAs only): Review the IRS regulated transactions for the current

and prior years. IRS Form 5498 fair market value is based on the current account value including

Alternative Investments as of December 31 of the previous year and will be furnished to the IRS.

Performance Summary: Monitor annual portfolio performance and the unrealized gains and losses

for your future investment strategy.

Account Positions: View your investments at the current market value and compare the original cost

to see unrealized gains and losses in your portfolio. Original cost is assigned using the first-in, first-out

(FIFO) method, which assumes the first shares you sell are those you purchased first. The estimated

investment income2 and average cost per share are displayed for your reference (the oldest purchase

date is shown for an indication of your holding period). This statement represents a statement of

account assets and account activity of your account only. There is no guarantee that you will receive

this amount or any dividend.

Account Activity: All account activity is listed in date order, and reflected in the closing cash

balance.

Trades Pending Settlement: Confirm executed trades with a settlement date after month end. These

transactions will be reflected in the Account Activity section next month.

Online Cash Services Transaction Detail: Cash management transactions that cleared during this

period, including check, debit card and ATM activity, are listed in date order.

Online Cash Services Summary: Credit and debit transaction totals for the current period are

summarized. Individual transactions are not listed.

TD Ameritrade does not provide legal or tax advice. Please consult your legal advisor or tax

accountant when necessary.

Accuracy of Reports: Please review this statement carefully. If you disagree with any

transaction, or if there are any errors or omissions, please contact TD Ameritrade, Inc. and

TD Ameritrade Clearing at 800-669-3900 within ten (10) days of your receipt of this statement.

To further protect your rights, including rights under the Securities Investor Protection Act (SIPA),

any oral statements that you have made should be confirmed to TD Ameritrade and

TD Ameritrade Clearing, Inc. in writing. The statement will otherwise be considered conclusive.

Account Protection: TD Ameritrade FDIC Insured Deposit Account ("IDA") deposits are held at one or

more banks ("Program Banks"). Three of the Program Banks are Charles Schwab Bank, SSB; Charles

Schwab Premier Bank, SSB; and Charles Schwab Trust Bank, each an affiliate of TD Ameritrade. IDA

deposits are insured by the FDIC (not covered by SIPC) up to $250,000. Limits are per account

ownership per institution. To learn more about FDIC coverage go to www.fdic.gov. Securities, including

mutual funds, held in your Brokerage Account are not deposits or obligations of, or guaranteed by,

any bank, are not FDIC-insured, and involve investment risks, including possible loss of principal.

TD Ameritrade is a member of SIPC, which protects securities customers of its members up to

$500,000 (including $250,000 for claims for cash). Explanatory brochure is available on request at

www.sipc.org.

Additionally, TD Ameritrade provides each client $149.5 million worth of protection for securities and $2

million of protection for cash through supplemental coverage provided by London insurers. In the event of

brokerage insolvency, a client may receive amounts due from the trustee in bankruptcy and then SIPC.

Supplemental coverage is paid out after the trustee and SIPC payouts and under such coverage each

client is limited to a combined return of $152 million from a trustee, SIPC and London insurers. The

TD Ameritrade supplemental coverage has an aggregate limit of $500 million over all customers. This

policy provides coverage following brokerage insolvency and does not protect against loss in market

value of the securities.

An investment in a money market fund is not insured or guaranteed by the FDIC or any other

government agency. Although certain money market funds may seek to preserve their value of your

investment at $1 per share, it is possible to lose money by investing in such a fund. Mutual fund

purchases may be subject to eligibility and other restrictions, as well as charges and expenses.

Certain money market funds may impose liquidity fees and redemption gates in certain circumstances.

Dividends are declared daily and paid/reinvested monthly. The prospectus contains this and other

important information. Read the prospectus carefully before investing. Non-deposit investments held by

your broker-dealer are NOT FDIC INSURED / NOT BANK GUARANTEED / MAY LOSE VALUE.

Due to rounding adjustments, the statement details may not equal the statement totals.

Estimated Annual Income and Estimated Annual Yield values are based upon the number of shares

owned or current value balance as of the statement date and the most recent dividend rate or cash

yield provided.

Cost Basis: Cost-Basis, tax lot and performance reporting and Gainskeeper are offered and

conducted by CCH INCORPORATED. TD Ameritrade is not responsible for the reliability or

suitability of the information. TD Ameritrade and its information providers do not guarantee

the accuracy of the information and data provided. CCH INCORPORATED is a separate company

and is not affiliated with TD Ameritrade.

Margin and Options Account Agreements: Be aware of the following: 1) Commissions and

other charges related to the execution of option transactions have been included in confirmations

of such transactions previously furnished to you and will be made available promptly upon request.

2) Promptly advise TD Ameritrade in writing of any change in your investment objectives or

financial situation as they pertain to your margin or options account agreements. Commission/Fee

represents base commission and any options contract, exercise, and assignment fees.

Current Market Prices: The market values of securities have been obtained, if available, from

quotation services and other independent sources. Values are based on the closing price, the mean

between the bid and asking prices, or other methods. If no market value is available from a quotation

service or other independent source, the security is subject to being reflected as Not Available (“NA”).

The valuations on your portfolio report are provided as general information and we do not guarantee

the accuracy of any securities prices. Mortgage backed positions are valued using the remaining

balance and the current market price. Portfolio report valuations may not represent sales proceeds.

The secondary market for Certificates of Deposits (“CDs”) is generally illiquid and the actual value

may be different from the purchase price. A significant loss of principal may result from the sale of a

CD prior to maturity. Bonds and/or Fixed Income Securities trade differently than equity securities and

do not trade on a liquid exchange. Rather, they trade in the OTC (over the counter) market and

sufficient liquidity may not exist for you to sell your position prior to maturity. The sale of bonds prior to

maturity may result in a loss of principal.

Bonds Quantity: The figure on the statement represents the number of bonds. For example, $3,000

of a $1,000 face value bond would display as “3” in the quantity.

Alternative Investments (“AI”), also called Non Standard Assets (“NSA”), are typically investments

in direct participation program securities (partnerships, limited liability companies, or real estate

investment trusts), commodity pools, private equity, private debt or hedge funds. AI are typically

illiquid investments and do not trade on a national securities exchange. The values shown for these

investments are estimated values derived from various methods, including, but not limited to,

unconfirmed management estimates, independent appraisals, the program’s net assets, and/or third

party tender offers that have been provided by the management, administrator, and/or sponsor of

each program, or by a third-party vendor without independent verification by TD Ameritrade. Values

may not reflect the original purchase price, actual market value or be realized upon liquidation. If an

estimated value cannot be established through these methods, the valuation may be reflected as Not

Available (“NA”). For additional detail regarding valuation for Alternative Investments, please contact

Client Services. These investments are not covered under the SIPC. AI transaction fees are

applicable to purchases, capital call processing, and redemptions.

D Distributions on Direct Participation Programs and/or REITs are reported and a net investment per

share estimated value is also reported. Pricing and distribution information has been provided by the

sponsor, issuer or other external party responsible for reporting of the DPP or REIT and the

classification of distributions as income or return of capital, in whole or in part, is subject to final

accounting by such party(ies) and will be reported to you on a Form 1099 or K-1, as applicable.

Auction Rate Securities ("ARS") Pricing: The market values for ARS securities have been

obtained, if available, from quotation services or other independent sources. The accuracy of the

pricing is not guaranteed. If a market value is not available, TD Ameritrade will price the ARS position,

taking into consideration both the liquidity and underlying credit quality. The ARS may lack liquidity

and, as a result, there can be no assurance that such securities can be sold under current market

conditions.

All transactions are subject to (i) the constitution, rules, regulations, customs and usages of the exchange or

market, and its clearinghouse, if any, on which such transactions are executed; (ii) federal and state laws, and the

rules and regulations promulgated thereunder; and (iii) the rules and regulations of FINRA and the Federal

Reserve System.

For an investor brochure that includes information describing FINRA’s Public Disclosure Program,

please contact FINRA at 800-289-9999 or www.finra.org.

The interest rate shown for TD Ameritrade Cash is taken from the applicable interest rate tier

for the Market Value balance in the TD Ameritrade Cash, as of the statement closing date.

Simple interest is accrued daily based on the interest rate tier applicable to each day’s balance.

MSRB RULE G-10: TD Ameritrade, Inc. is registered with the Municipal Securities Rulemaking

Board and the U.S. Securities and Exchange Commission. The website address for the Municipal

Securities Rulemaking Board is http://www.msrb.org. An investor brochure is available on the

website of the Municipal Securities Rulemaking Board which describes the protections that may be

provided by the Municipal Securities Rulemaking Board rules and how to file a complaint with an

appropriate regulatory authority.

Financial Statement Notification: The statement of financial condition for

TD Ameritrade Clearing, Inc. is available twice a year and may be obtained at no cost, via the

internet at http://www.tdameritrade.com/financialstatement.html.

Option Assignment: All short equity option positions and some index option positions are

available for assignment. Exercise assignment notices for equity or index options are randomly

allocated among all clients’ short positions.

Free Credit Balances (Rule 15c3-2 & 3): Under the client protection rules, we may use

free credit balances in your account in the ordinary course of our business which are

payable to you on demand.

Margin Accounts (Regulation T): If you have a margin account, this report is a combination of

your margin account and a special memorandum account. Trading on margin poses additional

risks and is not suitable for all investors. A complete list of the risks associated with margin trading is

available in the margin risk disclosure document. You may obtain a copy of this document by

contacting us at the number listed on page one of your statement.

Payment for Order Flow Disclosure (Rules 606 and 607): Rule 607 of Regulation NMS requires

broker-dealers to disclose, upon opening a new customer account and on an annual basis thereafter:

(i) its policies regarding receipt of payment for order flow, including a statement as to whether any

payment for order flow is received for routing customer orders and a detailed description of the

nature of the compensation received; and (ii) its policies for determining where to route customer

orders that are the subject of payment for order flow absent specific instructions.

The firm receives compensation for directing listed and OTC securities, and options order flow to

selected market centers (e.g., broker dealers, exchanges and alternative trading systems for

execution). Compensation generally is in the form of a per share or per contract cash payment. The

potential for receipt of order flow payment is not a factor in the routing determination. TD Ameritrade

also may receive compensation related to the foreign currency exchange component of transactions

in foreign securities from market centers executing such trades. In accordance with SEC Rule 606,

TD Ameritrade posts quarterly reports that detail the material market centers to which TD Ameritrade

routes orders in NMS Securities and TD Ameritrade’s material relationships with those market

centers. This report is made available at www.tdameritrade.com/historical-606-disclosure.page or in

written form upon request. As required under SEC Rule 606(b)(1), on request, TD Ameritrade will

provide the identity of the market center to which your orders were routed for execution in the six

months prior to the request, whether the orders were directed orders or non-directed orders, and the

time of the executions, if any, that resulted from such orders. This applies to both held and not held

order flow.

TD Ameritrade regularly assesses the execution quality provided by the market centers to which we

route order flow in seeking best execution for our clients. For non-directed client orders, it is our

policy to route orders to market centers based on a number of factors that are more fully discussed in

the Supplemental Materials of FINRA Rule 5310, including where applicable, but not necessarily

limited to, speed of execution, price improvement opportunities, differences in price disimprovement,

likelihood of executions, the marketability of the order, size guarantees, service levels and support,

the reliability of order handling systems, customer needs and expectations, transaction costs and

whether the firm will receive remuneration for routing order flow to such market centers. Price

improvement occurs when an order is executed at a price that is more favorable than the displayed

national best bid or offer.

Trade Confirmations (Rule 10b-10): All confirmations are transmitted on the transaction date. If

you participate in the Dividend Reinvestment Plan (DRIP) details regarding the reinvestment of

dividends will be included on your monthly statements. TD Ameritrade will act as agent in having

your DRIP purchases executed.

Futures/Options Disclosures for EU Clients: In accordance with the Packaged Retail and

Insurance-based Investment Products Regulation - EU No 1286, retail investors based in the

European Economic Area (EEA) can access Key Information Documents (KIDs) through the

following landing page: https://tdameritrade.com/priips-regulation.page

Taxes: Transactions in foreign securities (including foreign company ADRs that trade in the

U.S.) may include taxes and fees charged by the foreign markets or governments, which

may be reflected in the price of the security or charged as an independent line item.

www.tdameritrade.com

Callable Securities: The allocation of partial redemptions or calls is done using a pro-rata lottery

system. A description of the procedures for callable securities is available on the website or hard

copies are available upon request.

In case of errors or questions about your Electronic Fund Transfers, please contact us at

1-800-669-3900, or in writing to P.O. Box 2209, Omaha, NE 68103, or by email at

clientservices@tdameritrade.com. The information contained in your account statement shall be

binding upon you if you do not object within sixty (60) days for any transfer of funds subject to

Regulation E, such as ATM and point-of-sale transfers, debit transactions, direct deposits, and

withdrawals. We must hear from you no later than 60 days after we sent you the FIRST

statement on which the error or problem appeared.

(1) Tell us your name and account number.

(2) Describe the error or the transfer you are unsure about, and explain as clearly as you

can why you believe it is an error or why you need more information.

(3) Tell us the dollar amount of the suspected error.

We will investigate your complaint and will correct any error promptly. If we take more than 10

business days to do this, we will credit your account for the amount you think is in error, so that

you will have the use of the money during the time it takes us to complete our investigation.

TDA 150 10/21

Statement Reporting Period:

05/01/22 - 05/31/22

Statement for Account #

800-669-3900

TD AMERITRADE

DIVISION OF TD AMERITRADE INC

PO BOX 2209

OMAHA, NE 68103-2209

TD Ameritrade Clearing, Inc., Member SIPC

797

DONALD EASTERLIN

Portfolio Summary

Investment

Margin Loan

Insrd Dep Acct (IDA)

Money Market

Short Balance

Stocks

Short Stocks

Fixed Income

Options

Short Options

Mutual Funds

Other

Current

Value

($381.65)

Prior

Value

($4,900.74)

24,137.50

Period

Change

$4,519.09

(24,137.50)

Change

(100.0)%

Estimated

Income

Estimated

Yield

Total

($381.65)

$19,236.76

($19,618.41)

(102.0)%

$ 0.00

0.0%

Cash Activity Summary

Opening Balance

Securities Purchased

Securities Sold

Funds Deposited

Funds Disbursed

Income

Expense

Other

Closing Balance

Income & Expense Summary

Current

YTD

($4,900.74)

(33,409.14)

37,999.38

(71.15)

($39,538.76)

(591,107.99)

625,911.44

12,550.00

(7,891.00)

349.05

(679.40)

25.01

($381.65)

page 1 of 4

Reportable

Income

Dividends

Interest

Other

Expense

Interest

Fees

Other

Net

(71.15)

($71.15)

Portfolio Allocation

Margin Loan

100.0%

Performance Summary

Non

Reportable

YTD

$349.05

$0.00

(679.40)

($330.35)

Cost Basis As Of - 05/31/22 **

Unrealized Gains

Unrealized Losses

Funds Deposited/(Disbursed) YTD

Income/(Expense) YTD

Securities Received/(Delivered) YTD

4,659.00

(330.35)

0.00

**To view realized gains and losses for your account, login at

www.tdameritrade.com and visit My Account > Cost Basis.

Statement for Account #

05/01/22 - 05/31/22

6797

Online Cash Services Summary

Description

Current

CREDITS

Electronic Transfer

Subtotal

DEBITS

Electronic Transfer

Year To Date

0.00

12,550.02

(7,891.00)

0.00

Subtotal

TOTAL

4,659.02

0.00

Income Summary Detail*

Description

Ordinary Dividends

Margin Interest Charged

Current

$ 0.00

(71.15)

Year to Date

$ 349.05

(679.40)

*This section displays current and year to date totals for this account. The year to date totals will accurately reflect your cumulative amount for the year. Year-end tax reporting income amounts may differ from what is reflected on

monthly statements versus your tax documents. Please reference your official tax document(s) for tax reporting.

Account Activity

Trade

Date

Settle

Date

Acct

Type

Transaction/

Cash Activity*

Opening Balance

05/11/22 05/11/22

Cash

Journal - Other

TRANSFER 779236797-1 TO

797-2

04/28/22

05/02/22

Margin

Sell - Securities Sold

04/28/22

05/02/22

Margin

04/28/22

05/02/22

04/28/22

Symbol/

CUSIP

Price

Amount

Balance

$ 0.00

$ (310.50)

($4,900.74)

(5,211.24)

ACUMEN PHARMACEUTICALS INC ABOS

COM

Regulatory Fee 0.10

700-

3.91

2,736.90

(2,474.34)

Buy - Securities Purchased

BAUSCH HEALTH COMPANIES INC BHC

COM

925

21.15

(19,563.75)

(22,038.09)

Margin

Sell - Securities Sold

PALISADE BIO INC

COM

Regulatory Fee 0.20

PALI

1,425-

0.79

1,125.55

(20,912.54)

05/02/22

Margin

Sell - Securities Sold

ACUMEN PHARMACEUTICALS INC ABOS

COM

Regulatory Fee 0.19

1,300-

3.76

4,887.81

(16,024.73)

05/02/22

Margin

Buy - Securities Purchased

BAUSCH HEALTH COMPANIES INC BHC

COM

370

18.75

(6,937.50)

(22,962.23)

page 2 of 4

Description

Quantity

Statement for Account #

05/01/22 - 05/31/22

Account Activity

Trade

Date

Settle

Date

Acct

Type

Transaction/

Cash Activity*

04/28/22

05/02/22

Margin

Buy - Securities Purchased

BAUSCH HEALTH COMPANIES INC BHC

COM

04/28/22

05/02/22

Margin

Buy - Securities Purchased

PALISADE BIO INC

COM

04/29/22

05/03/22

Margin

Buy - Securities Purchased

PALISADE BIO INC

COM

05/06/22

05/10/22

Margin

05/06/22

05/10/22

05/11/22

Description

Symbol/

CUSIP

Quantity

Price

Amount

Balance

300

19.3499

(5,804.97)

(28,767.20)

PALI

1,270

0.78

(990.60)

(29,757.80)

PALI

144

0.78

(112.32)

(29,870.12)

Sell - Securities Sold

BAUSCH HEALTH COMPANIES INC BHC

COM

Regulatory Fee 0.17

800-

16.0801

12,863.91

(17,006.21)

Margin

Sell - Securities Sold

PALISADE BIO INC

COM

Regulatory Fee 0.85

PALI

6,414-

0.49

3,142.01

(13,864.20)

05/11/22

Margin

Journal - Other

TRANSFER 779236797-1 TO

97-2

0.00

310.50

(13,553.70)

05/10/22

05/12/22

Margin

Sell - Securities Sold

BAUSCH HEALTH COMPANIES INC BHC

COM

Regulatory Fee 0.04

250-

9.66

2,414.96

(11,138.74)

05/10/22

05/12/22

Margin

Sell - Securities Sold

BAUSCH HEALTH COMPANIES INC BHC

COM

Regulatory Fee 0.03

145-

9.61

1,393.42

(9,745.32)

05/10/22

05/12/22

Margin

Sell - Securities Sold

BAUSCH HEALTH COMPANIES INC BHC

COM

Regulatory Fee 0.09

500-

9.61

4,804.91

(4,940.41)

05/10/22

05/12/22

Margin

Sell - Securities Sold

BAUSCH HEALTH COMPANIES INC BHC

COM

Regulatory Fee 0.09

500-

9.26

4,629.91

(310.50)

05/31/22

Margin

Div/Int - Expense

MARGIN INTEREST CHARGE

Payable: 05/31/2022

0.00

(71.15)

(381.65)

Closing Balance

($381.65)

*For Cash Activity totals, refer to the Cash Activity Summary on page one of your statement.

TD Ameritrade Cash Interest Credit/Expense

Begin

Date

05/01/22

05/02/22

05/03/22

05/06/22

Margin

Balance

$ (4,900.74)

(29,447.30)

(29,559.62)

page 3 of 4

Credit

Balance

$ -

Number

of Days

Interest

Rate

9.75

9.25

9.75

Interest

Debited

$ 1.33

7.57

22.79

32.02

Interest

Credited

$ -

Statement for Account #

05/01/22 - 05/31/22

TD Ameritrade Cash Interest Credit/Expense

Begin

Date

05/10/22

05/11/22

Margin

Balance

(13,553.70)

(13,243.20)

Credit

Balance

Number

of Days

Total Interest Income/(Expense)

Interest

Rate

10.00

Interest

Debited

3.76

3.68

Interest

Credited

$71.15

$ 0.00

Important Information

BREAKPOINTS

Certain purchases of Class A Mutual Funds may be eligible for breakpoints on, and waivers of, the sales charge. To learn more about breakpoint discounts, go to

http://www.finra.org/industry/issues/breakpoints. For more information on waiver eligibility, please refer to the fund prospectus.

page 4 of 4

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.