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Firm Specific Disclosure

Risk Disclosure Statement

Risk Disclosure for Futures and Options

Uniform Futures and Options on Futures Disclosures

TD Ameritrade Futures & Forex LLC Futures Account Disclosure

Firm Specific Disclosure

INTRODUCTION
The Commodity Futures Trading Commission ("Commission") requires each futures commission merchant ("FCM"),
including TD Ameritrade Futures & Forex LLC ("TD Ameritrade Futures & Forex"), to provide the following
information to a customer prior to the time the customer first enters into an account agreement with the FCM or
deposits money or securities (funds) with the FCM. Except as otherwise noted below, the information set out is as
of July 16, 2018. TD Ameritrade Futures & Forex will update this information annually and as necessary to take
account of any material change to its business operations, financial condition or other factors that TD Ameritrade
Futures & Forex believes may be material to a customer's decision to do business with TD Ameritrade Futures &
Forex. Nonetheless, TD Ameritrade Futures & Forex's business activities and financial data are not static and will
change in non-material ways frequently throughout any 12-month period.

[NOTE: TD Ameritrade Futures & Forex LLC is a subsidiary of TD Ameritrade Holding Corporation. Information that
may be material with respect to TD Ameritrade Futures & Forex LLC for purposes of the Commission's disclosure
requirements may not be material to TD Ameritrade Holding Corporation for purposes of applicable securities laws.]

FIRM AND ITS PRINCIPALS

TD Ameritrade Futures & Forex LLC
600 West Chicago Ave.
Suite 100
Chicago, IL 60654
866-839-1100 phone
773-435-3232 fax
futuressupport@[Link]

TD Ameritrade Futures & Forex's Designated Self-Regulatory Organization (DSRO) is the National Futures
Association (NFA) [Link].

The following is a list of TD Ameritrade Futures & Forex's Principals along with their title, business address, business
background, areas of responsibility, and the nature of the duties of each principal as defined in CFTC § 3.1(a):

James Mackenzie, President, TD Ameritrade Futures & Forex

Business Address: 600 W. Chicago Ave, Suite 100, Chicago, IL 60654
Background: James Mackenzie has worked in the financial industry for more than 16 years. Prior to coming to TD
Ameritrade, he worked at MF Global, Penson Futures, and Goldenberg Hehmeyer where his main focus was with

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technology and trading. James holds a Series 3 and 34, has a Bachelor of Arts in Biology and Psychology from
Middlebury College, and an MBA from the University of Notre Dame.
Areas of Responsibility:Futures & Forex Operations
Duties: James Mackenzie is responsible for the Futures and Forex business at TD Ameritrade Futures & Forex.

William Yates, Treasurer, TD Ameritrade Futures & Forex

Business Address: 200 South 108th Avenue, Omaha, NE 68154
Background: William Yates is responsible for the development and implementation of treasury strategies,
managing treasury operations, liquidity, and cash management. William has been with TD Ameritrade since 1996,
serving in a number of roles within the company's finance, operations, and compliance functions during his tenure.
Prior to joining TD Ameritrade, William spent nine years with the public accounting firm Arthur Andersen LLP.
William has served in various capacities in the securities industry, including most recently as a member of the
Midwest District Committee of the Financial Industry Regulatory Authority (FINRA). He also serves on the boards
and various board committees of the Options Clearing Corporation and CHI Health. He holds Series 7, 24, 27, and
53 licenses, and is a member of the Nebraska State Society of Certified Public Accountants and the American
Institute of Certified Public Accountants.
Areas of Responsibility: Treasury
Duties: William Yates oversees treasury functions for TD Ameritrade Futures & Forex.

Gregg Fuesel, Director, Regulatory Reporting

Business Address: 200 South 108th Avenue, Omaha, NE 68154
Background: Gregg Fuesel is Director of Regulatory Reporting at TD Ameritrade. He started at TD Ameritrade in
March of 2011. He has worked at multiple broker-dealers along with ten years at the Options Clearing Corporation.
Regulatory Reporting is responsible for filing multiple regulatory reports and adhering to regulations of the SEC,
FINRA, CFTC, and the NFA along with coordinating the monthly Regulatory Reporting Committee which is
responsible for overseeing the regulatory reporting requirements of certain subsidiaries of the Company. He is also
a member of the SIFMA Capital Committee. He holds Series 3, 4, 7, 27, 34, and 63 licenses.
Areas of Responsibility: Regulatory Reporting
Duties: Gregg Fuesel oversees the 1-FR-FCM Report, Segregation Computation, and Regulatory Reporting for TD
Ameritrade Futures & Forex.

Joe Iraci, Managing Director, Financial Risk Management

Business Address: 1 Plaza Four A, Jersey City, NJ 07311
Background: Joe Iraci is a Managing Director at TD Ameritrade where he heads the Financial Risk Management
team. Prior to this position, he headed the Financial Markets Services Group, and the Corporate Risk team. Prior to
joining TD Ameritrade, Joe held several senior risk management positions within Fidelity Investments at both
Fidelity Employer Services Corporation and Fidelity Brokerage Company. Joe previously had been the Head of New
Business Operations, UBS AG, and the Regional Head Americas/Deputy Global Head of Operational Risk at Deutsche
Bank AG, a position he assumed from heading the Business Risk Management for Deutsche Bank's Corporate Trust
and Agency Services business. Prior to joining Deutsche Bank, Joe had been a Bank Examiner with the FDIC and
served in the United States Marine Corps. Joe completed his undergraduate studies at St. John's University and
received his MBA from New York University.
Areas of Responsibility: Risk Management
Duties: Joe Iraci oversees risk management functions for TD Ameritrade Futures & Forex.

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David Kimm, Executive Vice President, Chief Risk Officer

Business Address: 1 Plaza Four A, Jersey City, NJ 07311
Background: David Kimm works with business units throughout TD Ameritrade to identify and manage the
organization's credit, market, and operational risks. He also serves as a member of the Company's senior operating
committee (SOC), which shapes the strategic focus of the organization. David comes to TD Ameritrade with nearly
35 years in financial services, nearly 15 of which have included responsibility for risk management. He most
recently served as the senior vice president and CRO for Wachovia Securities LLC, during which time he established
the brokerage firm's risk management organization and was responsible for risk strategy, reporting, risk
assessments, operational risk, credit/counterparty management, and oversight of the company's margin portfolio.
David also serves on the Board of Directors of the Depository Trust and Clearing Corporation (DTCC).
Prior to joining Wachovia, David served in Chief Financial and Chief Operating Officer roles with several other
notable financial services firms, including LPL Financial Services, Fidelity Investments, Cowen & Company, and
PaineWebber, Inc.
David attended Michigan State University and received his master's in business administration from New York
University.
Areas of Responsibility: Risk Management
Duties: David Kimm oversees all risk management functions for TD Ameritrade Futures & Forex.

Ben Miller, Director, TD Ameritrade Futures & Forex

Business Address: 3000 TD Ameritrade Lane, Southlake, TX 76092
Background: Ben Miller has more than 18 years of financial industry experience. Prior to coming to TD Ameritrade,
he worked for Penson Futures for more than 10 years and he has experience with Coquest (a registered IB) and
ED&F Man where his main focus was with operations. Ben holds a Series 3, 30, and 34 and has a Bachelor of
Business Administration from the University of Oklahoma.
Areas of Responsibility: Futures & Forex Operations
Duties: Ben Miller oversees futures and forex operations for TD Ameritrade Futures & Forex.

Steven Quirk, Chief Executive Officer, TD Ameritrade Futures & Forex

Business Address: 600 West Chicago Avenue, Suite 100, Chicago, IL 60654
Background: Steven Quirk oversees the strategy and deployment of initiatives for the Active Trader segment at TD
Ameritrade. He also serves as a member of the Company's senior operating committee (SOC), which shapes the
strategic focus of the organization. Prior to his current role, Steven was responsible for the development of new
trading tools and technology enhancements for the thinkorswim by TD Ameritrade trading platform. Steven's 28-
year trading career began in 1987 as a Chicago Board Options Exchange (CBOE) market maker. While at the CBOE,
he served on the exchange's Index Market Performance Committee and the Arbitration Committee. Steven was a
partner with SCMS for seven years, trading options on index products. He also led the Chicago operations of Van
der Moolen USA. Steven graduated from the University of Wisconsin with a B.B.A. in Risk/Insurance and Marketing.
He holds Series 3, 4, 7, 24, 34, and 63 licenses.
Areas of Responsibility: Registered Principal; Trading
Duties: Steven Quirk oversees the strategy and deployment of initiatives for the Active Trader segment at TD
Ameritrade.

Susan Boudrot, Managing Director, Global Chief Compliance Officer, TD Ameritrade Holding Corporation
Business Address: 1 Plaza Four A, Jersey City, NJ 07311

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Background: Susan Boudrot has worked in the financial industry for over 28 years. She currently is a Managing
Director and the Global Chief Compliance Officer. She oversees Compliance for the TD Ameritrade Holding
Corporation. She is also on the board of directors for TD Ameritrade Futures & Forex. She previously worked at
Fidelity where she was responsible for the compliance teams which supported the retail brokerage firm, the defined
contribution/benefit organization, the trust company, the insurance agency, the custodial platform for third party
investment advisors, and the privacy program. Prior to that, she worked at Charles Schwab where her team
supported brokerage operations, advertising, retail sales, research, and the international affiliates of the firm. She
was the CCO and General Counsel at Brown & Company, a discount broker-dealer. She also was an Enforcement
Attorney with the SEC and an associate in private corporate practice. She has a JD and an MBA from Boston
University and a BA from Regis College. She holds the Series 3, 4, 7, 8, 14, 24, and 63 licenses.
Areas of Responsibility: Compliance
Duties: Susan Boudrot oversees the compliance functions of TD Ameritrade.

Scott Seiffert, Chief Financial Officer, TD Ameritrade Futures & Forex

Business Address: 200 South 108th Avenue, Omaha, NE 68154
Background: Scott Seiffert has more than 20 years of financial services industry experience and is Chief Financial
Officer at TD Ameritrade. He has been with TD Ameritrade since July 2016 and prior to joining, held several senior
finance positions with Wells Fargo Advisors. Scott previously worked in internal audit at Edward Jones and spent
almost 12 years in public accounting. Scott earned a bachelor's degree in Business Administration from the
University of Missouri-St. Louis. He holds a Series 27 license.
Areas of Responsibility: Accounting and Finance
Duties: Scott Seiffert oversees the accounting and financial functions for TD Ameritrade Futures & Forex.

Kirk Evangeliou, Chief Compliance Officer, TD Ameritrade Futures & Forex LLC
Business Address: 1 Plaza Four A, Jersey City, NJ 07311
Background: Kirk Evangeliou has worked in the financial industry for over 20 years. He is currently Managing
Director, Retail & Active Trader Compliance at TD Ameritrade Futures & Forex and is responsible for Active Trader
Compliance including futures and forex compliance. He also currently serves as the Chief Compliance Officer of TD
Ameritrade, Inc. Broker Dealer responsible for Retail and Product Compliance. Prior to joining TD Ameritrade
Futures & Forex, Kirk has held a variety of regulatory and compliance roles in the global financial services industry
serving in various Bank, Broker Dealer, and Investment Advisor Compliance and Operations roles. Kirk worked at
Fidelity where he managed and led the development and enhancement of the Internal Controls and Registration &
Licensing Groups for the retail brokerage firm. Additionally, while there, he was responsible for the oversight of the
Pyramis Investment Advisor and Broker Dealer Supervisory Structure, Sales Practices, AML, International, and
Private Offerings Compliance Programs. Prior to that, he worked at Leerink Swann & Company where he oversaw
firm compliance with regulatory rules as they pertained to the firm's Private Client and Institutional Sales Trading
Divisions. He has also held positions overseeing bank, brokerage, and wire house back office operations
departments supporting Retail and Institutional business lines. Kirk has a Bachelor of Science degree from
Providence College and holds the Series 3, 7, 24, 27, 34, and 63 licenses.
Areas of Responsibility: Compliance
Duties: Kirk Evangeliou oversees the compliance functions of TD Ameritrade Futures & Forex.

FIRM'S BUSINESS
TD Ameritrade Futures & Forex's business activity caters to self-directed retail futures and forex customers. Our
customer base is more than 90% individual or joint accounts. TD Ameritrade Futures & Forex clients do not have

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direct market or API access to the futures markets. TD Ameritrade Futures & Forex currently offers the ability to
execute orders on the CME Group (CME, CBOT, NYMEX & COMEX) ICE US, and CFE. Current product groups offered
to our customers to trade include: interest rates; metals; currency; grains; stock index; energy, softs; forest; and
livestock futures contracts. TD Ameritrade Futures & Forex offers approximately 77 different commission and non-
commission forex pairs. This business activity is supported by one hundred percent (100%) of the firm's assets and
capital.

FCM CUSTOMER BUSINESS

TD Ameritrade Futures & Forex is owned by TD Ameritrade Online Holding Corporation, which is a wholly owned
subsidiary of TD Ameritrade Holding Corporation (along with its subsidiaries "AMTD"), a publicly held company with
a market capitalization of over $27 billion and liquid assets in excess of $200 million. AMTD, through its broker-
dealer and FCM subsidiary, serves an investor base comprised of over 11.0 million funded customer accounts with
over $1.1 trillion in customer assets.

TD Ameritrade Futures & Forex caters to self-directed retail futures and forex customers. Our customer base is
more than 90% individual or joint accounts. TD Ameritrade Futures & Forex clients do not have direct market or API
access to the futures markets. TD Ameritrade Futures & Forex currently offers the ability to execute orders on the
CME Group (CME, CBOT, NYMEX, & COMEX), ICE US, and CFE. Current product groups offered to our customers to
trade include: interest rates, metals, currency, grains, stock index, energy, softs, forest, and livestock futures
contracts. TD Ameritrade Futures & Forex offers approximately 77 different commission and non-commission forex
pairs.

TD Ameritrade Futures & Forex does not own any futures exchange clearing memberships or self-clear any futures
or futures options products. TD Ameritrade Futures & Forex utilizes three clearing firms, Wedbush Securities Inc.,
Wells Fargo Securities LLC, and ABN AMRO Clearing Chicago LLC, to clear its futures business. TD Ameritrade
Futures & Forex is not involved directly or indirectly in taking proprietary trading positions in listed derivatives or
engaging in arbitrage activities of any kind. In addition, TD Ameritrade Futures & Forex is not involved in clearing
swaps or engaged in over-the-counter derivatives trading. TD Ameritrade Holding's international business is
currently limited to its offering of TD Ameritrade Singapore Pte. Ltd. and TD Ameritrade Hong Kong Ltd.

PERMITTED DEPOSITORIES AND COUNTERPARTIES

TD Ameritrade Futures & Forex will invest futures customer funds in cash and/or U.S. Government securities. The
customer segregated funds will remain in cash and/or U.S. Government securities held at US Bank, ABN AMRO,
Wells Fargo Securities LLC, and Wedbush Securities Inc. The omnibus accounts titled "TD Ameritrade Futures &
Forex LLC Regulation 1.20 Customer Segregated Account" will be a combination of cash and U.S. Government
securities pursuant to § 1.25.

TD Ameritrade Futures & Forex maintains and adheres to a separate Depository Selection Policy. TD Ameritrade
Futures & Forex performs regular reviews of their bank depositories, counterparties, and vendors to insure that
they can support the futures and forex business. The reviews include, but are not limited to:

A yearly review of the operational capabilities, ideally via a SOC1 or external audit.
A quarterly financial review by the Treasury department which includes, but is not limited to, a review of the
credit ratings from Moody's and S&P.
A quarterly operational review focused on any issues or concerns raised during the prior quarter.
A quarterly review of any regulatory actions or fines as well as any major changes in personnel supporting TD
Ameritrade Futures & Forex's business with the depository, counterparty, or vendor.

The results of each of these reviews are shared during the quarterly TD Ameritrade Futures & Forex Risk Committee

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meeting. An appropriate action plan, if needed, will be put in place. It is important to note that additional reviews
may take place outside of the listed formal reviews. Depending on the depth of the review, it may or may not be
reported to the Risk Committee.

MATERIAL RISKS
While TD Ameritrade Futures & Forex does not believe any of the following risks to be material, TD Ameritrade
Futures & Forex recognizes that customers may be subject to liquidity, credit, and/or counterparty risks by
entrusting funds with TD Ameritrade Futures & Forex. TD Ameritrade Futures & Forex attempts to limit these risks
by maintaining excess capital and investments in cash or highly liquid, readily accessible products.

In order to assure that it is in compliance with its regulatory capital requirements and that it has sufficient liquidity
to meet its ongoing business obligations, TD Ameritrade Futures & Forex holds a significant portion of its
nonsegregated liquid assets in cash, highly liquid money market mutual funds, and/or U.S. Treasury securities
guaranteed as to principal and interest. As of the date of this disclosure, all nonsegregated liquid funds are held in
either 1) cash in a bank account or 2) highly liquid money market mutual funds, both of which are in the name of
TD Ameritrade Futures & Forex. Therefore, all nonsegregated liquid assets are available on demand.

TD Ameritrade Futures & Forex carries no debt on the balance sheet and is therefore not financially leveraged. TD
Ameritrade Futures & Forex currently has approximately US$109 million of net capital as of March 1, 2018. TD
Ameritrade Futures & Forex holds 100% of investments in overnight cash or cash equivalents, and therefore has
adequate available liquidity at all times. Principal liabilities are payables to clients, accounts payable, and deferred
income taxes.

TD Ameritrade Futures & Forex holds customer funds in cash and U.S. Treasury securities within properly
established §1.20 accounts in the name of TD Ameritrade Futures & Forex LLC and in compliance with §1.25.
Customer funds are not invested in any affiliated entity. The weighted average maturity of customer funds invested
in U.S. Treasuries is 0.06 years and the weighted average yield is 1.54 percent.

TD Ameritrade Futures & Forex parent corporation, TD Ameritrade Holding Corp., is rated A and A2 by S&P and
Moody's, respectively.

TD Ameritrade Futures & Forex has no material commitments.

MATERIAL COMPLAINTS OR ACTIONS

There are no material administrative, civil, enforcement, or criminal complaints or actions filed against the FCM
where such complaints or actions have not concluded, and any enforcement complaints or actions filed against the
FCM during the last three years.

Other Legal and Regulatory Matters - TD Ameritrade Futures & Forex may be subject to a number of other lawsuits,
arbitrations, claims, and other legal proceedings in connection with its business. Some of these legal actions include
claims for substantial or unspecified compensatory and/or punitive damages. In addition, in the normal course of
business, TD Ameritrade Futures & Forex discusses matters with its regulators raised during regulatory
examinations or otherwise subject to their inquiry. These matters could result in censures, fines, penalties, or other
sanctions. In light of the uncertainties involved in such matters, TD Ameritrade Futures & Forex is unable to predict
the outcome or the timing of the ultimate resolution of these matters, or the potential losses, fines, penalties, or
equitable relief, if any, that may result, and it is possible that the ultimate resolution of one or more of these
matters may be material to TD Ameritrade Futures & Forex's results of operations for a particular reporting period.

CUSTOMER FUNDS SEGREGATION

Customer Accounts. FCMs may maintain up to three different types of accounts for customers, depending on the

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products a customer trades:

(i) a Customer Segregated Account for customers that trade futures and options on futures listed on U.S.
futures exchanges;
(ii) a 30.7 Account for customers that trade futures and options on futures listed on foreign boards of trade
(At this time, TD Ameritrade Futures & Forex customers do not engage in activity that requires a 30.7
account.); and
(iii) a Cleared Swaps Customer Account for customers trading swaps that are cleared on a DCO registered
with the Commission (At this time, TD Ameritrade Futures & Forex customers do not engage in activity that
requires a cleared swaps customer account.).

The requirement to maintain these separate accounts reflects the different risks posed by the different products.
Cash, securities, and other collateral (collectively, Customer Funds) required to be held in one type of account, for
example, the Customer Segregated Account, may not be commingled with funds required to be held in another
type of account, for example, the 30.7 Account, except as the Commission may permit by order. For example, the
Commission has issued orders authorizing ICE Clear Europe Limited, which is registered with the Commission as a
DCO, and its FCM clearing members: (i) to hold in Cleared Swaps Customer Accounts Customer Funds used to
margin both (a) Cleared Swaps and (b) foreign futures and foreign options traded on ICE Futures Europe, and to
provide for portfolio margining of such Cleared Swaps and foreign futures and foreign options; and (ii) to hold in
Customer Segregated Accounts Customer Funds used to margin both (c) futures and options on futures traded on
ICE Futures U.S. and (d) foreign futures and foreign options traded on ICE Futures Europe, and to provide for
portfolio margining of such transactions.

Customer Segregated Account. Funds that customers deposit with an FCM, or that are otherwise required to be
held for the benefit of customers, to margin futures and options on futures contracts traded on futures exchanges
located in the U.S., for example, designated contract markets, are held in a Customer Segregated Account in
accordance with section 4d(a)(2) of the Commodity Exchange Act and Commission Rule 1.20. Customer
Segregated Funds held in the Customer Segregated Account may not be used to meet the obligations of the FCM
or any other person, including another customer.

All Customer Segregated Funds may be commingled in a single account, such as a customer omnibus account, and
held with: (i) a bank or trust company located in the U.S.; (ii) a bank or trust company located outside of the U.S.
that has in excess of US$1 billion of regulatory capital; (iii) an FCM; or (iv) a DCO. Such commingled account must
be properly titled to make clear that the funds belong to, and are being held for the benefit of, the FCM's
customers. Unless a customer provides instructions to the contrary, an FCM may hold Customer Segregated Funds
only: (i) in the U.S.; (ii) in a money center country; or (iii) in the country of origin of the currency.

An FCM must hold sufficient U.S. dollars in the U.S. to meet all U.S. dollar obligations and sufficient funds in each
other currency to meet obligations in such currency. Notwithstanding the foregoing, assets denominated in a
currency may be held to meet obligations denominated in another currency (other than the U.S. dollar) as follows:
(i) U.S. dollars may be held in the U.S. or in money center countries1 to meet obligations denominated in any other
currency; and (ii) funds in money center currencies2 may be held in the U.S. or in money center countries to meet
obligations denominated in currencies other than the U.S. dollar.

30.7 Account. Funds that 30.7 Customers deposit with an FCM, or that are otherwise required to be held for the
benefit of customers, to margin futures and options on futures contracts traded on foreign boards of trade, for
example, 30.7 Customer Funds, and sometimes referred to as the foreign futures and foreign options
secured amount, are held in a 30.7 Account in accordance with Commission Rule 30.7.

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Funds required to be held in the 30.7 Account for or on behalf of 30.7 Customers may be commingled in an
omnibus account and held with: (i) a bank or trust company located in the U.S.; (ii) a bank or trust company
located outside the U.S. that has in excess of US$1 billion in regulatory capital; (iii) an FCM; (iv) a DCO; (v) the
clearing organization of any foreign board of trade; (vi) a foreign broker; or (vii) such clearing organization's or
foreign broker's designated depositories. Such commingled account must be properly titled to make clear that the
funds belong to, and are being held for the benefit of, the FCM's 30.7 Customers. As explained below, Commission
Rule 30.7 restricts the amount of such funds that may be held outside of the U.S.

Customers trading on foreign markets assume additional risks. Laws or regulations will vary depending on the
foreign jurisdiction in which the transaction occurs, and funds held in a 30.7 Account outside of the U.S. may not
receive the same level of protection as Customer Segregated Funds. If the foreign broker carrying 30.7 Customer
positions fails, the broker will be liquidated in accordance with the laws of the jurisdiction in which it is organized,
which laws may differ significantly from the U.S. Bankruptcy Code. Return of 30.7 Customer Funds to the U.S. will
be delayed and likely will be subject to the costs of administration of the failed foreign broker in accordance with
the law of the applicable jurisdiction, as well as possible other intervening foreign brokers, if multiple foreign
brokers were used to process the U.S. customers' transactions on foreign markets.

If the foreign broker does not fail but the 30.7 Customers' U.S. FCM fails, the foreign broker may want to assure
that appropriate authorization has been obtained before returning the 30.7 Customer Funds to the FCM's trustee,
which may delay their return. If both the foreign broker and the U.S. FCM were to fail, potential differences
between the trustee for the U.S. FCM and the administrator for the foreign broker, each with independent fiduciary
obligations under applicable law, may result in significant delays and additional administrative expenses. Use of
other intervening foreign brokers by the U.S. FCM to process the trades of 30.7 Customers on foreign markets may
cause additional delays and administrative expenses.

To reduce the potential risk to 30.7 Customer Funds held outside of the U.S., Commission Rule 30.7 generally
provides that an FCM may not deposit or hold 30.7 Customer Funds in permitted accounts outside of the U.S.
except as necessary to meet margin requirements, including prefunding margin requirements, established by rule,
regulation, or order of the relevant foreign boards of trade or foreign clearing organizations, or to meet margin calls
issued by foreign brokers carrying the 30.7 Customers' positions. The rule further provides, however, that in order
to avoid the daily transfer of funds from accounts in the U.S., an FCM may maintain in accounts located outside of
the U.S. an additional amount of up to 20% of the total amount of funds necessary to meet margin and prefunding
margin requirements to avoid daily transfers of funds.

Cleared Swaps Customer Account. Funds deposited with an FCM, or otherwise required to be held for the
benefit of customers, to margin swaps cleared through a registered DCO, that is, Cleared Swaps Customer
Collateral, are held in a Cleared Swaps Customer Account in accordance with the provisions of section 4d(f) of
the Act and Part 22 of the Commission's rules. Cleared Swaps Customer Accounts are sometimes referred to as
LSOC Accounts. LSOC is an acronym for "legally separated, operationally commingled." Funds required to be held in
a Cleared Swaps Customer Account may be commingled in an omnibus account and held with: (i) a bank or trust
company located in the U.S.; (ii) a bank or trust company located outside of the U.S. that has in excess of US$1
billion of regulatory capital; (iii) a DCO; or (iv) another FCM. Such commingled account must be properly titled to
make clear that the funds belong to, and are being held for the benefit of, the FCM's Cleared Swaps Customers.

Investment of Customer Funds. Section 4d(a)(2) of the Act authorizes FCMs to invest Customer Segregated
Funds in obligations of the United States, in general obligations of any State or of any political subdivision thereof,
and in obligations fully guaranteed as to principal and interest by the United States. Section 4d(f) authorizes FCMs
to invest Cleared Swaps Customer Collateral in similar instruments.

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Commission Rule 1.25 authorizes FCMs to invest Customer Segregated Funds, Cleared Swaps Customer Collateral,
and 30.7 Customer Funds in instruments of a similar nature. Commission rules further provide that the FCM may
retain all gains earned and is responsible for investment losses incurred in connection with the investment of
Customer Funds.

Permitted investments include:

(i) Obligations of the United States and obligations fully guaranteed as to principal and interest by the United
States (U.S. government securities);
(ii) General obligations of any State or of any political subdivision thereof (municipal securities);
(iii) Obligations of any United States government corporation or enterprise sponsored by the United States
government (U.S. agency obligations)3;
(iv) Certificates of deposit issued by a bank (certificates of deposit) as defined in section 3(a)(6) of the
Securities Exchange Act of 1934, or a domestic branch of a foreign bank that carries deposits insured by the
Federal Deposit Insurance Corporation;
(v) Commercial paper fully guaranteed as to principal and interest by the United States under the Temporary
Liquidity Guarantee Program as administered by the Federal Deposit Insurance Corporation (commercial
paper);
(vi) Corporate notes or bonds fully guaranteed as to principal and interest by the United States under the
Temporary Liquidity Guarantee Program as administered by the Federal Deposit Insurance Corporation
(corporate notes or bonds); and
(vii) Interests in money market mutual funds.

The duration of the securities in which an FCM invests Customer Funds cannot exceed, on average, two years.

An FCM may also engage in repurchase and reverse repurchase transactions with nonaffiliated registered broker-
dealers, provided such transactions are made on a delivery versus payment basis and involve only permitted
investments. All funds or securities received in repurchase and reverse repurchase transactions with Customer
Funds must be held in the appropriate Customer Account, that is, Customer Segregated Account, 30.7 Account, or
Cleared Swaps Customer Account. Further, in accordance with the provisions of Commission Rule 1.25, all such
funds or collateral must be received in the appropriate Customer Account on a delivery versus payment basis in
immediately available funds4.

No SIPC Protection. Although TD Ameritrade, Inc. is a registered broker-dealer, it is important to understand that
the funds you deposit with TD Ameritrade Futures & Forex LLC for trading futures and options on futures contracts
on either U.S. or foreign markets or cleared swaps are not protected by the Securities Investor Protection
Corporation.

Further, Commission rules require TD Ameritrade Futures & Forex to hold funds deposited to margin futures and
options on futures contracts traded on U.S. designated contract markets in Customer Segregated Accounts.
Similarly, TD Ameritrade Futures & Forex must hold funds deposited to margin cleared swaps and futures and
options on futures contracts traded on foreign boards of trade in a Cleared Swaps Customer Account or a 30.7
Account, respectively. In computing its Customer Funds requirements under relevant Commission rules, TD
Ameritrade Futures & Forex may only consider those Customer Funds actually held in the applicable Customer
Accounts and may not apply free funds in an account under identical ownership but of a different classification or
account type (for example, securities, Customer Segregated, 30.7) to an account's margin deficiency. In order to
be used for margin purposes, the funds must actually transfer to the identically owned undermargined account.

For additional information on the protection of customer funds, please see the Futures Industry Association's

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"Protection of Customer Funds Frequently Asked Questions" located at

[Link]

FILING A COMPLAINT
A customer that wishes to file a complaint about TD Ameritrade Futures & Forex or one of its employees with the
Commission can contact the Division of Enforcement either electronically at
[Link] or by calling the Division of Enforcement toll-free at 866-FON-
CFTC (866-366-2382).

A customer may file a complaint about TD Ameritrade Futures & Forex or one of its employees with the National
Futures Association electronically at [Link]/basicnet/[Link] or by calling NFA directly
at 800-621-3570.

RELEVANT FINANCIAL DATA

TD Ameritrade Futures & Forex's annual audited financial statements are available here:
[Link]
en_us/resources/pdf/TDAFF_Website_certified_annual_report.pdf

Financial Data as of month end February, 2018

Total Equity US$180,134,236
Regulatory Capital US$110,543,552
Net worth US$180,134,236
Proprietary margin requirements as a percentage of the aggregate margin requirement for:
futures customers US$0
cleared swaps customers N/A
30.7 customers N/A
Number of futures customers, cleared swaps customers, and 30.7 customers that comprise 50% of the
FCM's total funds held for:
futures customers 155
cleared swaps customers N/A
30.7 customers N/A
Aggregate notional value of all nonhedged, principal over-the-counter transactions N/A
Unsecured lines of credit the FCM has obtained but not yet drawn upon* US$22,500,000
Aggregated amount of financing the FCM provides for customer transactions involving illiquid financial 0
products
Percentage of futures customer, cleared swap customer, and 30.7 customer receivable balances that the 0
FCM had to writeoff as uncollectable during the past 12-month period

*The generic source is TD Ameritrade Holding Corp. and the purpose is Contingent liquidity.

At this time, TD Ameritrade Futures & Forex customers do not engage in activity that requires a 30.7 account or in
cleared swap activity. As such, TD Ameritrade Futures & Forex does not have any data to report 30.7 activity or
cleared swap activity.

Additional financial information on all FCMs is also available on the Commission's website at:
[Link]

Customers should be aware that the National Futures Association (NFA) publishes on its website certain financial
information with respect to each FCM. The FCM Capital Report provides each FCM's most recent month-end

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adjusted net capital, required net capital, and excess net capital. (Information for a twelve- month period is
available.) In addition, NFA publishes twice-monthly a Customer Segregated Funds report, which shows for each
FCM: (i) total funds held in Customer Segregated Accounts; (ii) total funds required to be held in Customer
Segregated Accounts; and (iii) excess segregated funds, that is, the FCM's Residual Interest. This report also shows
the percentage of Customer Segregated Funds that are held in cash and each of the permitted investments under
Commission Rule 1.25. Finally, the report indicates whether the FCM held any Customer Segregated Funds during
that month at a depository that is an affiliate of the FCM.

The report shows the most recent semimonthly information, but the public will also have the ability to see
information for the most recent twelve-month period. A 30.7 Customer Funds report and a Customer Cleared
Swaps Collateral report provides the same information with respect to the 30.7 Account and the Cleared Swaps
Customer Account.

The above financial information reports can be found by conducting a search for a specific FCM in NFA's BASIC
system ([Link] and then clicking on "View Financial Information" on the FCM's
BASIC Details page.

RISK MANAGEMENT SUMMARY

TD Ameritrade Futures & Forex has established, maintains, and enforces a system of risk management policies and
procedures designed to monitor and manage the risks associated with the activities of TD Ameritrade Futures &
Forex. TD Ameritrade Futures & Forex maintains written policies and procedures that describe the Risk Management
Program, which will be submitted to the CFTC per § 1.11. As part of the Risk Management Program, TD Ameritrade
Futures & Forex has established and maintains a Risk Management Unit with sufficient authority, qualified
personnel, and financial, operational, and other resources to carry out the Risk Management Program. The Risk
Management Unit reports directly to Senior Management and is independent from the business unit.

Risk Management Program

TD Ameritrade Futures & Forex currently has multiple, robust risk management processes in place. TD Ameritrade
Futures & Forex's Risk Management Program includes, but is not limited to, identifying risks and risk tolerance
limits, periodic risk exposure reports, and policies and procedures to monitor segregation, capital, and operational
risks.

Identifying Risks and Risk Tolerance Limits

TD Ameritrade Futures & Forex's Risk Management Program takes into account market, credit, liquidity, foreign
currency, legal, operational, settlement, segregation, technological, capital, and other applicable risks with a
description of the risk tolerance limits and methodology for these limits.

Periodic Risk Exposure Reports

The Risk Management Unit provides senior management and the CFTC quarterly written reports setting forth all
applicable risk exposures of TD Ameritrade Futures & Forex, any recommended or completed changes to the Risk
Management Program and time frame for implementing recommended changes, and the status of any incomplete
implementation of previously recommended changes to the Risk Management Program.

Segregation Risk
As part of TD Ameritrade Futures & Forex's Risk Management Program in regards to segregation risk, the following
processes and procedures have been established:

Policies designed to manage segregation risk, including a process for the evaluation of depositories for
segregated funds;
A process designed to monitor the residual interest TD Ameritrade Futures & Forex seeks to maintain in the

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segregated funds accounts;

A process designed for the withdrawal of cash or property from accounts holding segregated funds, where
withdrawal is not for payment or on behalf of TD Ameritrade Futures & Forex's customers;
A process for assessing the appropriateness of specific investments of segregated funds;
Procedures requiring the appropriate separation of duties among individuals responsible for compliance with
regulations relating to the protection and financial reporting of segregated funds;
A process and procedures for timely recording of transactions;
A program for annual training of all officers and employees regarding the segregation requirements for
segregated funds;
Policies for assessing the liquidity and mark-to-market valuation of all noncash assets held as segregated funds.

Operational Risk
TD Ameritrade Futures & Forex's Risk Management Program includes automated controls designed to prevent the
placing of erroneous trade orders. The Risk Management Program also ensures the supervision, maintenance,
testing, and inspection of automated trading programs.

Capital Risk
TD Ameritrade Futures & Forex's Risk Management Program ensures that TD Ameritrade Futures & Forex has
sufficient capital to be in compliance with the Act and the regulations, and sufficient capital and liquidity to meet
the reasonably foreseeable needs of TD Ameritrade Futures & Forex.

Supervision and Testing of the Risk Management Program

TD Ameritrade Futures & Forex's Risk Management Program includes a supervisory system that is reasonably
designed to ensure that the policies and procedures are diligently followed. The Risk Management Program is
reviewed and tested at least annually by internal audit staff or a third party audit service that is independent of the
business unit. TD Ameritrade Futures & Forex documents all internal and external reviews of the Risk Management
Program.

Distribution of the Risk Management Policies and Procedures

TD Ameritrade Futures & Forex's written risk management procedures are distributed to supervisory personnel and
a record of such distribution is maintained. Written approvals and all records or reports are maintained in
accordance with § 1.31.

Despite TD Ameritrade Futures & Forex's efforts to manage risk through policies, procedures, and governance
structures, there can be no assurance that TD Ameritrade Futures & Forex will not sustain material losses as part of
its operation.

LEVERAGE RATIO
The Firm's Leverage Ratio is provided pursuant to CFTC Rule 1.55(k)(5). As of February 28, 2018, the Firm's
Leverage Ratio was 1.09.

This Disclosure Document was first used on July 16, 2018.

1Money center countries means Canada, France, Italy, Germany, Japan, and the United Kingdom.
2Money center currencies means the currency of any money center country and the Euro.
3
Obligations issued by the Federal National Mortgage Association or the Federal Home Loan Mortgage Association are permitted only
while these entities operate under the conservatorship or receivership of the Federal Housing Finance Authority with capital support

[Link] Page 12 of 24
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from the United States.

4As discussed below, NFA publishes twice-monthly a report, which shows for each FCM, inter alia, the percentage of Customer Funds
that are held in cash and each of the permitted investments under Commission Rule 1.25. The report also indicates whether the FCM
held any Customer Funds during that month at a depository that is an affiliate of the FCM.

RISK DISCLOSURE STATEMENT

The risk of loss in trading commodity futures contracts can be substantial. You should, therefore, carefully consider
whether such trading is suitable for you in light of your circumstances and financial resources. You should be aware
of the following points:

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

2. The funds you deposit with a futures commission merchant for trading futures positions are not protected by
insurance in the event of the bankruptcy or insolvency of the futures commission merchant, or in the event your
funds are misappropriated.

3. The funds you deposit with a futures commission merchant for trading futures positions are not protected by the
Securities Investor Protection Corporation even if the futures commission merchant is registered with the Securities
and Exchange Commission as a broker or dealer.

4. The funds you deposit with a futures commission merchant are generally not guaranteed or insured by a
derivatives clearing organization in the event of the bankruptcy or insolvency of the futures commission merchant,
or if the futures commission merchant is otherwise unable to refund your funds. Certain derivatives clearing
organizations, however, may have programs that provide limited insurance to customers. You should inquire of your
futures commission merchant whether your funds will be insured by a derivatives clearing organization and you
should understand the benefits and limitations of such insurance programs.

5. The funds you deposit with a futures commission merchant are not held by the futures commission merchant in a
separate account for your individual benefit. Futures commission merchants commingle the funds received from
customers in one or more accounts and you may be exposed to losses incurred by other customers if the futures
commission merchant does not have sufficient capital to cover such other customers' trading losses.

6. The funds you deposit with a futures commission merchant may be invested by the futures commission merchant
in certain types of financial instruments that have been approved by the Commission for the purpose of such
investments. Permitted investments are listed in Commission Regulation 1.25 and include: U.S. government
securities; municipal securities; money market mutual funds; and certain corporate notes and bonds. The futures
commission merchant may retain the interest and other earnings realized from its investment of customer funds.
You should be familiar with the types of financial instruments that a futures commission merchant may invest
customer funds in.

7. Futures commission merchants are permitted to deposit customer funds with affiliated entities, such as affiliated

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banks, securities brokers or dealers, or foreign brokers. You should inquire as to whether your futures commission
merchant deposits funds with affiliates and assess whether such deposits by the futures commission merchant with
its affiliates increases the risks to your funds.

8. You should consult your futures commission merchant concerning the nature of the protections available to
safeguard funds or property deposited for your account.

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

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

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

12. In addition to the risks noted in the paragraphs enumerated above, you should be familiar with the futures
commission merchant you select to entrust your funds for trading futures positions. The Commodity Futures Trading
Commission requires each futures commission merchant to make publicly available on its website firm specific
disclosures and financial information to assist you with your assessment and selection of a futures commission
merchant. Information regarding this futures commission merchant may be obtained by visiting our website,
[Link]

ALL OF THE POINTS NOTED ABOVE APPLY TO ALL FUTURES TRADING WHETHER FOREIGN OR
DOMESTIC. IN ADDITION, IF YOU ARE CONTEMPLATING TRADING FOREIGN FUTURES OR OPTIONS
CONTRACTS, YOU SHOULD BE AWARE OF THE FOLLOWING ADDITIONAL RISKS:

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

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

THIS BRIEF STATEMENT CANNOT, OF COURSE, DISCLOSE ALL THE RISKS AND OTHER ASPECTS OF THE
COMMODITY MARKETS.

Risk Disclosure for Futures and Options:

Appendix A to CFTC Rule 1.55 (c) - Generic Risk Disclosure Statement

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This brief statement does not disclose all of the risks and other significant aspects of trading in futures and options.
In light of the risks, you should undertake such transactions only if you understand the nature of the contracts (and
contractual relationships) into which you are entering and the extent of your exposure to risk. Trading in futures
and options is not suitable for many members of the public. You should carefully consider whether trading is
appropriate for you in light of your experience, objectives, financial resources, and other relevant circumstances

Futures
1. Effect of "Leverage" or "Gearing"
Transactions in futures carry a high degree of risk. The amount of initial margin is small relative to the value of the
futures contract, so that transactions are "leveraged" or "geared". A relatively small market movement will have a
proportionately larger impact on the funds you have deposited or will have to deposit: this may work against you as
well as for you. You may sustain a total loss of initial margin funds and any additional funds deposited with the firm
to maintain your position. If the market moves against your position or margin levels are increased, you may be
called upon to pay substantial additional funds on short notice to maintain your position. If you fail to comply with a
request for additional funds within the time prescribed, your position may be liquidated at a loss and you will be
liable for any resulting deficit.

2. Risk-reducing orders or strategies

The placing of certain orders (e.g., "stop-loss" orders, where permitted, under local law, or "stop-limit" orders)
which are intended to limit losses to certain amounts may not be effective because market conditions may make it
impossible to execute such orders. Strategies using combinations of positions, such as "spread" and "straddle"
positions, may be as risky as taking simple "long" or "short" positions.

Options
3. Variable degree of risk
Transactions in options carry a high degree of risk. Purchasers and sellers of options should familiarize themselves
with the type of option (that is, put or call) which they contemplate trading and the associated risks. You should
calculate the extent to which the value of the options must increase for your position to become profitable, taking
into account the premium and all transaction costs.

The purchaser of options may offset or exercise the options or allow the options to expire. The exercise of an option
results either in a cash settlement or in the purchaser acquiring or delivering the underlying interest. If the option is
on a future, the purchaser will acquire a futures position with associated liabilities for margin (see the section on
Futures above). If the purchased options expire worthless, you will suffer a total loss of your investment which will
consist of the option premium plus transaction costs. If you are contemplating purchasing deep out-of- the-money
options, you should be aware that the chance of such options becoming profitable ordinarily is remote.

Selling ("writing" or "granting") an option generally entails considerably greater risk than purchasing options.
Although the premium received by the seller is fixed, the seller may sustain a loss well in excess of that amount.
The seller will be liable for additional margin to maintain the position if the market moves unfavorably. The seller
will also be exposed to the risk of the purchaser exercising the option and the seller being obligated to either settle
the option in cash or to acquire or deliver the underlying interest. If the option is on a future, the seller will acquire
a position in a future with associated liabilities for margin (see the section on Futures above). If the option is
"covered" by the seller holding a corresponding position in the underlying interest or a future or another option, the
risk may be reduced. If the option is not covered, the risk of loss can be unlimited.

Certain exchanges in some jurisdictions permit deferred payment of the option premium, exposing the purchaser to
liability for margin payments not exceeding the amount of the premium. The purchaser is still subject to the risk of
losing the premium and transaction costs. When the option is exercised or expires, the purchaser is responsible for

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any unpaid premium outstanding at that time.

Additional risks common to futures and options

4. Terms and conditions of contracts

You should ask the firm with which you deal about the terms and conditions of the specific futures or options which
you are trading and associated obligations (e.g., the circumstances under which you may become obligated to
make or take delivery of the underlying interest of a futures contract and, in respect of options, expiration dates,
and restrictions on the time for exercise). Under certain circumstances, the specifications of outstanding contracts
(including the exercise price of an option) may be modified by the exchange or clearing house to reflect changes in
the underlying interest.

5. Suspension or restriction of trading and pricing relationships

Market conditions (for example, illiquidity) and/or the operation of the rules of certain markets (for example, the
suspension of trading in any contract or contract month because of price limits or "circuit breakers") may increase
the risk of loss by making it difficult or impossible to effect transactions or liquidate/offset positions. If you have
sold options, this may increase the risk of loss.

Further, normal pricing relationships between the underlying interest and the future, and the underlying interest
and the option may not exist. This can occur when, for example, the futures contract underlying the option is
subject to price limits while the option is not. The absence of an underlying reference price may make it difficult to
judge "fair" value.

6. Deposited cash and property

You should familiarize yourself with the protections accorded money or other property you deposit for domestic and
foreign transactions, particularly in the event of a firm insolvency or bankruptcy. The extent to which you may
recover your money or property may be governed by specified legislation or local rules. In some jurisdictions,
property which had been specifically identifiable as your own will be prorated in the same manner as cash for
purposes of distribution in the event of a shortfall.

7. Commission and other charges

Before you begin to trade, you should obtain a clear explanation of all commissions, fees, and other charges for
which you will be liable. These charges will affect your net profit (if any) or increase your loss.

8. Transactions in other jurisdictions

Transactions on markets in other jurisdictions, including markets formally linked to a domestic market, may expose
you to additional risk. Such markets may be subject to regulation which may offer different or diminished investor
protection. Before you trade, you should inquire about any rules relevant to your particular transactions. Your local
regulatory authority will be unable to compel the enforcement of the rules of regulatory authorities or markets in
other jurisdictions where your transactions have been effected. You should ask the firm with which you deal for
details about the types of redress available in both your home jurisdiction and other relevant jurisdictions before
you start to trade.

9. Currency risks
The profit or loss in transactions in foreign-currency-denominated contracts (whether they are traded in your own
or another jurisdiction) will be affected by fluctuations in currency rates where there is a need to convert from the
currency denomination of the contract to another currency.

10. Trading facilities

Most open-outcry and electronic trading facilities are supported by computer-based component systems for the

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order-routing, execution, matching, registration, or clearing of trades. As with all facilities and systems, they are
vulnerable to temporary disruption or failure. Your ability to recover certain losses may be subject to limits on
liability imposed by the system provider, the market, the clearing house, and/or member firms. Such limits may
vary: you should ask the firm with which you deal for details in this respect.

11. Electronic trading

Trading on an electronic trading system may differ not only from trading in an open-outcry market but also from
trading on other electronic trading systems. If you undertake transactions on an electronic trading system, you will
be exposed to risk associated with the system, including the failure of hardware and software. The result of any
system failure may be that your order is either not executed according to your instructions or is not executed at all.

12. Off-exchange transactions

In some jurisdictions, and only then in restricted circumstances, firms are permitted to effect off-exchange
transactions. The firm with which you deal may be acting as your counterparty to the transaction. It may be difficult
or impossible to liquidate an existing position, to assess the value, to determine a fair price, or to assess the
exposure to risk. For these reasons, these transactions may involve increased risks. Off-exchange transactions may
be less regulated or subject to a separate regulatory regime. Before you undertake such transactions, you should
familiarize yourself with applicable rules and attendant risks.

UNIFORM FUTURES AND OPTIONS ON FUTURES DISCLOSURES

CROSS TRADE CONSENT

TD Ameritrade Futures & Forex LLC, its officers, directors, employees, or affiliates, or other customers of
TD Ameritrade Futures & Forex LLC or of the servicing floor broker may be from time to time on the opposite side of
orders for physicals or for purchase or sale of futures contracts and option contracts placed for your Account in
conformity with regulations of the Commodity Futures Trading Commission and the by-laws, rules, and regulations
of the applicable market (and its clearing organization, if any) on which such order is executed.

NOTICE REGARDING AVERAGE PRICE SYSTEM ("APS")

You should be aware that certain U.S. and non-U.S. exchanges, including the CME and CBOT, may now or in the
future allow a futures commission merchant ("FCM") such as TD Ameritrade Futures & Forex LLC to confirm trades
executed on such exchanges to some or all of their customers on an average price basis regardless of whether the
exchanges have average price systems of their own. Average prices that are not calculated by an exchange system
will be calculated by your FCM. In either case, trades that are confirmed to you at average prices will be designated
as such on your daily and monthly statements.

APS enables a clearing firm to confirm to customers an average price when multiple execution prices are received
on an order or series of orders for the same accounts. For example, if an order transmitted by an account manager
on behalf of several customers is executed at more than one price, those prices may be averaged and the average
may be confirmed to each customer. Customers may choose whether to use APS, and may request that APS be
used for discretionary or non-discretionary accounts.

An order subject to APS must be for the same commodity. An APS order may be used for futures, options, or
combination transactions. An APS order for futures must be for the same commodity and month, and for options, it

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must be for the same commodity, month, put/call, and strike.

An APS indicator will appear on the confirmation and monthly statement for a customer whose positions have been
confirmed at an average price. This indicator will notify the customer that the confirmed price represents an
average price or rounded average price.

The average price is not the actual execution price. APS will calculate the same price for all customers that
participate in the order.

APS may be used when a series of orders are entered for a group of accounts. For example, a bunched APS order
(an order that represents more than one customer account) executed at 10:00 a.m. could be averaged with a
bunched APS order executed at 12:00 p.m. provided that each of the bunched orders is for the same accounts. In
addition, market orders and limit orders may be averaged, as may limit orders at different prices, provided that
each order is for the same accounts.

The following scenario exemplifies what occurs if an APS order is only partially executed. At 10:00 a.m. an APS
order to buy 100 Dec S & P 500 futures contracts is transmitted at a limit price of $776; 50 are executed at $376,
and the balance is not filled. At 12:00 p.m. an APS order to buy 100 Dec S & P 500 futures contracts is transmitted
at a limit price of $775; 50 are executed at $375, and the balance is not filled. Both orders are part of a series for
the same group of accounts. In this example, the two prices will be averaged. If the order was placed for more than
one account, the account controller must rely on pre-existing allocation procedures to determine the proportions in
which each account will share in the partial fill.

Upon receipt of an execution at multiple prices for an order with an APS indicator, an average will be computed by
multiplying the execution prices by the quantities at those prices divided by the total quantities. An average price
for a series of orders will be computed based on the average prices of each order in that series. The actual average
price or the average price rounded to the next price increment may be confirmed to customers. If a clearing
member confirms the rounded average price, the clearing member must round the average price up to the next
price increment for a sell order. The rounding process will create a cash residual of the difference between the
actual average price and the rounded average price that must be paid to the customer.

APS may produce prices that do not conform to whole cent increments. In such cases, any amounts less than one
cent may be retained by the clearing member. For example, if the total residual to be paid to a customer on a
rounded average price for 10 contracts is $83.333333, the clearing member may pay $83.33 to the customer.

If you would like more information on APS orders, please contact TD Ameritrade Futures & Forex LLC Futures
Operations Department.

ELECTRONIC TRADING AND ORDER ROUTING SYSTEMS DISCLOSURE STATEMENT*

Electronic trading and order routing systems differ from traditional open outcry pit trading and manual order
routing methods. Transactions using an electronic system are subject to the rules and regulations of the
exchange(s) offering the system and/or listing the contract. Before you engage in transactions using an electronic
system, you should carefully review the rules and regulations of the exchange(s) offering the system and/or listing
contracts you intend to trade.

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DIFFERENCES AMONG ELECTRONIC TRADING SYSTEMS

Trading or routing orders through electronic systems vary widely among the different electronic systems. You
should consult the rules and regulations of the exchange offering the electronic system and/or listing the contract
traded or order routed to understand, among other things, in the case of trading systems, the system's order
matching procedure, opening and closing procedures and prices, error trade policies, and trading limitations or
requirements; and in the case of all systems, qualifications for access and grounds for termination and limitations
on the types of orders that may be entered into the system. Each of these matters may present different risk
factors with respect to trading on or using a particular system. Each system may also present risks related to
system access, varying response times, and security. In the case of Internet-based systems, there may be
additional types of risks related to system access, varying response times and security, as well as risks related to
service providers and the receipt and monitoring of electronic mail.

RISK ASSOCIATED WITH SYSTEM FAILURE

Trading through an electronic trading or order routing system exposes you to risks associated with system or
component failure. In the event of system or component failure, it is possible that, for a certain time period, you
may not be able to enter new orders, execute existing orders, or modify or cancel orders that were previously
entered. System or component failure may also result in loss of orders or order priority.

SIMULTANEOUS OPEN OUTCRY PIT AND ELECTRONIC TRADING

Some contracts offered on an electronic trading system may be traded electronically and through open outcry
during the same trading hours. You should review the rules and regulations of the exchange offering the system
and/or listing the contract to determine how orders that do not designate a particular process will be executed.

LIMITATION OF LIABILITY

Exchanges offering an electronic trading or order routing system and/or listing the contract may have adopted rules
to limit their liability, the liability of Futures Commission Merchants, and software and communication system
vendors and the amount of damages you may collect for system failure and delays. These limitations of liability
provisions vary among the exchanges. You should consult the rules and regulations of the relevant exchanges(s) in
order to understand these liability limitations.

* Each exchange's relevant rules are available upon request from the industry professional with whom you have an
account. Some exchanges' relevant rules also are available on the exchange's internet home page.

UNIFORM NOTIFICATION REGARDING ACCESS TO MARKET DATA

As a market user you may obtain access to Market Data available through an electronic trading system, software,
or device that is provided or made available to you by a broker or an affiliate of such. Market Data may include,
with respect to products of an exchange ("Exchange") or the products of third party participating exchanges that
are traded on or through the Exchange's electronic trading platform ("Participating Exchange"), but is not limited to,

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"real time" or delayed market prices, opening and closing prices and ranges, high-low prices, settlement prices,
estimated and actual volume information, bids or offers, and the applicable sizes and numbers of such bids or
offers.

You are hereby notified that Market Data constitutes valuable confidential information that is the exclusive
proprietary property of the applicable exchange, and is not within the public domain. Such Market Data may only be
used for your firm's internal use. You may not, without the written authorization of the applicable exchange,
redistribute, sell, license, retransmit, or otherwise provide Market Data, internally or externally and in any format
by electronic or other means, including, but not limited to the Internet. Further, you may not, without the written
authorization of the applicable exchange, use Exchange Market Data for purposes of determining any price,
including any settlement price, for any futures product, options on futures product, or other derivatives instrument
traded on any exchange other than an Exchange or a Participating Exchange; or in constructing or calculating the
value of any index or indexed product. Additionally, you agree you will not, and will not permit any other individual
or entity to, (i) use Exchange Market Data in any way so as to compete with an Exchange or to assist or allow a
third party to compete with an Exchange; or (ii) use that portion of Exchange Market Data which relates to any
product of a Participating Exchange in any way so as to compete with that Participating Exchange or to assist or
allow a third party to compete with such Participating Exchange.

You must provide upon request of the broker through which your firm has obtained access to Market Data, or the
applicable exchange, information demonstrating your firm's use of the Market Data in accordance with this
Notification. Each applicable exchange reserves the right to terminate a market user's access to Market Data for
any reason. You also agree that you will cooperate with an exchange and permit an exchange reasonable access to
your premises should an exchange wish to conduct an audit or review connected to the distribution of Market Data.

NEITHER AN EXCHANGE, NOR ANY PARTICIPATING EXCHANGE, NOR THE BROKER, NOR THEIR RESPECTIVE
MEMBERS, SHAREHOLDERS, DIRECTORS, OFFICERS, EMPLOYEES, OR AGENTS, GUARANTEE THE TIMELINESS,
SEQUENCE, ACCURACY, OR COMPLETENESS OF THE DESIGNATED MARKET DATA, MARKET INFORMATION, OR
OTHER INFORMATION FURNISHED NOR THAT THE MARKET DATA HAVE BEEN VERIFIED. YOU AGREE THAT THE
MARKET DATA AND OTHER INFORMATION PROVIDED IS FOR INFORMATION PURPOSES ONLY AND IS NOT
INTENDED AS AN OFFER OR SOLICITATION WITH RESPECT TO THE PURCHASE OR SALE OF ANY SECURITY OR
COMMODITY.

NEITHER AN EXCHANGE, NOR ANY PARTICIPATING EXCHANGE, NOR THE BROKER NOR THEIR RESPECTIVE
MEMBERS, SHAREHOLDERS, DIRECTORS, OFFICERS, EMPLOYEES, OR AGENTS, SHALL BE LIABLE TO YOU OR TO
ANY OTHER PERSON, FIRM, OR CORPORATION WHATSOEVER FOR ANY LOSSES, DAMAGES, CLAIMS, PENALTIES,
COSTS, OR EXPENSES (INCLUDING LOST PROFITS) ARISING OUT OF OR RELATING TO THE MARKET DATA IN ANY
WAY, INCLUDING BUT NOT LIMITED TO ANY DELAY, INACCURACIES, ERRORS OR OMISSIONS IN THE MARKET
DATA OR IN THE TRANSMISSION THEREOF, OR FOR NONPERFORMANCE, DISCONTINUANCE, TERMINATION OR
INTERRUPTION OF SERVICE, OR FOR ANY DAMAGES ARISING THEREFROM OR OCCASIONED THEREBY, DUE TO
ANY CAUSE WHATSOEVER, WHETHER OR NOT RESULTING FROM NEGLIGENCE ON THEIR PART. IF THE FOREGOING
DISCLAIMER AND WAIVER OF LIABILITY SHOULD BE DEEMED INVALID OR INEFFECTIVE, NEITHER AN EXCHANGE,
NOR ANY PARTICIPATING EXCHANGE, NOR THE BROKER, NOR THEIR RESPECTIVE SHAREHOLDERS, MEMBERS,
DIRECTORS, OFFICERS, EMPLOYEES, OR AGENTS SHALL BE LIABLE IN ANY EVENT, INCLUDING THEIR OWN
NEGLIGENCE, BEYOND THE ACTUAL AMOUNT OF LOSS OR DAMAGE, OR THE AMOUNT OF THE MONTHLY FEE PAID
BY YOU TO BROKER, WHICHEVER IS LESS. YOU AGREE THAT NEITHER AN EXCHANGE, NOR ANY PARTICIPATING
EXCHANGE, NOR THE BROKER NOR THEIR RESPECTIVE SHAREHOLDERS, MEMBERS, DIRECTORS, OFFICERS,

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EMPLOYEES, OR AGENTS, SHALL BE LIABLE TO YOU OR TO ANY OTHER PERSON, FIRM OR CORPORATION
WHATSOEVER FOR ANY INDIRECT, SPECIAL, OR CONSEQUENTIAL DAMAGES, INCLUDING WITHOUT LIMITATION,
LOST PROFITS, COSTS OF DELAY, OR COSTS OF LOST OR DAMAGED DATA.

DISCLOSURE STATEMENT ON FUTURES EXCHANGE OWNERSHIP INTERESTS AND INCENTIVE PROGRAMS

You should be aware that your Futures Commission Merchant ("FCM") or one or more of its affiliates may own stock
of, or has some other form of ownership interest in, one or more U.S. or foreign exchanges and clearing houses
that you may trade on or that may clear your trades. As a result, you should be aware that your FCM or its affiliate
might receive financial benefits related to its ownership interest when trades are executed on such an exchange or
cleared at such a clearing house.

In addition, futures exchanges from time to time have in place other arrangements that may provide members with
volume or market making discounts or credits, may call for participating members to pre-pay fees based on volume
thresholds or may provide other incentive or arrangements that are intended to encourage market participants to
trade on or direct trades to that exchange. Your FCM, or one or more of its affiliates, may participate in and obtain
financial benefits from such an incentive program.

You should contact your FCM directly if you would like to know whether it has an ownership interest in a particular
exchange or clearing house, or whether it participates in any incentive program on a particular exchange or clearing
house. You may also contact any particular futures exchange directly to ask if it has any such incentive program for
member firms.

CME DISCLOSURE ON PAYMENT FOR ORDER FLOW

When firms provide execution services to customers, either in conjunction with clearing services or in an execution
only capacity, they may, in some circumstances, direct orders to unaffiliated market makers, other executing firms,
individual floor brokers, or floor brokerage groups for execution. When such unaffiliated parties are used, they may,
where permitted, agree to price concessions, volume discounts or refunds, rebates, or similar payments in return
for receiving such business. Likewise, on occasion, in connection with exchanges that permit pre-execution
discussions and "off-floor" transactions such as block trading, exchanges of physicals, swaps or options for futures,
or equivalent transactions, a counterparty solicited to trade opposite customers of an executing firm may make
payments described above and/or pay a commission to the executing firm in connection with that transaction. This
could be viewed as an apparent conflict of interest. In order to determine whether transactions executed for your
account are subject to the above circumstances, please contact your executing firm account representative.

DIRECT ORDER TRANSMITTAL CLIENT DISCLOSURE STATEMENT

This statement applies to the ability of authorized customers of TD Ameritrade Futures & Forex LLC to place orders
for foreign futures and options transactions directly with non-U.S. entities (each, an "Executing Firm") that execute
transactions on behalf of TD Ameritrade Futures & Forex LLC's customer omnibus accounts.

Please be aware of the following should you be permitted to place the type of orders specified above:

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The orders you place with an Executing Firm are for TD Ameritrade Futures & Forex LLC's customer omnibus
account maintained with a foreign clearing firm. Consequently, TD Ameritrade Futures & Forex LLC may limit or
otherwise condition the orders you place with the Executing Firm.

You should be aware of the relationship of the Executing Firm and TD Ameritrade Futures & Forex LLC.
TD Ameritrade Futures & Forex LLC may not be responsible for the acts, omissions, or errors of the Executing
Firm, or its representatives, with which you place your orders. In addition, the Executing Firm may not be
affiliated with TD Ameritrade Futures & Forex LLC. If you choose to place orders directly with an Executing
Firm, you may be doing so at your own risk.

It is your responsibility to inquire about the applicable laws and regulations that govern the foreign exchanges
on which transactions will be executed on your behalf. Any orders placed by you for execution on that exchange
will be subject to such rules and regulations, its customs, and usages, as well as any local laws that may
govern transactions on that exchange. These laws, rules, regulations, customs, and usages may offer different
or diminished protection from those that govern transactions on U.S. exchanges. In particular, funds received
from customers to margin foreign futures transactions may not be provided the same protections as funds
received to margin futures transactions on domestic exchanges. Before you trade, you should familiarize
yourself with the foreign rules which will apply to your particular transaction. United States regulatory
authorities may be unable to compel the enforcement of the rules of regulatory authorities or markets in non-
U.S. jurisdictions where transactions may be effected.

It is your responsibility to determine whether the Executing Firm has consented to the jurisdiction of the courts
in the United States. In general, neither the Executing Firm nor any individuals associated with the Executing
Firm will be registered in any capacity with the Commodity Futures Trading Commission. Similarly, your
contacts with the Executing Firm may not be sufficient to subject the Executing Firm to the jurisdiction of courts
in the United States in the absence of the Executing Firm's consent. Accordingly, neither the courts of the
United States nor the Commission's reparations program will be available as a forum for resolution of any
disagreements you may have with the Executing Firm, and your recourse may be limited to actions outside the
United States.

Unless you object within five (5) days by giving notice as provided in your customer agreement after receipt of this
disclosure, TD Ameritrade Futures & Forex LLC will assume your consent to the aforementioned conditions.

FOREIGN TRADER DISCLOSURE STATEMENT(applicable to non-U.S. customers only)

Dear Customer:

In accordance with Rules 15.05 and 21.03 of the Commodity Futures Trading Commission ("CFTC"), 17 C.F.R.
§§15.05 and 21.03, we are considered to be your agent for purposes of accepting delivery and service of
communications from or on behalf of the CFTC regarding any commodity futures contracts or commodity option
contracts which are or have been maintained in your account(s) with us. In the event that you are acting as agent
or broker for any other person(s), we are also considered to be their agent, and the agent of any person(s) for
whom they may be acting as agent or broker, for purposes of accepting delivery and service of such
communications. Service or delivery to us of any communication issued by or on behalf of the CFTC (including any
summons, complaint, order, subpoena, special call, request for information, notice, correspondence, or other
written document) will be considered valid and effective service or delivery upon you or any person for whom you
may be acting, directly or indirectly, as agent or broker.

You should be aware that Rule 15.05 also provides that you may designate an agent other than

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TD Ameritrade Futures & Forex LLC. Any such alternative designation of agency must be evidenced by a written
agency agreement which you must furnish to us and which we, in turn, must forward to the CFTC. If you wish to
designate an agent other than us, please contact us in writing. You should consult 17 [Link]. § 15.05 for a more
complete explanation of the foregoing.

Upon a determination by the CFTC that information concerning your account(s) with us may be relevant in enabling
the CFTC to determine whether the threat of a market manipulation, corner, squeeze, or other market disorder
exists, the CFTC may issue a call for specific information from us or from you. In the event that the CFTC directs a
call for information to us, we must provide the information requested within the time specified by the CFTC. If the
CFTC directs a call for information to you through us as your agent, we must promptly transmit the call to you, and
you must provide the information requested within the time specified by the CFTC. If any call by the CFTC for
information regarding your account(s) with us is not met, the CFTC has authority to restrict such account(s) to
trading for liquidation only. You have the right to a hearing before the CFTC to contest any call for information
concerning your account(s) with us, but your request for a hearing will not suspend the CFTC's call for information
unless the CFTC modifies or withdraws the call. Please consult 17 C.F.R. §21.03 for a more complete description of
the foregoing (including the type of information you may be required to provide).

Certain additional regulations may affect you. Part 17 of the CFTC Regulations, 17 C.F.R. Part 17, requires each
futures commission merchant and foreign broker to submit a report to the CFTC with respect to each account
carried by such futures commission merchant or foreign broker which contains a reportable futures position.
(Specific reportable position levels for all futures contracts traded on U.S. exchanges are established in Rule 15.03.)
In addition, Part 18 of the CFTC Regulations, 17 C.F.R. Part 18, requires all traders (including foreign traders) who
own or control a reportable futures or options position and who have received a special call from the CFTC to file a
Large Trader Reporting Form (Form 103) with the CFTC within one day after the special call upon such trader by the
CFTC. Please consult 17 C.F.R. Parts 17 and 18 for more complete information with respect to the foregoing.

Very truly yours,

TD Ameritrade Futures & Forex LLC

Futures Account Disclosure:

All clients must have available in the account(s) the margin requirement for the particular Futures contract prior to
the entry of an order.
TD Ameritrade Futures & Forex LLC ("TD Ameritrade Futures & Forex") reserves the right to increase the margin
requirement at any time due to market conditions or as prescribed by the exchange(s).

TD Ameritrade Futures & Forex reserves the right to (but is not obligated to) close out any Futures position, if at
any time, TD Ameritrade Futures & Forex deems this necessary for whatever reason.

If, under any circumstance, TD Ameritrade Futures & Forex deems it necessary to close out (in part or in whole) a
position in a Futures contract, you hereby agree to accept full responsibility for such losses incurred and indemnify
and hold harmless TD Ameritrade Futures & Forex.

To hold a Futures position overnight in any Futures contract, clients must have available, at the close of the day's
session, the overnight margin requirement according to TD Ameritrade Futures & Forex's requirements for the

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particular contract.

Client acknowledges that holding a Futures contract overnight can subject you to significant risks including but not
limited to availability of markets, trading systems, and inherent market risk.

By submitting the form below, you understand that trading Futures involves a high degree of risk and that you are
prepared to lose all funds that are utilized for trading and that such trading could result in losses beyond your total
investment.

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