BTG Pactual US Capital Disclosures

BTG Pactual US Capital, LLC (“BTG” or the “Firm”) is registered with the Securities and Exchange Commission (SEC) as a broker-dealer and is a member of the Financial Industry Regulatory Authority (FINRA). We are also affiliated with a Registered Investment Adviser, BTG Pactual Asset Management US, LLC (“BTG Asset Management”). For additional information regarding advisory services available with BTG Asset Management or to request a copy of BTG Asset Management’s Form CRS, you can call (212) 293-4600.

This document is meant to provide additional information and disclosures regarding our Firm pursuant to Regulation Best Interest. This form should be used in conjunction with other documents which may be provided to you based on a specific type of account, investment, or service. These other types of documents include prospectuses, private placement memorandums and similar offering materials along with important information you will find in your account agreement/s, notices, policies, statements, trade confirmations, and similar materials. Please remember that investing involves risks. Past performance is no guarantee of future results.

On June 30th, 2020, the US Securities and Exchange Commission’s (“SEC”) Regulation Best Interest (Reg. BI) became effective. Reg. BI established a new set of standards that broker/dealers must comply with when dealing with retail customers. Among the new standards that Reg. BI sets forth is the requirement that broker/dealers must provide a disclosure document to all its retail customers where it clearly states all material facts relating to the scope and terms of the relationship with any retail customer including: (i) capacity in which the broker or dealer and/or their representative(s) is acting with respect to a recommendation in your account; (ii) fees and costs that apply to transactions, holdings, and accounts; (iii) the type and scope of services provided, any material limitations on the securities or investment, including conflicts of interest, risks, and basis for recommendation.

For purposes of the rule, a “retail customer” is a person, or the non-professional legal representative (i.e. non-regulated as a regulated financial services industry professional would not be deemed a “retail customer”) of such person, who: (1) receives a recommendation (i.e. reasonably could be viewed as a “call to action”) of any securities transaction or investment strategy involving securities from a broker, dealer, or an associated person of a broker or dealer, and (2) “uses” the recommendation primarily for personal, family or household purposes. Furthermore, Reg. BI is only applicable to your brokerage account and relationship. Reg. BI is not applicable to investment advisory accounts.

Your financial professional may be a registered representative of our Broker-Dealer, an investment adviser representative of our affiliated or an unaffiliated Registered Investment Adviser, or both. You can check your financial professional at www.adviserinfo.sec.gov or www.brokercheck.finra.org which will allow you to search for your financial professional by name. Their respective profile will show you if they are a broker, investment adviser, or both and you can also find additional information about our firm.

In most cases, when making a recommendation to you regarding investments in your brokerage account or directly with an investment sponsor (known as “direct business”), your financial professional is acting in his/her capacity as a registered representative under the broker-dealer. When providing advice or a recommendation regarding investments in a managed account , your professional is acting in the capacity of an investment adviser representative. Your account application or agreement will identify which type of account you have. Whenever your financial professional acts in a capacity that conflicts with this guidance, you will be notified in writing.

1 Brokerage Account – also known as a transactional account or commission-based account, is a type of account where the fee(s) paid by the client, in the form of commission, sales credit, a mark-up or mark-down, are charged on each transaction (buy or sell) that occurs in the account. These fees may be in addition to other fees applicable to the account as discussed herein.

2 Managed Account – also known as a fee-based account, advisory account or wrap fee account, is a type of account where the fee(s) paid by the client are based on a percentage of billable assets under management held in the account. These fees may be in addition to other fees applicable to the account as discussed herein.

BTG is a full-service broker-dealer which offers most account types, products, and securities; however, there may be additional account types, products, and securities that are not offered by the Firm.

Additionally, the financial professionals associated with our Firm are licensed to offer certain account types, products, and securities. There may be material limitations to the recommendations your financial professional provides. In some cases, based on the licensing of your financial professional, even when available through our firm or an affiliate, your financial professional might not be able to recommend a particular account type, product, and/or security. If your financial professional cannot recommend a particular account type, product, and/or security, it may be available by another financial professional at the Firm. You can check to see the licenses your financial professional holds, by visiting www.adviserinfo.sec.gov or www.brokercheck.finra.org.

Generally, the Firm makes its products and services available to all retail customers with no minimum amount required to open an investment account. However, it is important to note, some products and investments will require a minimum investment, which can be found on the investment prospectus, offering materials, or similar document.

BTG’s financial professionals uses industry knowledge and experience to provide brokerage services to retail clients. The Firm seeks to understand our client’s unique investment profiles and recommend investments and strategies consistent with their financial goals. However, the products and services offered by the Firm do vary and the investment philosophy, approach, risk, and objective of these investments will too. You should confirm all investment advice meets your specific objectives and risk tolerance and where applicable review the prospects or similar documents thoroughly before making an investment. You may also contact your financial professional should you have additional questions.

The Firm and its financial professionals receive compensation directly from their customers or indirectly from the investments a customer makes. This compensation takes the form of an upfront commission and/or ongoing compensation, known as trailing compensation. It is important to note that the amount of compensation can change over time. In order to receive specific and up-to-date information, customers should review the respective prospectus, offering document, and other account documents including account statements and trade confirmations. Customers should discuss with their financial professional if they have any questions regarding compensation and/or conflicts of interest.

Some financial professionals are paid a salary and receive a discretionary bonus which considers multiple factors, including their production at the Firm. Other financial professionals may be paid a percentage of the selling compensation described above. In this case the percentage may be fixed or based on a grid, where the percentage of the selling compensation increases with the professional’s overall production. In addition, financial professionals may receive reimbursement for certain types of expenses, travel, and entertainment and may also receive certain hiring incentives such as a bonus or forgivable loans which may or may not be contingent on a minimum level of production.

The Firm receives commissions when it buys or sells a security. This commission is also referred to as a concession, placement fee, markup/markdown, or sales charge/load. Typically, the Firm receives the commission and shares a certain percentage of the commission with the financial professional. Because the amount of commission charged can vary between different services, securities and products, this could create an incentive to recommend certain investments over others. It also could create an incentive to conduct a higher number of transactions. It's also important to note that the Firm maintains standard fee schedules for each type of services offered and may customize this schedule under certain circumstances. You should confirm the costs and fees of each transaction with your investment professional before making an investment decision.

For a detailed overview of the Firm's costs for each type of investment account, services, and transactions, please visit www.btgpactual.us/fee-schedule.

Certain types of product such as mutual funds, variable annuities, and 529s, usually offer multiple share classes which you choose from when making an investment. Share classes differ in the amount and way that fees are charged. The amount of upfront sales charges and trailing compensation will vary, depending on the share class selected. For example, Class A mutual fund shares typically will result in a higher upfront sales charge and lower trailing compensation, while the opposite is true for a Class C shares. In order to see a complete list of the share classes available for a particular investment and their respective costs, you should review the investment prospectus and other offering documents.

Financial professionals provide recommendations with respect to a broad range of investment products, including stocks, bonds, ETFs, mutual funds, alternative investments, and more. Many investment products charge fees and costs that are separate from and in addition to the sales compensation and fees that the Firm and financial professionals receive. You can learn more about these fees and costs charged by an investment product by reviewing the investment product’s prospectus, offering memorandum, or other disclosure documents.

In addition to the commissions and sales charges described above, customers can also be charged direct fees and charges for miscellaneous account services such as wire transfers, inactivity fees, account transfers (ACAT), error corrections, and account maintenance. These fees are typically charged by the clearing firm where your assets are custodied and some of these fees may be shared with the Firm. For a complete list of these charges and fees you should review your account agreement and fee schedule. You should also discuss these charges with your financial professional if you have any questions.

In addition to the commissions and sales compensation described above, the Firm and your investment professional may receive additional compensation from third parties. This additional compensation may incentivize your financial professional to recommend certain investments over others. It is important to note that the amount of compensation may vary between security types and product/investment sponsors. In order to receive specific and the most up-to-date information, customers should review the respective prospectus, offering document, and/or transaction confirmations.

• Other Trailing Compensation: The Firm may receive trailing compensation, including 12b-1 fees, which are paid from certain investment sponsors for mutual funds and alternative investments. The amount can vary based on the product and total amount invested.
• Mutual Fund Concessions and Finder’s Fees: The Firm may receive trailing compensation, including 12b-1 fees, which are paid from certain investment sponsors for mutual funds and alternative investments. The amount can vary based on the product and total amount invested.
• Product Onboarding: The Firm may receive onboarding fees or reimbursement for certain expenses associated with product onboarding, including due diligence. These payments can be fixed or a percentage of the total value of an offering.
• Cash Sweeps: The Firm receives compensation for when a cash balance is moved to a particular fund or account from which the Firm generates additional compensation.
• Securities Lending: The Firm along with the customer, may receive a fee for securities lent to the clearing firm as part of a securities lending agreement.
• Margin or Portfolio Line of Credit: When a customer utilizes margin or a portfolio line of credit, the Firm receive a percentage of the balance lent.
• Payment for Order Flow: The Firm may now or in the future receive remuneration for directing orders in securities to particular market centers for execution. The Account Holder understands that this remuneration, known as "payment for order flow," is considered compensation to the Firm.

• Gifts and Entertainment: A conflict of interest may arise when a financial professional receives or offers a gift, entertainment, or anything of value that could create an incentive for an employee, third party service provider, or a client to act in a certain way.
• Shared Revenues and Payments from Third Parties:We receive shared revenue, fees, and/or payments from our clearing firm, investment sponsors, and other third parties. This creates an incentive to offer or recommend certain products and services.
• Acting in Principal Capacities: The Firm may earn a profit from buying and selling investments from our own accounts therefor the Firm may have an incentive if you trade on a principal basis.
• Multiple Roles: The Firm or its affiliates may perform multiple roles with respect to a client or transaction (e.g., advisor, lender, broker, riskless principal counterparty). These roles mean we might be biased regarding the services we recommend as they relate to these roles.
• Outside Business Activities: If approved, financial professionals may engage in certain outside business activities. As a result, financial professionals may be incentivized to recommend certain products or services outside the scope of their relationship with the Firm and they may benefit financially from these recommendations. In addition, financial professionals may engage in personal trading which could conflict with a client or with the Firm.
• Political and Charitable Contributions: The Firm and/or its financial professionals’ may make charitable and/or political donations that could create the perception that the Firm or financial professional is seeking a quid pro quo from the recipient of the donation.
• Confidentiality: The Firm and its financial professionals are periodically exposed to confidential information which may benefit us or a client.
• Supervision Conflicts: When a manager is also a producing financial professional, he/she could be incentivized to spend more time on revenue generating activities than supervision activities. In addition, a conflict also exist as a portion of the supervisor’s compensation is determined by the production of his/her subordinates.
• Affiliated Entities: The Firm is affiliated with other financial services entities. The Firm and your investment professional are incentivized to refer customers to all of these affiliates as it usually generates additional compensation for the firm, its affiliates, owners, and investment professional, directly, or through the enterprise.
• Trade Aggregation and Allocation: A potential conflict of interest could arise when the BD aggregates orders and allocates securities among clients.
• Personal Securities Transactions: A potential conflict of interest could arise when an employee of the BD effects securities’ transactions in their personal accounts in the same or different securities than those purchased and sold for the accounts of BD’s clients.
• Recommendations to Other Financial Professionals: A conflict of interest may arise when the BD refers other professionals (e.g., lawyers, accountants, insurance agents, etc.) to clients or engaged directly by the client on an as‐needed basis. Although not directly compensated for these referrals to outside entities, the investment professional may receive referrals from these professionals, which might incentivize them to recommend a particular professional over another.
• Cross Trading: A potential conflict may occur when we engage in transactions between client accounts we manage, due to lack of market factors which help promote transparency.
• Foreign Affiliates: Currency Exchange and Transfer Pricing: Broker-dealers with foreign affiliates may face conflicts of interest related to currency exchange rates and transfer pricing practices, particularly when conducting transactions or transferring assets between entities in different jurisdictions.
• Principal Trading: The firm through affiliates sometimes engages in business and trading activities for its own account or client accounts while other clients are active in relevant markets at the same time. We are incentivized to maximize our returns and certain trades could disadvantage the performance if a client’s account.
• Proprietary Products: The Firm may create, manage, or underwrite some of the investments and products we recommend. Accordingly the Firm has an incentive to recommend proprietary products due to the potential to receive greater overall compensation across the enterprise.

Our Firm does not provide tax, legal or accounting advice. Accordingly, we encourage each customer to consult their own personal tax, legal and/or accounting advisers in order to understand the potential consequences associated with a particular investment strategy.

Investing in securities involves risk of loss that customers should be prepared to bear. Different types of investments involve varying degrees of risk and there can be no assurance that any specific investment or investment strategy will be profitable for a customer’s investment portfolio. Past performance is not indicative of future results. A customer should not assume that the future performance of any specific investment, investment strategy, or product will be profitable or equal to past or current performance levels. We cannot assure that the investment objectives of any client will be realized. The following is a non-exhaustive list of risks associated with investing. For additional product-specific risks, customers should review their prospectus, offering document, or similar materials and consider them carefully prior to making an investment decision.

• Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events.
• Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not.
• Financial/Credit Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value of securities.
• Third Party Manager Risk: Third Party portfolio managers typically have full discretion as to how manage the model portfolio based on the objective of the model. Such discretion increases the risk that the TPM may mismanage the portfolio and client’s assets which may result in client’s loss.

The Firm offers to its customers a wide range of investment products and services, including funds domiciled and operated outside of the United States that are only available to persons and entities that do not qualify as “U.S. Persons” under Regulation S of the Securities Act of 1933. These funds are generally referred to as “offshore” funds and although they are not registered as securities in the United States, they function similarly to U.S. registered mutual funds in terms of investment strategy, structure, operation, associated risks, and costs. In selecting the offshore fund that best suits your needs, some key factors to consider include the fund’s investment strategy, risk profile and risk factors, investment performance, and relationship to your overall asset allocation strategy and investment time horizon. An offshore fund’s fees and expenses have an impact on its investment returns and are important factors to consider as well. (Please note: Offshore funds are not intended to be utilized as short-term trading vehicles).

This disclosure statement is intended to provide you more information about fees and expenses related to transactions in offshore funds as well as compensation that The Firm and its financial professionals earn with respect to offshore funds.

Offshore Fund Share Classes In order to accommodate the various investment needs of different categories of investors, many offshore funds offer more than one “class” of shares. Each share class represents an interest in the same offshore fund’s investment portfolio but has different fees and expenses. Some offshore funds offer shares in multiple currencies and dividend & income distribution options. The availability of certain share classes offered by an offshore fund may be limited, depending on the fund family. For further information about a particular fund family and eligibility, please review the respective fund prospectus and consult with your financial professional for further questions.

Front Load Shares Front Front load shares, often referred to as “Class A Shares,” typically impose a negotiable front-end sales charge at the time of initial purchase. The front-end sales charge is deducted from your initial investment amount at the time of purchase. The front-end sales charge is paid to the Firm as a “dealer commission” and a portion (or, in some instances, all) of that commission amount is remunerated to your financial professional as part of their overall compensation. The fund’s annual asset-based fees, which typically include a management fee and shareholder/distribution fees (e.g. trailers and retrocessions), for front load shares of an offshore fund are typically lower than the annual operating expenses for that respective fund’s back end load funds. Front load shares are typically more suitable for investors who have an intermediate to longer term investment time horizon and are not intended to be utilized as short-term trading vehicles. The dollar amount at which you should consider purchasing front load shares of a fund should be evaluated by analyzing the front-end sales charge to be assessed, along with associated annual asset-based fees.

Level Load Shares Level often referred to as “Class C Shares,” typically do not impose a front-end sales charge, so the full value of your investment is used to purchase shares in a fund. Many Class C shares impose a contingent deferred sales charge (“CDSC”), typically a percentage of the redemption amount during the first year, with no CDSC thereafter. CDSC fees are typically paid to the fund’s distributor or other service provider, and not paid to The Firm or your financial professional. The Firm will typically receive up front compensation of the invested amount on Class C shares, paid by the fund’s distributor or other service provider at the time of sale and a portion (or, in some instances, all) of this amount is paid to your financial professional. Class C shares generally are subject to annual asset-based fees that typically include a management fee and shareholder/distribution fees (e.g. trailers and retrocessions), which are typically higher than comparable asset-based fees for the fund’s front load shares. Compared to Class A Shares, Class C shares generally become less economical for investors who hold their investments over a longer term. Typically, Class C shares are more economical for investors who have a short to intermediate investment horizon.

Rear Load Shares Rear load shares, often referred to as “Class B Shares” typically have higher total expenses than Class A shares. Most Class B shares convert to Class A shares after an investor has met a minimum holding period (established by the respective fund company). If you hold a Class B share fund, please check the fund family’s prospectus for conversion features. Similar to Class C shares, Class B share become less economical for investors who hold their investments over the longer term.

For more complete information on any offshore fund, please review the prospectus, offering document and/or, if available, key investor information document. Before investing, carefully consider the investment objectives, risks and charges and expenses of the fund. This and other information can be found in the fund’s prospectus. If you are a “U.S. Person” as defined in section 7701 (a)(30) of the Internal Revenue Code (or “Code”) and are considering whether to make an investment in an offshore fund, we strongly urge you to consult with your U.S. tax advisor before making such an investment. An offshore fund may constitute a “passive foreign investment company” (or “PFIC”) as defined in section 1297 of the Code. If an offshore fund is a PFIC, then you may be subject to adverse U.S. federal income tax consequences arising from the ownership and disposition of shares in such fund. Under certain circumstances, an election can be made to reduce the impact of those adverse tax consequences, but you should discuss with your U.S. tax advisor (i) whether you would be able to make such an election and (ii) the tax consequences if you are not able to make such an election. The Firm does not provide legal, tax or accounting advice. Please consult your legal and/or tax advisor regarding this information.

New York Registry Shares (NYRSs) represent shares of non-U.S. companies that trade in the United States in USD without needing Depositary Receipts (DRs). A U.S. bank appointed by the non-U.S. issuer handles shareholder registration, certificate transfer, dividend payment, and proxy services. The issuance of NYRSs requires compliance with both U.S. securities regulations and the legal requirements of the issuer's home market.

Tax Considerations: Potential investors should be aware of the tax implications, including withholding taxes on dividends, capital gains taxes, and compliance with reporting requirements. Non-U.S. investors should consider the potential impact of U.S. estate and gift taxes. Investors are strongly encouraged to seek independent legal and financial advice before making any investment decisions.

Pursuant to FINRA and SEC regulations, The Firm has implemented a Business Continuity Plan (“BCP”) in place to prepare for the possibility of future significant business disruptions (“SBD”) ranging in severity from a firm only disruption to a regional disruption. The Firm ’s recovery time from an SBD will depend on the severity and significance of the event. You may contact us at (212)293-4600 for additional information regarding our BCP Plan.

Plan Summary: The Firm has several offsite physical locations where it will move a core team of employees to continue to conduct business in the event of an SBD. In the event of a catastrophic failure on a scale up to and including a city-wide disruption, The Firm will continue business operations from these facilities. Customers may continue to contact us at (212)293-4600.

Contacting Us & Your Custodian: The Firm does not maintain custody of customer funds or securities, which are maintained at our custodian firms. In the event of an SBD, please contact:

• For Pershing, LLC Platform: Contact Pershing, LLC (“Pershing”), a wholly owned subsidiary of The Bank of New York Mellon Corp., directly to process limited trade related transactions, cash disbursements, security transfers, and other account related activity or request account related information. Instructions to Pershing must be in writing and transmitted via facsimile at (201) 413-5368 or by postal service as follows:

     Pershing LLC
     P.O. Box 2065
     Jersey City, NJ 07303-2065

• For DriveWealth, LLC Platform: To process limited risk-related orders, please contact: atendimentousinvestimentos@btgpactual.com.

The Firm is a member of SIPC. For information on coverage or to receive the SIPC brochure, please contact SIPC at:

Their website is www.sipc.org.
Their telephone number is (202) 371-8300.
Email: asksipc@sipc.org

Important Information About Opening an Account

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

What this means for you: When you open an account, we will ask (if applicable) for your name, address, date of birth, taxpayer identification number, driver’s licenses social security number, employer identification number, passport number and country of issuance, alien identification number, government issued identification (demonstrating nationality, residence and which includes a picture of you), employment status (including, occupation, and whether you are an associated person of a broker-dealer), annual income, net worth (excluding primary residence), source of wealth, investment objectives, investment experience, risk profile, and any other information that will allow us to identify or properly profile you.

A corporation, partnership, trust or other legal entity customer may be required to provide additional information, such as its beneficial owners, control persons, principal place of business, local office, employer identification number, certified articles of incorporation, government issued business license, certificate of good standing, a partnership agreement, or a trust agreement.

What happens if I don’t provide the information requested or my identity can’t be verified?

We may not be able to open an account or carry out transactions for you. If we have already opened an account for you, we may have to restrict, block, or close such account.

“Specified Adult” investors are of great concern to the industry; therefore, FINRA has taken additional measures to provide firms with the tools to respond more quickly and effectively to protect specified adults from financial exploitation.

The term “Specified Adult” shall mean: (A) a natural person age 65 and older; or (B) a natural person age 18 and older who the member reasonably believes has a mental or physical impairment that renders the individual unable to protect his or her own interests.

The term “financial exploitation” means: (A) the wrongful or unauthorized taking, withholding, appropriation, or use of a Specified Adult's funds or securities; or (B) any act or omission by a person, including through the use of a power of attorney, guardianship, or any other authority regarding a Specified Adult, to: (i) obtain control, through deception, intimidation or undue influence, over the Specified Adult's money, assets or property; or (ii) convert the Specified Adult's money, assets or property.

FINRA Rule 2165

The rule permits FINRA member firms to place a temporary hold on a disbursement of funds or securities from the account of a Specified Adult when the member firm reasonably believes that financial exploitation has occurred, is occurring, has been attempted, or will be attempted and to notify all parties authorized to transact for the customer, including the trusted contact person.

FINRA Rule 4512

Firms are required to make reasonable efforts to obtain the name of and contact information for a trusted contact person for a customer’s account.

FAQs that provide further guidance can be accessed by utilizing the following link:

http://www.finra.org/industry/frequently-asked-questions-regarding-finra-rules-relating-financial-exploitation-seniors

The FINRA Securities Help line for Seniors is a toll-free number established for senior investors to call to get assistance or raise concerns about issues with brokerage accounts and investments. The number is (844) 57-HELPS (844) 574-3577.

The Firm and their employees, agents, officers, and directors are obligated to comply with the applicable provisions of the U.S. Foreign Corrupt Practices Act (“FCPA”) and the UK Bribery Act with respect to activities and services in the United States and offshore. The FCPA and UK Bribery Act are designed to prevent persons from acting corruptly (i) in furtherance of an offer, payment or promise to pay, (ii) by giving anything of value to officials of a foreign government, public international organization or foreign political party (together “Foreign Public Entities”), or (iii) giving anything of value to any person, with the knowledge or belief that it will go to an individual associated with a Foreign Public Entity, for purposes of influencing official acts (including failures to act) that include obtaining or retaining business or securing any improper advantage.

In this regard, the Firm nor any of its officers, directors, employees, agents, or other representatives engages in the following actions, or receive any compensation related thereto:

• Pay, offer or promise to pay, or authorize the payment of, any money or anything else of value, either directly or through a third-party, to any Foreign Public Entities or other official or employee of any governmental authority/instrumentality or public international organization (or of any agency or subdivision thereof), or to any political party or official thereof, or to any candidate for political office, for the purpose;
• Give, promise to give, or authorize the giving of, any services, either directly or through a third party, to any official or employee of any Foreign Public Entities or other governmental authority/instrumentality or public international organization (or of any agency or subdivision thereof), or to any political party or official thereof, or to any candidate for political office, for the purpose;
• Influencing any act or decision of that person in his official capacity, including a decision to fail to perform his official functions with such Foreign Public Entity, governmental agency or instrumentality or such public international organization or such political party;
• Inducing such person to use his influence with such Foreign Public Entity, governmental agency or instrumentality or such public international organization or such political party to affect or influence any act or decision thereof; or
• Securing any improper advantage.

In addition to the foregoing, the Firm and their employees, officers, directors, agents, or other representatives are obligated to avoid even the appearance of impropriety in the course of its activities.

SEC Rule 606 of Regulation NMS requires all broker dealers to make publicly available quarterly reports, broken down by calendar month, a report on the broker dealer’s practices for routing orders for transactions in different kinds of securities to certain venues for execution when the customer has not otherwise directed the broker dealer to route the customer’s order to a particular venue (i.e. non-directed orders).

Please Visit:

https://www.finra.org/finra-data/606-nms-data

SEC Rule 606 further requires a broker dealer to disclose to its customers, upon request, the venues orders were routed to for execution during the previous six months (whether directed orders or non-directed orders) and the time of any transaction that resulted from such orders (if any).

For those customers who have accounts with the Firm that were introduced by a third-party, consistent and in accordance with applicable law, please be informed that in consideration for the referral of your business, the Firm will pay the introducer a portion of the revenues or fees derived from your account.

Pursuant to the terms of a carrying agreement between the Firm and a third-party adviser, for those customers that are provided services by The Firm and the third-party adviser, The Firm will retain a portion of the revenues or fees derived from such account and pay the remainder of the revenues or fees derived from such account to the third-party adviser.

To the extent you would like more information, please contact your financial professional.

The account holder acknowledges that their use of a mouse, or any other means to select an item, button, or icon constitutes their signature, acceptance, and agreement as if actually signed in paper form (“E-Signature”).

The account holder understands that the account holder’s E-Signature on any account applications and other account opening documents (including, but not limited to, this agreement), or any other agreements, authorizations, applications, or other documents that are required to be signed or accepted by the account holder constitutes the account holder’s signature, acceptance, acknowledgment and agreement.

The account holder understands that at any time prior to submitting the E-Signature, the account holder has the right to withdraw consent to E-Signature and/or request a paper version. Furthermore, the account holder understands that regardless of the withdrawn consent, any record that had been previously submitted with an E-Signature will continue to be in full force and effect.

To withdraw consent, request a paper version and/or to update your email address or other contact information, please contact our Firm.

Required hardware and software*

Operating System:

• Windows® 2000,
• Windows® XP,
• Windows® Vista;
• Mac OSX®

Browsers:

• Final release version of Internet Explorer® 6.0 or above (Windows only);
• Mozilla Firefox 2.0 or above (Windows and Mac);
• Safaritm 3.0 or above (Mac only)

PDF Reader:

• Acrobat® or similar software may be required to view and print PDF files.

Screen Resolution:

• 800 x 600 minimum

Enabled Security Settings:

• Allow per session cookies

*These minimum requirements are subject to change. If these requirements change, the account holder will be asked to re-accept this disclosure. Pre-release (e.g. beta) versions of operating systems and browsers are not supported.

A margin loan allows the account holder to borrow against the value of securities held in their account. We are providing this information to inform you of the basic facts about using and purchasing securities on margin, and to disclose the associated risks. However, the client should refer to their margin agreement for additional details.

Before you decide to borrow on margin (from any source), you should carefully review this statement, which describes certain risks associated with borrowing on margin.

When you borrow on margin, you agree to maintain the level of margin collateral required by the lender (which may change from time to time). If the securities in your account decline in value or the lender otherwise deems it necessary to protect their interest, the lender may, at any time and without prior notice to you, (i) sell assets in any of your accounts that serve as collateral; (ii) buy assets of which your account may be short; and/or (iii) place stop-loss orders with respect to any securities that serve as collateral.

• You can lose more funds than you deposit in the margin account. A decline in the value of securities that are purchased on margin may require you to provide additional funds to your lender to avoid the forced sale of those securities or other securities or assets in your account(s).
• The entity that has provided you with margin credit can force the sale of securities or other assets in your account(s). If the equity in your account falls below your lender’s margin requirements or below the requirements of the appropriate regulatory authority or the lender otherwise deems it necessary to protect their interest, your lender can sell the securities or other assets in any of your accounts to cover the margin deficiency. You also will be responsible for any shortfall in the account after such sale.
• The entity that has provided you with margin credit can sell your securities or other assets without contacting you. 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. Most firms will attempt to notify their customers of margin calls, but they are not required to do so. However, even if a firm has contacted a customer and provided a specific date by which the customer can meet a margin call, the firm can still take necessary steps to protect its financial interests, including immediately selling the securities without notice to the customer.
• You are not entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call. Because all of the securities in your accounts are collateral for the margin loan, your lender has the right to decide which security to sell in order to protect its interests.
• The entity that has provided you with margin credit may increase its margin maintenance requirements at any time and is not required to provide you advance written notice. These changes in firm policy often take effect immediately and may result in the issuance of a maintenance margin call or event. Your failure to satisfy the call may cause your lender to sell securities in your account(s).
• You are not entitled to an extension of time on a margin call. While an extension of time to meet margin requirements may be available to customers under exceptional conditions, a customer does not have a right to the extension.

BTG Pactual US may, upon request, make available to its bona fide customers a copy of the firm’s most recent balance sheet that was prepared in accordance with the applicable regulation. If you would like to receive a copy of the most recent balance sheet available, please contact SH-COMPLIANCE-US@btgpactual.com.

By requesting a copy of the balance sheet, you agree to receive the document and the information in its electronic form, only.

Please be advised that should you have a complaint regarding your financial professional or our Firm you may direct your complaint to our Ombudsman or Complaint Department, which can be reached via email at ombudsman@btgpactual.com.

You should consider the following points before engaging in extended hours trading. “Extended hours trading” means trading outside of “regular trading hours.” “Regular trading hours” generally means the time between 9:30 a.m. and 4:00 p.m. Eastern Standard Time.

• Risk of Lower Liquidity: Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for investors to buy or sell securities, and as a result, investors are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular trading hours. As a result, your order may only be partially executed, or not at all.
• Risk of Higher Volatility: Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended hours trading than in regular trading hours. As a result, your order may only be partially executed, or not at all, or you may receive an inferior price when engaging in extended hours trading than you would during regular trading hours.
• Risk of Changing Prices: The prices of securities traded in extended hours trading may not reflect the prices either at the end of regular trading hours, or upon the opening the next morning. As a result, you may receive an inferior price when engaging in extended hours trading than you would during regular trading hours.
• Risk of Unlinked Markets: Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended hours trading system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, you may receive an inferior price in one extended hours trading system than you would in another extended hours trading system.
• Risk of News Announcements: Normally, issuers make news announcements that may affect the price of their securities after regular trading hours. Similarly, important financial information is frequently announced outside of regular trading hours. In extended hours trading, these announcements may occur during trading, and if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of a security.
• Risk of Wider Spreads: The spread refers to the difference in price between what you can buy a security for and what you can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security.

For additional information related to extended hours trading via the DriveWealth platform, please visit https://legal.drivewealth.com/extended-hours-trading-disclosures.

Investors in Regulation S (“Reg S”), Rule 144A (“144A”), or foreign issuer securities should be aware of the following important considerations regarding Voluntary Corporate Actions:

• No Notification: BTG Pactual US will not provide notifications regarding voluntary actions affecting these securities, including voting rights, tender offers, or exchange offers.
• Limited Participation: Customers may be unable to participate in or vote on voluntary corporate actions related to these securities. Additionally, certain voluntary actions may have minimum investment thresholds, and investors holding amounts below these thresholds may not be eligible to participate.
• Customer Responsibility: It is the customer’s responsibility to independently monitor corporate actions for Reg S, 144A, and foreign issuer securities. BTG Pactual US does not assume responsibility for notifying customers or facilitating participation in these actions.