Firm Policies

Margins

Margin requirements may fluctuate from day to day. Therefore, it is the client’s responsibility to keep himself informed of current margin requirements and to be properly margined at all times. If the equity of your account falls below minimum margin requirements then, in effect, we have the right to liquidate, without notice, as many of your trades as necessary to bring your margin requirements up to the minimum standard again. In such situations, and depending on market conditions, and in the facts of each case, we may attempt to contact you by phone upon delivery of a margin deficiency.

Please remember, however, that we are not obligated to notify you in advance of liquidation and that it is your duty to keep your account properly margined at all times and to keep fully appraised of current margin requirements.

Statements

Client Statements – Clients with problems concerning their daily trade confirmation statements must contact us immediately – failure to do so may result in the error remaining the client’s responsibility. After thirty days, errors are the client’s liability.

Financial Obligation Approaching First Notice Day (FND) – When approaching FND, clients must have full contract value three days prior to FND in order to hold a long and/or a short position. When FND and Last Trading Day (LTD) are the same day, such as with currencies, clients must have a full contract value ten days prior to FND/LTD.

Anti-Money Laundering and Terrorist Prevention

Cunningham Commodities, LLC. (Cunningham) recognizes that The International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 ("Act") imposes important new obligations on all financial firms for the detection, deterrence and reporting of money laundering activities. Under the Act, money laundering is defined as any financial transaction using income derived from criminal activity including, but not limited to, drug trafficking, fraud, illegal gambling and terrorism. Cunningham has established the following policies to ensure thorough compliance with all laws and regulations regarding money laundering.

Information collected from customers on account applications will be used to verify their identities, as required under Federal law. Prior to the opening of any new account, Cunningham shall document the identity, nature of business, income, source of assets, and investment objectives of each prospective customer. Accounts for persons or entities from countries that do not cooperate with the Financial Action Task Force (FATF) guidelines on money laundering shall be subject to a heightened level of scrutiny. Accounts in the name of, or related to, any person or entity on the Office of Foreign Asset Control (OFAC) Specially Designated Nationals and Blocked Person list shall not be permitted. Likewise, under exchange rules, persons whose names subsequently appear on such lists will be prohibited from obtaining direct or indirect access to futures exchanges, such as the CME Group exchanges.

On an on-going basis, Cunningham shall review account activity for evidence of suspicious transactions that may be indicative of money laundering activities. This review may include surveillance of: 1) money flows into and out of accounts, 2) the origin and destination of wire transfers, 3) non-economic transactions, and 4) other activity outside the normal course of business.

Every officer, employee, and associated person (“AP”) of Cunningham shall be responsible for assisting in the firm’s efforts to undercover and report any activity that might constitute, indicate or raise suspicions of money laundering. To this end, Cunningham shall provide continuing education and training of all such persons.

Should any officer, employee or AP of Cunningham have any knowledge, suspicions or information regarding potential money laundering activities, that individual shall immediately notify Cunningham’s Compliance Department. Cunningham’s Compliance Officer shall document the reported activity, investigate fully, and, if warranted, report such activity to the senior management of Cunningham.

Cunningham shall comply with all trade and economic sanctions imposed by OFAC against targeted foreign countries and shall cooperate fully with government agencies, self-regulatory organizations and law enforcement officials. As provided by the Act, Cunningham may supply information about former, current or prospective customers to such bodies.

Any officer, employee or AP who fails to comply with Cunningham’s policies and procedures on money laundering may be subject to disciplinary action, including termination of employment. In addition, such failure may expose the individual to civil and criminal penalties under the Act.

Privacy

At Cunningham Commodities, LLC (Cunningham) we value our customers, and maintaining customer trust and confidence is our highest priority. While it is necessary that we obtain accurate and current information about our customers in order to provide the highest level of customer service, we are dedicated to protecting the privacy and confidentiality of our customers’ information.

Cunningham will never sell your personal information to anyone. We will not use or distribute your personal information in any way (except as specifically noted below) without prior notification to you. We promise that we will uphold the privacy policies and procedures as set forth below.

Information we collect about our Customers:

  • The personal information we collect from you comes from information you supply to us in account opening applications (whether written or electronic), or in other forms you may provide to us. This information may include your name, address, social security number or tax identification number, and financial information about you.
  • Information regarding your transactions with us including your trading history at Cunningham, your history of meeting margin calls or your use of the various services and products that we provide.
  • Information about your credit history and information we may receive from your introducing broker or associated person and other consumer reporting agencies.
  • Cookies are small text files consisting of encrypted information assigned to a computers browser. Cookies do not collect or transmit your personal information. For users of the non-public areas of our website or electronic trading platforms that require a User ID or password, Cunningham may use cookies to identify you so that you do not have to input your password multiple times as you navigate our site. Cunningham may also use cookies for administrative purposes, such as to maintain security on our site.

Information we may share about our Customers:

Cunningham will not sell personal information regarding our current or former customers.

  • Cunningham may share personal information about our current and former customers with our affiliated companies and service providers. In this case, your personal information will remain subject to the strictest confidentiality protections.
  • To the extent that we may engage unaffiliated companies to assist in providing services on our website, such providers will be subject to stringent contractual requirements to maintain the confidentiality of any personal information they may obtain in connection with the performance of their services for us. We will make every effort to make sure that they receive the minimum amount of personal information necessary and will be allowed to retain that information only for as long as necessary in order to provide such services. Such service providers will only be allowed to use personal information in the course of providing services to Cunningham and only for the purposes that we authorize.

Information we may disclose:

  • We may disclose information about current or former customers in order to cooperate with legal or regulatory authorities or pursuant to a court order or subpoena.
  • We may also disclose personal information as necessary to perform credit checks, collect debts, enforce our legal rights or otherwise protect our interests and property.

Data Security

Cunningham is committed to protection of your personal information and to protecting your privacy.

Only authorized Cunningham employees or agents will have access to your personal information. All of our employees, affiliates and service providers are held to the highest standards of privacy and security.

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