Segregation of Client Assets  

As required, Pershing segregates investor assets, which are fully paid-for, from its own assets. Therefore, in the unlikely event of the financial failure of Pershing, investors’ fully paid-for assets will remain separate from Pershing’s own assets. In addition to this,  Pershing takes the following measures to protect investors’ assets:

• Annual audit by a major independent audit firm and the audit team at our parent company, BNY Mellon

• An annual SAS 70 Type II audit is performed (as required) by a major independent audit firm to provide additional evaluation of the design and operating effectiveness of Pershing’s internal controls related to:

• Account transfers
• Clearance and settlement
• Confirmations and cash management functions
• Corporate actions
• Customer billing
• Foreign exchange and prime brokerage controls
• Interest
• Margin monitoring
• Order and trade processing
• Physical custody
• Pricing
• Statements

• Pershing is required to maintain enough liquid assets, net of anyliabilities, to ensure the return of investors’ fully paid-for assets in the event of Pershing’s failure and liquidation

• Quarterly vault inspection and securities verification to confirm custody of fully paid-for investors assets