Disclosures -Casey Securities | FCF Group Holdings

Disclosures

Casey Securities LLC (“CSEC”) is taking this opportunity to make certain disclosures to you and remind you of certain SEC and SRO regulations and policies of CSEC.

BUSINESS CONTINUITY PLANNING

Casey Securities LLC has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us - if you cannot contact us after a significant business disruption as you usually do at 415-954-5579, you should go to our website at www.caseysec.com If you cannot access us through either of those means, you can e-mail compliance@caseysec.com.

OUR BUSINESS CONTINUITY PLAN

We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and

operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

VARYING DISRUPTIONS

Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within three hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within one day. In either situation, we plan to continue in business,

transfer operations to our clearing firm if necessary, and notify you through our website www.caseysec.com how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.

For more information - if you have questions about our business continuity planning, you can contact us at compliance@caseysec.com or www.caseysec.com.

AML CIP DISCLOSURE

CUSTOMER IDENTIFICATION PROGRAM

To help the U.S. government fight the funding of terrorism and money laundering activities, Federal law requires all U.S. financial institutions, such as Casey Securities, to obtain, verify and record information that identifies each individual or institution that establishes a customer relationship with such financial institutions.

We deal generally with financial institutions that do not meet the definition of a customer. If a client, who does meet the definition of a customer, enters a relationship with Casey Securities, which includes opening an account at Casey Securities, we will request certain financial and legal information about such client, including such client’s legal name, tax identification number and address, and the identity of any individuals with any authority or control over such client. We also verify such information to the extent required as follows:

Taking steps to check the information provided – to verify that the clients are who they say they are.
Consult applicable governmental agency lists of known or suspected criminals, terrorists and terrorist organizations to determine if anyone on any such list is attempting to open or maintain an account.
Conduct, in certain instances, additional due diligence when accounts are opened for foreign persons, institutions or other clients.

The U.S. Department of the Treasury, U.S. Securities and Exchange Commission (the “SEC”) and FINRA rules already require clients to provide most of this information.

If a client refuses to provide the information requested or a client’s identity cannot be verified, Casey Securities may not be able to establish or maintain a business relationship with such client. If such client has already established a relationship with Casey Securities, we may have to terminate such relationship. If a client establishes a relationship with Casey Securities and refuses to provide this information, we may be required to report such refusal to appropriate governmental authorities.

Pursuant to U.S. regulations issued under section 311 of the USA PATRIOT Act, 31 CFR 103.192, we are prohibited from opening or maintaining a correspondent account for, or on behalf of the “Specified Institutions” or Jurisdictions of Primary Money Laundering Concern (https://www.fincen.gov/resources/statutes-and-regulations/311-special-measures). The regulations also require us to notify you that your correspondent account with our financial institution may not be used to provide the Specified Institutions with access to our financial institution. If we become aware that the Specified Institutions are indirectly using the correspondent account you hold at our financial institution, we will be required to take appropriate steps to prevent such access, including terminating your account.

Casey has a commitment to the protection of our client and counterparty privacy and confidentiality of client information and has in place systems and processes that isolate and protect our institutional customer’s proprietary and or confidential information from release to the general public. We do collect certain information from our customers in order to process their accounts and enact requested trades on their behalf. We do not release, resale or broadcast client information and our systems are set up to protect client confidential information. We will, however, release this information to federal, state and our DEA or SRO as required by law and statute. We may not be able to notify you of any such release, however, we will notify all of our counterparties if there is a resale of counterparty information to the

public.

ORDER ROUTING (606)

Casey Securities LLC, an agency floor broker on the NYSE Arca option trading floor, considers all orders sent to the Firm as directed order for the purposes of Rule 606 of SEC Regulation NMS.

TIED HEDGE DISCLOSURES

CBOE DISCLOSURES

When handling an option order of 500 contracts or more on your behalf, Casey Securities LLC may buy or sell a hedging stock, security futures or futures position following receipt of the option order but prior to announcing the option order to the trading crowd. The option order may thereafter be executed using the Chicago Board Options Exchange’s tied hedge procedures. These procedures permit the option order and hedging position to be presented for execution as a net-priced package subject to certain requirements. For further details on the operation of the procedures, please refer to Chicago Board Options Exchange Rule 6.74.10, which is available at www.cboe.org/Legal.

BOX DISCLOSURES

When handling an option order of 500 contracts or more on your behalf, Casey Securities LLC may buy or sell a hedging stock, security futures or futures position following receipt of the option order but prior to announcing the option order to the trading crowd. The option order may thereafter be executed using the BOX Exchange LLC tied hedge procedures. These procedures permit the option order and hedging position to be presented for execution as a net-priced package subject to certain requirements. For further details on the operation of the procedures, please refer to BOX Exchange

LLC Rule 7600 Commentary Interpretive Material IM-7600-2, which is available at https://rules.boxexchange.com/browse.

NYSE DISCLOSURES

When handling an option order of 500 contracts or more on your behalf, Casey Securities LLC may buy or sell a hedging stock, security futures or futures position following receipt of the option order but prior to announcing the option order to the trading crowd. The option order may thereafter be executed using the NYSE Arca Options tied hedge procedures. These procedures permit the option order and hedging position to be presented for execution as a net-priced package subject to certain requirements. For further details on the operation of the procedures, please refer to NYSE Arca

Options Rule 6.47 Commentary .01, which is available at https://www.nyse.com/regulation/arca-options.

NASDAQ PHLX DISCLOSURES

Nasdaq PHLX (PHLX) – Tied Hedge Transactions When handling an option order of 500 contracts or more on your behalf, Casey Securities LLC may buy or sell a hedging stock, security futures or futures position following receipt of the option order but prior to announcing the option order to the trading crowd. Except that options on the Nasdaq 100® Index including options with nonstandard expiration dates ("NDX" and "NDXP") may not be smaller than 50 contracts per order (there shall be no aggregation of multiple orders to satisfy the size parameter). The option order may thereafter be

executed using the Nasdaq PHLX tied hedge procedures. These procedures permit the option order and hedging position to be presented for execution as a net-priced package subject to certain requirements, including bringing the stock/future hedge to the trading crowd without undue delay and announcing it concurrently with the option order. For further details on the operation of the procedures, please refer to Nasdaq PHLX Rule Options 8 Section 30 which is available at Rules | Nasdaq PHLX.

CBOE EXCHANGE DISCLOSURE

Casey Securities’ Self-Regulatory Organization, Cboe Exchange, Inc. (“Cboe”), requires that we advise our clients for whom we execute orders but for whom we do not clear transactions (or carry or clear their account) regarding our responsibilities as an executing broker, your responsibilities as our client, and your clearing firm’s responsibilities relative to the orders we execute for you.

When you authorize Casey Securities to reflect bids or offers, enter orders for you, or otherwise act on your instructions or behalf, we act in the capacity of an “executing broker” only. Additionally, we may “show” you orders or potential trades or markets (i.e. bids and/or offers) that we are aware of, and we may reflect other possible executions. As a precondition for using our services, you understand and agree that:

Casey Securities is not making recommendations as to whether or not you should enter similar or contrary orders to the ones we show or reflect to you;
Casey Securities is not advising you as to the appropriateness of entering any order, or maintaining, establishing, or liquidating any position you may have;
You agree to make all such decisions based upon your professional knowledge, experience and capacity to sustain the result of any subsequent transaction and not based upon any communications made by Casey Securities to you;
You agree to hold Casey Securities and its personnel, agents, and associated parties harmless for such communication as a condition to receiving such communication; and
You agree to advise us if anyof these conditions become unacceptable to you and if, therefore, you do not wish to receive such "shows" or reflection of the market.

Casey Securities agrees to be responsible for providing you with market quotations, executing your orders and making certain reports to you and your clearing firm. We reserve the right to reject any order you attempt to give Casey Securities for execution. Casey Securities will notify you promptly if this becomes necessary. You agree that absent contrary instructions received from you or another representative from your firm, Casey Securities may use any floor broker, execution system, exchange, or alternate trading system or facility to carry out your instructions in accordance with your instructions. Casey Securities will send a report regarding all transactions executed for you to your Clearing Firm until we are notified by you, or the Clearing Firm, of a change in your clearing firm. Casey Securities agrees to promptly bill you for services provided to you.

As our client you agree to be responsible for: all orders and instructions given to Casey Securities. You will be responsible for notifying your Clearing Firm (even if it is your firm) of all transactions executed for you by Casey Securities.

As our customer you agree to promptly notify Casey Securities of any change in your clearing relationship and of any limit, or condition, or restriction placed upon your firm by your clearing firm, any regulator, or which result from your firm’s internal decision making process. You expressly understand and agree that Casey Securities may or may not agree to be bound by such limit, condition, or restriction, but only after Casey Securities is informed by you in writing or any such

limit, condition, or restriction.

Your Clearing Firm is responsible for: clearing all executed orders transmitted to them by Casey Securities until such time as written notice is received by Caey Securities of your Clearing Firm’s refusal to clear future transactions. Your Clearing Firm must agree to accept all transactions executed for your account prior to such notice being received by Casey Securities. By executing orders with us you acknowledge that you have discussed this understanding with your clearing firm and that they agree to these terms.

Casey Securities sincerely appreciates the opportunity to provide services to you. We hope that this notice clarifies each parties’ various responsibilities.

This is a negative consent letter, and no response is required by your firm or your clearing firm. However, if you disagree with any of the terms listed above, please contact us at 415-228-6845 or wwong@caseysec.com.

CUSTOMER COMPLAINTS

Please contact compliance@caseysec.com with any customer complaints.

MEMBER EXCHANGES

Casey Securities LLC is a member of FINRA, NYSE Arca Options, BOX Options Exchange, Cboe, and Nasdaq

PHLX.

OPTIONS DISCLOSURE DOCUMENT

The OCC Options Disclosure Document can be found here:

https://www.theocc.com/getmedia/dd6200a7-5982-4226-90e4-1f2d32a89911/june_2024_riskstoc.pdf

SIPC

Member of SIPC

AFFILIATIONS

Casey Securities LLC is under common control with FOG Equities LLC, and Hamilton Executions LLC.

RFA Securities and Fast Market Options are trading names for Casey Securities LLC.