Disclosures and Privacy Notice

Opening a new account

Important Information about Procedures for Opening a New 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 prospective client. When opening an account, ASL will request from each prospective client certain identifying information such as the customer's name and address and may request copies of identifying documents such as a corporate resolution, an operating agreement or a trading authorization.

ASL may not be able to establish an account or continue to carry out transactions for a counterparty that does not supply such information or cannot sufficiently verify its identity.

Business Continuity Plan Disclosures

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Payment for Order Flow Disclosures

ASL does not receive remuneration from the broker-dealer or market center through which a customer transaction may be executed.

Extended Hours Trading

Customers should note the following risks in connection with trading outside of regular market hours:

  1. 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 market hours. As a result, your order may only be partially executed, or not at all.
  2. 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 market hours. As a result, your order may only be partially executed, or not at all, or you may receive an inferior price in extended hours trading than you would during regular markets hours.
  3. Risk of Changing Prices. The prices of securities traded in extended hours trading may not reflect the prices either at the end of regular market hours, or upon the opening of the next morning. As a result, you may receive an inferior price in extended hours trading than you would during regular market hours.
  4. Risk of Unlinked Markets. Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended hours 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.
  5. Risk of News Announcements. Normally, issuers make news announcements that may affect the price of their securities after regular market hours. Similarly, important financial information is frequently announced outside of regular market 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.
  6. 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.
  7. Risk of Lack of Calculation or Dissemination of Underlying Index Value or Intraday Indicative Value ("IIV"). For certain Derivative Securities Products, an updated underlying index value or IIV may not be calculated or publicly disseminated in extended trading hours. Since the underlying index value and IIV are not calculated or widely disseminated during the pre-market and post-market sessions an investor who is unable to calculate implied values for certain Derivative Securities Products in those sessions may be at a disadvantage to market professionals.

Email Disclosure

Please read the following carefully as it contains the conditions governing any electronic communications between you and ASL Capital Markets Inc. or its affiliates (collectively, "ASL"). By corresponding with ASL you agree to these terms and conditions of use. ASL may amend these terms and conditions at any time without notice. You should check this webpage from time to time to review the current terms and conditions because they are binding on you.

Any correspondence relating to regulated securities products or services will be deemed to be sent by, addressed to, or related to the activities of ASL Capital Markets Inc., a registered broker-dealer.

Unless otherwise specifically indicated, the contents of any electronic communication (including e-mail, instant message, text messaging, etc.) and its attachments are for informational purposes only, and should not be regarded as an offer to sell or a solicitation of an offer to buy any securities, futures, options, loans, investment products or other financial product or service, an official confirmation of any transaction, an official valuation, or an official statement of ASL. Attachments that are part of an electronic communication may have additional important disclosures and disclaimers, which you should read.

ASL and/or its officers and employees may from time to time acquire, hold, or sell a position in the securities mentioned herein. Upon request, ASL will furnish specific information in this regard. If ASL is involved in the purchase or sale of any security, ASL may act as principal for its own account or as agent for the buyer and/or the seller.

Electronic communications may contain privileged or confidential information, or may otherwise be protected by work product immunity or other legal rules. No confidentiality or privilege is waived or lost by any mis-transmission. Access, copying or re-use of information by non-intended or non-authorized recipients is prohibited. If you are not an intended recipient of an electronic communication, please notify the sender, delete it and do not read, act upon, print, disclose, copy, retain or redistribute any portion of such electronic communication. Electronic communications are not intended for distribution to, or use by, any person or entity in any location where such distribution or use would be contrary to law or regulation, or which would subject any ASL affiliate to any registration requirement within such location.

ASL does not waive any intellectual property rights in any electronic communication.

ASL cannot provide absolute assurances that all electronic transmissions (sent or received) are secure, error free, not corrupted, incomplete or virus free and/or that they won't be lost, mis-delivered, destroyed, delayed, or intercepted/decrypted by others. Therefore, ASL advises against sending sensitive or personally identifiable information via electronic communications and disclaims all liability with regard to electronic communications (and the contents therein) if they are corrupted, lost, destroyed, delayed, incomplete, mis-delivered, intercepted, decrypted or otherwise misappropriated by others.

Information contained in any electronic communication has been obtained from sources which ASL believes to be reliable. However, ASL does not guarantee its accuracy, and such information may be incomplete or condensed. Unless otherwise indicated, the views expressed are the author's and may differ from those of others within ASL. The information represents a view as of the date of the electronic communication and is subject to change and/or withdrawal at any time without notice.

Privacy Notice

On June 29, 2000, the United States Securities and Exchange Commission published final Regulation S-P in the Federal Register. Regulation S-P requires financial institutions, including broker-dealers such as ASL Capital Markets Inc. ("ASL"), to develop privacy policies with respect to customer non-public information and to notify its customers of such policies.

Broker-dealers typically collect customer non-public information, including personally identifiable financial information (e.g., information the customer provides when the client relationship is established such as its name, address, social security number, tax identification number, etc.) to evaluate and to serve client needs and to complete client transactions. Many financial institutions also compile customer lists derived from such personally identifiable information.

ASL does not disclose any non-public personal information relating to its customers, or former customers, to affiliates or non-affiliated third parties, except as permitted by law, to process client transactions or to fulfill legal and/or regulatory requirements. ASL has implemented specific policies and practices with respect to safeguarding the confidentiality and security of customer non-public financial information. ASL's employees are instructed to protect such information and are required to comply with these established policies and practices. ASL always has considered its fiduciary responsibilities to be of paramount importance and will continue to vigorously protect the interests of its clients.

Should you require any additional information, please write to Chief Compliance Officer, ASL Capital Markets Inc., 600 Summer Street, Suite 202, Stamford, CT 06901.