Disclosures

EXCEED GENERAL DISCLOSURES

Exceed Holdings LLC (“Exceed”) is the parent company of the following entities, some of which are regulated by federal securities laws.

Exceed Securities LLC is a FINRA registered broker-dealer that seeks to offer investment services and products.

Exceed Advisory LLC is a registered investment advisor that seeks to offer investment services and products.

Exceed Indexes LLC is a non-registered entity which publishes and licenses financial indexes.

Exceed Investments is the brand name under which Exceed and its subsidiaries operate.

FIRM COMPENSATION

Exceed Advisory LLC seeks to earn revenue by charging a management fee. Exceed follows regulatory requirements concerning any fees charged to you and in reporting transaction fees to you.

Exceed Indexes LLC may receive compensation in connection with licensing its indexes to third parties.

INDICES GENERAL DISCLAIMER

Indexes are not securities and therefore investing directly in an index is not possible. Exposure to an asset class represented by an index is available through investable instruments based on that index. A decision to invest in any such investment fund or other investment vehicle should not be made in reliance on any of the statements set forth in this document. Prospective investors are advised to make an investment in any such fund or other vehicle only after carefully considering the risks associated with investing in such funds, as detailed in an offering memorandum or similar document that is prepared by or on behalf of the issuer of the investment fund or other vehicle. Inclusion of a security within an index is not a recommendation by Exceed Indexes to buy, sell, or hold such security, nor is it considered to be investment advice. Exceed makes no representation and warranty, express or implied, as to the ability of any index to accurately represent the asset class or market sector that it purports to represent and Exceed shall have no liability for any errors, omissions, or interruptions or any index or the data included therein. Past performance of an index is not a guarantee of future results. Charts and graphs are provided for illustrative purposes. These charts and graphs may reflect hypothetical historical performance. All information presented prior to the launch date is back-tested. Back-tested performance is not actual performance, but is hypothetical. The back-test calculations are based on the same methodology that was in effect when the index was officially launched. However, it should be noted that the historic calculations of an economic Index may change from month to month based on revisions to the underlying economic data used in the calculation of the index. Index returns do not reflect payment of any sales charges or fees an investor may pay to purchase the securities underlying the Index or investment funds that are intended to track the performance of the Index. The imposition of these fees and charges would cause actual and back-tested performance of the securities/fund to be lower than the Index performance shown.

IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT

USA PATRIOT Act

The USA PATRIOT Act is designed to detect, deter, and punish terrorists in the United States and abroad. The Act imposes anti-money laundering requirements on brokerage firms and financial institutions.

ANTI-MONEY LAUNDERING REQUIREMENTS

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 for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

What is money laundering?

To help you understand these efforts, we want to provide you with some information about money laundering and our steps to implement the USA PATRIOT Act. Money laundering is the process of disguising illegally obtained money so that the funds appear to come from legitimate sources or activities. Money laundering occurs in connection with a wide variety of crimes, including illegal arms sales, drug trafficking, robbery, fraud, racketeering, and terrorism.

How big is the problem and why is it important?

The use of the U.S. financial system by criminals to facilitate terrorism or other crimes could well taint our financial markets. According to the U.S. State Department, one recent estimate puts the amount of worldwide money laundering activity at $1 trillion a year.

What are we required to do to eliminate money laundering?

Under the USA PATRIOT Act, our anti-money laundering program must designate a special compliance officer, set up employee training, conduct independent audits, and establish policies and procedures to detect and report suspicious transactions and ensure compliance with the new laws. As part of our required program, we may ask you to provide various identification documents or other information. Until you provide the information or documents we need, we may not be able to open an account or effect any transactions for you.

We thank you for your patience and hope that you will support us in our efforts to deny terrorist groups access to America’s financial system.

BUSINESS CONTINUITY PLAN DISCLOSURE

Exceed has established a company-wide business continuity planning program to assess and manage the effects of a significant emergency disruption on its business operations in an effort to provide continuity of critical business functions. Such critical business functions include communicating with customers regarding their transactions.

Consistent with regulatory requirements, the Company provides this disclosure statement to its clients summarizing the program. Due to the proprietary nature of some information, detailed plans for the program cannot be publicly disseminated.

The business continuity planning program begins with each business units’ assessment of its business continuity risk. This process encompasses all aspects of the Company’s key business functions. The assessment defines, for each business process, its criticality and a method for recovery. Individual business unit plans are reviewed and updated annually, or as significant business changes occur.

The Plan is designed to account for the actions the Company will take in the event of disruptions of varying scope. This includes incidents involving a single office building where any of the Company’s offices may reside, city-wide or regional events of disruption. It also includes a plan for people loss, where staff members may be unable to work at their normal business location. The Plan has been reasonably designed to allow the Company to continue its business, likely at a reduced capacity, and safeguard the interests of our customers. The Company expects to be able to meet its client obligations within the business day.

While the Company’s business continuity plan has been reasonably designed to allow the Company to operate during emergency incidents of varying scope, such potential incidents are unpredictable. The Company has no control over certain infrastructure such as utilities, communication networks, transportation, and third party providers that the Company may rely upon during an emergency. Because of the unpredictable and unknown nature of a potential future business disruption, the Company cannot guarantee that our systems will always be available or able to be recovered in the event of a serious emergency disruption.

Please note that the Company’s business continuity plan is subject to change and modification. You may obtain updated summaries of the plan by contacting us at the following telephone number or address:

Exceed Investments LLC, 28 W. 44th Street, 16th Floor, New York, NY 10036, 646-580-7046

INVESTOR EDUCATION AND PROTECTION

Exceed Securities LLC is a member of the Securities Investor Protection Corporation (“SIPC”). Securities in your account are protected up to $500,000.

SIPC plays an important role in the overall system of investor protection in the United States by, in certain specified situations, restoring funds to investors with assets in the hands of bankrupt and otherwise financially troubled brokerage firms. When a brokerage firm is closed due to bankruptcy or other financial difficulties and customer assets are missing, SIPC steps in as quickly as possible and, within certain limits, works to return customers’ cash, stocks, and other securities. You may obtain more information about SIPC, including a brochure entitled How SIPC Protects You, by contacting SIPC at:

Securities Investor Protection Corporation
805 15th Street, N.W. Suite 800
Washington, D.C. 20005-2215

Tel: (202) 371-8300
Fax: (202) 371-6728
www.sipc.org
Email: asksipc@sipc.org

Exceed Securities LLC is required by FINRA Rules to provide you with information about the availability of information through the FINRA’s Public Disclosure Program. Please be advised that the FINRA offers an investor brochure describing the Public Disclosure Program. The investor brochure may be obtained via the FINRA Web Site (www.finra.org) or through FINRA Public Disclosure Program Hotline Number at (800) 289-9999.

QUESTIONS ABOUT YOUR ACCOUNT

Pursuant to SEC Rule 17(a)-3(a)(18)(ii), complaints should be directed to Exceed Securities LLC, 28 W. 44th Street, 16th Floor, New York, NY 10036, 646-580-7046

Securities offered through Exceed Securities LLC, Member FINRA, SIPC
Investment Advisory Services offered through Exceed Advisory LLC

All material or information shared herein is for informational or educational purposes only. Nothing on this web site shall constitute an offer or solicitation to purchase or sell any securities or funds. You are solely responsible for determining whether any investment, investment strategy, security or related transaction is appropriate for you based on your personal investment objectives, financial circumstances and risk tolerance. You should consult your legal or tax professional regarding your specific situation. Performance returns do not reflect any management fees, transaction costs or expenses. This material contains general information only and is not intended to represent general or specific investment advice. This material may contain forward-looking statements which involve certain risks and uncertainties. The information contained in the material provided on this web site are derived from proprietary and nonproprietary sources deemed to be reliable, but may not necessarily be all-inclusive and are not guaranteed as to accuracy. No part of this material may be reproduced without prior written consent of Exceed Investments.

Exceed Securities LLC, Exceed Indexes LLC and Exceed Advisory LLC are wholly owned subsidiaries of Exceed Holdings LLC, 28 W. 44th Street, 16th Floor, New York, NY 10036