Disclosure of Material Information for FX Transactions

Material Risks of Foreign Exchange ("FX") Transactions

The General Disclosure Statement for Transactions, together with the Disclosure Annex for Foreign Exchange Transactions, contain important information and disclosures about the associated material risks, characteristics, incentives and conflicts of interest that we as a registered swap dealer are required to disclose or furnish to you in advance of transacting. Therefore, we urge you to review carefully such information and disclosures prior to entering into any Swap.

Material Characteristics of Foreign Exchange Transactions

Material Economic Terms:

When we bilaterally negotiate the terms of a Swap with you, information about the material operational and economic terms of a Swap will generally be disclosed and discussed in the process of such negotiation. If you transact with us through an electronic platform, disclosure of the material operational and economic terms will be displayed on, or entered into, the terminal or screens through which the Swap is transacted. Additional information concerning material operational and economic terms of Swaps is included through the links in the sections below.

Transaction Terms:

The terms of any FX Transaction that we may enter into with you will generally be determined as described in this statement.  Transaction Terms

Rights and Obligations of the Parties:

The rights and obligations of the parties during the term of an FX Transaction, as well as operational terms, will be included in the documentation that governs the FX Transaction.

Material Conflicts of Interest and Incentives

DCOs, swap execution facilities and trading platforms may from time to time have in place arrangements that provide their members or participants with volume, market-making or other discounts or credits, may call for members or participants to pre-pay fees based on volume thresholds, or may provide other incentives or arrangements that are intended to encourage market participants to trade on or direct trades to that entity. We may participate in and obtain financial benefits from such incentive programs.

Daily Marks

We will provide you with a daily valuation (the "Daily Mark") for certain uncleared Swaps executed between us through Key2FX. If you need a password and log-in information for, or assistance with, accessing Key2FX and your Daily Mark page, please call 1-800-990-7647.

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