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About Safekeeping-in-Trust
Conservation policy

In this industry, safekeeping-in-trust typically means that client assets are placed in trust protection “within 2 business days.” With our firm, client assets are placed in trust protection "on the same day."

The amount of collateral deposits received from our clients, their realized profits and losses, their mark-to-market profits and losses, and their profits and losses on swap points are all held in trust protection. The trust company that performs safekeeping for us is Rakuten Trust Co., Ltd.
The funds subject to trust protection are as follows: client margin deposits, realized profits and losses, mark-to-market profits and losses, and profits and losses on swap points. The amount of funds we maintain in the trust account exceeds the sum-total of the above items at all times.
At a predetermined reference time—17:00 New York time (US Eastern Standard Time)--every business day, we calculate mark-to-market values of client assets and report the total amount of funds that should be held in trust protection to Beneficiaries' Agent (Beneficiaries' Agent B). The Beneficiaries' Agent B, every business day, verifies that the amount of funds held in the trust account exceeds the amount that should be held in trust protection. If a shortfall in funds is identified at that time, the firm will add additional funds to the trust assets.
Any withdrawals from the trust account are done only upon the Beneficiaries' Agent B's confirmation that, as of the reference time, the trust account assets were not below the amount that should be held in trust protection.
Should the firm, by any chance, experience difficulties, distributions from the available trust assets will be calculated pro rata based on the amount of each client's assets and returned to each client through Beneficiaries' Agent (Beneficiaries' Agent A).

Further, to give peace of mind to our clients, the firm reports mark-to-market values of client assets, for each individual client, to the trust company every business day.

Should our trust company, by any chance, experience difficulties, the funds in the trust account will be protected as trust assets by the Bank of Tokyo-Mitsubishi UFJ, Ltd.

Beneficiaries' Agents

The firm appoints two Beneficiaries'' Agents who represent interests of beneficiaries, i.e. our clients.
One--Beneficiaries' Agent B--is our own internal control manager, and the other--Beneficiaries' Agent A--is appointed from an outside third-party capable of exercising impartial judgment.
The Beneficiaries' Agent B is responsible for daily reconciliation of balances that go into trust protection and similar tasks, while the Beneficiaries' Agent A is in charge of exercising rights of beneficiaries, on their behalf, with the trust company.
While the clients themselves may not, under any circumstances, directly request the return of their funds from the trust company, they can receive, through the Beneficiaries' Agent A, distributions of the available trust assets pro rata based on the amount of their assets if the Beneficiaries' Agent A determines that there has emerged a grave concern in respect of trust protection of client funds.

Important Notes
Note 1: Trust protection is not a guarantee of your principal used in trading. Volatile moves in the currency markets may lead to your losses exceeding the amount of your margin deposit.
Note 2: Rakuten Trust Co., Ltd., our trust firm, does not guarantee our firm's performance of its duties related to trust protection and, further, bears no responsibility for the performance of duties carried out by Beneficiaries' Agents.

About Safekeeping-in-Trust