ACCOUNT DISCLOSURE STATEMENT AND AGREEMENT

Thank you for selecting IRA Club. Please read all pages of this statement. The Account Disclosure Statement and Agreement summarizes the requirements pursuant to the Internal Revenue Service regulations which require that the information provided in this agreement be provided to the person(s) for whom the IRA account is established. You must sign this agreement so IRA Club may complete the new account process for your Self Directed IRA account. If you have questions, please contact our office at (312) 795-0988. By executing the IRA Club Account Application package, you acknowledge receipt of IRS Form 5305 and receipt of this Disclosure Statement and Agreement.

SETTING UP A SELF DIRECTED IRA
Establishing the account requires many steps. You should allow approximately 30 days to complete the process. Investing on behalf of the IRA cannot begin until setup is complete.
IRA Club cannot be held responsible for the time required for a former custodian to release qualified funds. IRA Club will solely provide information about IRAs. Legal guidance can only be obtained from a qualified attorney. The IRA Club has no attorney/client relationship with its clients. The information you provide to IRA Club is accurate to the best of your knowledge and it is up to the IRA account owner to update information as it may change.
IRA Club, LLC (“IRA Club”) acts as Administrator of the Custodial Account and appoints MeridianBank to act as the Custodian.
It is important that all activities within your IRA adhere to the regulations relating to IRAs and specifically to the rules regarding Prohibited Transactions. The IRA Club and its corresponding custodian will not accept IRA accounts which are operating companies that generate unrelated taxable income to the IRA.
FUNDING THE IRA WITH A CONTRIBUTION
An annual contribution can be made to an IRA up to the annual limit. The annual contribution limit for 2020 is $6,000.00. If you are age 50 or older, you may make a catch-up contribution to the IRA for that year. The catch-up contribution is an additional $1,000.00 per year for a total catch-up contribution of $7,000.00. Contributions to the IRA must be made before the due date for your federal income tax return for that year (by April 15 for most). If you contribute more than your allowable amount, you may remove the excess amount or apply the excess to contributions for a later year. If you apply the amount of the excess contribution to a later year, you will be required to pay a 6% penalty tax on the amount of the excess contribution for the year in which the excess contribution was made.
ONGOING OPERATIONS OF A SELF DIRECTED IRA
I understand and agree that I am responsible for the investment decisions made for my IRA account.
I understand and agree that transactions in an IRA must adhere with IRS and DOL regulations as they relate to Individual Retirement Arrangements as described in the IRS Code: IRC 4975 and may be amended from time to time.
I understand and agree to provide an annual valuation of the IRA assets to IRA Club, on the IRA VALUATION request form. It is typically sent to account owners in December each year.
IRA Club may require a valuation at the time of any taxable distribution, such as a Roth conversion, investor distribution or required minimum distribution and that such a valuation must be certified by a licensed professional (CPA, Licensed Appraiser, etc.).
I will keep my IRA funds and personal funds separate. I will be sure all IRA investments and expenses are paid only from the IRA account. I will be sure all IRA income and earnings are paid to the IRA account. The IRA may not buy assets from me or members of my family or sell an asset to myself or a member of my family.
IRA Club may determine that the information I provide is not enough to complete its obligations to the Internal Revenue Service. After notifying me of such deficiencies and allowing me to correct them, IRA Club, at its sole discretion, may determine the sufficiency of the information to comply with the Internal Revenue Service regulations and if insufficient, elect to distribute the assets to me.
I understand that IRA Club is not a Fiduciary as that term may relate to investments my IRA may make and IRA Club does not select investments or perform Broker/Dealer functions for my account.
I acknowledge that any future changes in Internal Revenue Service regulations or other laws and regulations may require further action by me to allow the IRA Club to continue to maintain the IRA account.
I agree to hold harmless, protect and indemnify the Custodian and IRA Club from and against all liabilities, losses, damages, expenses and charges, including but not limited to attorney’s fees, penalties and expenses of litigation, which the Custodian and IRA Club may sustain
or might sustain resulting directly or indirectly from my IRA investment(s).
RELATIONSHIP WITH IRA CLUB
IRA Club nor any of its employees; (1) will not select or manage the investments in my IRA. (2) will not perform any due diligence on the investments I direct for my IRA. All investment decisions will be made by me and not by IRA Club nor the Custodian of my IRA account. IRA Club does not offer or sell investment products and is not responsible for any losses that my IRA account may experience due to investment decisions I have made.

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ANTI-MONEY LAUNDERING STATEMENT
IRA Club has procedures in place to comply with the Anti-Money Laundering program as described by the USA Patriot Act. The program includes but is not limited to, checking client identity via independent sources. Testing client names against the Office of Foreign Asset Control’s prohibited parties’ lists, reviewing sources of funds, limiting annual contributions to IRA Club accounts to the Internal Revenue
Service established limits and if deemed necessary, filing Suspicious Activity Reports.
PRIVACY NOTICE
IRA Club has requested you to provide significant personal information. Thank you. This information is necessary, so we may properly service your account. Please know that IRA Club will work to protect the information you provide to us.
DEFINITIONS
We, our, and us, when used in this notice, mean IRA Club. “You” and “Your” shall mean the client of IRA Club.
Non-public personal information means information about you that we collect in connection with providing a financial product or service to you. Non-public personal information does not include information that is available from public sources, such as telephone directories or government records.
GENERAL ACKNOWLEDGEMENT AND AGREEMENT
INFORMATION IRA CLUB COLLECTS ABOUT YOU
IRA Club may collect non-public personal information about you from the following sources: (1) Information we receive directly from you on
applications and other forms. (2) Information about transaction in your IRA account. (3) Information from consumer reporting agencies for identification verification.
Non-public personal information means information about you that we collect in connection with providing a financial administrative service to you. Non-public personal information does not include information that is available from public sources, such as telephone directories or government records. A non-affiliated third-party company that is a company that is not an affiliate of IRA Club.
INFORMATION IRA CLUB MAY DISCLOSE REGARDING YOUR ACCOUNT
IRA Club does not disclose non-public personal information about clients; except as required by law, a State or Federal Agency or by a State of Federal Court. In some instances, IRA Club must disclose some client information to State Regulators, our bank, custodian, or our attorneys. IRA Club limits access to non-public personal information only to those employees who need to know that information to provide services to you. IRA Club maintains physical, electronic, and procedural safeguards that comply with Federal standards to guard your non-public personal information.

By signing this agreement, I hereby acknowledge that I have read and understand this statement and agreement and that I understand my responsibilities to IRA Club. I acknowledge that I have not and will not engage in any prohibited transactions within my IRA my and (or an IRA LLC retirement account or its asset holdings). I further acknowledge that if I do not provide IRA Club with the information required by this agreement, IRA Club may elect to distribute the account in whole or in part to me and that this may be a taxable distribution. The Custodian may rely on the information provided by me both now and in the future regarding my IRA investments. I hold IRA Club harmless from any action taken against them due to the inadequacy or inaccuracy of any information or documentation I provide.

Form 5305-A (Rev. April 2017)
Department of the Treasury
Internal Revenue Service
The Depositor named on the IRA Club Self Directed IRA
CUSTODIAL ACCOUNT AGREEMENT: FOR TRADITIONAL IRAS
Under section 408(a) of the
Internal Revenue Code
Keep for your records. Do not file.
Article I
Application is establishing a traditional individual retirement account under section 408(a) to provide for his or her retirement and for the support of his or her beneficiaries after death.
The Custodian must be a bank or savings and loan association as defined in section 408(n), or any person who has the approval of the IRS to act as Custodian. The Custodian of the Custodial Account is MeridianBank.
The Depositor, the custodian and administrator make the following agreement.
Appointment of the Administration and the Custodian. The Depositor herby appoints The IRA Club, LLC (“IRA Club”) to act as Administrator of the Custodial Account and appoints MeridianBank to act as the Custodian. The depositor understands and acknowledges that the Administrator is to provide administrative service for the Custodial Account, and to properly fulfill its duties to the Depositor as the Administrator. Under the terms of the account agreement, all communication between the Depositor and the Custodian shall be handled through the Administrator. The Depositor acknowledges and agrees that this Custodial Account Application and Form 5305, together with the fee schedule and any other written instructions, collectively comprise of the entire agreement and govern all aspects of the relationship with the Custodian, Administrator and any future trust entity. The Depositor acknowledges and agrees that the Administrator is independent of the Custodian and not empowered or authorized to be obligated or bound by the Custodian, and vice versa. Furthermore, nothing in this Agreement shall be construed to render the Administrator, any future trust entity, affiliate, employee, joint venture partner, strategic partner, as an agent of, or with the Custodian.
Neither the Administrator nor the Custodian is a trustee, mortgage broker, asset manager, investment advisor or loan servicing agent with respect to the Depositor and/or the Custodial Account. Neither the Administrator nor the Custodian has any discretionary power, authority or control with respect to the acquisition, management, investment or disposition of the self-directed Custodial Account or assets held in the IRA (individual retirement account).
Except in the case of a rollover contribution described in section 402(c), 403(a)(4), 403(b)(8), 408(d)(3), or 457(e)(16), an employer contribution to a simplified employee pension plan as described in section 408(k), or a recharacterized contribution described in section 408A(d)(6), the custodian will accept only cash contributions. For individuals who have reached the age of 50 by the end of the year, the contribution limit is increased to an additional $1,000 per year. For years after 2020, these limits will be increased to reflect a cost-of-living adjustment, if any.
Article II
The Account Owner’s interest in the balance in the custodial account is nonforfeitable.
Article III
1. No part of the custodial account funds may be invested in life insurance contracts, nor may the assets of the custodial account be commingled with other property except in a common trust fund or common investment fund (within the meaning of section 408(a)(5)).
2. No part of the custodial account funds may be invested in collectibles (within the meaning of section 408(m)) except as otherwise permitted by section 408(m)(3), which provides an exception for certain gold, silver, and platinum coins, coins issued under the laws of any state, and certain bullion.
Article IV
1. Notwithstanding any provision of this agreement to the contrary, the distribution of the Account Owner’s interest in the custodial account shall be made in accordance with the following requirements and shall otherwise comply with section 408(a)(6) and the regulations thereunder, the provisions of which are herein incorporated by reference.
2. The Account Owner’s entire interest in the custodial account must be, or begin to be, distributed not later than the Account Owner’s required beginning date, April 1 following the calendar year in which the Account Owner reaches age 70 1/2. By that date, the Account Owner may elect, in a manner acceptable to the custodian, to have the balance in the custodial account distributed in: (a) A single sum or (b) Payments over a period not longer than the life of the Account Owner or the joint lives of the Account Owner and his or her designated beneficiary.
3. If the Account Owner dies before his or her entire interest is distributed to him or her, the remaining interest will be distributed as follows:
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(a) If the Account Owner dies on or after the required beginning date and: (i) The designated beneficiary is the Account Owner’s surviving spouse, the remaining interest will be distributed over the surviving spouse’s life expectancy as determined each year until such spouse’s death, or over the period in paragraph (a)(iii) below if longer. Any interest remaining after the spouse’s death will be distributed over such spouse’s remaining life expectancy as determined in the year of the spouse’s death and reduced by 1 for each subsequent year, or, if distributions are being made over the period in paragraph (a)(iii) below, over such period. (ii) The designated beneficiary is not the Account Owner’s surviving spouse, the remaining interest will be distributed over the beneficiary’s remaining life expectancy as determined in the year following the death of the Account Owner and reduced by 1 for each subsequent year, or over the period in paragraph (a)(iii) below if longer. (iii) There is no designated beneficiary, the remaining interest will be distributed over the remaining life expectancy of the Account Owner as determined in the year of the Account Owner’s death and reduced by 1 for each subsequent year.
(b) If the Account Owner dies before the required beginning date, the remaining interest will be distributed in accordance paragraph (i) below or, if elected or there is no designated beneficiary, in accordance with paragraph (ii) below. (i) The remaining interest will be distributed in accordance with paragraphs (a)(i) and (a)(ii) above (but not over the period in paragraph (a)(iii), even if longer), starting by the end of the calendar year following the year of the Account Owner’s death. If, however, the designated beneficiary is the Account Owner’s surviving spouse, then this distribution is not required to begin before the end of the calendar year in which the Account Owner would have reached age 701/2. But, in such case, if the Account Owner’s surviving spouse dies before distributions are required to begin, then the remaining interest will be distributed in accordance with paragraph (a)(ii) above (but not over the period in paragraph (a)(iii), even if longer), over such spouse’s designated beneficiary’s life expectancy, or in accordance with paragraph (ii) below if there is no such designated beneficiary. (ii) The remaining interest will be distributed by the end of the calendar year containing the fifth anniversary of the Account Owner’s death.
4. If the Account Owner dies before his or her entire interest has been distributed and if the designated beneficiary is not the Account Owner’s surviving spouse, no additional contributions may be accepted in the account.
5. The minimum amount that must be distributed each year, beginning with the year containing the Account Owner’s required beginning date, is known as the “required minimum distribution” and is determined as follows. (a) The required
CUSTODIAL ACCOUNT AGREEMENT: FOR TRADITIONAL IRAS
minimum distribution under paragraph 2(b) for any year,
beginning with the year the Account Owner reaches age 701/2,
is the Account Owner’s account value at the close of business
on December 31 of the preceding year divided by the
distribution period in the uniform lifetime table in Regulations
section 1.401(a)(9)- 9. However, if the Account Owner’s
designated beneficiary is his or her surviving spouse, the
required minimum distribution for a year shall not be more
than the Account Owner’s account value at the close of business
on December 31 of the preceding year divided by the number
in the joint and last survivor table in Regulations section
1.401(a)(9)-9. The required minimum distribution for a year
under this paragraph (a) is determined using the Account
Owner’s (or, if applicable, the Account Owner and spouse’s)
attained age (or ages) in the year. (b) The required minimum
distribution under paragraphs 3(a) and 3(b)(i) for a year,
beginning with the year following the year of the Account
Owner’s death (or the year the Account Owner would have
reached age 701/2, if applicable under paragraph 3(b)(i)) is the
account value at the close of business on December 31 of the
preceding year divided by the life expectancy (in the single life
table in Regulations section 1.401(a)(9)-9) of the individual
specified in such paragraphs 3(a) and 3(b)(i). (c) The required
minimum distribution for the year the Account Owner reaches
age 701/2 can be made as late as April 1 of the following year.
The required minimum distribution for any other year must be
made by the end of such year.
6. The owner of two or more traditional IRAs may satisfy the
minimum distribution requirements described above by taking
from one traditional IRA the amount required to satisfy the
requirement for another in accordance with the regulations
under section 408(a)(6)
Article V
1. The Account Owner agrees to provide the custodian with all
information necessary to prepare any reports required by
section 408(i) and Regulations sections 1.408-5 and 1.408-6.
2. The custodian agrees to submit to the Internal Revenue
Service (IRS) and Account Owner the reports prescribed by the
IRS.
Article VI
Notwithstanding any other articles which may be added or
incorporated, the provisions of Articles I through III and this
sentence will be controlling. Any additional articles inconsistent
with section 408(a) and the related regulations will be invalid.
Article VII
This agreement will be amended as necessary to comply with
the provisions of the Code and the related regulations. Other
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amendments may be made with the consent of the persons whose signatures appear below.
Stretch Provisions
Article VIII and any Article, thereafter, may be used for any additional provisions also referred to as Stretch Provisions of this Agreement. The Stretch Provisions added hereinafter must comply with applicable requirements of state law and the Internal Revenue Code and may not imply that they have been reviewed or preapproved by the IRS.
Article VIII
Definitions: In this part of this Agreement (Article VIII), the words “you” and “your” mean the Depositor, the words “we,” “us” and “our” mean the IRA Administrator and/or IRA Custodian (including its subsidiaries, agents and administrator), “Code” means the Internal Revenue Code, and “Regulations” means the
Treasury Regulations. The term “Broker” means the broker dealer/financial representative selected by you to provide investment services to your Traditional IRA.
Any notice to be given to us will be considered effective when we receive it. You must notify us in writing of a change of address.
Representations and Responsibilities: You represent and warrant to us that any information you have given or will give us, with respect to this Agreement is accurate. Further, you agree that any directions you give us, or action you take will be proper under this Agreement and that we are entitled to rely upon such information or directions.
We shall have no duty or responsibility to question any of your directions, review any securities or other property held in the Traditional IRA, or make any suggestions to you with respect to the investment, retention or disposition of any asset held in the Traditional IRA. We are entitled to act upon any instrument, certificate or form we believe is genuine and believe is signed or presented by the proper person or persons and we need not investigate or inquire as to any statement contained in any such document, but may accept it as true and accurate. We will not provide any tax, legal or investment advice.
We shall have no duty to monitor the sufficiency or adequacy of your actions or duties or those of your heirs, successors, agents, or assigns, nor shall we be required to monitor the acts of any paid consultant to whom we may have contractually delegated any duties or responsibilities pursuant to you or your agent’s direction.
We shall not be responsible for losses of any kind that may result from your directions to us or your actions or failures to act and you agree to reimburse us for any loss we may incur as a result of such directions, actions or failures to act. We shall not be responsible for any penalties, taxes, judgments or
CUSTODIAL ACCOUNT AGREEMENT: FOR TRADITIONAL IRAS
expenses you incur in connection with the Traditional IRA. We
have no duty to determine whether your contributions or
distributions comply with the Code, Regulations, rulings or this
Agreement
(a) Rollovers and Tax Consequences
You are responsible for determining whether a distribution
from another Traditional IRA or Qualified Retirement Plan may
be rolled over to this Traditional IRA.
You understand that we do not make any representation or
warranty that any rollover contribution will be excludable from
income for Federal or State income tax
purposes.
(b) Custodial Account
We shall maintain a custodial account for your benefit. The
custodial account will consist of an interest-bearing account
with us and all other investments purchased at your direction.
All assets in the custodial account will be registered in our name
as custodian or in the name of our nominee. We may, by or
through a Broker, or other such firm, hold any securities in
bearer form or deposit them with a central clearing corporation
or depository approved by the Securities and Exchange
Commission; provided that our records show that all such
investments are part of the custodial account.
(c) IRA Administrator & Custodian’s Reservation of Rights
Notwithstanding any other provision of this Article VIII, we
reserve the right to refuse to follow any investment direction by
you which we determine violates any Federal or State Law.
Service Fees: We have the right to charge an annual service fee
or other designated fees (for example, a transfer, rollover,
transaction, or termination fee) for maintaining this Traditional
IRA.
In addition, we have the right to be reimbursed or reserve funds
for all reasonable expenses we incur in connection with the
administration of the Traditional IRA. For more information on
our fees, please refer to the current separate Schedule of Fees.
Any brokerage commissions attributable to the assets in the
Traditional IRA will be charged to the Traditional IRA. You
cannot reimburse the Traditional IRA for those commissions.
Your Investment Powers and Our Custodial
Duties/Obligations:
(a) Investment of Traditional IRA
Subject to Section 8.05(f), you have sole authority and
discretion, fully and completely, to select and to direct the
investment of all assets in the Traditional IRA.
You accept full and sole responsibility for the success or failure
of any selection made. We shall have no discretion to direct any
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investment in the Traditional IRA. We will not act as investment advisor or counselor to you and will not advise you or offer any opinion or judgment on any matter pertaining to the nature, value, potential value or suitability of any investment or potential investment of the assets of the Traditional IRA and are merely authorized to acquire and hold the particular investments specified by you. We shall not have any responsibility nor any liability for any loss of income or of capital, nor for any unusual expense which we may incur, relating to any investment, or to the sale or exchange of any asset which you or your authorized agent directs the IRA Administrator to make.
After your death, your beneficiary shall have the right to direct the investment of the Traditional IRA assets, subject to the same conditions that applied to you during your lifetime under this Agreement. All transactions shall be subject to any and all applicable Federal and State laws and regulations and the rules, regulations, customs and usages of any exchange, market or clearing house where the transaction is executed and to our policies and practices.
(b) Limitation of Investment Powers
We, as Custodian of the Traditional IRA assets entrusted to us under the Traditional IRA, shall not commingle the Traditional IRA with any other property we hold except in a common trust fund or common investment fund. We retain the power to take such actions as are reasonable and necessary to carry out our duties under the Traditional IRA. We are under no duty to take any action other than as specified under this Agreement unless you provide us with instructions and agree to indemnify and hold us harmless from any claims arising out of such instructions. Subject to the rules imposed by us, and subject to investment directions given by you or your authorized agent, we are authorized and empowered, but not by way of limitation, with the following powers, rights and duties:
1) To hold or invest any part or all the Traditional IRA in any asset permissible under law as an investment for an individual retirement account;
2) To manage, sell, contract to sell, grant options to purchase, convey, petition, divide, subdivide, exchange, transfer, abandon, improve, repair, insure, lease for any term even though commencing in the future or extending beyond the term of the Traditional IRA, and otherwise deal with all property, real or personal, in such manner for such considerations and on such terms and conditions as are in accordance with the written direction we receive;
3) To borrow money, to lend money, to assume indebtedness, extend mortgages and encumber by mortgage or pledge;
4) To retain in cash so much of the Traditional IRA as you or your authorized agent directs, or pending other instructions from
CUSTODIAL ACCOUNT AGREEMENT: FOR TRADITIONAL IRAS
you or your authorized agent, and to deposit such cash held in
the Traditional IRA in a savings instrument at a reasonable rate
of interest, including specific authority to invest in an individual
savings account, an individual certificate of deposit, a money
market account, or in other savings instruments which we offer
and/or select. We may perform sub-accounting functions
related to the un-invested funds and may receive a fee directly
from an investment sponsor for these services;
5) To transfer all or any part of the Traditional IRA funds from
one type of savings instrument offered by us to another type of
savings instrument offered by us, to the extent permitted by the
applicable governmental regulations and our procedures;
6) To purchase and to hold annuity contracts and exercise all
rights of ownership of the contracts; and
7) To make, execute and deliver as Custodian contracts,
waivers, releases or other written instruments necessary to
exercise the powers enumerated above.
(c) IRA Administrator & Custodian’s Powers
We shall have the power or duty:
1)To hold any securities or other property in the Traditional IRA
in the name of the Custodian or its nominee, or in another form
as we may deem best, with or without disclosing the custodial
relationship;
2) To retain any funds or property subject to any dispute
without liability for the payment of interest and to decline to
make payment or delivery of the funds or property until a court
of competent jurisdiction makes final adjudication;
3) To charge against and pay from the Traditional IRA all taxes
of any nature levied, assessed, or imposed upon the Traditional
IRA, and to pay all reasonable expenses and attorney fees which
may be necessarily incurred by us with respect to the
Traditional IRA;
4) To file any tax or information return required of us, and to
pay any tax, interest or penalty associated with any such tax
return;
5) To act pursuant to written blanket settlement authorization
given by you on transactions executed by your designated
agent. We are authorized to honor all trade confirmations
received from such agent;
6) To furnish or cause to be furnished to you an annual calendar
year report concerning the status of the Traditional IRA,
including a statement of the assets of the Traditional IRA held
at the end of the calendar year;
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7) To begin, maintain or defend any litigation necessary in connection with the administration of the Traditional IRA, except that we shall not be obliged or required to do so unless indemnified to our satisfaction, including, without limitation, payment of such expenses out of Traditional IRA assets;
8) To exercise the voting rights and other shareholder rights with respect to securities in the Traditional IRA but only in accordance with the instructions you give to us;
9) To employ and pay from the Traditional IRA reasonable compensation to agents, attorneys, accountants and other professional persons for advice that in our opinion may be necessary. We may delegate to any agent, attorney, accountant and other persons selected by us any power or duty vested in us by this Agreement; and
10) To charge you separately for any fees or expenses or deduct the amount of the fees or expenses from the assets in the Traditional IRA at our discretion. We are also entitled to be reimbursed for any taxes and other expenses we assume or incur on behalf of your account. Our right to compensation and reimbursement from the account shall constitute a first prior lien against your account. We have the right to change our fee upon 30 days’ notice to you. We are authorized to liquidate assets of the Traditional IRA for any unpaid fee balance and can, at our discretion, require you to retain un- invested cash in the Traditional IRA in an amount not less than one year’s annual fees and termination fees and not more than $1,000. The choice of the selling broker and assets to be sold shall be at our sole discretion. Should fees or expenses not be collected, we shall have the option to cease performing any functions, including, but not limited to, processing investment transactions until such time as all fees and expenses charged against the account are fully paid.
In addition to the fees reflected on the most recent fee schedule, The Custodian may receive compensation from a depository bank for necessary administrative services as part of the establishment of and maintenance of the custodial cash account including, but not limited to sub-accounting services, depository institution selection, record-keeping and transaction
interest that shall be set by the Custodian’s Board of Directors at least annually consistent with rates being offered by one or more depository institutions for similar accounts. The Custodian, at its discretion, may place deposits with one or more depository banks. All these depository bank accounts will be FDIC insured up to the maximum allowed by law.
In addition, the Custodian may receive commissions, 12(b)1 fee, sub-transfer agent fees, marketing fees and other types of compensation from various entities relating to investments held in the Traditional IRA.
(d) Publicly‐Traded Securities
CUSTODIAL ACCOUNT AGREEMENT: FOR TRADITIONAL IRAS
If publicly-traded securities are to be included in the specified
investments, orders shall be executed through a securities
broker/dealer registered under the Securities Exchange Act of
1934 designated by you upon such form as we may prescribe.
Any brokerage account maintained in connection herewith shall
be in our name as the Custodian of your account. We shall be
authorized to honor transactions within the brokerage account
without obligation to verify prior authorization of same by you.
Any cash received by the brokerage account, whether as
income or proceeds of transactions, may be held by the
brokerage account pending directions, and we shall have no
obligation to direct the broker to remit such cash until directed
to do so by you, but may receive remittances without direction
if the same are made by the broker. Investments outside the
brokerage account shall be made in accordance with the other
provisions of this Article.
(e) Investment directions may be given by you directly to your
designated broker (in such manner as the broker may require)
and the broker shall be responsible for the execution of such
orders. When securities are purchased within your brokerage
account requiring that funds be remitted by us to make
settlement, you agree to telephonically notify us or instruct your
broker or agent to telephonically notify us on the trade date of
the pending securities transaction, and to request delivery of
the Traditional IRA account assets necessary to settle the trade.
You agree to hold us harmless for any losses resulting from
your failure to notify us of the pending trade and request for
settlement in the above-prescribed manner.
(f) Alternative Investments
You may, at your discretion, direct us to purchase “alternative”
investments which shall include, but not be limited to,
investments which are individually negotiated by you or your
agent, or part of a private placement of securities offered in
reliance upon exemptions provided by Sections 3(B) and 4(2) of
the Securities Act of 1933 and Regulation D promulgated
thereunder. It is your sole responsibility to determine whether
your selected investment(s) is required to be registered as a
security with any applicable federal and/or state regulatory
authority. We reserve the right to not follow such direction or
process such investment(s) for administrative reasons. Such
action should not be construed as investment advice or an
opinion by us as to the investment’s prudence or viability. If you
or your agent should direct us to purchase an alternative
investment, as defined above, the following special
certifications and provisions shall apply:
1) You agree to submit or cause to be submitted all offering
documentation related to the alternative investment for an
administrative review by us, if so requested. We reserve the
right to charge a reasonable fee for such administrative review.
2) If the alternative investment(s) contains a provision for future
contractual payments or assessments, including margin calls,

you acknowledge that such payments shall be borne solely by the Traditional IRA account, that authorization to make such payments shall come from you or your agent, and that making such payments may reduce or exhaust the value of the Traditional IRA account. You further agree to maintain enough liquid funds in the Traditional IRA account to cover any such payments or assessments and agree that we are not responsible for monitoring the balance of the account to verify compliance with this Section.
3) If the alternative investment(s) contain administrative and/or management requirements or duties beyond our capabilities or expertise to provide, then you agree to seek out suitable agents or counsel necessary to perform such duties and deliver a written service agreement acceptable to us for execution on behalf of the Traditional IRA account.
4) If you direct us to enter into an individually-negotiated debt instrument, including a promissory note, deed of trust, real estate contract, mortgage note or debenture, we strongly encourage you retain the services of a third-party Note Servicing Agent Agreement with a third-party Agent, on a form acceptable to us. Said Note Servicing Agent shall be your agent and not ours and shall be responsible for administering the terms of the debt instrument on behalf of the Traditional IRA account. Should the Note Servicing Agent ever become unwilling or unable to perform the duties outlined in the Note Servicing Agent Agreement, then you understand and agree that all duties of the Note Servicing Agent shall revert to you until a successor Agent is named. We will not act as a Note Servicing Agent, i.e., we do not monitor your account to ensure receipt of note payments, notify you in the event of default, prepare or compute payoff balances, prepare or file Form 1098, etc.
5) We are responsible for safekeeping only those documents which you or your agent deliver to us.
6) You agree to be responsible for any and all collection actions, including contracting with a collection agency or instituting legal action, and bring any other suits or actions which may become necessary to protect the rights of the account as a result of the operation or administration of the investment(s).
7) Once you or your agent authorize that funds to be distributed from your account for purposes of investment, you agree to be responsible for the following:
a) verifying that the individual or investment company that you selected placed your funds into the proper investment;
b) obtaining the necessary documentation from the individual or investment company to verify that the funds were correctly invested, including, but not limited to, shares or units, proper recordation, loan to value ratio, etc.; and
CUSTODIAL ACCOUNT AGREEMENT: FOR TRADITIONAL IRAS
c) sending the original documentation evidencing the
investment to us or, in the case of a promissory note
investment, to a third-party servicing agent. We will not monitor
the account to ensure receipt of such documentation and will
rely solely on you to provide this information.
(g) Delegation of Investment Responsibility
We may, but are not required to, permit you to delegate
investment responsibility for the Traditional IRA to another
party. On a form or format acceptable to us, you may designate
a representative for the purpose of communicating investment
directions to us and receiving information from us regarding
your account. Said representative may be a registered
representative of a broker/dealer organization, a financial
advisor or other person as may be acceptable to you. Such
person shall be your authorized agent, and not ours. We shall
construe any and all investment directions given by such
person, whether written or oral, as having been authorized by
you. You may appoint and/or remove such a person only by
written notice to us provided that their removal shall not have
the effect of canceling any notice, instruction, direction or
approval received by us from the removed person before we
receive notice of removal from you. We shall follow the proper
written direction of any such party who is properly appointed,
and we shall be under no duty to review or question, nor shall
we be responsible for, any of that party’s directions, actions or
failures to act. That party’s instructions to us shall be deemed
to be instructions by you for all purposes of this Article VIII.
(h) Broker
You have the sole responsibility for the appointment, selection
and retention of a Broker. You have the sole responsibility for
determining whether the Broker is qualified to act in that
capacity. We shall assume that the Broker appointed by you is
always qualified to act. We shall further assume that the Broker
possesses the authority to act in that capacity until such time as
you have appointed another Broker. The Broker will be
responsible for the execution of securities orders. The Broker
may require that you sign an agreement which sets forth,
among other things, its responsibilities and your
responsibilities regarding securities transactions for the
Traditional IRA.
(i) Authorization
On a form or in a format acceptable to us, you may authorize
us to accept written, verbal, fax, e-mail and other means of
communication for investment directions from you or your
designated representative. You agree that we are not
responsible for verifying the propriety of any investment
direction and that we are not responsible for unauthorized
trades in your account that may be affected under this Section.
(j) Valuation of Assets
We shall value assets of the account on a periodic basis utilizing
various outside sources. However, we do not guarantee the

accuracy of such prices obtained from quotation services, independent appraisal services, investment sponsors, or parties related thereto or other outside sources. Values for brokerage accounts shall be equal to the total equity value of the account and shall reflect only those assets that are priced by the brokerage firm. Individual assets held within your brokerage account may not be listed individually on our statements. Such information can be obtained directly from your brokerage statement.
The IRA Administrator or the IRA Custodian shall have no duty or responsibility to value illiquid assets such as promissory notes, real estate, privately held stocks, etc. These assets will be valued at cost (original purchase price) unless you provide us with documentation, in a form and from a source acceptable to us, which provides an alternative value. With respect to Limited Partnerships and Limited Liability Companies, we may solicit a value directly from the investment sponsor or other outside source. If the investment sponsor is unwilling or unable to provide a fair market value, then we may list the value of the asset at its original cost or as “Not Available.”
Assets which have no readily determinable market value, are bankrupt, or for which no original cost or value is otherwise available may have their value reflected as “Not Available” on our statements. Should we be required to provide such information for illiquid assets we may obtain suitable and independent advisors. The costs of the independent valuation shall be at the expense of the Traditional IRA.
(k) Unrelated Business Taxable Income (UBIT) and or Unrelated Debt Financing Income (UDFI)
Certain investments may generate taxable income within the Traditional IRA account. This is referred to as UBTI or UDFI. Such income must be considered in conjunction with all such income from all the Traditional IRA accounts and may be taxable to your account(s) to the extent that all UBTI and UDFI for a given taxable year exceeds the threshold amount set by the IRS (currently $1000). In such instances, the IRS requires that a Form 990-T be filed for the Traditional IRA account along with the appropriate amount of tax. We do not monitor the amount of UBTI or UDFI in the Traditional IRA account with us and do not prepare Form 990-T. Therefore, you must monitor UBTI and UDFI for this and any other Traditional IRA account which you may hold and prepare, or have prepared, the proper 990-T tax form and forward it to us for filing, along with authorization to pay any tax due from the Traditional IRA account.
(l) Life Insurance and Collectibles
You may not direct the purchase of a life insurance contract or a “collectible” as defined in Code Section 4011(m).
Beneficiary(ies): If you die before you receive all the amounts in your Traditional IRA, payments from your Traditional IRA will be made to your beneficiary(ies).
CUSTODIAL ACCOUNT AGREEMENT: FOR TRADITIONAL IRAS
You may designate one or more persons or entities as
beneficiary of your Traditional IRA. This designation can only be
made on a form provided by or acceptable to us, and it will only
be effective when it is filed with us during your lifetime or after
as provided by law. Unless otherwise specified, each beneficiary
designation you file with us will cancel all previous ones. The
consent of a beneficiary(ies) shall not be required for you to
revoke a beneficiary designation. If you have designated both
primary and contingent beneficiaries and no primary
beneficiary(ies) survives you, the estate will be the beneficiary.
A spouse beneficiary shall have all rights as granted under the
Code or applicable Regulations to treat your IRA as his or her
own.
We may allow, if permitted by state law, an original IRA
beneficiary(ies) (the beneficiary(ies) who is entitled to receive
distribution(s) from an inherited IRA at the time of your death)
to name a successor beneficiary(ies) for the inherited IRA. This
designation can only be made on a form provided by or
acceptable to us, and it will only be effective when it is filed with
us during the original IRA beneficiary’s(ies’) lifetime or after as
provided by law. Unless otherwise specified, each beneficiary
designation form that the original IRA beneficiary(ies) files with
us will cancel all previous ones. The consent of a successor
beneficiary(ies) shall not be required for the original IRA
beneficiary(ies) to revoke a successor beneficiary(ies)
designation. If the original IRA beneficiary(ies) does not
designate a successor beneficiary(ies), his or her estate will be
the successor beneficiary. In no event shall the successor
beneficiary(ies) be able to extend the distribution period
beyond that required for the original IRA beneficiary.
Termination: Either party may terminate this Agreement at any
time by giving written notice to the other. We can resign as
Custodian at any time effective 30 days after we mail written
notice of our resignation to you. Upon receipt of that notice, you
must decide to transfer the Traditional IRA to another financial
organization. If you do not complete a transfer of the
Traditional IRA within 30 days from the date we mail the notice
to you, we have the right to transfer the Traditional IRA assets
to a successor Traditional IRA Custodian or Trustee that we
choose in our sole discretion or we may pay the Traditional IRA
to you in a single sum. We shall not be liable for any actions or
failures to act on the part of the successor Custodian or Trustee
nor for tax consequences you may incur that result from the
transfer or distribution of the Traditional IRA assets pursuant to
this section.
If this Agreement is terminated, we may hold back from the
Traditional IRA a reasonable amount of money which we
believe is necessary to cover any one or more of the following:
(a) any fees, expenses or taxes chargeable against the
Traditional IRA;

(b) any penalties associated with the early withdrawal of any savings instrument or other investment in the Traditional IRA.
If our organization is merged with another organization (or comes under the control of any Federal or State agency) or if our entire organization (or any portion which includes the Traditional IRA) is bought by another organization, that organization (or agency) shall automatically become the Trustee or Custodian of the Traditional IRA, but only if it is the type of organization authorized to serve as a Traditional IRA Trustee or Custodian.
If we are required to comply with Section 1.408-2(e) of the Treasury Regulations and we fail to do so, or we are not keeping the records, making the returns or sending the statements as are required by forms or Regulations, the IRS may, after notifying you, require that a substitute Trustee or Custodian be appointed.
Amendments: We have the right to amend this Agreement at any time and charge a fee for IRS mandated amendments. Any amendment we make to comply with the Code and related Regulations does not require your consent.
Withdrawals: All requests for withdrawal shall be in writing on a form provided by or acceptable to us. The method of distribution must be specified in writing. The tax identification number of the recipient must be provided to us before we are obligated to make a distribution.
Age 72 Notice: Effective January 1, 2020, the SECURE Act has changed the age requirement for Account Owners to take their first RMD (“Required Minimum Distribution”) from 70 ½ to 72. This applies only to individuals reaching 72 after December 31, 2019. If you reached age 70 ½ in 2019, you are still subject to RMD, and must take your first distribution no later than April 1, 2020. I certify that I have read the applicable section for the transaction I have chosen,
and understand and agree to all terms.
Required Minimum Distributions: You may make an election to begin receiving payments from your IRA in a manner that satisfies the required minimum distribution rules no later than April 1st of the year following the year you reach age 70½ (this is called the “required beginning date”). If you fail to make such an election by your required beginning date, we can, at our complete and sole discretion, do any one of the following:
(a) make no payment until you give us a proper payment request;
(b) pay your entire IRA to you in a single sum payment or distribution in kind; or
(c) calculate your required minimum distribution each year for your IRA based on an IRS approved method and pay those distributions to you until you direct otherwise.
CUSTODIAL ACCOUNT AGREEMENT: FOR TRADITIONAL IRAS
We will not be liable for any penalties or taxes related to your
failure to take a distribution.
Transfers from Other Plans: We can receive amounts
transferred to the Traditional IRA from the Custodian or Trustee
of another Traditional IRA. We reserve the right not to accept
any transfer or rollover.
Liquidation of Assets: We have the right to liquidate assets in
the Traditional IRA if necessary, to make distributions or to pay
fees, expenses or taxes properly chargeable against the
Traditional IRA. If you fail to direct us as to which assets to
liquidate, we will decide in our complete and sole discretion and
you agree not to hold us liable for any adverse consequences
that result from our decision.
Restrictions on The Fund: Neither you nor any beneficiary
may sell, transfer or pledge any interest in the Traditional IRA in
any manner whatsoever, except as provided by law or this
Agreement. The assets in the Traditional IRA shall not be
responsible for the debts, contracts or torts of any person
entitled to distributions under this Agreement.
What Law Applies: This Agreement is subject to all applicable
Federal and State laws and regulations. If it is necessary to apply
any State law to interpret and administer this Agreement, the
law of the state of Illinois shall govern.
If any part of this Agreement is determined by a court of
competent jurisdiction to be invalid, the remaining parts shall
not be affected. Neither you nor our failure to enforce at any
time or for any period any of the provisions of this Agreement
shall be construed as a waiver of such provisions, or the parties’
right thereafter to enforce each such provision. These rights
and liabilities are continuous, covering individually and
collectively, all accounts you may open with us or our agent for
the same Traditional IRA, and inure to the benefit of us, our
successors or assigns and are binding on you and your heirs,
successors or assigns.
Indemnity of Custodian: To the extent not prohibited by
Federal or State law, you agree to indemnify, defend and hold
the Custodian, its subsidiaries and administrator (including
their officers, agents and employees) harmless against and
from any and all claims, demands, liabilities, costs and expenses
(including reasonable attorneys’ fees and expenses), arising in
connection with this agreement, with respect to (A) any
negligence or alleged negligence, whether passive or active, by
the Custodian, its subsidiaries and administrator (including its
officers, agents and employees), (B) any breach or alleged
breach, whether passive or active, by the Custodian, its
subsidiaries and administrator (including their officers, agents
and employees) of any responsibilities under this Agreement,
or (C) any breach or alleged breach, whether passive or active,
by a third party of responsibilities under this Agreement. You

further agree to pay for the defense of the Custodian, its subsidiaries and administrator, (including their officers, agents and employees) by independent counsel of the Custodian’s choice against any such claims, demands, liabilities or costs referred to in the preceding sentence.
You agree to indemnify, defend and hold the Custodian, its subsidiaries and administrator (including their officers, agents and employees) harmless against and from any and all payments or assessments which may result from holding any publicly- traded security or alternative investment within the Traditional IRA account, and further agree that the Custodian, its subsidiaries and administrator (including their officers, agents and employees) shall be under no obligation whatsoever to extend credit or otherwise disburse payment beyond the cash balance of your account for any payment or assessment related to such investment(s).
Adverse Claims: If we receive any claim to the assets held in the Traditional IRA which is adverse to your interest or the interest of your beneficiary, and we in our absolute discretion decide that the claim is, or may be, meritorious, we may withhold distribution until the claim is resolved or until instructed by a court of competent jurisdiction. As an
alternative, we may deposit all or any portion of the assets in the Traditional IRA into the court through a motion of interpleader. Deposit with the court shall relieve IRA Administrator of any further obligation with respect to the assets deposited. We have the right to be reimbursed from the funds deposited for our legal fees and costs incurred.
Fund Not Guaranteed: We do not guarantee the Fund (the Traditional IRA account) from loss or depreciation. Our liability to make payment to you at any time and all times is limited to the available assets of the Fund.
Arbitration: Any controversy or claim arising out of or relating to this Agreement or the breach thereof, shall be governed by the laws of the State of Illinois, and any action commenced arising out of or relating to this agreement shall be resolved by arbitration in Cook County, Illinois, unless another location is mutually agreed upon, in accordance with the Commercial Arbitration Rules of the American Arbitration Association. The award rendered by the Arbitrator(s) shall be final, and judgement upon the award may be entered by any court located in Cook County, Illinois.
Choice of Law: This Agreement will be governed, construed, and enforced in accordance with the laws of the State of Illinois without regard to its conflict of laws principals. Venue for any and all suits arising hereunder shall be with the federal or state courts located in the State of Illinois, Cook County.
Legal Fees and Expenses: In the event a suit or action is filed to enforce the Agreement, the prevailing Party shall be entitled to reimbursement from the other Party for all costs and
CUSTODIAL ACCOUNT AGREEMENT: FOR