Customer Agreement and Terms of Service
This Customer Agreement and Terms of Service (this “Agreement”) is entered into by and between Six Two Five Management LLC (“625 Management,” the “Firm,” “we,” “us,” or “our”), a Delaware limited liability company with its principal office at 16192 Coastal Highway, Lewes, Delaware 19958, registered with the Commodity Futures Trading Commission (“CFTC”) as an introducing broker (“IB”) and a Member of the National Futures Association (“NFA”) (NFA ID 0576299), and each person who opens an Account (“Customer,” “you,” or “your”). This Agreement governs each account (each, an “Account”) introduced by the Firm to Webull Futures LLC (“Webull Futures” or the “FCM”), a futures commission merchant registered with the CFTC and a Member of NFA (NFA ID 0568685), for the purpose of trading event contracts listed on one or more contract markets designated by the CFTC and made available through the Firm (each, an “Exchange,” and such contracts, collectively, “Contracts”). As of the Effective Date, the sole Exchange is KalshiEX LLC (“Kalshi”). The Firm may make additional Exchanges available, or cease offering an Exchange, upon notice to you as provided in Section 1.3. The Firm introduces event contracts only; the Account may not be used to trade other futures or options products through the Firm.
1. Role of the Firm; Role of the FCM; Role of the Exchange
1.1 Introducing Broker. The Firm acts solely as an introducing broker. The Firm solicits and accepts customer accounts and orders for Contracts and introduces those accounts, on a fully disclosed basis, to the FCM. The Firm does not accept, hold, or handle customer funds, securities, or other property at any time. All Customer funds must be transmitted directly to the FCM.
1.2 The FCM. Webull Futures LLC carries all introduced Accounts, holds and safeguards all Customer funds in accordance with CFTC segregation and related requirements, executes and clears (or arranges for the execution and clearing of) transactions, calculates and collects required payment or collateral, performs risk management including position monitoring and liquidation, and prepares and delivers trade confirmations and account statements. The relationship between you and the FCM is governed by the FCM’s separate customer agreement and disclosures, which you must accept in order to open the Account.
1.3 The Exchanges. All Contracts are listed on, executed on, and settled by an Exchange and cleared through that Exchange’s designated derivatives clearing organization. Your trading on each Exchange is subject to that Exchange’s member or participant agreement, rulebook(s), clearing rules, and the terms of each individual Contract, each as amended from time to time (collectively, the “Exchange Rules”). In the event of any conflict between this Agreement and the Exchange Rules with respect to matters governed by an Exchange, the Exchange Rules control. As of the Effective Date, the sole Exchange is Kalshi, whose Exchange Rules include the Kalshi Member Agreement (https://kalshi.com/docs/kalshi-member-agreement.pdf), the KalshiEX Rulebook, and the Kalshi Klear Rulebook (see https://kalshi.com/regulatory). The Firm may add an Exchange upon written or electronic notice to you; before trading on an added Exchange you may be required to accept that Exchange’s member or participant agreement, and your first order on that Exchange constitutes your acceptance of its Exchange Rules. The Firm may cease offering an Exchange at any time, in which case your positions on that Exchange may be limited to closing transactions or transferred or liquidated as permitted by the FCM’s customer agreement and applicable Exchange Rules.
1.4 No Agency. The Firm is not an agent of the FCM or the Exchange, and neither the FCM nor the Exchange is an agent of the Firm, except to the limited extent expressly required by applicable CFTC or NFA rules. Neither party is responsible for the acts or omissions of the other except as required by law. The Firm has no authority to bind the FCM or to enter into any commitment on the FCM’s behalf.
1.5 Customer Support; Complaints. The Firm is responsible for providing customer support for your Account. Support inquiries and complaints should be directed to the Firm at the address in Section 17 or through the contact channels published on the Firm’s platform. Complaints received by the FCM regarding your Account will be forwarded to the Firm for resolution, and you will be notified that your complaint was received and forwarded; complaints alleging an act or omission of the FCM will be addressed in consultation with the FCM.
2. Nature of Event Contracts
2.1 Event contracts are derivatives contracts based on a specified binary (yes/no) outcome, listed and traded on a CFTC-regulated designated contract market. Event contracts are regulated as swaps under the Commodity Exchange Act; your Account is carried by the FCM as a cleared swap account, and Contracts are cleared through the applicable derivatives clearing organization. A contract that expires “in the money” settles at $1.00 per contract; a contract that expires “out of the money” settles at $0.00 per contract. Prior to expiration, contract prices generally range from $0.01 to $0.99 and reflect market-implied probability of the underlying outcome.
2.2 Fully Paid Positions. Event contract purchases must be fully paid at the time of purchase, and short (sell-to-open) positions must be fully collateralized at the maximum potential loss, in each case as required by the FCM and the Exchange Rules. You may nevertheless lose the entire amount paid or posted as collateral for any position.
2.3 Exchange Rules Govern. Each Contract has specific terms that dictate, in addition to the applicable Exchange rulebook, its trading period, settlement, payout, and outcome determination. You are responsible for reading and understanding the terms of each Contract before trading it. Exchange settlement and outcome determinations are generally final and binding. Trading in a Contract may be halted, restricted, or placed in closing-only status, and a Contract will expire pursuant to its terms even if the trading system is not accessible.
3. Eligibility; Account Opening
3.1 To open an Account, you must (a) be at least 18 years of age (or the age of majority in your state of residence, if higher); (b) be a resident of the United States and satisfy any state or territorial eligibility requirements applicable to particular Contracts; (c) satisfy the FCM’s account approval, identity verification, and screening requirements; (d) accept the member or participant agreement and Exchange Rules of each Exchange on which you trade; and (e) not be domiciled in, organized in, or located in any jurisdiction where access to or trading on an Exchange is prohibited under applicable law, Exchange policy, or U.S. sanctions. Certain Contracts, including certain sports-related event contracts, are not available in all states or territories, and availability may change without notice.
3.2 You authorize the Firm, the FCM, and the Exchange to obtain, verify, record, and share information about you, including identity verification, credit, and background information, as reasonably necessary to open and maintain the Account and to comply with the USA PATRIOT Act, anti-money laundering, sanctions, and other applicable laws.
3.3 You agree to promptly notify the Firm in writing of any material change to the information provided in your account application, including changes to your financial condition, residence, employment, or contact information.
3.4 Training and Materials. You agree to review any onboarding, educational, or training materials the Firm makes available or requires concerning the Exchange Rules and the proper use of the trading platform, and to enter orders only in the manner contemplated by those materials and the Exchange Rules.
4. Self-Directed Accounts; No Advice
4.1 Your Account is self-directed. All trading decisions are made solely by you. The Firm does not provide, and nothing communicated by the Firm (including market data, news, probabilities, prices, research, educational materials, or platform features) constitutes, investment, trading, legal, tax, or accounting advice, or a recommendation or solicitation to buy or sell any Contract.
4.2 Neither the Firm, the FCM, nor the Exchange guarantees profits, guarantees against losses, or assumes responsibility for your trading results. Any discussion of market conditions or hypothetical performance is for informational purposes only.
5. Orders; Execution; Errors
5.1 Orders are submitted through the trading platform made available by the Firm and are transmitted by the Firm to the FCM, which executes them on the applicable Exchange. The FCM accepts orders for your Account solely from you (or a third party you have designated in accordance with the FCM’s customer agreement). The Firm, the FCM, and the Exchange may, without prior notice, refuse, reject, cancel, or place conditions on any order, and may restrict trading in any Contract, in their reasonable discretion, including for risk-management, regulatory, or operational reasons.
5.2 You are responsible for the accuracy of every order you enter, and you are solely responsible for monitoring your open orders and positions and the status of your Account. None of the Firm, the FCM, or the Exchange is responsible for any loss due to your failure to cancel or replace an order prior to execution. Reported fills are subject to correction for exchange error-trade rulings, cancellations, and adjustments under the Exchange Rules, and the Exchange’s deadlines for raising a transaction error may be as short as one (1) day after the Exchange sends the confirmation — you must therefore report any suspected error immediately upon discovery.
5.3 ELECTRONIC TRADING RISK. Trading through an electronic system exposes you to risks associated with system or component failure, including hardware, software, and internet connectivity failures. In the event of a system failure, it is possible that your order will not be entered, executed, or canceled as instructed, and orders and their priority in the order queue may be lost. Liquidity in a Contract may cease due to a lack of bids or offers. The Firm and the FCM are not liable for losses caused by electronic system failures beyond their reasonable control.
6. Fees, Commissions, and Other Charges
6.1 You agree to pay the commissions, fees, and charges set forth in the Firm’s Fee Disclosure and Commission Schedule, as amended from time to time, together with all Exchange fees, FCM fees, and any regulatory fees applicable to your Account. As of the Effective Date, total transaction fees are $0.015 per contract, per side, consisting of: the Firm’s commission of $0.0025 per contract; the FCM’s fee of $0.0025 per contract (each equal to 25 basis points of the $1.00 contract notional value); and the Kalshi exchange fee of $0.01 per contract. If Contracts are made available on an additional Exchange, the fees applicable to that Exchange will be disclosed in an updated Fee Disclosure and Commission Schedule before trading begins. Exchange and FCM fees are set by those parties and are not controlled by the Firm.
6.2 Compensation of the Firm. The Firm is compensated for introducing your Account through the Firm’s commission and/or a share of commissions and fees charged to your Account pursuant to the Firm’s introducing arrangement with the FCM. In addition, the Firm receives from the FCM a percentage of the interest income the FCM earns on customer cash balances held in connection with introduced Accounts. Unless the FCM separately provides otherwise, you do not receive interest on cash balances in your Account. These arrangements create incentives for the Firm to encourage trading activity and the maintenance of cash balances. You should consider the effect of transaction costs on your trading results, particularly for frequent trading and for low-priced contracts.
6.3 Authorization to Deduct. You authorize the FCM to deduct from your Account all commissions, fees, and charges owed in connection with the Account, including amounts payable to the Firm and the Exchange.
6.4 Fee Changes. The Firm’s fees may be changed upon at least thirty (30) days’ advance written or electronic notice as described in the Fee Disclosure and Commission Schedule. Exchange and FCM fees may change as provided by those parties. Your continued use of the Account after the effective date of a fee change constitutes acceptance of the change.
7. Payment; Collateral; Liquidation
7.1 You agree to maintain in your Account funds sufficient to fully pay for each purchase and to fully collateralize each short position at its maximum potential loss, and to satisfy such other requirements as the FCM or the Exchange may impose, which may be changed at any time without prior notice.
7.2 If your Account fails to satisfy any payment, collateral, or fee obligation, or if the FCM or the Firm reasonably determines that action is necessary for its protection, the FCM may, without prior demand or notice, close out any or all open positions, cancel open orders, and take any other action permitted under the FCM’s customer agreement and applicable law. You remain liable for any deficit balance in your Account, together with costs of collection to the extent permitted by law.
8. Customer Representations and Warranties
You represent and warrant, as of the date of this Agreement and each time you place an order, that:
- all information provided in your account application is true, complete, and current;
- you have the legal capacity and authority to enter into this Agreement and to trade the Contracts;
- you are acting for your own account and not on behalf of any undisclosed third party, and you will not permit any person not identified to the Exchange and the FCM to access or use the Account;
- you are financially able to bear the risks of trading event contracts, including the loss of your entire investment;
- you are not statutorily disqualified from trading on any Exchange, and, if you are an affiliated person, officer, director, or employee of a securities broker or dealer, introducing broker, futures commission merchant, exchange, market, or clearing organization, or of a futures industry regulator, you have disclosed that status to the Firm and the FCM and provided all documentation and consents required before trading;
- you will not use the Account in connection with any unlawful activity, including trading on material non-public information where prohibited by the Exchange Rules or applicable law, manipulation, or wash trading; and
- with respect to event contracts tied to real-world outcomes (including sports, economics, or entertainment), you are not a person prohibited by the Exchange Rules or the terms of the applicable Contract from trading such contracts (for example, certain contest participants, insiders, or persons with the ability to influence or non-public knowledge of the outcome).
9. Risk Acknowledgment
9.1 YOU ACKNOWLEDGE THAT TRADING EVENT CONTRACTS IS SPECULATIVE, INVOLVES A HIGH DEGREE OF RISK AND VOLATILE MARKETS, AND IS NOT SUITABLE FOR ALL PERSONS. YOU MAY LOSE THE ENTIRE AMOUNT PAID OR POSTED AS COLLATERAL FOR ANY POSITION. FEES WILL ADD TO LOSSES AND MAY SIGNIFICANTLY REDUCE EARNINGS. YOU SHOULD TRADE ONLY WITH RISK CAPITAL.
9.2 You acknowledge receipt, prior to or at the time of account opening, of: (a) the Risk Disclosure Statement required by CFTC Regulation 1.55; (b) the event contract and electronic trading risk disclosures contained in each applicable Exchange’s member or participant agreement and any product-specific disclosures provided by the FCM or the Exchange; (c) the Electronic Trading and Order Routing Systems Disclosure; and (d) the Firm’s Fee Disclosure and Commission Schedule. You have read and understood these documents.
9.3 Market prices for event contracts reflect market sentiment and implied probabilities; they are not predictions, guarantees, or advice, and they can change rapidly, including in response to real-time developments in the underlying event. Liquidity may be limited or absent, and you may be unable to exit a position at a favorable price or at all. Exchanges may operate market maker programs under which market makers may receive fee discounts, rebates, or other benefits and risk-management tools not available to other participants, which may give market makers a trading advantage, and pricing and liquidity may be worse outside required market-making times.
9.4 Exchange Systems and Liability. You acknowledge that the Exchange provides its trading system “AS IS” and without warranty, that the Exchange’s liability to market participants is limited as set forth in the applicable Exchange Rules (in the case of Kalshi, including KalshiEX Rule 11.3), and that any claim by you against an Exchange or another member of an Exchange is subject to the dispute resolution procedures of that Exchange’s rules (which, in the case of Kalshi, provide for mandatory arbitration), as accepted by you under that Exchange’s member or participant agreement.
10. Statements, Confirmations, and Objections
Trade confirmations, purchase-and-sale statements, and monthly account statements will be prepared and delivered by the FCM. You agree to review each confirmation and statement promptly. Absent manifest error, confirmations and statements will be deemed conclusive and binding unless you object in writing (a) in the case of a trade confirmation, within two (2) business days of delivery, and (b) in the case of a monthly statement, within ten (10) business days of delivery. Failure to object within these periods constitutes ratification of the transactions and balances reported.
11. Electronic Delivery and Communications
11.1 You consent to receive this Agreement, all disclosures, confirmations, statements, notices, and other communications electronically, including by email, in-application notification, or posting to a website or platform. Electronic delivery constitutes good and effective delivery. You may revoke this consent, or request paper copies, by contacting the Firm; a reasonable fee may apply to paper delivery as set forth in the Fee Disclosure and Commission Schedule.
11.2 You are responsible for maintaining a current email address and for your ability to access electronic communications. Communications sent to the contact information on file are deemed delivered whether or not actually received.
11.3 You acknowledge and consent that telephone conversations and electronic communications with the Firm, the FCM, and the Exchange — including keystrokes, order messages, and other content submitted through the trading platform or the Exchange’s systems — may be recorded and retained without further notice, may be provided to the CFTC, NFA, the Exchange, or other regulatory or self-regulatory authorities, and may be used as evidence in any dispute, investigation, or proceeding.
12. Position Limits; Trading Restrictions; Exchange Authority; Cooperation; Market Data
12.1 The FCM, the Firm, and the Exchange may impose position limits, exposure limits, message or order-rate limits, or trading restrictions on your Account, including restrictions applicable to specific Contracts, contract categories (such as sports event contracts), or jurisdictions, and may place your Account or specific Contracts in a position-closing-only status. You agree to comply with all such limits and restrictions, and with all applicable position limits established by the CFTC or the Exchange.
12.2 Exchange Authority Over Access. Each Exchange reserves the right to deny, condition, suspend, or terminate the access of any customer to its trading system when the Exchange determines such action would serve the best interests of the Exchange, its members, or its market, and the Firm and the FCM may take corresponding action with respect to your Account. Open orders may be canceled upon any suspension, termination, or closure of your Account.
12.3 Identification; Cooperation; Continuing Jurisdiction. Your orders are submitted to the Exchange under identification codes associated with you, and the Exchange may require the Firm or the FCM to disclose your identity and account information on very short notice (in some cases within minutes) for market surveillance and regulatory purposes. You consent to such disclosure and agree to cooperate promptly and fully with any inquiry, investigation, or proceeding of the Firm, the FCM, the Exchange, NFA, or the CFTC, including by providing information and data relating to your identity and trading. You acknowledge that you remain subject to the jurisdiction of each applicable Exchange with respect to conduct occurring while your Account was open, including for investigations or proceedings commenced up to two (2) years after your Account is closed, and that you remain subject to the jurisdiction of the CFTC.
12.4 Market Data. Quotes, trade data, and other market information made available through the platform are the property of the applicable Exchange or its licensors and are provided for your personal use in connection with your Account. You may not reproduce, retransmit, disseminate, sell, or distribute such information, or use it for any unlawful purpose.
13. Privacy
The Firm’s Privacy Notice, delivered with this Agreement and available upon request, describes how the Firm collects, uses, shares, and protects your nonpublic personal information in accordance with applicable law, including CFTC Regulation Part 160. Information will be shared with the FCM, the Exchange, and with service providers, clearing organizations, and regulators as necessary to service the Account and comply with law.
14. Limitation of Liability; Indemnification
14.1 TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE FIRM AND ITS OFFICERS, MEMBERS, EMPLOYEES, AND AGENTS SHALL NOT BE LIABLE FOR ANY LOSS ARISING FROM OR RELATED TO: (A) YOUR TRADING DECISIONS OR TRADING RESULTS; (B) ACTS OR OMISSIONS OF THE FCM, THE EXCHANGE, ANY CLEARING ORGANIZATION, OR OTHER THIRD PARTY; (C) EXCHANGE SETTLEMENT OR OUTCOME DETERMINATIONS; (D) GOVERNMENT, EXCHANGE, OR CLEARING ORGANIZATION ACTION; (E) SUSPENSION, HALT, RESTRICTION, OR TERMINATION OF TRADING IN ANY CONTRACT; (F) ELECTRONIC OR COMMUNICATION SYSTEM FAILURE, DELAY, OR MALFUNCTION; OR (G) ANY OTHER CAUSE BEYOND THE FIRM’S REASONABLE CONTROL. IN NO EVENT SHALL THE FIRM BE LIABLE FOR INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, OR PUNITIVE DAMAGES, OR FOR LOST PROFITS OR LOST OPPORTUNITY.
14.2 Nothing in this Agreement waives or limits any rights you may have under the Commodity Exchange Act, CFTC regulations, or NFA rules that may not be waived or limited by agreement.
14.3 You agree to indemnify and hold harmless the Firm and its officers, members, employees, and agents from and against any losses, liabilities, damages, costs, and expenses (including reasonable attorneys’ fees) arising out of your breach of this Agreement, your violation of applicable law or the Exchange Rules, or the Firm’s acting in reliance on your instructions or information.
15. Termination
Either party may terminate this Agreement at any time by written or electronic notice. The Firm or the FCM may restrict, suspend, or close your Account at any time, with or without cause, subject to applicable law. Termination does not affect obligations arising from transactions entered into before termination, including your obligation to pay fees, charges, and any deficit balance, and does not affect Sections 10, 14, 16, 17, and 18, which survive termination.
16. Amendments; Entire Agreement
The Firm may amend this Agreement upon written or electronic notice to you. Your continued use of the Account after the effective date of an amendment constitutes acceptance. This Agreement, together with the Fee Disclosure and Commission Schedule, the Privacy Notice, the required risk disclosures, the FCM’s customer agreement and disclosures, and the member or participant agreement and Exchange Rules of each applicable Exchange, constitutes the entire agreement between you and the Firm with respect to its subject matter. If any provision is held invalid, the remaining provisions remain in full force.
17. Governing Law; Miscellaneous
This Agreement is governed by the laws of the State of Delaware, without regard to conflict-of-laws principles, and by applicable federal law, including the Commodity Exchange Act and CFTC regulations. (Each Exchange’s member or participant agreement is separately governed by the law specified in that agreement; the Kalshi Member Agreement is governed by New York law.) The Firm may assign this Agreement to a successor or affiliate; you may not assign this Agreement without the Firm’s written consent. No failure to exercise a right is a waiver of that right. Headings are for convenience only. Notices to the Firm should be directed to Six Two Five Management LLC, 16192 Coastal Highway, Lewes, Delaware 19958.
18. Arbitration Agreement (Voluntary)
18.1 Any dispute or controversy between you and the Firm arising out of or relating to your Account, transactions in your Account, or this Agreement shall, at your election or the Firm’s election, be resolved by arbitration conducted before National Futures Association, or such other qualified forum as you may select as provided below, in accordance with the rules of the selected forum.
18.2 THREE FORUMS EXIST FOR THE RESOLUTION OF COMMODITY DISPUTES: CIVIL COURT LITIGATION, REPARATIONS AT THE COMMODITY FUTURES TRADING COMMISSION (CFTC) AND ARBITRATION CONDUCTED BY A SELF-REGULATORY OR OTHER PRIVATE ORGANIZATION.
18.3 THE CFTC RECOGNIZES THAT THE OPPORTUNITY TO SETTLE DISPUTES BY ARBITRATION MAY IN SOME CASES PROVIDE MANY BENEFITS TO CUSTOMERS, INCLUDING THE ABILITY TO OBTAIN AN EXPEDITIOUS AND FINAL RESOLUTION OF DISPUTES WITHOUT INCURRING SUBSTANTIAL COSTS. THE CFTC REQUIRES, HOWEVER, THAT EACH CUSTOMER INDIVIDUALLY EXAMINE THE RELATIVE MERITS OF ARBITRATION AND THAT YOUR CONSENT TO THIS ARBITRATION AGREEMENT BE VOLUNTARY.
18.4 BY ACCEPTING THIS ARBITRATION AGREEMENT, YOU: (1) MAY BE WAIVING YOUR RIGHT TO SUE IN A COURT OF LAW; AND (2) ARE AGREEING TO BE BOUND BY ARBITRATION OF ANY CLAIMS OR COUNTERCLAIMS WHICH YOU OR THE FIRM MAY SUBMIT TO ARBITRATION UNDER THIS AGREEMENT. YOU ARE NOT, HOWEVER, WAIVING YOUR RIGHT TO ELECT INSTEAD TO PETITION THE CFTC TO INSTITUTE REPARATIONS PROCEEDINGS UNDER SECTION 14 OF THE COMMODITY EXCHANGE ACT WITH RESPECT TO ANY DISPUTE THAT MAY BE ARBITRATED PURSUANT TO THIS AGREEMENT. IN THE EVENT A DISPUTE ARISES, YOU WILL BE NOTIFIED IF THE FIRM INTENDS TO SUBMIT THE DISPUTE TO ARBITRATION. IF YOU BELIEVE A VIOLATION OF THE COMMODITY EXCHANGE ACT IS INVOLVED AND IF YOU PREFER TO REQUEST A SECTION 14 “REPARATIONS” PROCEEDING BEFORE THE CFTC, YOU WILL HAVE 45 DAYS FROM THE DATE OF SUCH NOTICE IN WHICH TO MAKE THAT ELECTION.
18.5 YOU NEED NOT ACCEPT THIS ARBITRATION AGREEMENT TO OPEN OR MAINTAIN AN ACCOUNT WITH THE FIRM. SEE 17 CFR 166.5. CONSENT TO THIS SECTION 18 IS PRESENTED AS A SEPARATE, OPTIONAL ELECTRONIC ACKNOWLEDGMENT DURING SIGN-UP, APART FROM YOUR ACCEPTANCE OF THE REST OF THIS AGREEMENT, AND SECTION 18 APPLIES ONLY IF YOU PROVIDE THAT SEPARATE CONSENT.
18.6 If, by reason of your election or otherwise, a dispute is to be arbitrated, you shall have the opportunity to elect a qualified forum for conducting the proceeding within 45 days after receipt of notice from the Firm of its intent to arbitrate, from a list of qualified forums provided by the Firm, which list shall include National Futures Association. Any claim by you against an Exchange or another member of an Exchange is separately subject to the dispute resolution procedures of that Exchange’s rules (which, in the case of Kalshi, provide for mandatory arbitration); this Section 18 governs only disputes between you and the Firm.
19. Electronic Acceptance
19.1 This Agreement is accepted electronically as part of the account sign-up process. By completing sign-up and clicking “I Agree” (or a similar button or checkbox), you acknowledge that you have received, read, and understood this Agreement, the Fee Disclosure and Commission Schedule, the Privacy Notice, and the Risk Disclosure Statement required by CFTC Regulation 1.55, and you agree to be bound by this Agreement (excluding Section 18, which applies only if you provide the separate consent described in Section 19.2). You agree that your electronic acceptance satisfies any legal requirement that this Agreement be signed, in accordance with the federal Electronic Signatures in Global and National Commerce Act (E-SIGN Act) and applicable state law.
19.2 Arbitration Consent. Consent to the Arbitration Agreement in Section 18 is presented during sign-up as a separate, optional electronic acknowledgment. You are not required to provide that consent to open or maintain an Account, and declining it does not affect your Account or the remainder of this Agreement.
19.3 Records. The Firm and the FCM will maintain a record of the date, time, and manner of your electronic acceptance, and a copy of the version of this Agreement you accepted, which records will be conclusive evidence of your acceptance absent manifest error. A copy of this Agreement as accepted is available to you upon request at no charge.