Hughes & Company's Disclosures:
Registration Confirmation & Disclosure:
Hughes & Company is registered with CFTC as an Independent Introducing Broker and is a member of NFA, regulated by both NFA and CFTC. Its current NFA Registration Status, and that of its individuals, is listed here.
Before working with any persons or companies involved in the futures industry, it is best practice to consult this link which assists with ensuring the persons or companies you may be working with are properly registered:
https://www.cftc.gov/check
Futures Risk Disclosure:
The risk of loss in trading commodity futures contracts and options on futures, whether on one’s own, or through your account managed by a third party, can be substantial. You should therefore carefully consider whether such trading is suitable for you in light of your financial condition. You may sustain a total loss of the funds that you deposit with your broker to establish or maintain a position in the commodity futures market, and you may incur losses beyond these amounts. A full list of disclosures regarding the risks involved is outlined in your Futures and Exchange-Traded Options Account Application (Account Agreement with FCM) which is required to be fully reviewed and completed in order to open an account and is located below.
We recommend investors also visit the NFA website at the following address before opening an account:
https://www.nfa.futures.org/investors/investor-best-practices.html
Futures Commission Merchant Risk Disclosure:
Hughes & Company does not hold customer funds but acts as an introducing broker to Futures Commission Merchants (FCMs) which hold customer funds. As an independent introducing broker, Hughes & Company is able to maintain separate clearing agreements with multiple FCMs. It is important to work with well capitalized FCMs. Funds deposited at FCMs are segregated from the funds used in general purposes of the FCM’s business, though there is the possibility an FCM could sustain losses due to business conditions, or other clients, which could adversely affect your account. FCM financial information, which provides a window into the financial well-being of FCMs, is able to be accessed here:
https://www.cftc.gov/MarketReports/financialfcmdata/index.htm
Hughes & Company currently opens accounts with and clears business through StoneX Financial Inc. as well as ED&F Man Capital Markets Inc.
StoneX Disclosures:
https://www.stonex.com/FCStoneDisclosure/
ED&F Man Disclosures:
https://www.edfmancapital.com/index.php/corporate-info/
Managed Futures Disclosure:
Managed Futures may not be suitable for all investors. There is no guarantee that the selection of any advisor(s) will result in profitable performance. Any tear sheets on Managed Futures Programs are provided to us directly by the Advisor(s). We do not guarantee that such information is accurate. You should not rely on any of the information as a substitute for the exercise of your own skill and judgment in making such a decision on the appropriateness of such investments. CTA Disclosure documents contain a complete description of the principal risk factors, any conflicts of interest, and each fee to be charged to your account by the CTA. (Except those programs which are offered exclusively to qualified eligible persons as defined by CFTC regulation 4.7) Due diligence must be performed, then Disclosure documents and all other applicable documents must be reviewed & completed before opening an account managed by a CTA. Past performance, whether actual or indicated by simulated historical tests of strategies, is not indicative of future results.
Fees & Conflicts of Interest Disclosure:
Hughes & Company receives a portion of the commission fees generated in your account, as well as a portion of interest that the FCMs may generate internally, if any. Hughes & Company may establish different commission, clearing, and execution costs with the FCMs. Additionally, Hughes & Company may not maintain an existing clearing agreement with an FCM of your choice. Therefore, we could have an incentive to recommend one particular FCM over another.
Hughes & Company may also receive a portion of management and/or incentive fees generated by third party Commodity Trading Advisors in the trading of your account should we have a fee sharing arrangement in place with that particular CTA and introduce you to that CTA. Between the fee sharing with both the FCM as well as potentially the CTA, we could have an incentive to recommend a particular CTA based upon its trading frequency as well as the fee sharing arrangement. However, it is our practice to be agnostic in these regards and any recommendations reflect our good faith judgment at a specific time and any recommendation is subject to change without notice.
Trade Platforms Disclosure:
Trade Platforms, for example those outlined above, are not affiliated with Hughes & Company and could experience technical difficulties beyond our control which could adversely affect your account. Traders should have additional safeguards in place to mitigate this risk, which Hughes & Company can assist with implementing. Hughes & Company is not liable for the outage of any particular Trading Platform.
Proprietary Trading Disclosure:
Hughes & Company and its principals and associated persons may trade proprietary accounts on their own behalf. These accounts may take positions that are opposite from you or may compete with you for positions unknowingly, though would be unrelated to and independent of your trading.
Margin Calls & Deficit Disclosure:
The ability to withstand losses and to adhere to a particular trading program or to maintain your own positions, in spite of trading losses, are material points which can adversely affect your performance. Should a margin call be generated in your account by your trading or your advisor’s trading, it is expected that per your Account Agreement with FCM, this would be satisfied by depositing additional funds by Wire, ACH, or Check mailed to your clearing FCM. Alternatively, you or the Advisor are able to adjust positions to reduce your initial margin requirement to satisfactory levels to meet the margin call. Should your account experience a deficit/debit balance for whatever reason, per your Account Agreement with FCM you would be required to deposit additional funds by Wire, ACH, or Check mailed to FCM.
Futures and Exchange-Traded Options Account Documentation (FCM Account Agreements):
These contain a full list of disclosures and must be fully reviewed and completed in order to open an account. The latest are located here:
StoneX (Entities):
https://www.hughesandco.ltd/pdf/StoneX_FullApp_Entities.pdf
StoneX (Individuals):
https://www.hughesandco.ltd/pdf/StoneX_FullApp_Individuals.pdf
ED&F Man (Entities & Individuals):
https://www.hughesandco.ltd/pdf/EDFM_FullApp.pdf
For any questions on the above, or assistance with opening an account, please email us at info@hughesandco.ltd, or call 954-500-0500 anytime.
Thank you!
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