Investment Direction Letter and Authorization for Futures Account for IRA

For purposes of this Direction Letter, the words "you" and "your" mean the owner of the Individual Retirement Account ("IRA") held at and by Morgan Stanley Smith Barney LLC. The words "we," "us," "our," and the “Company” mean Morgan Stanley Smith Barney LLC (“MSSB”) ("Custodian"), as Custodian of the IRA held at the Company and, by extension E*TRADE Futures LLC ("ETF"), as Sub-Custodian. In addition to the Representations and Responsibilities outlined in Section 8.03 of the Individual Retirement Custodial Account Agreement ("Custodial Agreement"), under this Investment Direction Letter and Authorization ("Authorization"), the IRA owner and the Custodian make the following agreement:

You hereby authorize and direct us to transfer funds from your primary Company IRA to your Futures Sub-Account ("Account") with ETF acting in its capacity as a Futures Commission Merchant ("FCM") for futures and options on futures investment (including satisfaction of any futures margin requirement or account deficiency).

Conditions and Limitations

The Company serves as Custodian of your IRA, but may, at its discretion, transfer such property to a sub-custodian of its own selection for safekeeping including, but not limited to ETF. The sole obligation of the Company in its capacity as Custodian and, by extension, ETF shall be the safekeeping of property upon receipt, if applicable, and acceptance and maintenance of such property under the Custodial Agreement. By directing the Company to open an IRA sub-account at ETF, you agree to hold the Company and ETF harmless from any and all claims, demands, and causes of action arising from this Authorization including, but not limited to costs, attorney’s fees, and/or other expenses incurred in connection with our defense of such claims, demands, and causes of action.

The Company and ETF have made no representation, recommendation, or other statement concerning agents, FCMs, or institutions with whom you now or in the future may be dealing. You have been advised to make appropriate investigation of such persons or institutions before directing the Company to make any transfer of funds to or from the Account.

This Authorization authorizes the Company and, by extension, ETF to permit futures contracts to be electronically traded in the Account subject to the limits prescribed by the Company and ETF, which are subject to change from time to time without notice.

The Company’s and, by extension, ETF’s sole obligation with respect to the Account is to execute the order initiated by you as a self-directed trader. You shall hold the Company and ETF and their directors, employees, and affiliates harmless for any and all claims, demands, and causes of action arising from this Authorization including, but not limited to, trading losses, any and all court costs, attorney’s fees and other expenses you may incur with respect to such claims, demands and/or causes of action.

You and your authorized agent(s) understand and acknowledge that you are solely responsible for the investment decisions involving the Account. Neither the Company nor ETF has provided nor will provide any recommendations or advice in connection with the opening of your Account or when accepting orders from you in accordance with this Authorization. You must take into consideration your own personal financial situation, investment objectives, risk tolerance, and tax consequences with respect to any activities initiated in the Account. You acknowledge and understand that neither the Company nor ETF is acting as a "fiduciary" within the meaning of Section 3(21)(A)(ii) of the Employment Retirement Income Security Act of 1974 and/or Section 4975(e)(3) of the Internal Revenue Code in connection with the opening of your Account or when accepting orders from you in accordance with this Authorization.

You acknowledge that market conditions (e.g., illiquidity, volatility) and/or the operation of the rules of certain markets (e.g., the suspension of trading in a particular contract month because of price limits or "circuit breakers") may increase the risk of loss by making it difficult or impossible to effect transactions or liquidate or offset positions.

In connection with trading of futures in the Account in accordance with this Authorization (and the various other agreements to which you have agreed with respect to your IRA), the Company and ETF including their agents and clearing partners are authorized, instructed, and directed as follows:

Note: You must complete any suitability questions and carefully review all risk disclosures and any other applicable documentation before either the Company or ETF can process futures trades in the Account. Pursuant to this Authorization, the Account may be held by the Company ETF or an authorized agent of ether in an omnibus account maintained by the Company, ETF or an authorized agent of ether for the benefit of their customers.

Specific Terms and Conditions

1. You represent and warrant that you are the creator, beneficial owner, and depositor of the Account and understand that the Account is a self-directed account and that as such, you understand that you have exclusive authority over the Account to make investment decisions for the Account and that neither the Company, ETF nor any authorized agents are responsible or liable for any investment decisions you make with respect to the Account. You acknowledge and agree that neither the Company, ETF nor any of their authorized agents shall exercise or have any authority to exercise any discretionary control with respect to the management, administration, or deposition of the Account or with respect to any assets of or in the Account with the exception of a margin call or other similar situation or account deficiency, which may require the Company, ETF and/or one or more of their authorized agents to take action.
2. You have received copies of, have reviewed and understand, and agreed to all necessary agreements and disclosures regarding the IRA and the Account and as are necessary to establish and maintain the Account including, but not limited to the Custodial Agreement, E*TRADE from Morgan Stanley Client Agreement for Self-Directed Accounts, Futures Supplement, and Futures Trading Risk Disclosure. All documents executed or agreed to with the Company in its capacity as Custodian regarding the IRA and the Account and as are necessary to establish and maintain the Account shall be equally applicable to ETF with respect to the Account. To the extent that the terms of any of the other agreements or disclosures regarding the IRA and the Account or that are necessary to establish and maintain the Account are inconsistent with the terms of this Authorization, the terms of this Authorization shall supersede and govern.
3. You have received a copy of and have reviewed and understand the Futures in Self-Directed IRA Additional Risk Disclosure and agree to maintain a minimum net liquidating value of $25,000 in the IRA in order to trade futures in the Account. In addition, you represent and warrant that you have a minimum of three-years derivatives trading experience. You further agree to the terms that in connection with trading futures in the Account, futures contracts will be held at not less than 150% of the exchange minimum margin requirement and that the Company and ETF reserve the right to raise (or lower) such margin requirements in our sole and absolute discretion, consistent with all applicable regulatory rules. You understand that the Company, ETF, their clearing firms and agents reserve the right to raise margin requirements and/or liquidate all or a portion of the position in your account in the event that you cannot or are not able to timely deposit sufficient funds to satisfy the requirements of the Account.
4. You have determined that futures and futures options transactions in the Account (and shall determine with respect to each futures and futures options transaction in the Account) are suitable in view of your investment objectives and risks associated with investments in futures contracts transactions. You acknowledge that the establishment of the Account and all transactions executed in and through the Account are subject to certain restrictions under Section 408(a) or 408A (if the IRA is a Roth IRA) of the Internal Revenue Code of 1986, as amended (the "Code"), as applicable and that certain transactions entered into by the IRA may cause the IRA to lose its tax-exempt status and/or may result in the recognition of taxable income under Section 511 of the Code. You represent and warrant that, with respect to each transaction to be executed in and through the Account, you shall immediately notify the Company and/or ETF in the event that any of the above representations or warranties cease to be true and correct.
5. To the extent that funds are available, you hereby direct the Company to pay ETF any or all amount held by the IRA, which ETF may from time to time request to satisfy margin calls, debit balances, and/or other obligations of the Account arising from, or in connection with the trading activity on behalf of the IRA. To the extent that such funds are not available, you hereby direct the Company and ETF to liquidate any positions held in the IRA to satisfy margin calls, debit balances, and/or other obligations of the Account arising from, or in connection with the trading activity on behalf of the IRA. Any such payment or liquidation of positions and payment may be with or without prior notice to you, however, the giving or withholding of such notice shall in no way affect the Company’s ability to promptly pay ETF such amounts as it may request pursuant to the foregoing direction. You acknowledge that no liability shall ever be asserted against the Company for refusing to pay ETF if funds are not available to cover margin calls, debit balances, or other obligations arising from the Account. In the event that the assets in the IRA are insufficient to satisfy margin calls, debit balances, or any other obligations of the IRA, the Company or ETF in its discretion, may close the Account. The Company and ETF will not draw or pledge assets from other accounts to satisfy margin calls, debit balances, and/or other obligations of the Account arising from, or in connection with the trading activity on behalf of the IRA. To the extent that funds and/or positions in the IRA are not sufficient to satisfy margin calls, debit balances, and/or other obligations of the Account arising from, or in connection with the trading activity on behalf of the IRA, you agree to make a contribution to the IRA in the amounts owing.
6. YOU UNDERSTAND THAT THE INVESTMENT IN A FUTURES CONTRACT AND OPTIONS ON A FUTURES CONTRACT OR OTHER SIMILAR TYPES OF INVESTMENTS COVERED BY THIS AUTHORIZATION ARE SPECULATIVE IN NATURE AND SUBJECT TO RISK OF LOSS THAT MAY BE GREATER THAN THOSE OF OTHER INVESTMENT VEHICLES IN WHICH RETIREMENT FUNDS MAY BE INVESTED. YOU REPRESENT AND WARRANT THAT YOU HAVE EVALUTATED SUCH RISKS AND THAT THE INVESTMENT IN THE IRA IS SUITABLE IN VEIW OF YOUR ASSETS, OTHER INVESTMENTS, RETIREMENT OBJECTIVES, AND INVESTMENT EXPERIENCE. YOU FURTHER UNDERSTAND AND AGREE THAT THE INVESTMENT OF RETIREMENT FUNDS IN FUTURES CONTRACTS AND OPTIONS ON FUTURES CONTRACTS, AS WITH ANY OTHER TYPE OF INVESTMENT, MAY INVOLVE INCOME TAX CONSIDERATIONS AND CONSEQUENCES FOR WHICH NEITHER THE COMPANY NOR ETF RENDERS ADVICE NOR ASSUMES ANY LIABILITY WHATSOEVER. YOU UNDERSTAND THAT IRA FUNDS ALLOCATED TO FUTURES TRANSACTIONS ARE NOT SUBJECT TO THE PROTECTIONS OF THE SECURITIES INVESTOR PROTECTION ACT, AS AMENDED.
7. You acknowledge and agree that all of the representations and warranties on this Authorization and the other agreements regarding the IRA and the Account and as are necessary to establish and maintain the Account are true and correct and you understand that all of the duties and obligations of the Company and ETF contained in this Authorization and the other agreements regarding the IRA and the Account and as are necessary to establish and maintain the Account (including, but not limited to, the obligations imposed relating to indemnification, margin requirements, and security) shall only apply to the Company and ETF as Custodian and Sub-Custodian of the IRA, respectively.
8. Consistent with Paragraph 2 above, notwithstanding any contemporaneous or subsequent communications (oral or written) to the contrary, the authorizations and directions contained in this Authorization may not be revoked by you for any reason whatsoever so long as the Account remains open or so long as any amount due and owing or claimed to be due and owing to ETF remains outstanding. The authorizations and directions contained in this Authorization shall be binding upon you, your heirs, successors, and legal representatives.