Disclosure Documentation

Commodity Futures Trading Commission Rule 1.55

ADVANTAGE FUTURES LLC – Disclosure Document

The Commodity Futures Trading Commission (“CFTC”) requires each futures commission merchant (“FCM”), including Advantage Futures LLC (“Advantage”), to provide the following information to a client prior to the time the client first enters into an account agreement with the FCM or deposits money or securities (funds) with the FCM. Except as otherwise noted below, the information set out is as of September 1, 2024. Advantage will update this information annually and as necessary to account for any material change to its business operations, financial condition or other factors Advantage believes may be material to a potential client decision to do business with Advantage.

I. Advantage Information and Principals

Advantage is the primary operating subsidiary of Advantage Financial LLC, our holding company. Advantage is registered with the CFTC as a FCM, Commodity Pool Operator (“CPO”) and Commodity Trading Advisor (“CTA”) and is a member of the National Futures Association (“NFA” [Member ID # 327359]). Advantage does not currently have any funds or accounts under management in its capacities as a CPO or CTA. Advantage Securities LLC (“Advantage Securities”), a broker dealer registered with FINRA, operates as a wholly owned subsidiary of Advantage, and is currently not clearing any business.

Advantage Financial LLC has three other subsidiaries: Advantage Capital Resource LLC, LaSalle Street Technology LLC and Advantage Building LLC. Advantage Capital Resource LLC exists to provide margin financing for customers under certain limited conditions. Advantage Building LLC is an entity formed to own the office building located in Downers Grove, Illinois, which serves as the Advantage business continuity site, while also providing office space for Advantage clients and some employees. LaSalle Street Technology LLC offers server hosting, colocation, and information technology services.

Advantage’s Principal Place of Business and contact information:

Headquarters:

                                                            141 West Jackson Boulevard
                                                            Suite 3900
                                                            Chicago, IL 60604
                                                            Telephone Number: 312-800-7000
                                                            Fax Number: 312-800-7810
                                                            ContactUs@advantagefutures.com
                                                            www.advantagefutures.com

Business Continuity Site and Branch Office:

                                                           1501 West Warren Avenue
                                                           Downers Grove, IL 60515
                                                           Telephone Number: 312-800-7000
                                                           Fax Number: 312-800-7810

Principals:

Joseph M. Guinan, Jr.         Founding Chairman & CEO
Business Location: Main Office

The Chief Executive Officer (“CEO”) oversees and is responsible for all operations and resources of Advantage.

Mr. Guinan is the Founding Chairman, CEO, Governing Body, and Managing Member of Advantage. Prior to establishing Advantage in June 2003, Mr. Guinan served as Executive Vice President, Mizuho Securities USA. Previously, he was President and CEO of Fuji Futures Inc. where he worked from 1995 to 2002. Prior to Fuji Futures, he held various trading and management positions at Irving Trust, Kidder Peabody, and Merrill Lynch. He is a member of the Chicago Board of Trade and NYMEX. Mr. Guinan received a BA majoring in economics and an MBA concentrating in finance and accounting from Columbia University.

Thomas Guinan            Chief Technology Officer
Business Location: Main Office

Reporting to the CEO, the CTO manages the Information Technology Department and is responsible for implementing and monitoring the Advantage Information System Security Program (“ISSP”) and Cybersecurity initiatives. Mr. Guinan has managed the Information Technology team since the inception of Advantage in 2003. Mr. Guinan began his career in the futures industry on the CME trading floor in 1987 and migrated to information technology after earning an MBA and an MS in Computer Science from the University of Chicago. He earned a BBA from the University of Texas

Lisa C. Jones             Chief Compliance Officer
Business Location: Main Office

Reporting to the CEO, the CCO is responsible for ensuring Advantage-related business is conducted in compliance with current CFTC, NFA, and exchange rules and regulations.

Prior to joining Advantage in 2004, Ms. Jones served in a variety of compliance roles within the Fuji Bank Ltd. subsidiaries, including CCO of Fuji Futures Inc. She began her career in 1990 at Lind-Waldock & Company, a registered FCM and Broker Dealer, where she served as Compliance Officer. In 1995, Ms. Jones joined the Bank of Montreal and Harris Bank as the US Treasury Compliance Manager, where her primary responsibility was overseeing US Treasury securities activities, including exchange-traded and over-the-counter markets. Ms. Jones holds a BBA from Loyola University of Chicago.

Sung Soo Kim
Business Location: N/A

Mr. Sung Soo Kim is a passive investor of Advantage Financial LLC. Mr. Kim does not have management oversight for business activities or day-to-day responsibilities of Advantage operations.

Michael McLaughlin         President – Institutional Sales
Business Location: Main Office

Reporting to the CEO, President of Institutional Sales at Advantage, Mr. McLaughlin oversees the CME and off-floor execution team and is responsible for leading business development in these areas.

Mr. McLaughlin joined Advantage in 2004. He began his career in the financial industry at Merrill Lynch in 1986, where he served as Manager of Short-Term Interest Rates until 1995. He later held the position of Managing Director at Fuji Futures where he managed the CME, CBOT, and upstairs sales staff for eight years. Mr. McLaughlin holds a BS in finance from the University of Iowa.

Curt Paloumpis           Chief Risk Officer
Business Location: Main Office

Reporting to the CEO, the CRO monitors, manages, mitigates, and reports the nature and extent of material Advantage risks and financial exposures. He implements and ensures compliance with enterprise risk management policies and procedures.

Mr. Paloumpis rejoined Advantage in October 2014 and was appointed CRO effective April 10, 2019. Mr. Paloumpis was an Advantage salesman from January 2004 to June 2011, most of that time executing trades for institutional clients on the Chicago Mercantile Exchange trading floor. After that, Mr. Paloumpis traded for various proprietary trading firms. Mr. Paloumpis has extensive experience in the futures and derivatives industry. In 1983, he began his career at Drexel Burnham Lambert as a short-term interest rate trader. Mr. Paloumpis was a member of the Chicago Mercantile Exchange from 1990 – 2010. He earned a Bachelor of Science in Finance from Southern Illinois University.

Carlos Rodriguez          Chief Financial Officer
Business Location: Main Office

Reporting to the CEO, the CFO oversees accounting at Advantage. The CFO protects the assets of the company, ensures regulatory compliance and protection of customer funds, accurately reports Advantage financial results, and forecasts Advantage capital requirements.

Mr. Rodriguez joined Advantage in June 2017 as CFO. He oversees Advantage finance, accounting, treasury, and human resource functions. Mr. Rodriguez previously served as an Executive Director in the CME Group Financial and Regulatory Surveillance Department. During over 20 years at CME Group, Mr. Rodriguez was responsible for the regulatory, financial and compliance oversight of clearing member firms. Mr. Rodriguez earned a BA in Accounting from the University of Illinois at Chicago.

Robert Wittbrodt            Operations Manager
Business Location: Main Office

Reporting to the CEO, the Operations Manager oversees all aspects of the Advantage Operations Department including monitoring client position balances and related trade price information, reconciling exchange clearing and NFA fees, performing trade allocations, balancing carrying broker accounts, submitting regulatory data to exchanges and CFTC, and preparing client statements.

Mr. Wittbrodt rejoined Advantage in October 2021. After departing Advantage in May 2019, Mr. Wittbrodt worked for Societe Generale as a Deliveries Analyst where he was responsible for processing physical deliveries in futures products on various U.S. exchanges, as well as handling firm-wide options on futures expirations for U.S. exchanges. Mr. Wittbrodt originally joined Advantage in March 2016. Mr. Wittbrodt has eight years of futures industry experience and is also a Qualified Back-Office Representative of Eurex.

II. Advantage Business

Advantage Futures LLC (“Advantage”) is a futures commission merchant and clearing member of CME Group (including CME, CBOT, NYMEX, and COMEX), ICE Futures Europe, ICE Clear Europe, Ice Abu Dhabi, ICE Endex, Options Clearing Corp, CBOE Futures Exchange, Coinbase Derivatives Exchange, Nodal Clear, as well as a non-clearing member of Eurex. Advantage maintains carrying broker relationships facilitating client access to products on exchanges of which Advantage is not a member. Advantage has carrying broker relationships with RBC Capital Markets, LLC, Phillip Capital Inc., Marex Capital Markets, Inc., Marex Financial, and Nissan Securities Co., Ltd

Client commissions derived from executing and clearing trades for futures and options on futures are the primary source of revenue for Advantage. Advantage clears trades for clients including professional traders, proprietary trading groups, institutional clients, exchange-traded funds, foreign and domestic non-clearing FCMs, hedge funds, and individuals. Advantage also values and works closely with various introducing brokers. Advantage offers client execution services via CME Group trading floor and office-based personnel. Advantage utilizes ADM Investor Services to provide global execution services to our clients. ADM Investor Services execute trades that are given-up to Advantage for clearing. Advantage hosts technology equipment and provides other technology-related services for clients.

The majority of Advantage cleared volume is self-executed electronically by clients who employ various trading styles including spreading, relative value, option market making, directional, momentum, and high-frequency day trading. Advantage clients are domiciled in 64 countries, territories, and jurisdictions. Advantage does not conduct speculative proprietary trading. Advantage operates an agency model brokerage and does not trade for its own account; thereby avoiding a conflict of interest since Advantage is not competing with client trading. From time to time, Advantage may mitigate risks through hedging activities. These hedges are not intended to create profit; rather, the intent is to mitigate specific risks, thus focusing Advantage resources and approximately 100% of Firm capital (except for a de minimis amount of capital used for hedging activities) in support of client business.

The CME Group is the Designated Self-Regulatory Organization for Advantage. Additional information can be obtained on their website http://www.cmegroup.com/clearing/financial-and-regulatory-surveillance.html.l

A. Permitted Depositories and Counterparties

Advantage appreciates its responsibility to protect and separately account for funds in both Customer Segregated and Customer Secured 30.7 origins (collectively “segregated funds”). This is necessary to protect both customers and Advantage, as the FCM is ultimately responsible for any loss of segregated or secured 30.7 funds due to their mishandling. To that end, Advantage developed procedures for:

• Evaluating suitability of depositories and counterparties designated for holding customer segregated funds;
• Opening    and    documenting   segregated    accounts    at    approved depositories and counterparties;
• Monitoring approved depositories and counterparties;
• Establishing appropriate level of FCM residual interest in these segregated accounts, including regular review of the suitability level;
• Withdrawing funds from segregated accounts when the withdrawal is not for the benefit of customers;
• Assessing suitability and appropriate allocation of segregated funds to specific investments permitted per CFTC Rule 1.25.

B. Evaluating the Suitability of Customer Fund Depositories and Counterparties

There are three primary depositories/counterparties holding segregated or secured funds of Advantage customers: banks, carrying brokers, and clearing organizations. Advantage established policies and procedures reasonably designed to ensure institutions holding Advantage deposits of customer segregated funds are financially sound and otherwise appropriate for this purpose.

Criteria utilized in this analysis of banks, carrying brokers, and clearing organizations include but are not limited to a review of the following, as applicable:

• Institutional size and capitalization
• Creditworthiness
• Access to liquidity
• Operational reliability
• Concentration of segregated funds with any depository or group of depositories
• Regulatory oversight
• Outside rating agency opinions
• Availability of deposit insurance

III. Material Risks

Advantage faces several potential risks in the ordinary course of business, including Credit Risk, Market Risk, Operational Risk, Legal, Regulatory & Compliance Risk, Human Resources Risk, Financial Risk, Information Technology Risk, and Strategic Risk, each defined as follows:

Credit Risk – The risk of loss from failure of client or counterparty to meet financial obligations or default of client or counterparty.

Market Risk – The risk of loss from fluctuations in market prices or changes in market conditions that impact investment values or result in client deficit balances. Also includes foreign currency exposure.

Operational Risk – The risk of loss due to inadequate systems and controls, human error, or management failure.

Legal, Regulatory, & Compliance Risk – The risk of fines, penalties, or reputational damage due to real or perceived noncompliance with laws, rules, regulations, agreements, or failure to meet professional obligations.

Human Resources Risk – The risk of loss due to ineffective hiring/recruitment, loss of key employees, inadequate corporate governance, or legal risks arising from employees.

Financial Risk – The risk of loss or missed business opportunities due to insufficient financial controls, including capital risk, liquidity risk, segregation risk, and accounting risk.

Information Technology Risk – The risks associated with critical systems, technology practices, cybersecurity, business data, and interruption of business activity.

Strategic Risk – The risk of internal or external events that inhibit or prevent Advantage from achieving objectives or damage Advantage reputation.

A. Investments Made by the Advantage

Advantage holds significant assets in cash and may also hold US Treasury and Agency securities guaranteed by the US Government, while ensuring compliance with regulatory capital requirements and maintaining sufficient liquidity to meet ongoing business obligations. Advantage maintains proprietary accounts to hedge Advantage risk exposures, including risk in foreign currency price fluctuation.

Advantage investments of customer funds comply with CFTC Regulation 1.25. As permitted under CFTC regulations, client funds are invested in cash, US Treasury and Agency securities, and Reverse Repurchase Agreements with US Treasury and Agency securities. Advantage daily financial and quarterly investment information can be found on Advantage website www.advantagefutures.com under section About > Financials.

As of July 31, 2024, the average weighted maturity of all customer segregated investments held is 1.83 months. Note: As of July 31, 2024, Advantage does not maintain any customer secured 30.7 investments. In addition, as Advantage does not maintain any Mortgage-Backed Securities (MBS), weighted average coupon is not applicable.

B. Advantage Creditworthiness, Leverage, Capital, Liquidity, Principal Liabilities, Balance Sheet Leverage and Other Lines of Business

Advantage pays its financial obligations in a timely manner and has never failed to meet a payment obligation to an exchange, clearing organization, or carrying broker. When and as needed, Advantage has been able to establish new banking, exchange, and carrying broker relationships. As an LLC and non-publicly held company, Advantage does not have a formal credit rating with major credit rating agencies.

Advantage balance sheet leverage as computed under NFA Financial Requirements Section 16 was 4.67 as of July 31, 2024.

Advantage strives to maintain capital necessary to support business needs and comply with regulatory requirements. As of July 31, 2024, Advantage had Net Capital of $37,088,691, Adjusted Net Capital of $36,767,043 and Excess Net Capital of $21,245,811.

Advantage strives to transparently reflect our liquidity by graphically displaying on our website how we invest Customer Segregated and Customer Secured 30.7 funds. Additional liquidity for Advantage is provided via a $76,000,000 delivery line of credit from one of our bank relationships. In addition, Advantage maintains $15,000,000 in revolving unsecured subordinated debt loan agreements. As of July 31, 2024, $0 was drawn down on the revolver agreements. If, when, and as additional liquidity may be needed, Advantage will seek equity or debt funding from private sources of capital.

Principal liabilities for Advantage are balances in customer and non-customer accounts. As of July 31, 2024, these comprised 97.56% of Advantage liabilities. Various other payables and accrued expenses (including compensation and accounts payable) represent the remaining 2.44% of liabilities carried by Advantage as of July 31, 2024.

C. Risks to the Firm Created by its Affiliates

Advantage does not invest customer or house funds with affiliated entities, except to the extent Advantage invests house funds in Advantage Securities.

Advantage Securities is a wholly owned subsidiary of Advantage. Advantage Securities is a broker dealer registered with the Financial Industry Regulatory Authority and the Securities and Exchange Commission. Advantage Securities does not currently conduct any securities business and maintains excess net capital of $270,381 as of July 31, 2024. Although Advantage Securities is a regulated entity with separate policies and procedures in place, parent company Advantage may have financial exposure if the broker dealer became illiquid or required additional capital to support its business activities.

No other affiliates of Advantage pose a material risk to the FCM business.

D. Significant Liabilities and Material Commitments

Advantage has a liability in the form of its lease on its main office located at 141 West Jackson Boulevard, Suite 3900, Chicago, IL. The lease is a non-cancellable operating lease with rental commitments totaling $2,803,860 beyond July 31, 2024.

E. Summary of Current Risk Practices, Controls and Procedures

Pursuant to CFTC Regulation 1.11(c), Advantage has a Risk Management Program to establish, maintain, and enforce a system of risk management policies and procedures designed to monitor and manage risks associated with Advantage activities. Advantage maintains written policies and procedures describing the Risk Management Program, approved in writing by the Advantage Governing Body.

Advantage maintains a Risk Management Program Framework which describes the principles, policies, and functional responsibilities for risk management throughout Advantage. The Framework identifies the goals, business context, regulatory background, business model, governance structure, supervision, methodologies, controls, monitoring, reporting, and resources utilized to manage risk.

Advantage maintains Specific Risk Management Policies, which identify various risks Advantage faces and describes how Advantage manages these risks. Advantage categorized risk exposures into Credit Risk, Market Risk, Operational Risk, Legal, Regulatory & Compliance Risk, Human Resources Risk, Financial Risk, Liquidity Risk, Segregation Risk, Accounting Risk, Information Technology Risk, and Strategic Risk. Advantage appreciates its business activities present various combinations and concentrations of risks. The Advantage Risk Management Program also establishes Risk Tolerance Limits, accounts for risks posed by affiliates and all lines of business and includes policies and procedures for detecting and appropriately escalating breaches of risk tolerance limits.

IV. Customer Funds Segregation

Customer Accounts. FCMs may maintain up to three different types of accounts for customers, depending on the products customers trade:

(i) Customer Segregated Accounts for customers that trade futures and options on futures listed on US futures exchanges;

(ii) 30.7 Accounts for customers that trade futures and options on futures listed on foreign boards of trade; and

(iii) Cleared Swaps Customer Accounts for customers trading swaps that are cleared on a Derivatives Clearing Organization (“DCO”) registered with the CFTC.

The requirement to maintain these separate accounts reflects the different risks posed by the products. Cash, securities and other collateral (collectively, Customer Funds) required to be held in one type of account, e.g., the Customer Segregated Account, may not be commingled with funds required to be held in another type of account, e.g., the 30.7 Account, except as the CFTC may permit by order.

Customer Segregated Account. Funds that customers deposit with an FCM, or that are otherwise required to be held for the benefit of customers, to margin futures and options on futures contracts traded on futures exchanges located in the US, i.e., designated contract markets, are held in a Customer Segregated Account in accordance with section 4d(a)(2) of the Commodity Exchange Act and CFTC Rule 1.20. Customer Segregated Funds held in the Customer Segregated Account may not be used to meet the obligations of the FCM or any other person, including another customer.

Customer Segregated Funds may be commingled in a single account, i.e., a customer omnibus account, and held with: (i) a bank or trust company located in the US; (ii) a bank or trust company located outside the US that has in excess of $1 billion of regulatory capital; (iii) an FCM; or (iv) a DCO. Such commingled accounts must be properly titled to make clear the funds belong to and are being held for the benefit of FCM customers. Unless a customer provides instructions to the contrary, an FCM may hold Customer Segregated Funds only: (i) in the US; (ii) in a money center country; or (iii) in the country of origin of the currency.

An FCM must hold sufficient US dollars in the US to meet all US dollar obligations and sufficient funds in each other currency to meet obligations in such currency. Notwithstanding the foregoing, assets denominated in a currency may be held to meet obligations denominated in another currency (other than the US dollar) as follows: (i) US dollars may be held in the US or in money center countries to meet obligations denominated in any other currency; and (ii) funds in money center currencies2 may be held in the US or in money center countries to meet obligations denominated in currencies other than the US dollar.

30.7 Account. Funds that 30.7 Customers deposit with an FCM, or that are otherwise required to be held for the benefit of customers, to margin futures and options on futures contracts traded on foreign boards of trade, i.e., 30.7 Customer Funds, and sometimes referred to as the foreign futures and foreign options secured amount, are held in a 30.7 Account in accordance with Commission Rule 30.7.

Funds required to be held in the 30.7 Account for or on behalf of 30.7 Customers may be commingled in an omnibus account and held with: (i) a bank or trust company located in the US; (ii) a bank or trust company located outside the US that has in excess of $1 billion in regulatory capital; (iii) an FCM; (iv) a DCO; (v) the clearing organization of any foreign board of trade; (vi) a foreign broker; or
(vii) such clearing organization or foreign broker designated depositories. Such commingled account must be properly titled to make clear the funds belong to and are being held for the benefit of the FCM 30.7 Customers. As explained below, CFTC Rule 30.7 restricts the amount of such funds that may be held outside the US.

Customers trading on foreign markets assume additional risks. Laws or regulations will vary depending on the foreign jurisdiction in which the transaction occurs, and funds held in a 30.7 Account outside the US may not receive the same level of protection as Customer Segregated Funds. If a foreign broker carrying 30.7 Customer positions fails, the broker will be liquidated in accordance with the laws of the jurisdiction in which it is organized. Such laws may differ significantly from the US Bankruptcy Code. Return of 30.7 Customer Funds to the US will be delayed and likely will be subject to the costs of administration of the failed foreign broker in accordance with the law of the applicable jurisdiction, as well as possible other intervening foreign brokers, if multiple foreign brokers were used to process the US customer transactions on foreign markets.

If the foreign broker does not fail but the US FCM of the 30.7 Customer fails, the foreign broker may want to assure that appropriate authorization has been obtained before returning the 30.7 Customer Funds to the US FCM trustee, which may delay their return. If both the foreign broker and the US FCM were to fail, potential differences between the trustee for the US FCM and the administrator for the foreign broker, each with independent fiduciary obligations under applicable law, may result in significant delays and additional administrative expenses. Use of foreign brokers by the US FCM to process trades of 30.7 Customers on foreign markets may cause additional delays and administrative expenses.

Use of foreign brokers by the US FCM to process trades of 30.7 Customers on foreign markets may cause additional delays and administrative expenses.

To reduce potential risk to 30.7 Customer Funds held outside the US, CFTC Rule 30.7 generally provides that an FCM may not deposit or hold 30.7 Customer Funds in permitted accounts outside the US except as necessary to meet margin requirements, including prefunding margin requirements, established by rule, regulation, or order of the relevant foreign boards of trade or foreign clearing organizations, or to meet margin calls issued by foreign brokers carrying the 30.7 Customers’ positions. The rule further provides, to avoid the daily transfer of funds from accounts in the US, an FCM may maintain in accounts located outside of the US an additional amount of up to 20% of the total amount of funds necessary to meet margin and prefunding margin requirements to avoid daily transfers of funds.

Investment of Customer Funds. Section 4d(a)(2) of the Commodity Exchange Act authorizes FCMs to invest Customer Segregated Funds in obligations of the US, in general   obligations of any State or of any political subdivision thereof, and in obligations fully guaranteed as to principal and interest by the US. Section 4d(f) authorizes FCMs to invest Cleared Swaps Customer Collateral in similar instruments.

CFTC Rule 1.25 authorizes FCMs to invest Customer Segregated Funds, Cleared Swaps Customer Collateral and 30.7 Customer Funds in instruments of a similar nature. CFTC rules further provide that FCM may retain gains earned and is responsible for investment losses incurred in connection with the investment of Customer Funds. However, the FCM and customer may agree that FCM will pay customer interest on funds deposited.

The average duration of the securities in which an FCM invests Customer Funds cannot exceed two years.

An FCM may also engage in repurchase and reverse repurchase transactions with non-affiliated registered broker dealers, provided such transactions are made on a delivery versus payment basis and involve only permitted investments. Funds or securities received in repurchase and reverse repurchase transactions with Customer Funds must be held in the appropriate Customer Account, i.e., Customer Segregated Account, 30.7 Account or Cleared Swaps Customer Account. In accordance with the provisions of CFTC Rule 1.25, such funds or collateral must be received in the appropriate Customer Account on a delivery versus payment basis in immediately available funds (NFA publishes a report twice monthly, which displays for each FCM, inter alia, the percentage of Customer Funds that are held in cash and each of the permitted investments under CFTC Rule 1.25. The report also indicates whether the FCM held any Customer Funds during that month at a depository that is an affiliate of the FCM).

Funds deposited with Advantage for trading futures and options on futures contracts on either US or foreign markets are not protected by the Securities Investor Protection Corporation.

CFTC rules require Advantage to hold funds deposited to margin futures and options on futures contracts traded on US designated contract markets in Customer Segregated Accounts.

Advantage must hold funds deposited to margin options on futures contracts traded on foreign boards of trade in a 30.7 Account. In computing its Customer Funds requirements under relevant CFTC rules, Advantage may only consider those Customer Funds actually held in the applicable Customer Accounts and may not apply free funds in an account under identical ownership but of a different classification or account type (e.g. Customer Segregated) to an account’s margin deficiency. In order to be used for margin purposes, the funds must transfer to the identically owned under margined account.

For additional information on the protection of customer funds, please see the Futures Industry Association’s “Protection of Customer Funds Frequently Asked Questions” located at http://www.futuresindustry.org/downloads/PCF-FAQs.PDF.

V. Filing a Complaint

A client may file a complaint directly by contacting the Advantage  Compliance Department at compliance@advantagefutures.com or by calling 312-800-7000.

Additional options include:

A client may file a complaint about Advantage or one of its employees with the CFTC. Contact the Division of Enforcement at https://forms.cftc.gov/Forms/Complaint/Screen1 or call the Division of Enforcement toll-free at 866-FON-CFTC (866-366-2382).

A client may file a complaint about Advantage or one of its employees with the NFA at http://www.nfa.futures.org/basicnet/Complaint.aspx or by calling NFA at 800-621-3570.

A client may file a complaint about Advantage or one of its employees with Advantage DSRO, CME Group, electronically at: http://www.cmegroup.com/market-regulation/file-complaint.html or by calling the CME at 312.341.7970.

VI. Material Complaints or Actions

At any given time, in the normal course of business, Advantage may be involved in or subject to litigation, investigations, arbitration matters or regulatory reviews, which may or may not seek significant damages. Advantage is currently not involved in a litigation matter.

All regulatory actions taken against Advantage by any Exchange, CFTC or NFA are documented and summarized on the NFA website at: http://www.nfa.futures.org/basicnet/CaseInfo.aspx?entityid=0327359&type=reg

As a regulated entity, complaints or actions filed against Advantage are generally accessed by the above link. This section of the disclosure document is updated with any material actions or complaints filed against the FCM not otherwise available on the source provided above.

VII. Relevant Financial Data

Advantage annual audited financial statements are made available on Advantage website at https://www.advantagefutures.com/about/financials/. Also included, are monthly net capital summaries, monthly segregation statements, daily and monthly segregation and secured statements and investment of client funds historical data for a minimum of the past 12 months.

Other Financial data as of July 31, 2024:

                 Total Ownership Equity:              $39,786,546

                 Net Capital:                                $37,088,961

                 Tangible Net Worth:                   $39,686,270

Advantage proprietary margin requirement:

Advantage does not conduct speculative proprietary trading. Advantage does maintain an immaterial margin requirement from time to time which represents open positions which hedge Advantage risk including currency exposure. This margin requirement represented .001% of Advantage aggregate margin requirement for futures customers and non-customers.

* Eleven clients represent at least 50% of the FCMs total funds held for futures customers.

* One client represent at least 50% of the FCMs total funds held for 30.7 futures customers.

* Advantage does not enter into any principal over-the-counter transactions.

* Advantage maintains $15,000,000 in revolving unsecured subordinated debt loan agreements.

* Advantage does not provide financing for customer transactions involving illiquid financial products.

* Advantage has not written off any new material segregated or secured 30.7 customer receivables as uncollectable during the past 12-month period.

Additional financial information on all FCMs is also available on the CFTC’s website at: http://www.cftc.gov/MarketReports/financialfcmdata/index.htm

Clients should be aware that the NFA publishes certain financial information with respect to each FCM on its website. The Financial Data for FCMs report provides most recent month-end adjusted net capital, required net capital, and excess net capital for each FCM (information dates back to 2002). In addition, NFA publishes a Customer Segregated Funds report twice monthly, which displays for each FCM: (i) total funds held in Customer Segregated Accounts; (ii) total funds required to be held in Customer Segregated Accounts; and (iii) excess segregated funds, i.e., the FCM’s Residual Interest. This report also displays the percentage of Customer Segregated Funds that are held in cash and each of the permitted investments under CFTC Rule 1.25. Finally, the report indicates whether the FCM held any Customer Segregated Funds during that month at a depository that is an affiliate of the FCM.

The report reflects the most recent semi-monthly information, and the public also can see information for the most recent twelve-month period. A 30.7 Customer Funds report and a Customer Cleared Swaps Collateral report provides the same information with respect to the 30.7 Account and the Cleared Swaps Customer Account.

The above financial information reports can be found by conducting a search for a specific FCM in NFA’s BASIC system (http://www.nfa.futures.org/basicnet/) and then clicking on “View Financial Information” on the FCM’s BASIC Details page.

This disclosure document was first used September 1, 2024.