Declaration in Support of Motion to Compel Arbitration

Date: 2024-12-09

Full text

Exhibit B
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1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 21-MD-02989-ALTONAGA
In re:
JANUARY 2021 SHORT SQUEEZE
TRADING LITIGATION
_________________________________/
This Document Relates to All Actions.
DECLARATION IN SUPPORT OF MOTION TO COMPEL ARBITRATION
1.
My name is Marc O’Such. I am over 18 years old. I am a Senior Paralegal for
Robinhood Markets, Inc., and am authorized to make this declaration on behalf of Defendants
Robinhood Markets, Inc., Robinhood Financial LLC, and Robinhood Securities, LLC
(collectively, “Robinhood”). The facts in this declaration are based on my own personal
knowledge after review of Robinhood’s business records. If called as a witness, I could and would
testify competently to those facts.
2.
I have reviewed the customer agreements entered into by each of the plaintiffs
named in the “Remaining Actions,” as that term is defined in Robinhood’s Motion to Compel
Arbitration and For Stay Pending Arbitration. I am also familiar with the account creation process
via Robinhood’s mobile application (“App”) and website.
3.
When a new customer signs up for an online account with Robinhood, the customer
is presented with a webpage that asks the customer to consent to the terms of Robinhood’s
customer agreement. In general, all customers who apply for a Robinhood brokerage account must
submit an application through Robinhood’s App or website.
4.
I have reviewed Robinhood’s business records, including the program code
showing the text that was presented to customers when they applied for a brokerage account, which
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is set forth in detail below. In general, to consent to the terms of the customer agreement, the
customer must click a “Submit Application” button. The text on the screen also states, in pertinent
part, “By clicking the ‘Submit Application’ button, . . . I also agree to the terms of the Robinhood
Terms and Conditions [and] Robinhood Financial Customer Agreement,” or some substantially
similar language, as set forth in further detail below.
5.
If the customer clicks “Submit Application,” he or she may continue signing up for
the account. If the customer does not click “Submit Application,” Robinhood will not open an
account for the customer and will not permit the customer to conduct any trading through
Robinhood’s platform.
6.
When presented with the option to “Submit Application” and agree to the terms of
the customer agreement, a new customer may click on a hyperlink to the customer agreement.
This hyperlink would open a new webpage displaying the customer agreement in a downloadable,
printable, PDF format.
7.
Each plaintiff named in the Remaining Actions indicated his or her agreement to
the then-operative customer agreement by clicking “Submit Application” when signing up for an
online account with Robinhood.
8.
The customer agreement in effect when each plaintiff in the Remaining Actions
signed up for their respective brokerage accounts provided (and each plaintiff accepted) a clause
establishing pre-dispute arbitration before Financial Institution Regulatory Authority Dispute
Resolution (“FINRA DR”).
9.
The customer agreements also provided (and the plaintiffs acknowledged) that the
customer agreement could be amended or updated, that the operative version of the customer
agreement was available on Robinhood’s public website, and that by maintaining their Robinhood
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brokerage account, the plaintiffs had agreed to any new or amended terms of the customer
agreement.
10.
A copy of the customer agreement in effect at the time that each plaintiff filed suit
in April 2021 is attached as Exhibit 1, and is Exhibit A to the Motion to Compel Arbitration. I
also understand that plaintiffs Maurice Scarborough and Scott Schiller filed a second suit on or
around April 26, 2023. A copy of the customer agreement in effect on April 26, 2023, is attached
as Exhibit 2.
11.
As reflected in the table below, attached as exhibits to this Declaration are copies
of the customer agreements in effect when each plaintiff opened their Robinhood brokerage
account.
Exhibit
Plaintiff Name
Account Opening Date
3
Chance Daniels
August 21, 2020
4
Robert Days
August 22, 2016
5
Aaron Fassinger
June 13, 2020
6
Richard Gatz
March 23, 2020
7
Josh Gossett
July 24, 2020
8
Igor Kravchenko
December 13, 2018
9
Jordan Krumenacker
April 15, 2020
10
James Laplant
May 9, 2018
11
Michael McFadden
July 29, 2020
12
Danielle Perreault
February 24, 2019
13
Mike Ross
December 19, 2014
14
Eric Quat
July 25, 2018
15
Maurice Scarborough
August 19, 2017
16
Scott Schiller
August 25, 2015
17
Tenzin Woiser
January 13, 2017

12.
I have reviewed Robinhood’s program code, which is kept in the ordinary course
of Robinhood’s business, at the time each plaintiff opened their respective Robinhood brokerage
accounts.

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Chance Daniels
13.
Robinhood’s business records reflect that plaintiff Daniels opened a Robinhood
brokerage account on August 21, 2020.
14.
Attached as Exhibit 3 is a true and correct copy of the customer agreement in effect
on August 21, 2020. As part of the application to open the account, Daniels was required to click
a button on his computer or mobile device screen, equivalent to a signature, acknowledging that
he or she would be bound by the customer agreement.
15.
The program code for the App in effect at the time of August 21, 2020, shows that
the App presented the following text to applicants as part of the process before the applicant could
click the “Submit Application” button:
By tapping or clicking the “Submit Application” button, I agree to this Robinhood
Financial Brokerage Application Agreement (this “Application Agreement”). I also agree
to the terms of the RHF-RHS Customer Agreement . . . which are incorporated by reference
and constitute a part of this Application Agreement. . . . I agree to read this Application
Agreement and all incorporated disclosures, terms, and agreements carefully and retain
copies for My records. MY WARRANTIES AND REPRESENTATIONS I represent and
warrant that: . . . I have carefully reviewed, understand and agree to the terms and
provisions of the following: RHF-RHS Financial Customer Agreement . . . . Tapping or
clicking the “Submit Application” button is equivalent to My written signature, and I
understand that I am entering into legal agreements. I HAVE READ THE RHF-RHS
CUSTOMER ACCOUNT AGREEMENT WHICH CONTAINS A PREDISPUTE
ARBITRATION CLAUSE (SECTION 28 ON PAGES 20 AND 21) AND AGREE IN
ADVANCE TO ARBITRATE ANY CONTROVERSIES WHICH MAY ARISE
BETWEEN OR AMONG ME, YOU, AND/OR ROBINHOOD SECURITIES IN
ACCORDANCE WITH SUCH SECTION 28. . . . BY TAPPING OR CLICKING ON
THE ‘SUBMIT APPLICATION’ BUTTON, I : . . . AGREE TO THIS APPLICATION
AGREEMENT.
(underlining added).
16.
According to the App code, the underlined words above provided hyperlinks to a
webpage where the applicant could review the relevant agreement, including the Customer
Agreement in effect at the time of the application.

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Robert Days
17.
Robinhood’s business records reflect that plaintiff Days opened a Robinhood
brokerage account on August 22, 2016.
18.
Attached as Exhibit 4 is a true and correct copy of the customer agreement in effect
on August 22, 2016. As part of the application to open the account, Days was required to click a
button on his computer or mobile device screen, equivalent to a signature, acknowledging that he
or she would be bound by the customer agreement.
19.
The program code for the App in effect at the time of August 22, 2016, shows that
the App presented the following text to applicants as part of the process before the applicant could
click the “Submit Application” button:
By tapping the "Submit Application" button below, I agree to this Robinhood Financial
Brokerage Application Agreement (this "Application Agreement") and elect to participate
in the FDIC-Insured Sweep Program (as defined below). I also agree to the terms of the . .
. Robinhood Financial Customer Agreement, which are incorporated by reference and
constitute part of this Application Agreement. . . . I agree to read this Application
Agreement and all incorporated disclosures, terms, and agreements carefully and retain
copies for My records. . . . MY WARRANTIES AND REPRESENTATIONS I represent
and warrant that: . . . I have carefully reviewed, understand and agree to the terms and
provisions of the following: . . . Apex Customer Account Agreement, Robinhood Financial
Customer Agreement . . . . Tapping the “Submit Application” button below is equivalent
to My written signature, and I understand that I am entering into legal agreements. I HAVE
READ THE APEX CUSTOMER ACCOUNT AGREEMENT, WHICH CONTAINS A
PREDISPUTE ARBITRATION CLAUSE (SECTION 8 ON PAGES 2 AND 3) AND
AGREE IN ADVANCE TO ARBITRATE ANY CONTROVERSIES WHICH MAY
ARISE BETWEEN OR AMONG ME, YOU, AND/OR APEX IN ACCORDANCE
WITH SUCH SECTION 8. I HAVE READ THE ROBINHOOD FINANCIAL
CUSTOMER AGREEMENT, WHICH CONTAINS A PREDISPUTE ARBITRATION
CLAUSE (SECTION 29). . . . BY TAPPING THE “SUBMIT APPLICATION” BUTTON
BELOW, I AGREE TO THIS APPLICATION AGREEMENT AND AND [sic] ELECT
TO PARTICIPATE IN THE FDIC-INSURED SWEEP PROGRAM.
(underlining added).
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20.
According to the App code, the underlined words above provided hyperlinks to a
webpage where the applicant could review the relevant agreement, including the customer
agreement in effect at the time of the application.
Aaron Fassinger
21.
Robinhood’s business records reflect that plaintiff Fassinger opened a Robinhood
brokerage account on June 13, 2020.
22.
Attached as Exhibit 5 is a true and correct copy of the customer agreement in effect
on June 13, 2020. As part of the application to open the account, Fassinger was required to click
a button on his computer or mobile device screen, equivalent to a signature, acknowledging that
he or she would be bound by the Customer Agreement.
23.
The program code for the App in effect at the time of June 13, 2020, shows that the
App presented the following text to applicants as part of the process before the applicant could
click the “Submit Application” button:
By tapping or clicking the "Submit Application" button, I agree to this Robinhood Financial
Brokerage Application Agreement (this "Application Agreement"). I also agree to the
terms of the RHF-RHS Customer Agreement . . . which are incorporated by reference and
constitute part of this Application Agreement. . . . MY WARRANTIES AND
REPRESENTATIONS I represent and warrant that: . . . I have carefully reviewed,
understand and agree to the terms and provisions of the following: RHF-RHS Financial
Customer Agreement . . . . Tapping or clicking the “Submit Application” button is
equivalent to My written signature, and I understand that I am entering into legal
agreements. I HAVE READ THE RHF-RHS CUSTOMER ACCOUNT AGREEMENT
WHICH CONTAINS A PREDISPUTE ARBITRATION CLAUSE (SECTION 28 ON
PAGES 20 AND 21) AND AGREE IN ADVANCE TO ARBITRATE ANY
CONTROVERSIES WHICH MAY ARISE BETWEEN OR AMONG ME, YOU,
AND/OR ROBINHOOD SECURITIES IN ACCORDANCE WITH SUCH SECTION 28.
. . . BY TAPPING OR CLICKING ON THE "SUBMIT APPLICATION" BUTTON, I
AGREE TO THIS APPLICATION AGREEMENT.
(underlining added).
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24.
According to the App code, the underlined words above provided hyperlinks to a
webpage where the applicant could review the relevant agreement, including the customer
agreement in effect at the time of the application.
Richard Gatz
25.
Robinhood’s business records reflect that plaintiff Gatz opened a Robinhood
brokerage account on March 23, 2020.
26.
Attached as Exhibit 6 is a true and correct copy of the customer agreement in effect
on March 23, 2020. As part of the application to open the account, Gatz was required to click a
button on his computer or mobile device screen, equivalent to a signature, acknowledging that he
or she would be bound by the customer agreement.
27.
The program code for the App in effect at the time of March 23, 2020, shows that
the App presented the following text to applicants as part of the process before the applicant could
click the “Submit Application” button:
By tapping or clicking the "Submit Application" button, I agree to this Robinhood Financial
Brokerage Application Agreement (this "Application Agreement"). I also agree to the
terms of the Robinhood Financial Customer Agreement . . . which are incorporated by
reference and constitute a part of this Application Agreement. . . . MY WARRANTIES
AND REPRESENTATIONS I represent and warrant that: . . . I have carefully reviewed,
understand and agree to the terms and provisions of the following: Robinhood Financial
Customer Agreement . . . . Tapping or clicking the "Submit Application" button is
equivalent to My written signature, and I understand that I am entering into legal
agreements. . . . I HAVE READ THE APEX CUSTOMER ACCOUNT AGREEMENT
WHICH CONTAINS A PREDISPUTE ARBITRATION CLAUSE (SECTION 8 ON
PAGES 2 AND 3) AND AGREE IN ADVANCE TO ARBITRATE ANY
CONTROVERSIES WHICH MAY ARISE BETWEEN OR AMONG ME, YOU,
AND/OR APEX IN ACCORDANCE WITH SUCH SECTION 8. . . . I HAVE READ THE
ROBINHOOD FINANCIAL CUSTOMER AGREEMENT, WHICH CONTAINS A
PREDISPUTE ARBITRATION CLAUSE (SECTION 29). . . . BY TAPPING OR
CLICKING ON THE "SUBMIT APPLICATION" BUTTON, I AGREE TO THIS
APPLICATION AGREEMENT.
(underlining added).
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28.
According to the App code, the underlined words above provided hyperlinks to a
webpage where the applicant could review the relevant agreement, including the customer
agreement in effect at the time of the application.
Josh Gossett
29.
Robinhood’s business records reflect that plaintiff Gossett opened a Robinhood
brokerage account on July 24, 2020.
30.
Attached as Exhibit 7 is a true and correct copy of the customer agreement in effect
on July 24, 2020. As part of the application to open the account, Gossett was required to click a
button on his computer or mobile device screen, equivalent to a signature, acknowledging that he
or she would be bound by the Customer Agreement.
31.
The program code for the App in effect at the time of July 24, 2020, shows that the
App presented the following text to applicants as part of the process before the applicant could
click the “Submit Application” button:
Brokerage Application Agreement: By tapping or clicking the "Submit Application"
button, I agree to this Robinhood Financial Brokerage Application Agreement (this
"Application Agreement"). I also agree to the terms of the RHF-RHS Customer Agreement
. . . which are incorporated by reference and constitute part of this Application Agreement.
. . . MY WARRANTIES AND REPRESENTATIONS I represent and warrant that: . . . I
have carefully reviewed, understand and agree to the terms and provisions of the following:
RHF-RHS Financial Customer Agreement . . . Tapping or clicking the "Submit
Application" button is equivalent to My written signature, and I understand that I am
entering into legal agreements. I HAVE READ THE RHF-RHS CUSTOMER ACCOUNT
AGREEMENT WHICH CONTAINS A PREDISPUTE ARBITRATION CLAUSE
(SECTION 28 ON PAGES 20 AND 21) AND AGREE IN ADVANCE TO ARBITRATE
ANY CONTROVERSIES WHICH MAY ARISE BETWEEN OR AMONG ME, YOU,
AND/OR ROBINHOOD SECURITIES IN ACCORDANCE WITH SUCH SECTION 28.
. . . By tapping the “Submit Application” button below, I agree to this Application
Agreement.
(underlining added).
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32.
According to the App code, the underlined words above provided hyperlinks to a
webpage where the applicant could review the relevant agreement, including the customer
agreement in effect at the time of the application.
Igor Kravchenko
33.
Robinhood’s business records reflect that plaintiff Kravchenko opened a
Robinhood brokerage account on December 13, 2018.
34.
Attached as Exhibit 8 is a true and correct copy of the customer agreement in effect
on December 13, 2018. As part of the application to open the account, Kravchenko was required
to click a button on his computer or mobile device screen, equivalent to a signature, acknowledging
that he or she would be bound by the customer agreement.
35.
The program code for the App in effect at the time of December 13, 2018, shows
that the App presented the following text to applicants as part of the process before the applicant
could click the “Submit Application” button:
By tapping or clicking the "Submit Application" button, I agree to this Robinhood Financial
Brokerage Application Agreement (this "Application Agreement"). I also agree to the
terms of the Robinhood Financial Customer Agreement, Apex Customer Account
Agreement, . . . which are incorporated by reference and constitute part of this Application
Agreement. . . . MY WARRANTIES AND REPRESENTATIONS I represent and warrant
that: . . . I have carefully reviewed, understand and agree to the terms and provisions of the
following: Robinhood Financial Customer Agreement, Apex Customer Account
Agreement, . . . . Tapping or clicking the “Submit Application button is equivalent to My
written signature, and I understand that I am entering into legal agreements. . . . I HAVE
READ THE APEX CUSTOMER ACCOUNT AGREEMENT WHICH CONTAINS A
PREDISPUTE ARBITRATION CLAUSE (SECTION 8 ON PAGES 2 AND 3) AND
AGREE IN ADVANCE TO ARBITRATE ANY CONTROVERSIES WHICH MAY
ARISE BETWEEN OR AMONG ME, YOU, AND/OR APEX IN ACCORDANCE WITH
SUCH SECTION 8. . . . I HAVE READ THE ROBINHOOD FINANCIAL CUSTOMER
AGREEMENT WHICH CONTAINS A PREDISPUTE ARBITRATION CLAUSE
(SECTION 29). . . . BY TAPPING OR CLICKING ON THE “SUBMIT APPLICATION”
BUTTON, I AGREE TO THIS APPLICATION AGREEMENT.
(underlining added).
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36.
According to the App code, the underlined words above provided hyperlinks to a
webpage where the applicant could review the relevant agreement, including the customer
agreement in effect at the time of the application.
Jordan Krumenacker
37.
Robinhood’s business records reflect that plaintiff Krumenacker opened a
Robinhood brokerage account on April 15, 2020.
38.
Attached as Exhibit 9 is a true and correct copy of the customer agreement in effect
on April 15, 2020. As part of the application to open the account, Krumenacker was required to
click a button on his or her computer or mobile device screen, equivalent to a signature,
acknowledging that he or she would be bound by the customer agreement.
39.
The program code for the App in effect at the time of April 15, 2020, shows that
the App presented the following text to applicants as part of the process before the applicant could
click the “Submit Application” button:
By tapping or clicking the "Submit Application" button, I agree to this Robinhood Financial
Brokerage Application Agreement (this "Application Agreement"). I also agree to the
terms of the RHF-RHS Customer Agreement . . . which are incorporated by reference and
constitute part of this Application Agreement. . . . MY WARRANTIES AND
REPRESENTATIONS I represent and warrant that: . . . I have carefully reviewed,
understand and agree to the terms and provisions of the following: RHF-RHS Financial
Customer Agreement . . . . Tapping or clicking the "Submit Application" button is
equivalent to My written signature, and I understand that I am entering into legal
agreements. I HAVE READ THE RHF-RHS CUSTOMER ACCOUNT AGREEMENT
WHICH CONTAINS A PREDISPUTE ARBITRATION CLAUSE (SECTION 28 ON
PAGES 20 AND 21) AND AGREE IN ADVANCE TO ARBITRATE ANY
CONTROVERSIES WHICH MAY ARISE BETWEEN OR AMONG ME, YOU,
AND/OR ROBINHOOD SECURITIES IN ACCORDANCE WITH SUCH SECTION 28.
. . . BY TAPPING OR CLICKING ON THE "SUBMIT APPLICATION" BUTTON, I
AGREE TO THIS APPLICATION AGREEMENT.
(underlining added).
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40.
According to the App code, the underlined words above provided hyperlinks to a
webpage where the applicant could review the relevant agreement, including the customer
agreement in effect at the time of the application.
James Laplant
41.
Robinhood’s business records reflect that plaintiff Laplant opened a Robinhood
brokerage account on May 9, 2018.
42.
Attached as Exhibit 10 is a true and correct copy of the customer agreement in
effect on May 9, 2018. As part of the application to open the account, Laplant was required to
click a button on his or her computer or mobile device screen, equivalent to a signature,
acknowledging that he or she would be bound by the customer agreement.
43.
The program code for the App in effect at the time of May 9, 2018, shows that the
App presented the following text to applicants as part of the process before the applicant could
click the “Submit Application” button:

By clicking the “Submit Application” button I agree to this Robinhood Financial Brokerage
Agreement (this “Application Agreement”). I also agree to the terms of the Robinhood
Terms and Conditions, Apex Customer Account Agreement, Robinhood Financial
Customer Agreement . . ., which are incorporated by reference and constitute part of this
Application Agreement. . . . I agree to read this Application Agreement and all incorporated
disclosures, terms, and agreements carefully and retain copies for My records. MY
WARRANTIES AND REPRESENTATIONS I represent and warrant that: . . . I have
carefully reviewed, understand and agree to the terms and provisions of the following:
Robinhood Terms and Conditions, Apex Customer Account Agreement, Robinhood
Financial Customer Agreement . . . . Clicking the “Submit Application” button is
equivalent to My written signature, and I understand that I am entering into legal
agreements. I HAVE READ THE APEX CUSTOMER ACCOUNT AGREEMENT
WHICH CONTAINS A PREDISPUTE ARBITRATION CLAUSE (SECTION 8 ON
PAGES 2 AND 3) AND AGREE IN ADVANCE TO ARBITRATE ANY
CONTROVERSIES WHICH MAY ARISE BETWEEN OR AMONG ME, YOU,
AND/OR APEX IN ACCORDANCE WITH SUCH SECTION 8. I HAVE READ THE
ROBINHOOD FINANCIAL CUSTOMER AGREEMENT, WHICH CONTAINS A
PREDISPUTE ARBITRATION CLAUSE (SECTION 29). . . . BY CLICKING ON THE
“SUBMIT APPLICATION” BUTTON, I AGREE TO THIS APPLICATION
AGREEMENT.
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(underlining added).
44.
According to the App code, the underlined words above provided hyperlinks to a
webpage where the applicant could review the relevant agreement, including the customer
agreement in effect at the time of the application.
Michael McFadden
45.
Robinhood’s business records reflect that plaintiff McFadden opened a Robinhood
brokerage account on July 29, 2020.
46.
Attached as Exhibit 11 is a true and correct copy of the Customer Agreement in
effect on July 29, 2020. As part of the application to open the account, McFadden was required to
click a button on his or her computer or mobile device screen, equivalent to a signature,
acknowledging that he or she would be bound by the Customer Agreement.
47.
The program code for the App in effect at the time of July 29, 2020 shows that the
App presented the following text to applicants as part of the process before the applicant could
click the “Submit Application” button:
Brokerage Application Agreement: By tapping or clicking the "Submit Application"
button, I agree to this Robinhood Financial Brokerage Application Agreement (this
"Application Agreement"). I also agree to the terms of the RHF-RHS Customer Agreement
. . . which are incorporated by reference and constitute part of this Application Agreement.
. . . MY WARRANTIES AND REPRESENTATIONS I represent and warrant that: . . . I
have carefully reviewed, understand and agree to the terms and provisions of the following:
RHF-RHS Financial Customer Agreement . . . . Tapping or clicking the "Submit
Application" button is equivalent to My written signature, and I understand that I am
entering into legal agreements. I HAVE READ THE RHF-RHS CUSTOMER ACCOUNT
AGREEMENT WHICH CONTAINS A PREDISPUTE ARBITRATION CLAUSE
(SECTION 28 ON PAGES 20 AND 21) AND AGREE IN ADVANCE TO ARBITRATE
ANY CONTROVERSIES WHICH MAY ARISE BETWEEN OR AMONG ME, YOU,
AND/OR ROBINHOOD SECURITIES IN ACCORDANCE WITH SUCH SECTION 28.
. . . By tapping the “Submit Application” button below, I agree to this Application
Agreement.
(underlining added).
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48.
According to the App code, the underlined words above provided hyperlinks to a
webpage where the applicant could review the relevant agreement, including the customer
agreement in effect at the time of the application.
Danielle Perreault
49.
Robinhood’s business records reflect that plaintiff Perreault opened a Robinhood
brokerage account on February 24, 2019.
50.
Attached as Exhibit 12 is a true and correct copy of the customer agreement in
effect on February 24, 2019. As part of the application to open the account, Perreault was required
to click a button on his or her computer or mobile device screen, equivalent to a signature,
acknowledging that he or she would be bound by the customer agreement.
51.
The program code for the App in effect at the time of February 24, 2019, shows
that the App presented the following text to applicants as part of the process before the applicant
could click the “Submit Application” button:
By tapping or clicking the "Submit Application" button, I agree to this Robinhood Financial
Brokerage Application Agreement (this "Application Agreement"). I also agree to the
terms of the RHF-RHS Customer Agreement, . . . which are incorporated by reference and
constitute a part of this Application Agreement. . . . MY WARRANTIES AND
REPRESENTATIONS I represent and warrant that: . . . I have carefully reviewed,
understand and agree to the terms and provisions of the following: RHF-RHS Financial
Customer Agreement . . . . Tapping or clicking the "Submit Application" button is
equivalent to My written signature, and I understand that I am entering into legal
agreements. I HAVE READ THE RHF-RHS CUSTOMER ACCOUNT AGREEMENT
WHICH CONTAINS A PREDISPUTE ARBITRATION CLAUSE (SECTION 28 ON
PAGES 20 AND 21) AND AGREE IN ADVANCE TO ARBITRATE ANY
CONTROVERSIES WHICH MAY ARISE BETWEEN OR AMONG ME, YOU,
AND/OR ROBINHOOD SECURITIES IN ACCORDANCE WITH SUCH SECTION 28.
. . . By tapping the “Submit Application” button below, I agree to this Application
Agreement.
(underlining added).
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52.
According to the App code, the underlined words above provided hyperlinks to a
webpage where the applicant could review the relevant agreement, including the customer
agreement in effect at the time of the application.
Mike Ross
53.
Robinhood’s business records reflect that plaintiff Ross opened a Robinhood
brokerage account on December 19, 2014.
54.
Attached as Exhibit 13 is a true and correct copy of the customer agreement in
effect on December 19, 2014. As part of the application to open the account, Ross was required
to click a button on his or her computer or mobile device screen, equivalent to a signature,
acknowledging that he or she would be bound by the customer agreement.
55.
The program code for the App in effect at the time of December 19, 2014, shows
that the App presented the following text to applicants as part of the process before the applicant
could submit the application:
I have carefully reviewed, understand and agree to the terms and provisions of the
following: Robinhood Terms and Conditions, APEX Customer Agreement, RHF Customer
Agreement, . . . . Checking the box below is equivalent to my written signature, and I
understand that I am entering into legal agreements. . . . BY E-SIGNING THIS
APPLICATION, I (WE) ACKNOWLEDGE THE FOLLOWING: (1) THAT, PAGE 4
PARAGRAPH 8 OF THE APEX CUSTOMER AGREEMENT CONTAINS A
PREDISPUTE ARBITRATION CLAUSE AND IN ACCORDANCE WITH THIS
AGREEMENT
I
(WE)
AGREE
IN
ADVANCE
TO
ARBITRATE
ANY
CONTROVERSIES WHICH MAY ARISE BETWEEN OR AMONG ME (US), MY
BROKER, AND/OR CLEARING FIRM, (2) RECEIPT OF A COPY OF THE
CUSTOMER ACCOUNT AGREEMENT FOLLOWING THIS APPLICATION AND
MY (OUR) AGREEMENT WITH THE TERMS THEREIN AND (3) THE
INFORMATION PROVIDED ABOVE IS ACCURATE.
(underlining added).
56.
According to the App code, the underlined words above provided hyperlinks to a
webpage where the applicant could review the relevant agreement, including the customer
agreement in effect at the time of the application.
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Eric Quat
57.
Robinhood’s business records reflect that plaintiff Quat opened a Robinhood
brokerage account on July 25, 2018.
58.
Attached as Exhibit 14 is a true and correct copy of the customer agreement in
effect on July 25, 2018. As part of the application to open the account, Quat was required to click
a button on his or her computer or mobile device screen, equivalent to a signature, acknowledging
that he or she would be bound by the customer agreement.
59.
The program code for the App in effect at the time of July 25, 2018, shows that the
App presented the following text to applicants as part of the process before the applicant could
click the “Submit Application” button:
By tapping or clicking the "Submit Application" button, I agree to this Robinhood Financial
Brokerage Application Agreement (this "Application Agreement"). I also agree to the
terms of the Robinhood Financial Customer Agreement, Apex Customer Account
Agreement, . . . which are incorporated by reference and constitute part of this Application
Agreement. . . . I agree to read this Application Agreement and all incorporated disclosures,
terms, and agreements carefully and retain copies for My records. MY WARRANTIES
AND REPRESENTATIONS I represent and warrant that: . . . I have carefully reviewed,
understand and agree to the terms and provisions of the following: Robinhood Financial
Customer Agreement, Apex Customer Account Agreement . . . . Tapping or clicking the
"Submit Application" button is equivalent to My written signature, and I understand that I
am entering into legal agreements. I HAVE READ THE APEX CUSTOMER ACCOUNT
AGREEMENT WHICH CONTAINS A PREDISPUTE ARBITRATION CLAUSE
(SECTION 8 ON PAGES 2 AND 3) AND AGREE IN ADVANCE TO ARBITRATE
ANY CONTROVERSIES WHICH MAY ARISE BETWEEN OR AMONG ME, YOU,
AND/OR APEX IN ACCORDANCE WITH SUCH SECTION 8. I HAVE READ THE
ROBINHOOD FINANCIAL CUSTOMER AGREEMENT, WHICH CONTAINS A
PREDISPUTE ARBITRATION CLAUSE (SECTION 29). . . . BY TAPPING OR
CLICKING ON THE "SUBMIT APPLICATION" BUTTON, I AGREE TO THIS
APPLICATION AGREEMENT.
(underlining added).
60.
According to the App code, the underlined words above provided hyperlinks to a
webpage where the applicant could review the relevant agreement, including the customer
agreement in effect at the time of the application.
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Maurice Scarborough
61.
Robinhood’s business records reflect that plaintiff Scarborough opened a
Robinhood brokerage account on August 19, 2017.
62.
Attached as Exhibit 15 is a true and correct copy of the customer agreement in
effect on August 19, 2017. As part of the application to open the account, Scarborough was
required to click a button on his or her computer or mobile device screen, equivalent to a signature,
acknowledging that he or she would be bound by the customer agreement.
63.
The program code for the App in effect at the time of August 19, 2017, shows that
the App presented the following text to applicants as part of the process before the applicant could
click the “Submit Application” button:
By tapping the “Submit Application” button below, I agree to this Robinhood Financial
Brokerage Application Agreement (this “Application Agreement”). I also agree to the
terms of the Robinhood Terms and Conditions, Apex Customer Account Agreement,
Robinhood Financial Customer Agreement, . . . which are incorporated by reference and
constitute part of this Application Agreement. . . . I agree to read this Application
Agreement and all incorporated disclosures, terms, and agreements carefully and retain
copies for My records. MY WARRANTIES AND REPRESENTATIONS I represent and
warrant that: . . . I have carefully reviewed, understand and agree to the terms and
provisions of the following: Robinhood Terms and Conditions, Apex Customer Account
Agreement, Robinhood Financial Customer Agreement, . . . Tapping the “Submit
Application” button below is equivalent to My written signature, and I understand that I
am entering into legal agreements. I HAVE READ THE APEX CUSTOMER ACCOUNT
AGREEMENT, WHICH CONTAINS A PREDISPUTE ARBITRATION CLAUSE
(SECTION 8 ON PAGES 2 AND 3) AND AGREE IN ADVANCE TO ARBITRATE
ANY CONTROVERSIES WHICH MAY ARISE BETWEEN OR AMONG ME, YOU,
AND/OR APEX IN ACCORDANCE WITH SUCH SECTION 8. I HAVE READ THE
ROBINHOOD FINANCIAL CUSTOMER AGREEMENT, WHICH CONTAINS A
PREDISPUTE ARBITRATION CLAUSE (SECTION 29). . . . BY TAPPING ON THE
“SUBMIT APPLICATION” BUTTON BELOW, I AGREE TO THIS APPLICATION
AGREEMENT.
(underlining added).
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64.
According to the App code, the underlined words above provided hyperlinks to a
webpage where the applicant could review the relevant agreement, including the customer
agreement in effect at the time of the application.
Scott Schiller
65.
Robinhood’s business records reflect that plaintiff Schiller opened a Robinhood
brokerage account on August 25, 2015.
66.
Attached as Exhibit 16 is a true and correct copy of the customer agreement in
effect on August 25, 2015. As part of the application to open the account, Schiller was required
to click a button on his or her computer or mobile device screen, equivalent to a signature,
acknowledging that he or she would be bound by the customer agreement.
67.
The program code for the App in effect at the time of August 25, 2015, shows that
the App presented the following text to applicants as part of the process before the applicant could
click the “Submit Application” button:
I have carefully reviewed, understand and agree to the terms and provisions of the
following: Robinhood Terms and Conditions, APEX Customer Agreement, RHF Customer
Agreement . . . . Checking the box below is equivalent to my written signature, and I
understand that I am entering into legal agreements. . . . BY E-SIGNING THIS
APPLICATION, I (WE) ACKNOWLEDGE THE FOLLOWING: (1) THAT, PAGE 4
PARAGRAPH 8 OF THE APEX CUSTOMER AGREEMENT CONTAINS A
PREDISPUTE ARBITRATION CLAUSE AND IN ACCORDANCE WITH THIS
AGREEMENT
I
(WE)
AGREE
IN
ADVANCE
TO
ARBITRATE
ANY
CONTROVERSIES WHICH MAY ARISE BETWEEN OR AMONG ME (US), MY
BROKER, AND/OR CLEARING FIRM, (2) RECEIPT OF A COPY OF THE
CUSTOMER ACCOUNT AGREEMENT FOLLOWING THIS APPLICATION AND
MY (OUR) AGREEMENT WITH THE TERMS THEREIN AND (3) THE
INFORMATION PROVIDED ABOVE IS ACCURATE.
(underlining added).
68.
According to the App code, the underlined words above provided hyperlinks to a
webpage where the applicant could review the relevant agreement, including the customer
agreement in effect at the time of the application.
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Tenzin Woiser
69.
Robinhood’s business records reflect that plaintiff Woiser opened a Robinhood
brokerage account on January 13, 2017.
70.
Attached as Exhibit 17 is a true and correct copy of the customer agreement in
effect on January 13, 2017. As part of the application to open the account, Woiser was required
to click a button on his or her computer or mobile device screen, equivalent to a signature,
acknowledging that he or she would be bound by the customer agreement.
71.
The program code for the App in effect at the time of January 13, 2017, shows that
the App presented the following text to applicants as part of the process before the applicant could
click the “Submit Application” button:
By tapping the “Submit Application” button below, I agree to this Robinhood Financial
Brokerage Application Agreement (this “Application Agreement”). I also agree to the
terms of the Robinhood Terms and Conditions, Apex Customer Account Agreement,
Robinhood Financial Customer Agreement, . . . which are incorporated by reference and
constitute part of this Application Agreement. . . . I agree to read this Application
Agreement and all incorporated disclosures, terms, and agreements carefully and retain
copies for My records. MY WARRANTIES AND REPRESENTATIONS I represent and
warrant that: . . . I have carefully reviewed, understand and agree to the terms and
provisions of the following: Robinhood Terms and Conditions, Apex Customer Account
Agreement, Robinhood Financial Customer Agreement . . . . Tapping the “Submit
Application” button below is equivalent to My written signature, and I understand that I
am entering into legal agreements. I HAVE READ THE APEX CUSTOMER ACCOUNT
AGREEMENT, WHICH CONTAINS A PREDISPUTE ARBITRATION CLAUSE
(SECTION 8 ON PAGES 2 AND 3) AND AGREE IN ADVANCE TO ARBITRATE
ANY CONTROVERSIES WHICH MAY ARISE BETWEEN OR AMONG ME, YOU,
AND/OR APEX IN ACCORDANCE WITH SUCH SECTION 8. I HAVE READ THE
ROBINHOOD FINANCIAL CUSTOMER AGREEMENT, WHICH CONTAINS A
PREDISPUTE ARBITRATION CLAUSE (SECTION 29). . . . BY TAPPING ON THE
“SUBMIT APPLICATION” BUTTON BELOW, I AGREE TO THIS APPLICATION
AGREEMENT.
(underlining added).
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72.
According to the App code, the underlined words above provided hyperlinks to a
webpage where the applicant could review the relevant agreement, including the customer
agreement in effect at the time of the application.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.

Executed on December 9, 2024
______________________________
Name: Marc O’Such
Title: Senior Paralegal, Robinhood Markets, Inc.

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Exhibit 1

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562

Revised December 30, 2020
Robinhood Financial LLC & Robinhood Securities, LLC Customer Agreement
In consideration of Robinhood Financial LLC, Robinhood Securities, LLC, and their agents and assigns
(collectively, "Robinhood") opening one or more accounts on my behalf ("My Account(s)" or the
"Account(s)") for the purchase, sale or carrying of securities or contracts relating thereto and/or the
borrowing of funds, which transactions are cleared through Robinhood Securities, I represent and agree
with respect to all Accounts, whether margin or cash, to the terms set forth below (the "Agreement").
When used in this Agreement, the words "I", "Me", "My", "We", or "Us" mean the owner(s) of the
Account. For purposes of this Agreement, Business Days are Monday through Friday, excluding federal
holidays. Any references to "days" found in this Agreement are calendar days unless indicated
otherwise.
I UNDERSTAND THAT THE TERMS AND CONDITIONS OF THIS AGREEMENT GOVERN ALL
ASPECTS OF MY RELATIONSHIP WITH ROBINHOOD REGARDING MY ACCOUNTS. I WILL
CAREFULLY READ, UNDERSTAND AND ACCEPT THE TERMS AND CONDITIONS OF THIS
AGREEMENT BEFORE I CLICK "SUBMIT APPLICATION" OR OTHER SIMILARLY WORDED
BUTTON. IF I HAVE ANY QUESTIONS ABOUT ANY OF THE PROVISIONS IN THIS AGREEMENT,
I WILL EMAIL HELP@ROBINHOOD.COM. I UNDERSTAND THAT CLICKING "SUBMIT
APPLICATION" IS THE LEGAL EQUIVALENT OF MY MANUALLY SIGNING THIS AGREEMENT
AND I WILL BE LEGALLY BOUND BY ITS TERMS AND CONDITIONS. BY ENTERING INTO
THIS AGREEMENT, I ACKNOWLEDGE RECEIPT OF THE ROBINHOOD PRIVACY POLICY AND
PRIVACY AND SECURITY STATEMENT. I UNDERSTAND THAT THIS AGREEMENT MAY BE
AMENDED FROM TIME TO TIME BY ROBINHOOD, WITH REVISED TERMS POSTED ON THE
ROBINHOOD WEBSITE. I AGREE TO CHECK FOR UPDATES TO THIS AGREEMENT. I
UNDERSTAND THAT BY CONTINUING TO MAINTAIN MY SECURITIES BROKERAGE
ACCOUNT WITHOUT OBJECTING TO ANY REVISED TERMS OF THIS AGREEMENT, I AM
ACCEPTING THE TERMS OF THE REVISED AGREEMENT AND I WILL BE LEGALLY BOUND
BY ITS TERMS AND CONDITIONS. IF I REQUEST OTHER SERVICES PROVIDED BY
ROBINHOOD THAT REQUIRE ME TO AGREE TO SPECIFIC TERMS AND CONDITIONS
ELECTRONICALLY (THROUGH CLICKS OR OTHER ACTIONS) OR OTHERWISE, SUCH TERMS
AND CONDITIONS WILL BE DEEMED AN AMENDMENT AND WILL BE INCORPORATED INTO
AND MADE PART OF THIS AGREEMENT. I ALSO UNDERSTAND THAT BY CLICKING "SUBMIT
APPLICATION" I HAVE ACKNOWLEDGED THAT THIS AGREEMENT CONTAINS A PREDISPUTE
ARBITRATION CLAUSE IN SECTION 38 HEREIN.
1. Capacity and Status.
If an individual, I am of legal age under the laws of the state where I reside and authorized to enter into
this Agreement. If an entity, I am duly formed, validly existing and in good standing in My state of
organization, have full power and authority to enter and perform this Agreement, and the persons signing
the account application are fully authorized to act on My behalf. No person, except Myself, has any
interest in the Account opened pursuant to this Agreement. I acknowledge that unless Robinhood
receives written objection from Me, Robinhood may provide My name, address, and securities positions
to requesting companies in which I hold securities. Except as otherwise disclosed to Robinhood in
writing, neither I nor any member of My immediate family is an employee of any exchange, any
corporation of which any exchange owns a majority of the capital stock, a member of any exchange or
self-regulatory organization, a member of any firm or member corporation registered on any exchange, a
bank, trust company, insurance company or any corporation, firm or individual engaged in the business
of dealing either as a broker-dealer or as principal in securities. I understand and agree that I am
obligated to promptly notify Robinhood in writing if I or a member of My immediate family becomes
registered or employed in any of the above-described capacities. Except as otherwise disclosed to
Robinhood in writing, I am not a Professional (as defined below). I further agree to promptly notify
Robinhood in writing if I am now or if I become a Professional or an officer, director or 10% stockholder
of any publicly traded company.
2. Market Data.
Robinhood may choose to make certain market data available to Me pursuant to the terms and
conditions set forth in this Agreement. By executing this Agreement, I agree to comply with those terms
and conditions.
1
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A. Definitions.
"Market Data" means (a) last sale information and quotation information relating to securities that
are admitted to dealings on the New York Stock Exchange ("NYSE"), (b) such bond and other
equity last sale and quotation information, and such index and other market information, as United
States-registered national securities exchanges and national securities associations (each, an
"Authorizing SRO") may make available and as the NYSE may from time to time designate as
"Market Data"; and (c) all information that derives from any such information.
"Nonprofessional" means any natural person who receives market data solely for his/her
personal, non- business use and who is not a "Professional." A "Professional" includes an
individual who, if working in the United States, is: (i) registered or qualified with the Securities and
Exchange Commission (the "SEC"), the Commodity Futures Trading Commission (the "CFTC"),
any state securities agency, any securities exchange or association, or any commodities or
futures contract market or association; (ii) engaged as an "investment advisor" as that term is
defined in Section 202 (a) (11) of the Investment Advisers Act of 1940 (whether or not registered
or qualified under that Act), or (iii) employed by a bank or other organization exempt from
registration under federal and/or state securities laws to perform functions that would require him
or her to be so registered or qualified if he or she were to perform such functions for an
organization not so exempt. A person who works outside of the United States will be considered a
"Professional" if he or she performs the same functions as someone who would be considered a
"Professional" in the United States.
B. Provisions Applicable to All Users.
Proprietary Nature of Data. I understand and acknowledge that each Authorizing SRO and Other
Data Disseminator (as defined below) has a proprietary interest in the Market Data that originates
on or derives from it or its market(s). I agree not to reproduce, distribute, sell or commercially
exploit the Market Data in any manner.
Enforcement. I understand and acknowledge that (a) the Authorizing SROs are third-party
beneficiaries under this Agreement and (b) the Authorizing SROs or their authorized
representative(s) may enforce this Agreement, by legal proceedings or otherwise, against Me or
any person that obtains Market Data that is made available pursuant to this Agreement other than
as this Agreement contemplates.
Data Not Guaranteed. I understand that neither Robinhood nor any Authorizing SRO, other entity
whose information is made available over the Authorizing SROs' facilities (an "Other Data
Disseminator"), or information processor that assists any Authorizing SRO or Other Data
Disseminator in making Market Data available (collectively, the "Disseminating Parties")
guarantees the timeliness, sequence, accuracy, completeness, reliability, or content of Market
Data or of other market information or messages disseminated to or by any Disseminating Party. I
understand that neither Robinhood Financial nor any Disseminating Party guarantees the
timeliness, sequence, accuracy, completeness, reliability or content of market information, or
messages disseminated to or by any party. I understand that neither Robinhood Financial nor any
Disseminating Party warrants that the service provided by any such entity will be uninterrupted or
error-free. I further understand that Market Data by Xignite provides market data to Robinhood
Financial customers. NEITHER ROBINHOOD FINANCIAL, ANY OF ITS AFFILIATES, THEIR
RESPECTIVE OFFICERS OR EMPLOYEES, NOR ANY DISSEMINATING PARTY SHALL BE
LIABLE IN ANY WAY FOR (A) ANY INACCURACY, ERROR OR DELAY IN, OR OMISSION
OF, (I) ANY MARKET DATA, INFORMATION OR MESSAGE, OR (II) THE TRANSMISSION
OR DELIVERY OF ANY SUCH DATA, INFORMATION OR MESSAGE; OR (B) ANY LOSS (AS
DEFINED IN THIS AGREEMENT) OR DAMAGE ARISING FROM OR OCCASIONED BY (I)
ANY SUCH INACCURACY, ERROR, DELAY OR OMISSION, (II) NON-PERFORMANCE OR
III) INTERRUPTION IN ANY SUCH MARKET DATA, INFORMATION, OR MESSAGE,
WHETHER DUE TO ANY ACT OR OMISSION BY ROBINHOOD FINANCIAL, ANY OF ITS
AFFILIATES, THEIR RESPECTIVE OFFICERS OR EMPLOYEES, OR ANY DISSEMINATING
PARTY, OR TO ANY "FORCE MAJEURE" (E.G., FLOOD, EXTRAORDINARY WEATHER
CONDITIONS, EARTHQUAKE OR OTHER ACT OF GOD, FIRE, WAR, INSURRECTION,
RIOT, LABOR DISPUTE, ACCIDENT, ACTION OF GOVERNMENT, OR COMMUNICATIONS
OR POWER FAILURE, EQUIPMENT OR SOFTWARE MALFUNCTION) OR ANY OTHER
1.
2.
1.
2.
3.
2
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CAUSE BEYOND THE REASONABLE CONTROL OF ROBINHOOD FINANCIAL, ITS
AFFILIATES, THEIR RESPECTIVE OFFICERS AND EMPLOYEES, OR ANY
DISSEMINATING PARTY.
Permitted Use. I shall not furnish Market Data to any other person or entity. If I receive Market
Data other than as a Nonprofessional, I shall use Market Data only for My individual use.
Dissemination, Discontinuance, or Modification. I understand and acknowledge that, at any time,
the Authorizing SROs may discontinue disseminating any category of Market Data, may change
or eliminate any transmission method and may change transmission speeds or other signal
characteristics. The Authorizing SROs shall not be liable for any resulting liability, loss or
damages that may arise therefrom.
Duration; Survival. This Section 2 of this Agreement remains in effect for so long as I have the
ability to receive Market Data as contemplated by this Section 2. In addition, Sections 2(B)(1)-(3)
and the first two sentences of Section 2(B)(7), survive any termination of this Agreement.
Miscellaneous. The laws of the State of New York shall govern this Section 2 and it shall be
interpreted in accordance with those laws. This Subsection is subject to the Securities Exchange
Act of 1934, the rules promulgated under that act, and the joint-industry plans entered into
pursuant to that act.
C. Provisions Applicable to Nonprofessionals.
Permitted Receipt. I understand that I may not receive Market Data from Robinhood as a
Nonprofessional, and Robinhood may not provide Market Data to Me as a Nonprofessional,
unless Robinhood first properly determines that I qualify as a Nonprofessional as defined above
and I in fact qualify as a Nonprofessional. I agree that, as a prerequisite to Robinhood Financial
qualifying Me as a Nonprofessional, I will provide to Robinhood truthful and accurate information
about Me, such as: my occupation, employer, employment position and functions; my use of
Market Data; my registration status with any securities agency, exchange, association, or
regulatory body, or any commodities or future contract market, association, or regulatory body,
whether in the United States or elsewhere; and any compensation of any kind I may receive from
any individual or entity for my trading activities, asset management, or investment advice. Except
as otherwise declared to Robinhood in writing, by executing this Agreement, I certify that I meet
the definition of Nonprofessional as set forth in this Agreement.
Permitted Use. If I am a Nonprofessional, I agree to receive Market Data solely for my personal,
non-business use.
Notification. I shall notify Robinhood promptly in writing of any change in my circumstances that
may cause Me to cease to qualify as a Nonprofessional.
3. NASDAQ OMX Information.
A. Definitions.
"Information" means certain market data and other data disseminated that has been collected,
validated, processed, and recorded by any system NASDAQ OMX has developed for the creation
or dissemination of Information or other sources made available for transmission to and receipt
from either a distributor such as RHF or from NASDAQ OMX relating to: a) eligible securities or
other financial instruments, markets, products, vehicles, indicators, or devices; b) activities of a
NASDAQ OMX company; c) other information and data from a NASDAQ OMX company.
"Information" also includes any element of Information as used or processed in such a way that
the Information can be identified, recalculated or re-engineered from the processed Information or
that the processed Information can be used as a substitute for Information.
"NASDAQ OMX" means The NASDAQ OMX Group, Inc., a Delaware limited liability company
and its subsidiaries and Affiliates (collectively, "NASDAQ OMX").
4.
5.
6.
7.
1.
2.
3.
1.
2.
3
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B. Use of Data.
I understand that I may use the Information only for personal use and not for any business purpose. I
may not sell, lease, furnish or otherwise permit or provide access to the Information to any other natural
person or entity ("Person") or to any other office or place. I will not engage in the operation of any illegal
business use or permit anyone else to use the Information, or any part thereof, for any illegal purpose or
violate any NASDAQ OMX or SEC Rule or any FSA rule or other applicable law, rule or regulation. I may
not present the Information rendered in any unfair, misleading or discriminatory format. I shall take
reasonable security precautions to prevent any Person other than Myself from gaining access to the
Information.
C. Proprietary Data.
I acknowledge and agree that NASDAQ OMX has proprietary rights to the Information that originates on
or derives from markets regulated or operated by NASDAQ OMX, and compilation or other rights to
Information gathered from other sources. I further acknowledge and agree that NASDAQ OMX's third-
party information providers have exclusive proprietary rights to their respective Information. In the event
of any misappropriation or misuse by Me or anyone who accesses the Information through Me,
NASDAQ OMX or its third-party information providers shall have the right to obtain injunctive relief for its
respective materials.
D. System.
I acknowledge that NASDAQ OMX, in its sole discretion, may from time-to-time make modifications to
its system or the Information. Such modifications may require corresponding changes to be made in
Robinhood Financial's service. Changes or the failure to make timely changes by Me may sever or
affect My access to or use of the Information. I understand that neither NASDAQ OMX nor Robinhood
shall be responsible for such effects.
E. NASDAQ OMX Limitation of Liability.
Except as may otherwise be set forth herein, NASDAQ OMX shall not be liable to Me for indirect,
special, punitive, consequential or incidental loss or damage (including, but not limited to, trading losses,
lost profits, or other indirect loss or damage) of any nature arising from any cause whatsoever, even if
NASDAQ OMX has been advised of the possibility of such damages. NASDAQ OMX shall not be liable
to Me for any unavailability, interruption, delay, incompleteness or inaccuracy of the Information. This
Section shall not relieve NASDAQ OMX or Me from liability for damages that result from their own gross
negligence or willful tortious misconduct or from personal injury or wrongful death claims. I agree that the
terms of this Section reflect a reasonable allocation of risk and limitation of liability.
F. Disclaimers of Warranties.
NASDAQ OMX and its third-party information providers make no warranties of any kind with respect to
the Information---express, implied or statutory (including without limitation, timeliness, truthfulness,
sequence, completeness, accuracy, freedom from interruption), any implied warranties arising from trade
usage, course of dealing, course of performance or the implied warranties of merchantability or fitness
for a particular use or purpose or noninfringement.
G. Termination by NASDAQ OMX.
I acknowledge that NASDAQ OMX, when required to do so in fulfillment of statutory obligations, may by
notice to Robinhood unilaterally limit or terminate the right of any or all Persons to receive or use the
4
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Information and that Robinhood will comply with any such notice and will terminate or limit the furnishing
of the Information.
4. Authorization.
I understand that My Account is self-directed. Accordingly, I appoint Robinhood Financial as My agent for
the purpose of carrying out My directions to Robinhood Financial in accordance with the terms and
conditions of this Agreement and any attendant risks with respect to the purchase or sale of securities.
Robinhood Financial is authorized to open or close My Account(s), place and withdraw orders and take
such other steps as are reasonable to carry out My directions. All transactions will be effected only on
My order or the order of My authorized delegate, except as described in Section 10. I understand
Robinhood Financial provides trading and brokerage services through the Robinhood website (the
"Website") and the Robinhood mobile application (the "App"). I agree to receive and transmit financial
information through such electronic means. My use or My grant of access to My Account to any third
party to access information or place transactions in My Account is solely at My risk.
5. Customer Representations and Responsibilities.
A. Self-directed Account.
I understand that My Account is self-directed, and so that I am solely responsible for any and all orders
placed in My Account and that all orders entered by Me or on My behalf are unsolicited and based on My
own investment decisions or the investment decision of My duly authorized representative or agent.
Accordingly, I agree that neither Robinhood nor any of its employees, agents, principals, or
representatives:
provide investment advice in connection with this Account;
recommend any security, transaction or order;
solicit orders;
act as a market maker in any security;
make discretionary trades; and
produce or provide first-party research providing a specific investment strategies such as buy, sell
or hold recommendations, first-party ratings and/or price targets. To the extent research materials
or similar information are available through the App or the Website or the websites of any entity
controlled by, controlling, or under common control with Robinhood (such entity, an "Affiliate"), I
understand that these materials are intended for informational and educational purposes only and
they do not constitute a recommendation to enter into any securities transactions or to engage in
any investment strategies.
B. Information Accuracy.
I: (i) certify that the information contained in this Agreement, the account application, and any other
document that I furnish to Robinhood Financial in connection with My Account(s) is complete, true and
correct, and acknowledge that knowingly giving false information for the purpose of inducing Robinhood
Financial to extend credit is a federal crime; (ii) authorize Robinhood Financial to contact any individual
or firm noted herein or on the documents referred to in subsection (i) of this Section and any other normal
sources of debit or credit information; (iii) authorize anyone so contacted to furnish such information to
Robinhood Financial as Robinhood may request; and (iv) agree that this Agreement, the account
application and any other document I furnish in connection with My Account is Robinhood's property, as
the case may be. I shall promptly advise Robinhood Financial of any changes to the information in such
agreements and documents in writing within ten (10) calendar days. I authorize Robinhood Financial to
obtain reports and provide information to others concerning My creditworthiness and business conduct.
Upon My request, Robinhood agrees to provide Me a copy of any report so obtained. Robinhood may
1.
2.
3.
4.
5.
6.
5
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retain this Agreement, the Account application, and all other such documents and their respective
records at Its sole discretion, whether or not credit is extended.
C. Risks.
I understand that all investments involve risk, that losses may exceed the principal invested, and that
the past performance of a security, industry, sector, market, or financial product does not guarantee
future results or returns.
D. Account Defaults.
I understand that My Account comes with many defaulted service instruction features and preferences. I
further understand that I am not required to use these defaulted options or preferences and that once My
Account is approved and opened I have the sole discretion to control and adjust such defaulted service
preferences that relate to My account.
E. Knowledge of Account.
I understand that I am solely responsible for knowing the rights and terms for all securities purchased,
sold and maintained in My Account including mergers, reorganizations, stock splits, name changes or
symbol changes, dividends, option symbols, and option deliverables. I further understand that certain
securities may grant Me valuable rights that may expire unless I take specific action. These securities
include bonds, convertible securities, warrants, stock rights and securities subject to exchange offers or
tenders. I am responsible for knowing all expiration dates, redemption dates, and the circumstances
under which rights associated with My securities may be called, cancelled, or modified. Robinhood may,
but are not obligated to, notify Me of any upcoming expiration or redemption dates, or take any action on
My behalf without My specific instructions except as required by law and the rules of regulatory
authorities. I acknowledge that Robinhood may adjust My Account to correct any error. If My Account
has an option position on the last trading day prior to expiration, which is one cent or more in the money,
Robinhood Financial will generally exercise the option, on My behalf. However, Robinhood Financial
reserves the right at Its discretion to close any option position prior to expiration date or any position
resulting from the exercising/assignment after option expiration. I will be charged a commission for any
such transaction. Robinhood Financial is not obligated to take any of these actions and Robinhood
Financial is not liable for Losses should it not take them.
F. Purchases.
All orders for the purchase of securities given for My Account will be authorized by Me and executed in
reliance on My promise that an actual purchase is intended. It is My obligation to pay for purchases
immediately or on Robinhood's demand. I understand Robinhood may at any time, in its sole discretion
and without prior notice to Me, prohibit or restrict My ability to trade securities. I further agree not to
allow any person to trade for My Account unless a trading authorization for that person has been
received and approved by Robinhood. Robinhood reserve the right to require full payment in cleared
funds prior to the acceptance of any order. In the event that I fail to provide sufficient funds, Robinhood
may, at its option and without notice to Me, i) charge a reasonable rate of interest, ii) liquidate the
Property subject of the buy order, or iii) sell other Property owned by Me and held in any of My Accounts.
Robinhood may also charge any consequential Loss to My Account. For purposes of this Agreement,
"Property" shall mean all monies, contracts, investments and options, whether for present or future
delivery, and all related distributions, proceeds, products and accessions.
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G. Sales/Short Sales.
I promise to deliver all securities sold in My Account and to provide collateral of a type and amount
acceptable to Robinhood Financial for all short sales in My Account. Robinhood Financial requires that a
security be held in My Account prior to the acceptance of a sell order with respect to such security
unless the order is specifically designated as a "short sale." If a security is not held in My Account and a
sell order is processed, I must promptly deliver such security to Robinhood Financial for receipt in good
deliverable form on or before the settlement date. Any order accepted without negotiable certificates or
positions in My Account will be subject, at Robinhood Financial's sole discretion, to cancellation or buy-
in. To ensure this will not occur, I agree to only place sell orders for securities owned by Me and held in
My Account at the time My order is placed.
Proceeds of a sale will not be paid to Me or released into My Account until Robinhood Financial has
received the security in good deliverable form, whether from a transfer agent or from Me and the
settlement of the security is complete. If the security is not received on or before settlement date, or as
market conditions warrant, Robinhood Financial may in its sole discretion purchase the security on the
open market for My Account and may liquidate and close out any and all securities in My Account in
order to pay for such purchase. In the event a security is bought in, I will be responsible for all resulting
Losses incurred by Robinhood Financial.
I understand that I may execute short sales only in a margin Account and that such execution must
comply with applicable short sales rules.
H. Assistance by Robinhood.
I understand that when I request assistance from Robinhood or its employees in using the investment
tools available on the Website or the App, it will be limited to an explanation of the tool's functionality
and, if requested by Me, to the entry by Robinhood or its employees of variables provided by Me, and
that such assistance does not constitute investment advice, an opinion with respect to the suitability of
any transaction, or solicitation of any orders.
I. No Tax or Legal Advice.
I understand that Robinhood does not provide tax or legal advice.
J. Discontinuation of Services.
I understand that Robinhood may discontinue My Account and any services related to My Account
immediately by providing written notice to Me
K. Electronic Access.
I am solely responsible for keeping My Account numbers and PINs confidential and will not share
them with third parties. "PINs" shall mean My username and password.
I agree and accept full responsibility for monitoring and safeguarding My Accounts and access to
My Accounts.
I agree to immediately notify Robinhood in writing, delivered via e-mail and a recognized
international delivery service, if I become aware of: (i) any loss, theft, or unauthorized use of My
PINs or Account numbers; (ii) any failure by Me to receive any communication from Robinhood
indicating that an order was received, executed or cancelled, as applicable; (iii) any failure by Me
to receive an accurate written confirmation of an order, execution, or cancellation; (iv) any receipt
by Me of confirmation of an order, execution or cancellation, which I did not place; (v) any
1.
2.
3.
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inaccurate information in or relating to My orders, trades, margin status, Account balances,
deposits, withdrawals, securities positions or transaction history; or (vi) any other unauthorized
use or access of My Account.
Each of the events described in subsections (K)(3)(i)-(vi) shall be deemed a "Potential Fraudulent
Event". The use and storage of any information including My Account numbers, PINs, portfolio
information, transaction activity, account balances and any other information or orders available
on My wireless, web-enabled cellular telephone or similar wireless communications device
(collectively, "Mobile Device") or My personal computer is at My own risk and is My sole
responsibility. I represent that I am solely responsible for and have authorized any orders or
instructions appearing in, originating from, or associated with My Account, My Account number,
My username and password, or PINs. I agree to notify Robinhood immediately after I discover
any Potential Fraudulent Event, but in no event more than twenty-four (24) hours following
discovery. Upon request by Robinhood, I agree to report any Potential Fraudulent Event promptly
to legal authorities and provide Robinhood a copy of any report prepared by such legal authorities.
I agree to cooperate fully with the legal authorities and Robinhood in any investigation of any
Potential Fraudulent Event and I will complete any required affidavits promptly, accurately and
thoroughly. I also agree to allow Robinhood access to My Mobile Device, My computer, and My
network in connection with Robinhood's investigation of any Potential Fraudulent Event. I
understand that if I fail to do any of these things I may encounter delays in regaining access to
the funds in My Account. I agree to indemnify and hold Robinhood, its Affiliates, and Robinhood
and its Affiliates' respective officers, directors, and employees harmless from and against any
Losses arising out of or relating to any Potential Fraudulent Event. I acknowledge that Robinhood
does not know when a person entering orders with My username and password is Me.
Trusted Contact Person. I understand that, pursuant to FINRA regulations, Robinhood is
authorized to contact the Trusted Contact Person (as defined by FINRA Rule 4512) designated
for My Account and to disclose information about My account to address possible financial
exploitation, to confirm the specifics of My current contact information, health status, or the
identity of any legal guardian, executor, trustee or holder of a power of attorney, or as otherwise
permitted by Rule 2165.
6. Clearance of Trades.
I understand that Robinhood Financial has entered into a clearing agreement with Robinhood Securities
whereby Robinhood Financial will introduce My Account to Robinhood Securities, and Robinhood
Securities will clear all transactions, on a fully-disclosed basis. I understand that Robinhood Securities
carries My Account(s) and is responsible for the clearing and bookkeeping of transactions, but is not
otherwise responsible for the conduct of Robinhood Financial.
Until receipt from Me of written notice to the contrary, Robinhood Securities may accept from Robinhood
Financial, without inquiry or investigation, (i) orders for the purchase or sale of securities and other
property on margin, if I have elected to have a margin account, or otherwise, and (ii) any other
instructions concerning my Accounts. Robinhood Securities shall look solely to Robinhood Financial
unless otherwise directed by Robinhood Financial, and not to Me, with respect to any such orders or
instructions; except that I understand that Robinhood Securities will deliver confirmations, statements,
and all written or other notices with respect to My Account directly to Me with copies to Robinhood
Financial, and that Robinhood Securities will look directly to Me or Robinhood Financial for delivery of
margin, payment, or securities. I agree to hold Robinhood Securities harmless from and against any
Losses arising in connection with the delivery or receipt of any such communication(s), provided
Robinhood Securities has acted in accordance with the above. The foregoing shall be effective as to My
Account(s) until written notice to the contrary is received from Me by Robinhood Securities or Robinhood
Financial.
7. Review of Confirmations and Statements.
I agree that it is My responsibility to review order execution confirmations and statements of My
Account(s) promptly upon receipt. I agree to receive all confirmations and account statements, as well
as all tax related documents, in electronic format. I understand that account statements will evidence all
activity in My Account for the stated period, including securities transactions, cash balances, credits to
My Account and all fees paid from My Account. Notwithstanding Section 36.B, confirmations will be
considered binding on Me unless I notify Robinhood of any objections within two (2) calendar days from
the date confirmations are sent. Account statements will be considered binding on Me unless I notify you
4.
5.
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of any objections within ten (10) calendar days after My Account statements are posted online. Such
objection may be oral or in writing, but any oral objection must be immediately confirmed in writing. In all
cases, Robinhood reserves the right to determine the validity of My objection. If I object to a transaction
for any reason, I understand and agree that I am obligated to take action to limit any losses that may
result from such transaction or I will bear sole responsibility for any losses relating to the transaction,
even if My objection to the transaction is ultimately determined to be valid. Nothing in this Section 7
shall limit My responsibilities as described in Section 5 of this Agreement.
8. Important Information Needed to Open a New Account.
To help the government better detect the funding of terrorism and money laundering activities, federal
law requires all financial institutions to obtain, verify, and record information that identifies each person
who opens an account. Therefore, I understand that when I open My Account Robinhood will ask for My
name, address, date of birth and other identifying information. Robinhood may also ask copies of My
driver's license, passport or other identifying documents. I understand that Robinhood may take steps to
verify the accuracy of the information I provide to Robinhood in My Account application or otherwise, and
that Robinhood may restrict My access to My Account pending such verification. I will provide prompt
notification to Robinhood of any changes in the information including My name, address, e-mail address
and telephone number.
I further understand that if I attempt to access My Account from a jurisdiction subject to certain U.S.
sanctions or I am ordinarily resident in such a jurisdiction, or if you reasonably believe that I am
attempting such access or have become a resident in such a jurisdiction, you may restrict My Account,
and any pending orders may be cancelled. If this happens, I understand that I should contact
help@robinhood.com, and that I may be asked to provide supplemental information as part of this
process. I further understand that I must close My Account before establishing residency in any
jurisdiction subject to U.S. sanctions.
9. Telephone Conversations and Electronic Communications.
I understand and agree that Robinhood may record and monitor any telephone or electronic
communications with Me. Unless otherwise agreed in writing in advance, Robinhood does not consent
to the recording of telephone conversations by any third party or Me. I acknowledge and understand that
not all telephone or electronic communications are recorded by Robinhood, and Robinhood does not
guarantee that recordings of any particular telephone or electronic communications will be retained or
capable of being retrieved.
10. Oral Authorization.
I agree that Robinhood shall be entitled to act upon any oral instructions given by Me so long as
Robinhood reasonably believes such instruction was actually given by Me or My authorized agent.
11. Applicable Laws and Regulations.
All transactions in My Account will be subject to federal securities laws and regulations, the applicable
laws and regulations of any state or jurisdiction in which Robinhood Financial is registered, the rules of
any applicable self-regulatory organization of which Robinhood Financial is a member and the rules,
regulations, customs and usages of the exchange or market, and its clearing house, if any, where the
transactions are executed. In no event will Robinhood Financial be obligated to effect any transaction it
believes would violate any federal or state law, rule or regulation or the rules or regulations of any
regulatory or self-regulatory organization.
12. Erroneous Distributions.
I agree to promptly return to Robinhood any assets erroneously distributed to Me. In the event that I sell
a security prior to its ex-dividend/distribution date, and I receive the related cash/stock dividend or
distribution in error, I direct Robinhood on My behalf to pay such dividend/distribution to the entitled
purchaser of the securities I sold, and I guarantee to promptly reimburse Robinhood for, or deliver to
Robinhood, said dividend or distribution.
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13. Market Volatility; Market Orders; Limit Orders; and Queued Orders.
I understand that, whether I place a market or limit order, I will receive the price at which My order is
executed in the marketplace, subject to any clarification stated below. Particularly during periods of high
volume, illiquidity, fast movement or volatility in the marketplace, the execution price received may differ
from the quote provided on entry of an order, and I may receive partial executions of an order at different
prices. I understand that Robinhood Financial is not liable for any price fluctuations. I also understand
that price quotes generally are for only a small number of shares as specified by the marketplace, and
larger orders are relatively more likely to receive executions at prices that vary from the quotes or in
multiple lots at different prices.
I understand that Robinhood Financial does not currently support sending traditional market buy orders
and that Robinhood Financial collars all market buy orders (other than dollar-based buy orders executed
during market hours) by using limit orders priced up to 5% above the last trade price. This is not the
case for market sell orders. I further understand that when I send a market buy order through Robinhood
Financial's trading system, the trading system generates a limit order up to 5% above the last trade
price, and then Robinhood Financial sends the order to an executing broker. I understand that Robinhood
Financial's implementation of market buy orders may vary depending on prices of instruments, market
conditions, and other factors. I further understand that Robinhood Financial uses the following rounding
mechanics with respect to buy orders: the last trade price is (i) multiplied by 1.05; (ii) rounded down to
two decimal places if the last trade price is over $1.00; otherwise, rounded down to four decimal places;
and (iii) for securities included in the SEC's Tick Size Pilot Program, rounded down to the nearest $.05
increment. I understand that securities may open for trading at prices substantially higher or lower than
the previous closing price or the anticipated price. If I place a market order (whether during normal
market hours or when the market is closed), I agree to pay or receive the prevailing market price at the
time My market order is executed, subject to the specific clarification above relating to buy orders. I
understand that the price I pay may be significantly higher or lower than anticipated at the time I placed
the order. To avoid buying a security at a higher price and possibly exceeding My purchasing power, I
understand My option to enter a limit order. I also understand that limit orders may not be executed at
any particular time, or at all, if there is not sufficient trading at or better than the limit price I specify, and
are only good until the end of the trading day in which they are entered. The Website contains further
information regarding order types and limitations, which I agree to read and understand before placing
such orders.
As a customer of Robinhood Financial, I understand that after the market has closed for the day, I have
the ability to place in a queue order requests to be executed the following day upon the opening of the
market ("Queued Order"). I understand that My Queued Order request is prioritized based on the order in
which it is received by Robinhood Financial, and that the Queued Order requests are sent out for
execution shortly after the market opens on the next day of trading. I further understand that each
Queued Order request is sent out per customer and per security as Robinhood Financial market orders
(described above), and that they are not aggregated.
A limit order may be "good till cancelled" which means the order remains valid until (A) it is executed; (B)
I cancel the order; (C) approximately 90 days from when the order is placed; or (D) the contract to which
it relates is closed. I understand that Robinhood will cancel a "good till cancelled" order at the end of
every trading day (on the exchange on which the instrument to which the contract relates is traded) and
place such order again at the start of the following trading day. This process will be repeated every day
for as long as the "good till cancelled" order remains valid. I further agree that any "good till cancelled"
orders I place should be treated as "do not reduce" orders.
14. Bulletin Board/Pink Sheet Stocks.
Bulletin board, pink sheet and other thinly-traded securities (collectively "bulletin board stocks") present
particular trading risks, in part because they are relatively less liquid and more volatile than actively
traded securities listed on a major exchange. I understand that bulletin board stocks may be subject to
different trading rules and systems than other securities and that I may encounter significant delays in
executions, reports of executions, and updating of quotations in trading bulletin board stocks. Robinhood
Financial in its sole discretion may require limit orders on certain bulletin board stock transactions.
15. Research and Internet Links.
News, research, links to outside websites, and other information accessible through the App or Website
("Content") may be prepared by independent external providers not affiliated with Robinhood Financial,
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including Morningstar, Inc. (all such providers, the "Providers"). I agree not to distribute, reproduce, sell,
or otherwise commercially use the Content in any manner. I understand that Robinhood may terminate
My access to the Content. I understand that none of the Content is a recommendation by Robinhood to
buy or sell any securities or to engage in any investment strategy.
16. Restrictions on Trading.
I understand that Robinhood may, in its discretion, prohibit or restrict the trading of securities, or the
substitution of securities, in any of My Accounts. I understand that Robinhood may execute all orders by
Me on any exchange or market, unless I specifically instruct Robinhood to the contrary. In the event of a
breach or default by Me under this Agreement, Robinhood shall have all rights and remedies available to
a secured creditor under all applicable laws and in addition to the rights and remedies provided herein. I
understand that Robinhood may at any time, at its sole discretion and without prior notice to Me: (i)
prohibit or restrict My access to the use of the App or the Website or related services and My ability to
trade, (ii) refuse to accept any of My transactions, (iii) refuse to execute any of My transactions, or (iv)
terminate My Account. The closing of My Account will not affect the rights or obligations of either party
incurred prior to the date My Account is closed.
Further, Robinhood will not tolerate any foul or abusive language, physical violence, threatening behavior,
or other inappropriate conduct directed toward Robinhood, its Affiliates' officers, employees, contractors
or customers. If I engage in any such behavior, as determined by Robinhood in its sole discretion, I
agree that Robinhood is authorized to: (i) liquidate any securities, instruments or other property in My
Account, (ii) send Me the proceeds, and (iii) close My account. Robinhood will not be responsible for any
Losses caused by the liquidation of securities, instruments or other property pursuant to this paragraph,
including any tax liabilities.
17. Waiver; Limitation of Liability; Indemnification.
I agree that My use of the App or the Website or any other service provided by Robinhood Financial or
its Affiliates is at My sole risk. The Robinhood Financial service (including the App, the Website, the
provision of Market Data, Information, Content, or any other information provided by Robinhood
Financial, any of its Affiliates, or any third-party content provider or market data provider) is provided on
an "as is," "as available" basis without warranties of any kind, either express or implied, statutory
(including without limitation, timeliness, truthfulness, sequence, completeness, accuracy, freedom from
interruption), implied warranties arising from trade usage, course of dealing, course of performance, or
the implied warranties of merchantability or fitness for a particular purpose or application, other than
those warranties which are implied by and incapable of exclusion, restriction or modification under the
laws applicable to this Agreement.
Although considerable effort is expended to make the Website, App and other operational and
communications channels available around the clock, Robinhood does not warrant that these channels
will be available and error free every minute of the day. I agree that Robinhood will not be responsible for
temporary interruptions in service due to maintenance, Website or App changes, or failures, nor shall
Robinhood be liable for extended interruptions due to failures beyond our control, including but not limited
to the failure of interconnecting and operating systems, computer viruses, forces of nature, labor
disputes and armed conflicts.
EXCEPT AS OTHERWISE EXPRESSLY PROVIDED IN THIS AGREEMENT, I UNDERSTAND AND
AGREE THAT ROBINHOOD, ITS AFFILIATES, THEIR RESPECTIVE OFFICERS, DIRECTORS,
EMPLOYEES AND AGENTS, AND THE PROVIDERS (COLLECTIVELY THE "ROBINHOOD
PARTIES") WILL NOT BE LIABLE TO ME OR TO THIRD PARTIES UNDER ANY
CIRCUMSTANCES, OR HAVE ANY RESPONSIBILITY WHATSOEVER, FOR ANY SPECIAL,
INDIRECT, INCIDENTAL, PUNITIVE OR CONSEQUENTIAL DAMAGES (INCLUDING TRADING
LOSSES, DAMAGES, LOSS OF PROFITS, REVENUE, OR GOODWILL) THAT I MAY INCUR IN
CONNECTION WITH MY USE OF THE SERVICE PROVIDED BY ROBINHOOD OR ANY OF ITS
AFFILIATES UNDER THIS AGREEMENT (INCLUDING MY USE OF THE APP, THE WEBSITE, THE
MARKET DATA, THE INFORMATION, OR THE CONTENT), BREACH OF THIS AGREEMENT, OR
ANY TERMINATION OF THIS AGREEMENT, WHETHER SUCH LIABILITY IS ASSERTED ON THE
BASIS OF CONTRACT, TORT (INCLUDING NEGLIGENCE), OR OTHERWISE, AND WHETHER OR
NOT FORESEEABLE, EVEN IF ANY ROBINHOOD PARTY HAS BEEN ADVISED OR WAS AWARE
OF THE POSSIBILITY OF SUCH LOSS OR DAMAGES. THE ROBINHOOD PARTIES SHALL NOT
BE LIABLE BY REASON OF DELAYS OR INTERRUPTIONS OF THE SERVICE OR
TRANSMISSIONS, OR FAILURES OF PERFORMANCE OF THEIR RESPECTIVE SYSTEMS,
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REGARDLESS OF CAUSE, INCLUDING THOSE CAUSED BY GOVERNMENTAL OR
REGULATORY ACTION, THE ACTION OF ANY EXCHANGE OR OTHER SELF REGULATORY
ORGANIZATION, OR THOSE CAUSED BY SOFTWARE OR HARDWARE MALFUNCTIONS.
Except as otherwise provided by law, Robinhood or any of its affiliates or respective partners, officers,
directors, employees or agents (collectively, "Indemnified Parties") shall not be liable for any expenses,
losses, costs, damages, liabilities, demands, debts, obligations, penalties, charges, claims, causes of
action, penalties, fines and taxes of any kind or nature (including legal expenses and attorneys' fees)
(whether known or unknown, absolute or contingent, liquidated or unliquidated, direct or indirect, due or
to become due, accrued or not accrued, asserted or unasserted, related or not related to a third party
claim, or otherwise) (collectively, "Losses") by or with respect to any matters pertaining to My Account,
except to the extent that such Losses are actual Losses and are determined by a court of competent
jurisdiction or an arbitration panel in a final non-appealable judgment or order to have resulted solely from
Robinhood's or any of its affiliates' gross negligence or intentional misconduct. In addition, I agree that
the Indemnified Parties shall have no liability for, and I agree to indemnify, defend and hold harmless the
Indemnified Parties from all Losses that result from: (i) any noncompliance by Me with any of the terms
and conditions of this Agreement; (ii) any third-party actions related to My receipt and use of any
Information, Market Data, Content, market analysis, other third-party content, or other such information
obtained on the App or Website, whether authorized or unauthorized under this Agreement; (iii) any third-
party actions related to My use of the App or the Website; (iv) My or My agent's misrepresentation or
alleged misrepresentation, or act or omission; (v) Indemnified Parties following My or My agent's
directions or instructions, or failing to follow My or My agent's unlawful or unreasonable directions or
instructions; (vi) any activities or services of the Indemnified Parties in connection with My Account
(including any technology services, reporting, trading, research or capital introduction services); or (vii)
the failure by any person not controlled by the Indemnified Parties and their affiliates to perform any
obligations to Me. Further, if I authorize or allow third parties to gain access to Robinhood's services,
including My Accounts, I will indemnify, defend and hold harmless the Indemnified Parties against any
Losses arising out of claims or suits by such third parties based upon or relating to such access and
use. Robinhood does not warrant against loss of use or any direct, indirect or consequential damages or
Losses to Me caused by My assent, expressed or implied, to a third party accessing My Account or
information, including access provided through any other third party systems or sites.
I consent to the use of automated systems or service bureaus by Robinhood and its respective affiliates
in conjunction with My Account, including automated order entry and execution, record keeping, reporting
and account reconciliation and risk management systems (collectively "Automated Systems"). I
understand that the use of Automated Systems entails risks, such as interruption or delays of service,
errors or omissions in the information provided, system failure and errors in the design or functioning of
such Automated Systems (collectively, a "System Failure") that could cause substantial damage,
expense, or liability to Me. I understand and agree that Indemnified Parties will have no liability
whatsoever for any of my Losses arising out of or relating to a System Failure.
I also agree that Indemnified Parties will have no responsibility or liability to Me in connection with the
performance or non-performance by any exchange, clearing organization, market data provider, or other
third party (including other broker-dealers and clearing firms, and banks) or any of their respective agents
or affiliates, of its or their obligations relative to any securities. I agree that Indemnified Parties will have
no liability, to Me or to third parties, or responsibility whatsoever for: (i) any Losses resulting from a
cause over which Indemnified Parties do not have direct control, including the failure of mechanical
equipment, unauthorized access, theft, operator errors, government restrictions, force majeure (as
defined in this Agreement), market data availability or quality, exchange rulings or suspension of trading;
and (ii) any special, indirect, incidental, consequential, punitive or exemplary damages (including lost
profits, trading losses and damages) that I may incur in connection with My use of the App, the Website,
Robinhood's brokerage, and other services provided by Indemnified Parties under this Agreement.
18. Mutual Fund Transactions.
In the event that I purchase or hold a mutual fund, I agree to read and understand the terms of its
prospectus. I understand that certain mutual funds reserve the right to change their purchasing,
switching or redemption procedures or suspend or postpone redemptions under certain market
conditions. I further understand that any mutual fund order entered with Robinhood is placed by
Robinhood on a best efforts basis as prescribed and recognized by the individual fund, and that
Robinhood is not responsible for unexecuted orders due to the failure of any communication system. I
agree to be fully responsible for the information contained within the mutual fund prospectus and to hold
Robinhood, its Affiliates, and Robinhood and its Affiliates' respective officers and employees harmless
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for any deficiencies contained therein. I authorize Robinhood to act as My agent in the purchase and
redemption of fund shares.
19. Exchange Traded Funds.
I understand that I should consider the investment objectives and unique risk profile of Exchange Traded
Funds ("ETFs") carefully before investing, and that ETFs are subject to risks similar to those of other
diversified portfolios. I further understand that leveraged and inverse ETFs may not be suitable for all
investors and may increase exposure to volatility through the use of leverage, short sales of securities,
derivatives, and other complex investment strategies, and that although ETFs are designed to provide
investment results that generally correspond to the performance of their respective underlying indices,
they may not be able to exactly replicate the performance of the indices because of expenses and other
factors. I further understand that ETFs are required to distribute portfolio gains to shareholders at year
end, which may be generated by portfolio rebalancing or the need to meet diversification requirements,
and that ETF trading will also generate tax consequences. I understand that I can obtain prospectuses
from issuers or their third party agents who distribute and make prospectuses available for review.
Additional regulatory guidance on ETFs can be found here.
20. Effect of Attachment or Sequestration of Accounts.
Robinhood shall not be liable for refusing to obey any orders given by or for Me with respect to any of
My Accounts that has or have been subject to an attachment or sequestration in any legal proceeding
against Me, and Robinhood shall be under no obligation to contest the validity of any such attachment or
sequestration.
21. Event of Death.
It is agreed that in the event of My death, the representative of My estate or the survivor or survivors
shall immediately give Robinhood written notice thereof, and Robinhood may, before or after receiving
such notice, take such proceedings, require such papers and inheritance or estate tax waivers, retain
such portion of, or restrict transactions in the Account as Robinhood may deem advisable to protect
Robinhood against any tax, liability, penalty or loss under any present or future laws or otherwise.
Notwithstanding the above, in the event of My death, all open orders shall be canceled, but Robinhood
shall not be responsible for any action taken on such orders prior to the actual receipt of notice of death.
Further, Robinhood may in Its discretion close out any or all of the Accounts without awaiting the
appointment of a personal representative for My estate and without demand upon or notice to any such
personal representative. The estate of any of the Account holders who have died shall be liable and each
survivor shall continue to be liable, jointly and severally, to Robinhood for any net debit balance or loss in
said account in any way resulting from the completion of transactions initiated prior to the receipt by
Robinhood of the written notice of the death of the decedent or incurred in the liquidation of the Account
or the adjustment of the interests of the respective parties, and for all other obligations pursuant to this
Agreement. Such notice shall not affect Robinhood's rights under this Agreement to take any action that
Robinhood could have taken if I had not died.
22. Tax Reporting; Tax Withholding.
The proceeds of sale transactions and dividends paid will be reported to the Internal Revenue Service
("IRS") in accordance with applicable law.
A. U.S. Persons.
This subsection is applicable if I am a U.S. person. Under penalties of perjury, I certify that the taxpayer
identification number that I have provided or will provide to Robinhood (including any taxpayer
identification number on any Form W-9 that I have provided or will provide to Robinhood) is My correct
taxpayer identification number. I certify that I am not subject to backup withholding and I am a United
States Person (including a U.S. resident alien) as such term is defined in section 7701(a)(30) of the
Internal Revenue Code of 1986, as amended ("U.S. Person"). If a correct Taxpayer Identification
Number is not provided Robinhood Financial, I understand I may be subject to backup withholding tax at
the appropriate rate on all dividends, interest and gross proceeds paid to me. Backup withholding taxes
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are sent to the IRS and cannot be refunded by Robinhood Financial. I further understand that if I waive
tax withholding and fail to pay sufficient estimated taxes to the IRS, I may be subject to tax penalties.
B. Non-U.S. Persons.
This subsection is applicable if I am not a U.S. Person. I certify that I fully understand all the information
on any Form W-8BEN that I have submitted or will submit to Robinhood. Under penalties of perjury, I
declare that (i) I have examined all the information (including all the information in the English language)
on any Form W-8BEN that I have submitted or will submit to Robinhood and (ii) to the best of My
knowledge and belief all such information is true, correct, and complete. I authorize Robinhood to
provide any such Form W-8BEN to Robinhood Securities or any withholding agent that has control,
receipt, or custody of the income of which I am the beneficial owner or any withholding agent that can
disburse or make payments of the income of which I am the beneficial owner. I agree that I will submit a
new Form W-8BEN to Robinhood within 30 calendar days if any certification made on any previously
submitted Form W-8BEN becomes incorrect. I understand that the IRS does not require My consent to
any provisions of such Form W-8BEN other than the certifications required to establish My status as a
non-U.S. Person and, if applicable, obtain a reduced rate of withholding.
23. Equity Orders and Payment For Order Flow.
SEC rules require all registered broker-dealers to disclose their policies regarding any "payment for order
flow" arrangement in connection with the routing of customer orders. "Payment for order flow" includes,
among other things, any monetary payment, service, property, or other benefit that results in
remuneration, compensation, or consideration to a broker-dealer from any broker-dealer in return for
directing orders. I understand that Robinhood transmits customer orders for execution to various
exchanges or market centers based on a number of factors. These include: size of order, trading
characteristics of the security, favorable execution prices (including the opportunity for price
improvement), access to reliable market data, availability of efficient automated transaction processing
and reduced execution costs through price concessions from the market centers. I further understand
that certain of the exchanges or market centers may execute orders at prices superior to the publicly
quoted market in accordance with their rules or practices and that while a customer may specify that an
order be directed to a particular market center for execution, the order-routing policies, taking into
consideration all of the factors listed above, are designed to result in favorable transaction processing for
customers. The nature and source of any payments or credits received by Robinhood in connection with
any specific transactions will be furnished upon written request.
24. Free Credit Balances and Sweep Service.
If I enroll in Robinhood Financial Cash Management ("Cash Management"), I understand that I am
electing to participate in the Insured Network Deposit ("IND") sweep service (the "Sweep Service").
Under the Sweep Service, free credit balances in My Account will be deposited into interest-bearing
accounts at one or more banks ("Participating Depository Institutions"), in accordance with the Insured
Network Deposit Sweep Program Disclosures ("IND Disclosures") available on the Website and in the
App. By enrolling in Cash Management, I represent and warrant that I have reviewed the IND
Disclosures and agree to the terms set forth in the IND Disclosures. If I am not enrolled in Cash
Management, free credit balances in My Account will remain in My Account, will not earn interest and
will not be eligible for FDIC insurance, but will be eligible for SIPC protection as described in the IND
Disclosures.
25. Fees and Charges.
I understand that Robinhood does not charge fees or commissions for executing buy and sell orders.
However, I understand that other fees may apply. The current fees are included in the fee schedule
available in the App and on the Website. I agree to pay any such fees at the then-prevailing rate. I
acknowledge that the prevailing fees may change and that change may occur without notice. I agree to
be bound by such changes once they are posted in the fee schedule available in the App and on the
Website. I also agree to pay all applicable federal, state, local, and foreign taxes. I authorize Robinhood
Financial to automatically debit My Account for any such fees and taxes. I also agree to pay such
expenses incurred by Robinhood in connection with collection of any unpaid balance due on My
Accounts including attorney's fees allowed by law.
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26. ACH Transactions.
A. Debit Transactions.
Robinhood will initiate an ACH debit at My request to debit funds from an account that I own at another
financial institution ("External Account") for deposit into My Account. I understand that in order for
Robinhood to initiate an ACH debit, the financial institution holding my External Account must participate
in the ACH system. I understand that for the ACH transfers to be established, at least one common
name must match exactly between My Account and My External Account. I authorize Robinhood to take
such steps as it deems appropriate to verify my ownership of External Account, including by telling the
bank at which such External Account is held that I have authorized and consented to such bank
disclosing to Robinhood any information that Robinhood may request about Me or My External Account.
I also agree to cooperate with Robinhood's verification of my ownership of such External Account by
promptly providing any identification and/or other documentation that Robinhood may request regarding
such External Account. I represent and warrant that there are sufficient funds in My External Account to
cover the amount of the deposit to My Account. Robinhood will initiate the ACH debit to My External
Account on the Business Day or next Business Day after I request the transfer. A transfer request will be
deemed to have been made on a Business Day if it is received by Robinhood by 7:00 p.m. (Eastern
Time) on such Business Day; if received after that time, the transfer request will be deemed to have
been made on the next Business Day.
Within 60 days of the date of My ACH deposit, My funds may only be withdrawn to the External Account
from which such funds were debited.
I understand that an ACH debit transfer may be reversed or rejected if: (A) there are insufficient funds in
My External Account; (B) there is a duplicate transaction; (C) the transaction is denied by the bank
holding My External Account; or (D) My External Account does not support ACH transfers. I
acknowledge that in the event of an ACH reversal, I will incur a fee. Before initiating making an ACH
debit transfer, I agree to check Robinhood Financial's most recent Commissions and Fees Schedule. I
agree that I am solely liable and responsible for any ACH reversal fees that I incur.
B. Credit Transactions.
Robinhood will initiate an ACH credit at My request to transfer funds from My Account to a recipient that
I designate. I agree that I will have sufficient Available Funds in My Account to cover the amount of any
ACH credit that I ask Robinhood to initiate. Robinhood will debit the amount of such request from My
Account on the Business Day or next Business Day after I request the transfer. A transfer request will be
deemed to have been made on a Business Day if it is received by Robinhood on such Business Day; if
received after that time, the transfer request will be deemed to have been made on the next Business
Day.
I agree that Robinhood may use any means which Robinhood, in its sole discretion, considers suitable
to execute my ACH credit transfers.
27. Fractional Shares.
I acknowledge and understand that Robinhood rounds all holdings of fractional shares to the sixth
decimal place, the value of fractional shares to the nearest cent, and any dividends paid on fractional
shares to the nearest cent. I further understand that Robinhood will not accept dollar-based purchases or
sales of less than $1.00 and that I will receive proceeds from the sale of any whole or fractional shares
rounded to the nearest cent.
I understand that if I enter repeated fractional orders with individual notional values of less than $0.01,
my account may be restricted.
I understand that a vendor employed by Robinhood will aggregate any proxy votes for fractional shares
of Robinhood’s customers with all votes reported to the issuer or issuer’s designated vote tabulator and
that, while Robinhood’s vendor will report such proxy votes on fractional shares, the issuer or tabulator
may not fully count such votes.
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I understand that Robinhood will execute all orders that include fractional shares ("Fractional Orders") on
a principal basis. To the extent that Robinhood must purchase or sell shares in the market to fulfill any
part of my Fractional Order, the fractional component of that order will be fulfilled at the execution price
Robinhood received for the corresponding whole shares. To the extent that Robinhood fulfills my
Fractional Order for national exchange-listed securities ("NMS Securities") entirely out of its inventory
and without purchasing or selling shares in the market ("Inventory Fulfillment"), Robinhood will endeavor
to price such shares or fractional shares at a price between the National Best Bid and Offer (“NBBO”) at
the time of the order for orders made during market hours, or, for such orders made during extended
hours trading (9:00-9:30 a.m. and 4:00-6:00 p.m. Eastern), Robinhood will endeavor to price such orders
between the best bid and offer at the time of the order, as reported by an external vendor ("Vendor
BBO"). For Inventory Fulfillment of Fractional Orders for securities not listed on a national exchange
("Non-NMS Securities") made during market hours as well as extended hours trading, Robinhood will
endeavor to price such orders between Vendor BBO.
All non-market orders placed outside market hours and extended hours trading are queued and fulfilled
either at or near the beginning of extended hours trading (9:00 a.m. Eastern) or at or near market open
(9:30 a.m. Eastern), according to my instructions. All market orders placed outside market hours and
extended hours trading are queued and fulfilled at or near market open. To the extent that I trade outside
of market hours, these trades are subject to Robinhood’s Extended Hours Trading Disclosure.
I understand Robinhood only accepts market orders for fractional shares at this time and does not permit
limit orders for fractional shares. I understand that fractional shares within My Account (i) are
unrecognized, unmarketable, and illiquid outside the Robinhood platform, (ii) are not transferrable in-kind,
and (iii) may only be liquidated and the proceeds transferred out via a wire transfer. I acknowledge that,
subject to applicable requirements, Robinhood may report holdings and transactions in My Account in
terms of either U.S. Dollars, shares, or both.
I agree that my fractional share holdings shall be treated as a "financial asset" under Article 8 of the
Uniform Commercial Code.
28. Phone Calls.
You agree that, by providing information Robinhood requests, Robinhood and its third party services
providers may contact you via mail, phone or email.
Specifically, if you provide us with a phone number: (a) you represent and warrant that the number you
provide is your phone number, and you will promptly notify us if that changes, and (b) you consent to
receive calls (including text messages) made to that phone number that may be prerecroded and/or
completed with an automatic telephone dialing system (automated calls) for purposes including but not
limited to providing account-related communications (including security alerts), investigating or
preventing fraud, and/or collecting amounts owed to Robinhood. We may share your number with third
parties that provide services to us in connection with any of the foregoing purposes, including but not
limited to debt collectors. You understand that message, telephone minute and data rates may apply for
calls made to a mobile phone number. You may opt out at any time from receiving these types of calls
orally or in writing to limitsharing@robinhood.com. Please note, even if you opt out, we may still make
other calls as permitted by law.
You consent to our recording of phone calls, including calls we make to you or that we receive from you.
29. Dividend Reinvestment Program.
Except as expressly stated otherwise, the provisions of this Section 29 will only apply if I am enrolled in
Robinhood’s Dividend Reinvestment Program (“DRIP”). My enrollment in the DRIP will be activated
within three business days after I notify Robinhood of my intention to enroll an eligible security through
the App. “Eligible security” means all shares available for fractional investing through Robinhood. I
understand that in order to be eligible for dividend reinvestment, the securities must be held in My
Account.
I may specify individual securities or have all Eligible securities in My Account enrolled for dividend
reinvestment. If I choose to reinvest dividends from all Eligible securities, I understand that individual
securities could subsequently no longer be Eligible securities at Robinhood’s discretion or under
applicable law. In those cases, only those securities will be discontinued from the DRIP. If I specify
individual securities, I may add additional Eligible securities to the DRIP at any time if I hold a position
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in those securities. Enrollment with respect to these additional Eligible securities will be effective within
three business days after Robinhood receives notification from me through the App. If I maintain open
orders for securities I do not already hold, I may not enroll those securities for dividend reinvestment
until my open orders are executed. If my entire Account is set up for dividend reinvestment, any eligible
securities I purchase in the future will automatically participate in the DRIP.
All eligible cash distributions will be reinvested on all securities I have selected in the DRIP, provided
that I owned the securities on the record date for determining shareholders eligible to receive dividends,
and continue to hold the securities through payable date. “Eligible cash distributions” means most cash
distributions, including regular and optional dividends, cash-in-lieu payments, and capital gains
distributions. Special dividends, late ex-date, liquidation, and miscellaneous payments may not be
eligible distributions. Optional dividends will be processed in accordance with dividend reinvestment
instructions. If I have a margin account, Robinhood is permitted to borrow a dividend paying stock in the
normal course of business and, as a result, in such situations instead of a dividend payment I may
receive a cash in lieu payment. If I receive a cash in lieu payment, I authorize Robinhood to treat such
payment as if it was not “in lieu” and reinvest it accordingly.
Robinhood will credit My Account upon completion of the dividend reinvestment. Robinhood will reinvest
dividends on the business day following receipt of funds. In the rare instance in which Robinhood is
unable to reinvest all dividends on the business day following receipt, it will reinvest the remaining funds
as soon as reasonably possible thereafter, which may take up to five business days. I will not have use
of the funds prior to reinvestment.
I understand that my participation in the DRIP is voluntary and that Robinhood has not made any
recommendation that I should participate. I further understand that Robinhood is not recommending or
offering any advice regarding the purchase of any security included as an Eligible security in the DRIP. I
further understand that dividend reinvestment does not assure profits on my investments, nor does it
protect against losses in declining markets.
I may terminate my participation in the DRIP, or the enrollment of individual securities in the DRIP, at
any time by giving notice through the App. Termination will take effect prior to the next Eligible cash
distribution provided my notice to terminate was received at least three business days prior to the record
date of that distribution. I understand that my notice to terminate my participation in the DRIP will not
affect any obligations that may result from transactions initiated prior to Robinhood’s receipt and
processing of my notice.
If I participate in the DRIP, I understand Robinhood will reinvest the dividends of a particular stock at or
near the opening price on the trading day following receipt of the dividend. Robinhood will combine
Eligible cash distributions from My Account with those from other Robinhood clients requesting dividend
reinvestment in the same security and use these combined funds to purchase securities on my behalf
and on behalf of these other clients. If the combined reinvested funds do not total the purchase price of
at least one share, the distribution will be invested in fractional shares. On that same day, Robinhood will
credit My Account with that number of shares, including fractional shares, equal to my Eligible cash
distribution divided by the purchase price per share. Robinhood does not intend to charge a fee for
transactions executed pursuant to the DRIP.
Dividend reinvestment may result in my owning interests in fractional shares of a security. I will be
entitled to receive future dividend payments on my fractional shares, although other corporate actions
may result in allocation of only whole shares and cash in lieu of fractions as determined by the issuer. In
mandatory corporate reorganizations, my partial interest will be handled according to the specific terms
of the reorganization. In voluntary corporate reorganizations, Robinhood will act on my instructions with
respect only to my whole shares.
Because fractional share positions cannot be transferred, reorganized, or issued in certificate form, my
partial interest will be liquidated, without commission charges to me, at prevailing market prices in the
event My Account is transferred or closed, the stock is reorganized, or stock certificates are ordered out
of My Account. The timing of such liquidations will be at the discretion of Robinhood.
Reinvestment of dividends may result in my owning a fractional share position in securities that are
callable in part. In the event of a call, fractional shares to be called will be determined through a random
selection process. The probability of my fractional share holdings being called will be proportional to the
holdings of all Robinhood clients who own a fractional share position in that security. Prior to the
publication date of such a call, I have the right to withdraw from My Account cash in lieu of my uncalled,
fully paid partial holdings. Once a call is announced, however, all shares, whether registered or held in
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street name, participate in the random selection process. If my fractional shares are selected and I no
longer hold the shares that I held on the publication date of the call, I will be responsible for covering
those shares.
30. Cash Management Services.
Except as expressly stated otherwise, the provisions of this Section 30 will only apply if I am enrolled in
Cash Management.
A. General.
I understand and agree that by enrolling in Cash Management, I may apply for a Robinhood-branded
debit card issued by the bank identiﬁed in My Robinhood Debit Card Agreement ("Card"). I further
understand and agree that by using My Card, exercising My electronic fund transfer ("EFT") privileges
offered in connection with My Account, and/or by successfully completing a request using Pay by
Check, I authorize Robinhood to debit My Account immediately whenever an electronic draft or Card
transaction is presented for payment on My behalf, when an EFT transaction is effected, when a Pay by
Check request is successfully completed on My Account and/or when any fee or charge is due
(collectively "Payment" or “Payments”). I further understand and agree that when I request a Payment or
withdrawal or instruct Robinhood to make a purchase of securities from My Account, Robinhood is
authorized to place a block on the amount of the transaction ("Blocked Amounts") prior to the settlement
date of the Payment, withdrawal or trade, and that the Blocked Amounts will not be available for use for
additional Payments or the purchase of securities. I agree to maintain Available Funds sufﬁcient to pay
for Payments made by Me or any Authorized Card User (as deﬁned below) and to pay for any securities
trades and for interest on any margin loans and other transaction fees. For this purpose, "Available
Funds" in My Account will ﬂuctuate daily and means the sum of (i) free credit balances, (ii) deposits to
Participating Depository Institutions through the Sweep Service, and (iii) available margin loan value if
My Account has margin privileges, minus (x) uncleared funds, (y) Blocked Amounts, and (z) deposits
subject to a hold. The loan value of eligible securities for the purpose of margin is subject to regulatory
requirements and Robinhood credit policies then in effect.
B. Payments and Withdrawals.
I agree that any Payments that I make from My Account will be lawful. I agree that Payments will be
deducted from the Available Funds in My Account in the following order: ﬁrst, from free credit balances;
second, by withdrawal of funds deposited to Participating Depository Institutions as part of the Sweep
Service; and third, if My Account has margin privileges, from margin loans on the eligible securities in
My margin Account. Robinhood will debit My Account only up to an amount equal to the Available Funds.
I understand and agree that (i) if there are insufﬁcient Available Funds in My Account to cover Payments
when they become due, Robinhood has no obligation to make such Payments, and (ii) Robinhood has
no obligation to make partial Payments. Robinhood will not charge a fee with respect to any declined
Payment for which there were insufﬁcient Available Funds. I acknowledge and agree, however, that
Robinhood will not be responsible for any costs or losses that I may incur (including fees, costs,
charges, attorneys' fees, investment losses, claims, demands, or liability resulting from any litigation or
other actions) as a result of Robinhood's decision to decline any Payment or withdrawal or other
transaction because My Account has insufﬁcient Available Funds.
I understand that if a Payment is funded by a margin loan, I will incur interest until the margin loan is
repaid.
I agree that if my Available Funds at any time falls below zero, Robinhood may suspend my ability to
make Payments and terminate My Card. If this occurs, I agree to immediately pay all amounts owed to
Robinhood, including any purchases on My Card which will be immediately charged to My Account.
I acknowledge and agree that Robinhood reserves the right to decline any Payments at any time for any
reason with or without notice to Me. If Robinhood decides to take such action, I understand and agree
that I am responsible for any pending debits, which will be processed and deducted from My Account.
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I understand that transactions will post to My Account in any order determined by Robinhood and that
Robinhood may change that order without prior notice to Me. Robinhood will comply with requirements of
applicable law regarding the order of posting transactions.
C. Limitation of Liability.
I agree that, subject to any limitations imposed by applicable law, and except as otherwise set forth in
this Agreement or in the disclosures contained in the Robinhood Debit Card Agreement, which has been
provided to Me or made available to me in connection with the opening of My Account, Robinhood,
Robinhood’s agents, any processing bank, and the Card issuer will not be liable for any loss I incur in
connection with My Account and any Payments or other features of My Account unless Robinhood is
grossly negligent in fulﬁlling this Agreement. In no event will Robinhood, Robinhood’s agents, any
processing bank, and the Card issuer shall not be liable for consequential, special or indirect damages or
losses unless applicable law requires otherwise. I also agree that liability regarding online services or
use of the App is further limited by the Robinhood Terms and Conditions, available at https://
about.robinhood.com/legal/. To the extent I utilize online services or the App I acknowledge that I am
bound by such Robinhood Terms and Conditions.
D. Debit Cards.
I understand and agree that My use of the Card is subject to the terms, conditions and disclosures set
forth in the Robinhood Debit Card Agreement, which has been provided to Me in connection with the
opening of My Account and which I may access on the Website.
I understand and agree that I cannot request a Card for another person to use. I agree, however, that if I
permit another person to have access to use My Card or Card number (an "Authorized Card User"), I am
authorizing all Card transactions by such person and I agree that there are no limits to my authorization.
I accept all liability with respect to the Card transactions effected by Me and any Authorized Card Users.
I further agree that I may terminate the authority of an Authorized Card User only by contacting
help@robinhood.com, to cancel my Card. I agree that the cancellation of My Card is effective only after
Robinhood has a reasonable period to act on My notice.
If My Card is cancelled, I agree to destroy, or if requested by Robinhood, return the Card to Robinhood. I
acknowledge that I will be responsible for any Card transactions that are processed because of My
failure to destroy or return the Card following cancellation.
If My Account includes margin privileges, I agree that transactions that exceed My free credit balances
and deposits in the Sweep Service may result in margin credit being extended to My Account, for which
I will be charged interest. I agree to review the Margin Disclosure Statement, which is available at
https://about.robinhood.com/legal/.
E. Deposits.
The provisions in this Section 30.E shall apply to My Account whether or not I am enrolled in Cash
Management.
General; Holds. I acknowledge and agree that funds that I deposit to My Account may be subject to one
or more hold periods, which are described in the RHF Funds Availability schedule available at https://
about.robinhood.com/legal/. I understand and agree that Robinhood reserves the right to modify the RHF
Funds Availability schedule at any time by posting an updated schedule at https://about.robinhood.com/
legal/, or otherwise providing notice to me. During the applicable hold period, My funds will not be
available for Payments, withdrawal, or the settling of securities transactions, in each case as described
in the RHF Funds Availability schedule. I further understand and agree that Robinhood reserves the right
to further delay making deposited funds available for periods longer than the hold periods specified in the
RHF Funds Availability schedule to the extent Robinhood determines that additional time is needed to
verify information about the item deposited or the sender or if Robinhood otherwise believes there is a
risk of fraud or other unlawful activity with respect to My Account.
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Mistaken Deposits. If funds are deposited or transferred into My Account by mistake or otherwise, I
agree that Robinhood may correct the situation and deduct any interest paid by Participating Depository
Institutions, if applicable, without prior notice to Me.
Returned Funds. I acknowledge and agree that I am responsible for returned transactions. If I have
funds transferred into My Account and that transfer is returned for any reason, Robinhood may charge
the transfer and interest paid by Participating Depository Institutions, if applicable, against My Account,
without prior notice to Me.
F. Electronic Fund Transfers.
The provisions in this Section 30.F relating to EFTs other than Card transactions shall apply to My
Account whether or not I am enrolled in Cash Management.
I understand that My Account may be eligible for a variety of EFTs, which may be subject to separate
agreements, terms and conditions. These services may include use of the Card, and the "Move Money"
functionality of the App. I understand that I may be required to agree to separate terms and conditions
governing the particular service I use to initiate EFTs. In addition, I understand and agree that my use of
EFT services are subject to the disclosures set forth in Appendix A (Electronic Fund Transfer
Disclosures), and acknowledge that I have received and reviewed such disclosures.
G. Security.
I agree to protect My Card, and My PINs, from access by anyone not authorized by Me to use them. I
acknowledge that I will be liable for all Card and online transactions conducted by anyone to whom I
have given access or who has obtained access even if not authorized by Me, up to applicable legal
limits. I understand that I am responsible for reviewing My Account statement promptly to discover and
report unauthorized activity, including use of My Card, Card number or PIN. I agree to notify Robinhood
as provided in Appendix A (Electronic Fund Transfer Disclosures) if I believe or have reason to believe
that there has been unauthorized activity in My Account or that My Card, Card number or PIN has been
lost, stolen or may be used by an unauthorized person. Unless limited by law or as otherwise set forth in
this Agreement or in the disclosures contained in Robinhood Debit Card Agreement, which is provided to
Me as part of the Account opening process and is available on the Website, I agree that I will be
responsible for losses that arise from My failure to (i) safeguard My Card and PINs, (ii) review My
monthly statement for possible unauthorized activity and (iii) report any unauthorized activity to
Robinhood as provided herein or in the Robinhood Debit Card Agreement.
H. No Illegal Purpose.
I agree and understand that I may not use my debit card or any Payments on My Account for any illegal
purpose. I agree and understand that Robinhood may, in its discretion, deny any transactions that appear
to be made for an illegal purpose.
I. Pay by Check.
I agree and understand that if I try to stop payment on a check after it has been mailed to the payee,
Robinhood will attempt to but cannot guarantee that payment on the check will be stopped. I understand
that a stop payment order on a check is valid for six months. I understand that if I wish to renew a stop
payment on a check after the six month period, I must contact Robinhood to request another stop
payment. I agree and understand that I may still be liable to the holder of the check even if I have
requested a stop payment for the amount of the check. I agree and understand that Robinhood may
deduct My Account for the amount on the check if the stop payment request is unsuccessful.
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J. Disclosure of Information.
I agree and understand that all disclosures of My non-public personal information shall be made in
accordance with the terms of the this Agreement or the Robinhood Privacy Policy (available on the
Website at https://about.robinhood.com/legal/, as applicable. I agree that My consent to sharing non-
public personal information will remain in effect until I revoke such consent by updating My settings and
visibility, which I may do at any time through the App.
In addition, I understand and agree that Robinhood may disclose information about My Account and My
related activities to third parties under the following circumstances: - As necessary to complete My
Payment transactions; - To investigate any complaint, disputed transaction, transaction inquiry or
request I make or as necessary to investigate potential fraud or misuse related to My Account; - To
respond to requests from credit bureaus, creditors or other third parties for account-related information, to
the extent such inquiries are necessary for processing My transactions or are usual and customary in
the course of servicing similar products or accounts; - As necessary to comply with any applicable law,
government or court order or subpoena; or - In accordance with My written permission or as otherwise
permitted under the Robinhood Privacy Policy.
I. Termination.
I understand that Robinhood may terminate my participation in Cash Management or in specific features
of Cash Management for any reason, upon notice to me.
31. Consent to Redeem Shares.
I understand and agree that whenever it is necessary for Robinhood's protection or to satisfy a margin
call, deficiency, debit or other obligation owed to Robinhood, Robinhood may (but is not required to) sell,
assign and deliver all or any part of the securities in My Account, or close any or all transactions in My
Account. I understand that Robinhood may, but is not obligated to, attempt to contact Me before taking
any such action. I understand and agree that Robinhood reserves the right to take any such action
without prior notice or demand for additional collateral, and free of any right of redemption, and that any
prior demand, call or notice will not be considered a waiver of our right to sell or buy without demand,
call or notice.
I further understand that Robinhood may choose which securities to buy or sell, which transactions to
close, and the sequence and timing of liquidation, and may take such actions on whatever exchange or
market and in whatever manner (including public auction or private sale) that Robinhood chooses in the
exercise of its business judgment. I agree not to hold Robinhood liable for the choice of which securities
to buy or sell or of which transactions to close or for the timing or manner of the liquidation. I also agree
not to hold Robinhood liable for taking such action.
I understand and agree that Robinhood is entitled to exercise the rights described in this section in its
sole discretion, including, but not limited to, whenever any of the following occurs:
The equity level in My Account falls below required minimums;
Sufficient funds or securities are not deposited to pay for transactions in My Account;
I reverse any ACH debit transfer to My Account;
A petition of bankruptcy or for the appointment of a receiver is filed by or against Me;
An attachment is levied against My Account;
I die or become incapacitated or incompetent; or
My Account is closed.
32. Electronic Delivery of Trade and Account Information; Notice.
All communications, notices, legal disclosures, and other materials related to My Account or this
Agreement, including account statements, trade confirmations, margin calls, notices, disclosures,
regulatory communications and other information, documents, data and records regarding My Account
(the "Communications"), or an alert that any such Communication has been posted to the secure section
of the Website or the App, and is available for viewing, may be sent to Me at the mailing address for My
Account or the e-mail address that I have given to Robinhood in My account application or at such other
•
•
•
•
•
•
•
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address as I may hereafter give Robinhood in writing or by e-mail at least ten (10) calendar days prior to
delivery, and all communications so sent, whether in writing or otherwise, shall be deemed given to Me
personally, whether actually received or not.
33. API.
A. Overview; Definitions.
Robinhood may, in Robinhood's sole discretion, provide third parties with an application programming
interface and other materials in accordance with any accompanying documentation (collectively, the "API
Package") (such third parties, "API Licensees"), to make available certain features and functionality of
Robinhood's mobile applications, websites, or technology platform via the API Licensees' products (such
products, the "Licensee Products"). The API Package and the Licensee Products are collectively
referred to as the "API Products". "Personal Information" means My personally identifiable information
(including username, logon password, financial information, trade data, and other financial information)
and all data exchanged between Robinhood and the API Products.
B. Access to My Personal Information.
Through My use of any API Products, I may be providing API Licensees with access to My Account and
Personal Information. By using any API Products, I acknowledge that such API Products may employ
security, policies, procedures and systems of API Licensees which may or may not be less stringent and
secure than Robinhood's policies, procedures and systems. I agree that My use of any API Products
shall be subject to the terms and conditions of this Agreement, in addition to any other agreements
which I executed with respect to any such API Products. I understand and agree that any end user
agreement that I executed with any API Licensee is concluded between Me and such API Licensee only,
and not with Robinhood; and such API Licensee, not Robinhood, is solely responsible for such Licensee
Product and the content thereof. I understand and agree that the API Products may deliver Personal
Information to Robinhood, and that Robinhood is authorized to receive and store such Personal
Information consistent with Robinhood's then-in-effect policies and procedures. Further, I agree that the
API Products may request Personal Information stored by Robinhood, and I consent to Robinhood's
disclosure of such Personal Information to the API Products.
C. No Recommendations.
To the extent the Licensee Products or API Licensees express opinions or make recommendations, I
understand that such opinions and recommendations are expressed solely by API Licensees and are not
the opinions or recommendations of Robinhood. The existence of the API Products and Robinhood's
consent to any connectivity between any Licensee Products and Robinhood's technology, the App, the
Website, or trading platform(s) does not constitute (i) any recommendation by Robinhood to invest in any
security or utilize any investment strategy; or (ii) any representation, warranty, or other guarantee by
Robinhood as to the present or future value or suitability of any sale, trade, or other transaction involving
any particular security or any other investments. The existence of any and all information, tools and
services provided by API Licensees or by the Licensee Products shall not constitute Robinhood's
endorsement of API Licensees or the Licensee Products.
D. Data Provided by Robinhood to API.
From time to time, and subject to then-in-effect agreements between Robinhood and API Licensees,
Robinhood may, in its own discretion, make market data feeds received from third parties available via
the API Products. Robinhood does not make any guarantees in regard to such market data feeds.
Furthermore, API Licensees or Licensee Products may make available to Me market data feeds
independent of Robinhood. I am aware that from time to time that there may be discrepancy between the
market data presented on the App or Website and information provided by any API Products due to a
variety of reasons, including the time to update and transmit such data to a mobile application or website
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and latency caused by such API Product's or My local environment (such as computer set up,
connection speed, etc.). Robinhood is not responsible for the accuracy of any market data displayed on
any API Products or otherwise made available by API Licensees.
E. Risks; No Liability.
I acknowledge that there may be latency between the time an order (or other Personal Information) is
submitted from the API Products and the time such order or Personal Information is received by
Robinhood. Latency may also affect order modification and order cancellation requests. The time an
order or a request is actually received by Robinhood (including for execution) will be the official time,
including for the purposes of routing the order to the market for execution. In addition, all orders
submitted to Robinhood are subject to order vetting by Robinhood. Orders created and submitted through
any API Products are not vetted until they are received by Robinhood. It is possible that Robinhood may
reject an order placed through any API Products. Robinhood cannot guarantee that any order will be
accepted when such order is routed to the market for execution, and Robinhood cannot guarantee that
notifications and Personal Information provided to Me by Robinhood will be successfully delivered to or
displayed by any API Products.
Without limiting the generality of any other terms in this Agreement, I agree that:
Robinhood or its Affiliates shall not be liable for any Losses as a result of any issues addressed
in this Section 33 of this Agreement, nor shall Robinhood or its Affiliates be liable for any Losses
realized for technical issues involving any API Products or API Licensee technology or product
offerings (including system outages or downtime).
Robinhood or its Affiliates shall not be responsible for any investment research provided by any
API Licensee or any Licensee Products.
Robinhood or its Affiliates makes no representations, warranties or other guarantees as to the
accuracy, timeliness or efficacy of any market data, information, or other functionality made
available by any API Licensee or any API Products.
F. Intellectual Property.
My use of any API Products will not confer to Me any title, ownership interest or intellectual property
rights that otherwise belongs to Robinhood or any of its affiliates. The API Package, including content, is
protected under U.S. patent, copyright laws, international treaties or conventions, and other laws and will
remain Robinhood's exclusive property, as applicable. Names, logos, and all related product and service
names, design marks, and slogans displayed by or relating to Robinhood or any of its Affiliates or API
Licensees in the context of the API Products shall remain the property of the respective owner, and use
of such property by Robinhood or any API Licensee in marketing or provision of any API Products does
not grant ownership of or entitle Me to use any such name or mark in any manner.
G. User's Representations and Warranties.
I represent and warrant that:
By virtue of utilizing any API Products, I consent to and accept any risk associated with
Robinhood's sharing of Personal Information with any API Licensee and shall not hold Robinhood,
its Affiliates, or their respective officers, directors, or employees responsible for any Losses
resulting from the sharing of such Personal Information.
I agree that My use of any API Products or API Licensee's content, information, technology, or
functionality is at My own risk.
I agree that Robinhood may revoke any API Licensee or API Products' authorization at any time,
for any reason, with or without cause and without prior notice to Me.
1.
2.
3.
1.
2.
3.
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34. Electronic Signatures; Modifications to the Agreement.
I agree to transact business with Robinhood electronically. By electronically signing an application for an
Account, I acknowledge and agree that such electronic signature is valid evidence of My consent to be
legally bound by this Agreement and such subsequent terms as may govern the use of Robinhood's
services. The use of an electronic version of any document fully satisfies any requirement that the
document be provided to Me in writing. I accept notice by electronic means as reasonable and proper
notice, for the purpose of any and all laws, rules and regulations. I acknowledge and agree that
Robinhood Financial may modify this Agreement from time to time and I agree to consult the Website
from time to time for the most up-to-date Agreement. The electronically stored copy of this Agreement is
considered to be the true, complete, valid, authentic and enforceable record of the Agreement,
admissible in judicial or administrative proceedings to the same extent as if the documents and records
were originally generated and maintained in printed form. I agree to not contest the admissibility or
enforceability of Robinhood Financial's electronically stored copy of the Agreement.
35. Margin Accounts.
A. Election.
This numbered section applies to my account to the extent I elect and am approved for a Robinhood
Gold margin account.
B. Margin Trading.
I understand that margin trading involves interest charges and risks, including the potential to lose more
than deposited or the need to deposit additional collateral in a falling market. Before using margin,
customers must determine whether this type of trading strategy is right for them given their specific
investment objectives, experience, risk tolerance, and financial situation. If I have elected to have a
margin Account, I represent that I have read the Margin Disclosure Statement, Day Trading Risk
Disclosure, and FINRA Investor Information. These disclosures contain information on Robinhood's
lending policies, interest charges, and the risks associated with margin accounts.
C. Hypothecation.
Within the limitations imposed by applicable laws, rules and regulations, all securities now or hereafter
held by Robinhood, or carried by Robinhood in any account for Me (either individually or jointly with
others), or deposited to secure same, may from time to time, without any notice, be carried in your
general loans and may be pledged, repledged, hypothecated or re-hypothecated, separately or in
common with other securities for the sum due to you thereon or for a greater sum and without retaining
in your possession or control for delivery a like amount of similar securities. The IRS requires Broker
Dealers to treat dividend payments on loaned securities positions as payments received in lieu of
dividends for 1099 tax reporting purposes. Taxation of substitute dividend payments may be greater than
ordinary on qualified dividends. It is understood, however, that you agree to deliver to Me upon My
demand and upon payment of the full amount due thereon, all securities in such accounts, but without
obligation to deliver the same certificates or securities deposited by Me originally. Any securities in My
margin or short account may be borrowed by you, or lent to others.
D. Interest.
Debit balances in My Accounts shall be charged with interest in accordance with your established
custom, as disclosed to Me in the Customer Information Brochure pursuant to the provisions of the
Securities Exchange Act.
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E. Margin.
I agree to maintain in all accounts with Robinhood such positions and margins as required by all
applicable statutes, rules, regulations, procedures and custom, or as you deem necessary or advisable. I
agree to promptly satisfy all margin and maintenance calls.
F. Sales.
I agree to specifically designate any order to sell a security, which I do not own as a short sale, and
understands that Robinhood will mark such order as a short sale. I agree that any order which is not
specifically designated as a short sale is a sale of securities owned by me, and that I will deliver the
securities on or before settlement date, if not already in the account. If I should fail to make such
delivery in the time required, Robinhood is authorized to borrow such securities as necessary to make
delivery for the sale, and I agree to be responsible for any loss you may thereby sustain, or which you
may sustain as a result of your inability to borrow such securities.
36. Consent to Electronic Delivery of Documents.
A. Consent.
By agreeing to electronic delivery, I am giving My informed consent to electronic delivery of all
Account Documents, as defined below, other than those I have specifically requested to be
delivered in paper form. "Account Documents" include notices, disclosures, current and future account
statements, regulatory communications (such as prospectuses, proxy solicitations, and privacy notices),
trade confirmations, tax-related documents, and any other information, documents, data, and records
regarding My Account, this Agreement (including amendments to this Agreement), and the agreements
and disclosures governing the services delivered or provided to Me by Robinhood Financial, the issuers
of the securities or other property in which I invest, and any other parties. I agree that I can access,
view, download, save, and print any Account Documents I receive via electronic delivery for My records.
B. Electronic Delivery System.
I acknowledge that Robinhood's primary methods of communication with Me include (A) posting
information on the Website, (B) providing information via the App, (C) sending email(s) to My email
address of record, and, to the extent required by law, (D) providing Me with notice(s) that will direct Me
to the App or the Website where I can read and print such information. Unless otherwise required by law,
Robinhood reserves the right to post Account Documents on the Website without providing notice to Me.
Further, Robinhood reserves the right to send Account Documents to My postal or email address of
record, or via the App or Website. I agree that all Account Documents provided to Me in any of the
foregoing manner is considered delivered to Me personally when sent or posted by Robinhood, whether I
receive it or not.
All e-mail notifications regarding Account Documents will be sent to My e-mail address of record. I agree
to maintain the e-mail address that I have provided Robinhood until I provide Robinhood with a new one.
I understand that e-mail messages may fail to transmit promptly or properly, including being delivered to
SPAM folders. I further understand that it is My sole responsibility to ensure that any emails from
Robinhood or its Affiliates are not marked as SPAM. Regardless of whether or not I receive an e-mail
notification, I agree to check the Website regularly to avoid missing any information, including time-
sensitive or otherwise important communication. If I authorize someone else to access the e-mail
account I have provided Robinhood, I agree to tell them to share the Account Documents with Me
promptly, and I accept the risk that they will see My sensitive information. I understand that if I use a
work e-mail address or computing or communications device, My employer or other employees may
have access to the Account Documents.
Additionally, I acknowledge that the Internet is not a secure network and agree that I will not send any
confidential information, including Account numbers or passwords, in any unencrypted e-mails. I also
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understand that communications transmitted over the Internet may be accessed by unauthorized or
unintended third parties and agree to hold Robinhood, its Affiliates, and Robinhood and its Affiliates'
respective officers and employees harmless for any such access regardless of the cause.
I agree to promptly and carefully review all Account Documents when they are delivered and notify
Robinhood Financial in writing within five (5) calendar days of delivery if I object to the information
provided (or other such time specified herein). If I fail to object in writing within such time, Robinhood
Financial is entitled to treat such information as accurate and conclusive. I will contact Robinhood to
report any problems with accessing the Account Documents.
C. Costs.
Potential costs associated with electronic delivery of Account Documents may include charges from
Internet access providers and telephone companies, and I agree to bear these costs. Robinhood
Financial will not charge Me additional online access fees for receiving electronic delivery of Account
Documents.
D. Archival.
Upon My request, I may obtain copies of up to six (6) prior years of account statements, and three (3)
prior years of trade confirmations.
E. Revocation of Consent.
Subject to the terms of this Agreement, I may revoke or restrict My consent to electronic delivery of
Account Documents at any time by notifying Robinhood Financial in writing of My intention to do so. I
also understand that I have the right to request paper delivery of any Account Document that the law
requires Robinhood Financial to provide Me in paper form. Robinhood Financial will not treat My request
for paper copies as a withdrawal of My consent to electronic delivery of Account Documents. I
understand that if I revoke or restrict My consent to electronic delivery of Account Documents or request
paper delivery of same, Robinhood Financial, in its sole discretion, may charge Me a reasonable service
fee for the delivery of any Account Document that would otherwise be delivered to Me electronically,
restrict or close My account, or terminate My access to Robinhood Financial's services. I understand
that neither My revocation or restriction of consent, My request for paper delivery, nor Robinhood
Financial's delivery of paper copies of Account Documents will affect the legal effectiveness or validity
of any electronic communication provided while My consent was in effect.
F. Duration of Consent.
My consent to receive electronic delivery of Account Documents will be effective immediately and will
remain in effect unless and until either I or Robinhood Financial revokes it. I understand that it may take
up to three (3) Business Days to process a revocation of consent to electronic delivery, and that I may
receive electronic notifications until such consent is processed.
G. Hardware and Software Requirements.
I understand that in order to receive electronic deliveries, I must have access to a computer or Mobile
Device with Internet access, a valid e-mail address, and the ability to download such applications as
Robinhood Financial may specify and to which I have access. I also understand that if I wish to
download, print, or save any information I wish to retain, I must have access to a printer or other device
in order to do so.
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H. Consent and Representations.
I hereby agree that I have carefully read the above information regarding informed consent to electronic
delivery and fully understand the implications thereof. Additionally, I hereby agree to all conditions
outlined above with respect to electronic delivery of any Account Document. I will maintain a valid e-mail
address and continue to have access to the Internet. If My e-mail address changes, I agree to
immediately notify Robinhood Financial of My new e-mail address in writing.
37. Miscellaneous Provisions.
The following provisions shall also govern this Agreement:
A. Contact Information.
Robinhood Customer Service may be contacted by visiting support.robinhood.com or by email at
help@robinhood.com.
B. Interpretation.
The heading of each provision hereof is for descriptive purposes only and shall not be (1) deemed to
modify or qualify any of the rights or obligations set forth herein or (2) used to construe or interpret any of
the provisions hereunder. When a reference is made in this Agreement to a Section, such reference shall
be to a Section of this Agreement unless otherwise indicated. Whenever the words "include," "includes"
or "including" are used in this Agreement, they shall be deemed to be followed by the words "without
limitation." The word "or," when used in this Agreement, has the inclusive meaning represented by the
phrase "and/or." Unless the context of this Agreement otherwise requires: (i) words using the singular or
plural number also include the plural or singular number, respectively; and (ii) the terms "hereof,"
"herein," "hereunder" and derivative or similar words refer to this entire Agreement. References to any
law shall be deemed to refer to such law as amended from time to time and to any rules or regulations
promulgated thereunder.
C. Binding Effect; Assignment.
This Agreement shall bind My heirs, assigns, executors, successors, conservators and administrators. I
may not assign this Agreement or any rights or obligations under this Agreement without first obtaining
Robinhood's prior written consent. Robinhood may assign, sell, or transfer My Account and this
Agreement, or any portion thereof, at any time, without My prior consent.
D. Severability.
If any provisions or conditions of this Agreement are or become inconsistent with any present or future
law, rule, or regulation of any applicable government, regulatory or self-regulatory agency or body, or are
deemed invalid or unenforceable by any court of competent jurisdiction, such provisions shall be deemed
rescinded or modified, to the extent permitted by applicable law, to make this Agreement in compliance
with such law, rule or regulation, or to be valid and enforceable, but in all other respects, this Agreement
shall continue in full force and effect.
E. Website Postings.
I agree and understand that Robinhood Financial may post other specific agreements, disclosures,
policies, procedures, terms, and conditions that apply to My use of the App, the Website, or My Account
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on the Website ("Website Postings"). I understand that it is My continuing obligation to understand the
terms of the Website Postings, and I agree to be bound by the Web Postings as are in effect at the time
of My use.
F. Entirety of Agreement.
This Agreement, any attachments hereto, other agreements and policies referred to in this Agreement
(including the Website Postings), and the terms and conditions contained in My Account statements and
confirmations, contain the entire agreement between Robinhood and Me and supersede all prior or
contemporaneous communications and proposals, whether electronic, oral, or written, between
Robinhood and Me, provided, however, that any and all other agreements between Robinhood and Me,
not inconsistent with this Agreement, will remain in full force and effect.
G. Amendment.
Robinhood may at any time amend this Agreement without prior notice to Me. The current version of the
Agreement will be posted on the Website and My continued Account activity after such amendment
constitutes My agreement to be bound by all then-in-effect amendments to the Agreement, regardless of
whether I have actually reviewed them. Continued use of the App, the Website or any other Robinhood
Financial services after such posting will constitute My acknowledgment and acceptance of such
amendment. I agree to regularly consult the Website for up-to-date information about Robinhood
Financial services and any modifications to this Agreement. Robinhood is not bound by any verbal
statements that seek to amend the Agreement.
H. Termination.
Robinhood may terminate this Agreement, or close, deactivate, or block access to My Account at any
time in its sole discretion. I will remain liable to Robinhood for all obligations incurred in My Account,
pursuant to this Agreement, or otherwise, whether arising before or after termination. I may terminate this
Agreement after paying any obligations owed upon written notice. This Agreement survives termination
of My Account.
I. No Waiver; Cumulative Nature of Rights and Remedies.
I understand that Robinhood's failure to insist at any time upon strict compliance with any term
contained in this Agreement, or any delay or failure on Robinhood's part to exercise any power or right
given to Robinhood in this Agreement, or a continued course of such conduct on Robinhood's part, shall
at no time operate as a waiver of such power or right, nor shall any single or partial exercise preclude
any other further exercise. All rights and remedies given to Robinhood in this Agreement are cumulative
and not exclusive of any other rights or remedies to which Robinhood is entitled.
J. International Customers.
The products and services described on the Website are offered only in jurisdictions where they may be
legally offered. Neither the Website nor the App shall be considered a solicitation for or offering of any
investment product or service to any person in any jurisdiction where such solicitation or offering would
be illegal. I understand that Robinhood, in its sole discretion, may accept unsolicited accounts from non-
U.S. residents, depending on the country of residence and other factors. I understand that Robinhood is
based in the United States and that Robinhood accepts only U.S. currency in Robinhood's customer
accounts.
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K. Governing Law.
This Agreement and all transactions made in My Account shall be governed by the laws of the State of
California (regardless of the choice of law rules thereof), except to the extent governed by the federal
securities laws, FINRA Rules, and the regulations, customs and usage of the exchanges or market (and
its clearing house) on which transactions are executed.
38. Arbitration.
A. This Agreement contains a pre-dispute arbitration clause. By signing an arbitration agreement,
the parties agree as follows: (1) All parties to this Agreement are giving up the right to sue each
other in court, including the right to a trial by jury, except as provided by the rules of the
arbitration forum in which a claim is filed. (2) Arbitration awards are generally final and binding; a
party's ability to have a court reverse or modify an arbitration award is very limited. (3) The ability
of the parties to obtain documents, witness statements and other discovery is generally more
limited in arbitration than in court proceedings. (4) The arbitrators do not have to explain the
reason(s) for their award unless, in an eligible case, a joint request for an explained decision has
been submitted by all parties to the panel at least 20 days prior to the first scheduled hearing
date. (5) The panel of arbitrators will typically include a minority of arbitrators who were or are
affiliated with the securities industry. (6) The rules of some arbitration forums may impose time
limits for bringing a claim in arbitration. In some cases, a claim that is ineligible for arbitration
may be brought in court. (7) The rules of the arbitration forum in which the claim is filed, and any
amendments thereto, shall be incorporated into this Agreement. B. Any controversy or claim
arising out of or relating to this Agreement, any other agreement between Me and Robinhood, any
Account(s) established hereunder, any transaction therein, shall be settled by arbitration in
accordance with the rules of FINRA Dispute Resolution, Inc. ("FINRA DR"). I agree to arbitrate
any controversy or claim before FINRA DR in the State of California. C. This agreement to
arbitrate constitutes a waiver of the right to seek a judicial forum unless such a waiver would be
void under the federal securities laws. If I am a foreign national, non-resident alien, or if I do not
reside in the United States, I agree to waive My right to file an action against Robinhood in any
foreign venue. D. No person shall bring a putative or certified class action to arbitration, nor seek
to enforce any pre-dispute arbitration agreement against any person who has initiated in court a
putative class action; or who is a member of a putative class who has not opted out of the class
with respect to any claims encompassed by the putative class action until: (1) the class
certification is denied; or (2) the class is decertified; or (3) the customer is excluded from the
class by the court. Such forbearance to enforce an agreement to arbitrate shall not constitute a
waiver of any rights under this Agreement except to the extent stated herein.
ACCEPTED AND AGREED: I acknowledge that I have read the preceding terms and conditions of this
Agreement, that I understand them and that I hereby manifest my assent to, and my agreement to
comply with, those terms and conditions by accepting this agreement. I ALSO UNDERSTAND THAT
BY ACCEPTING THIS AGREEMENT I HAVE ACKNOWLEDGED THAT THIS AGREEMENT
CONTAINS A PREDISPUTE ARBITRATION CLAUSE IN SECTION 38 HEREIN. I ALSO AGREE (1)
THAT ANY OF MY MARGIN ACCOUNT SECURITIES MAY BE BORROWED BY ROBINHOOD OR
LOANED TO OTHERS; (2) I HAVE RECEIVED OF A COPY OF THIS AGREEMENT AND (3) I HAVE
REVIEWED A COPY OF THE MARGIN DISCLOSURE STATEMENT.
Appendix A
Electronic Fund Transfer Services Disclosures
The following disclosures apply to the use of any EFT services offered by Robinhood, including the
Card, ACH transactions and the Move Money functionality of the App.
Solely for purposes of these disclosures: (i) references to the Bank shall include any financial institution
that issues the Card or provides services in connection with ACH, Move Money or other EFT
transactions; (ii) "you" and "your" mean the owner of the Account; and (iii) "we" and "us" means
Robinhood and the Bank collectively.
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1. Your Liability.
Contact Robinhood Customer Service AT ONCE if you believe your Card or PIN has been lost or stolen
or if you believe that an electronic fund transfer has been made without your permission. Telephoning is
the best way of keeping your losses down. You could lose all the Available Funds in your Account (plus
your maximum overdraft line of credit). If you tell Robinhood within 2 business days after you learn of
the loss or theft of your Card or PIN, you can lose no more than $50 if someone used your Card or PIN
without your permission.
If you do NOT tell Robinhood within 2 business days after you learn of the loss or theft of your Card or
PIN, and Robinhood can prove that it could have stopped someone from using your Card or PIN without
your permission if you had told Robinhood, you could lose as much as $500.
Also, if your statement shows transfers that you did not make, including those made by Card or using
your PIN, tell Robinhood at once. If you do not tell Robinhood within sixty (60) days after the statement
was mailed to you, or otherwise made available to you, you may not get back any money you lost after
the sixty (60) days if Robinhood can prove that Robinhood could have stopped someone from taking the
money if you had told Robinhood in time. If a good reason (such as a long trip or a hospital stay) kept
you from telling Robinhood, Robinhood will extend the time periods.
2. Contact in event of unauthorized transfer.
If you believe your Card or PIN has been lost or stolen, contact Robinhood by emailing
help@robinhood.com,.
3. Business Days.
Business Days are Monday through Friday, excluding federal holidays.
4. Transfer Types and Limitations.
You may use your Card to make purchases at any merchant that accepts Mastercard debit cards or
debit cards of other networks in which the Bank participates, and to make ATM withdrawals, in each
case subject to the Available Funds in your Account, the transaction limits described below, and the
other terms and conditions of this Agreement. You acknowledge and agree that the value available to
you for use with the Card is limited to the Available Funds in your Account. So long as you do not
exceed the Available Funds in your Account, you may use the Card to purchase goods or services
wherever the Card is honored, and to obtain cash by initiating cash withdrawal transactions through the
Card from any financial institution or ATM that accepts the Card. Each time you use the Card, you
authorize Robinhood to reduce the Available Funds in your Account by the amount of the purchase or
withdrawal and any applicable fees, costs, or holdings. Nevertheless, if you exceed the Available Funds
in your Account you shall remain fully liable to Robinhood for the amount of the transactions and any
applicable fees and charges.
You may also make ACH withdrawals from your Account, either originated through Robinhood or
originated by a third party (a "non-originated" withdrawal), subject to the Available Funds in your Account,
the transaction limits described below, and the other terms and conditions of this Agreement. You also
may make ACH deposits to your Account, either originated through Robinhood or originated by a third
party (a "non-originated" deposit), subject to the transaction limits described below.
There are limits on the dollar amount of transactions you can make with your Card each day and each
month, and limits on the amount of ACH withdrawals and deposits you can make each day. The
following lists the limits for each type of transaction:
Originated ACH Withdrawals* Daily Limit: $50,000.00
Weekly Limit: N/A Monthly Limit: N/A
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Originated ACH Deposits* Daily Limit: $50,000.00
Weekly Limit: N/A Monthly Limit: N/A
Non-Originated ACH Withdrawals* Daily Limit: $250,000.00
Weekly Limit: N/A Monthly Limit: N/A
Non-Originated ACH Deposits* Daily Limit: $250,000.00
Weekly Limit: N/A Monthly Limit: N/A
Point of Sale Purchases with the Card* Daily Limit: $5,000.00 Weekly Limit: N/A Monthly Limit:
$15,000.00
ATM Withdrawals* Daily Limit: $510.00 Weekly Limit: N/A Monthly Limit: $5,000.00
Originated ACH* Daily Limit: N/A, subject to the Weekly Limit Weekly Limit: $2,999 Monthly Limit: N/A
5. Fees.
We will not charge you any fees for use of ATMs that are part of the AllPoint or MoneyPass ATM
networks, or for point of sale transactions using the Card, or for initiating other EFTs on your behalf. If
you withdraw funds from ATMs outside of the AllPoint or MoneyPass ATM networks, you may be
separately assessed fees by those ATM owners or operators.
6. Confidentiality.
We may disclose information to third parties about you, your Card, or the transactions you make using
any of the EFT services we provide:
Where it is necessary or helpful for completing or correcting transactions and resolving claims
regarding transactions;
In order to verify the existence and condition of your Card or your Account for a third party, such
as a merchant;
In order to comply with a valid request by a government agency, a court order, or other legal or
administrative reporting requirements;
If you consent by giving us your written permission;
To our employees, auditors, affiliates, service providers, or attorneys as needed;
In order to prevent, investigate or report possible illegal activity;
In order to issue authorizations for transactions on the Card;
As permitted by applicable law; or
Otherwise as necessary to fulfill our obligations under this Agreement and the terms applicable to
the EFT service you are using.
Please see Robinhood's privacy policy, available at about.robinhood.com/legal, and the applicable
Bank's privacy policy, available at https://www.suttonbank.com/_/kcms-doc/85/49033/WK-Privacy-
Disclosure-1218.pdf, for further details. (The Robinhood privacy policy and the applicable Bank's privacy
policy are referred to collectively as the "Privacy Policies"). You hereby agree to Robinhood's and the
Bank's collection, use and sharing of information about you and the Card as provided in the Privacy
Policies, which are made a part of this Agreement. The Privacy Policies also tell you how you can (i)
limit the ways in which Bank and Robinhood share information about you, or (ii) request corrections to
the information that Bank or Robinhood maintain about you. You agree that information you provide in
connection with your Card or other EFT services you use is being provided directly to both Robinhood as
the holder of the Account associated with the service and the Bank as the Card issuer or provider of the
EFT service, as applicable.
7. Documentation.
Terminal Transfers. You can get a receipt at the time you make any transfer to or from your Account
using an ATM from the AllPoint or MoneyPass ATM networks or at the point of sale.
1.
2.
3.
4.
5.
6.
7.
8.
9.
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Preauthorized Credits. If you have arranged to have direct deposits made to your Account at least once
every 60 days from the same person or company, the person or company making the deposit will tell you
every time they send us the money. You can also check your Account online to see if a deposit has been
received.
Periodic Statements. You will get a monthly Account statement, unless there are no transfers in a
particular month. In any case you will get the statement at least quarterly. You may obtain information
about the Available Funds in your Account and a history of your Cash Management transactions on the
App.
8. Preauthorized Payments/Stop Payment Procedure and Notice of Varying
Amounts.
You do not have the right to request that Robinhood in advance make regular payments out of your
Account, although you may ask third parties to initiate regular payments out of your Account.
Right to stop payment: If you have automatic recurring payments taken out of your Account, you can
stop any of these payments by contacting us at help@robinhood.com,. You must contact us in time for
us to receive your request at least three business days before the payment is scheduled to be made.
Notice of varying amounts: If these regular payments vary in amount, the party you are going to pay will
tell you, 10 days before each payment, when the payment will be made and how much it will be. (The
party you are going to pay may allow you to choose to get this notice only when the payment would
differ by more than a certain amount from the previous payment, or when the amount would fall outside
certain limits that you set.)
Liability for failure to stop payment of a preauthorized transfer: If you order us to stop a payment at least
three business days before the transfer is scheduled and we do not do so, we will be liable for your
losses or damages.
9. Our Liability.
If we do not complete a transaction to or from your Account on time or in the correct amount according
to our Agreement with you, we will be liable for your losses or damages. However, there are some
exceptions. We will not be liable, for instance:
If through no fault of Robinhood or the Bank, you do not have enough Available Funds in your
Account to complete the transaction;
If a merchant refuses to accept your Card;
If an electronic terminal where you are making a transaction does not operate properly, and you
knew about the problem when you initiated the transaction;
If access to your Card has been blocked after you reported your Card lost or stolen;
If there is a hold or your funds are subject to legal or administrative process or other encumbrance
restricting their use;
If Robinhood or the Bank have reason to believe the requested transaction is unauthorized;
If circumstances beyond the control of Robinhood or the Bank (such as fire, flood, or computer or
communication failure) prevent the completion of the transaction, despite reasonable precautions
that Robinhood or the Bank have taken; or
For any other exception stated in this Agreement with you or by applicable law.
1.
2.
3.
4.
5.
6.
7.
8.
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10. Errors or Questions About Electronic Transfers.
In case of errors or questions about your electronic transfers, including your Card transactions, or if you
think your statement or receipt is wrong or if you need more information about a transaction listed on the
statement or receipt, contact Robinhood by emailing help@robinhood.com,. Robinhood must hear from
you no later than sixty (60) days after you were sent the FIRST statement on which the problem or error
appeared.
Tell Robinhood your name and account number.
Describe the error or the transfer you are unsure about, and explain as clearly as you can why
you believe it is an error or why you need more information.
Tell Robinhood the dollar amount of the suspected error.
Robinhood will determine whether an error occurred within ten (10) business days after Robinhood hears
from you and will correct any error promptly. If Robinhood needs more time, however, it may take up to
forty-five (45) days to investigate your complaint or question. If Robinhood decides to do this, Robinhood
will credit your Account within ten (10) business days for the amount you think is in error, so that you will
have the use of the money during the time it takes Robinhood to complete our investigation.
For errors involving new accounts, point of sale, or foreign initiated transactions, Robinhood may take up
to ninety (90) days to investigate your complaint or question. For new accounts, Robinhood may take up
to twenty (20) business days to credit your Account for the amount you think is in error.
Robinhood will tell you the results of our investigation within three (3) business days after completing the
investigation. If Robinhood decides that there was no error, Robinhood will send you a written
explanation. You may ask for copies of the documents that Robinhood used in our investigation.
1.
2.
3.
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Exhibit 2

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Revised February 22, 2023

Robinhood Financial LLC & Robinhood Securities, LLC
Customer Agreement

1.
Introduction.

This Customer Agreement (“Agreement”) sets out the terms and conditions pursuant to which
Robinhood Financial LLC, Robinhood Securities, LLC, and their agents and assigns (collectively in this
Agreement, “Robinhood”) may open and operate one or more accounts on your behalf for the purchase,
sale or carrying of securities or contracts relating thereto or the borrowing of funds (each, an “Account”),
which transactions are cleared through Robinhood Securities. In this Agreement, “Customer”, “you”, or
“your” (or similar) refer to the Account owner, and “we”, “us” or “our” (or similar) refers to Robinhood.
References to this “Agreement” include these terms and conditions as well as any other agreements or
disclosures that apply to your Account, each as amended or supplemented from time to time.

BY AGREEING TO THIS AGREEMENT AND OPENING OR USING AN ACCOUNT, YOU
EXPRESSLY AGREE TO THE TERMS OF THIS AGREEMENT AND ANY OTHER AGREEMENTS OR
TERMS INCORPORATED INTO IT. CLICKING OR TAPPING “SUBMIT APPLICATION”, “AGREE” OR
ANY SIMILAR BUTTON OR ACKNOWLEDGEMENT AS PART OF THE APPLICATION PROCESS, IS
LEGALLY EQUIVALENT TO MANUALLY SIGNING THIS AGREEMENT, AND YOU WILL BE LEGALLY
BOUND BY THIS AGREEMENT WHEN YOU CLICK OR TAP SUCH BUTTON.

THIS AGREEMENT AND ITS TERMS MAY BE SUPPLEMENTED OR AMENDED FROM TIME TO
TIME BY ROBINHOOD BY NOTICE TO YOU, AND SUCH NOTICE REQUIREMENT MAY BE
SATISFIED BY THE REVISED TERMS BEING POSTED ON THE ROBINHOOD WEBSITE, AND YOU
AGREE TO CHECK FOR UPDATES TO THIS AGREEMENT. BY CONTINUING TO MAINTAIN ANY
ACCOUNT OR ACCESS ANY SERVICES WITHOUT OBJECTING TO ANY REVISED TERMS OF
THIS AGREEMENT, YOU ARE DEEMED TO ACCEPT THE TERMS OF THE REVISED AGREEMENT
AND WILL BE LEGALLY BOUND BY ITS TERMS AND CONDITIONS. IF YOU REQUEST OTHER
SERVICES PROVIDED BY ROBINHOOD THAT REQUIRE YOU TO AGREE TO SPECIFIC TERMS AND
CONDITIONS ELECTRONICALLY (THROUGH CLICKS OR OTHER ACTIONS) OR OTHERWISE, SUCH
TERMS AND CONDITIONS WILL BE DEEMED AN AMENDMENT AND WILL BE INCORPORATED
INTO AND MADE PART OF THIS AGREEMENT. YOU ALSO UNDERSTAND THAT BY CLICKING OR
TAPPING “SUBMIT APPLICATION” YOU HAVE ACKNOWLEDGED THAT THIS AGREEMENT
CONTAINS A PREDISPUTE ARBITRATION CLAUSE IN SECTION 39 HEREIN.

THIS AGREEMENT IS A LEGAL AGREEMENT AND IT IS IMPORTANT THAT YOU CAREFULLY
READ AND UNDERSTAND ITS TERMS BEFORE AGREEING TO IT. IF YOU HAVE ANY
QUESTIONS YOU SHOULD CONTACT help@robinhood.com OR SEEK INDEPENDENT ADVICE.

By entering into this Agreement, you acknowledge receipt of the Robinhood Financial LLC Form CRS,
and you acknowledge receipt of and agree to the terms of the Robinhood Terms and Conditions, RHF
Use and Risk Disclosures, Robinhood Financial Product Features Disclosures, Day Trading Risk
Disclosure, Extended Hours Trading Disclosure, ETF Disclosure, RHF Funds Availability, RHF
Business Continuity Plan Summary, and FINRA Public Disclosure Program, which are incorporated
by reference into this Agreement. You also acknowledge receipt of the Robinhood Privacy Policy.

2.
Your Account.
2.1.
When you open or apply to open an Account to access services on the Robinhood mobile
application(s) (each, an “App”) or on the Robinhood Website (the Apps and the Website,
together with any programs, tools, features, functionality, services, transactions, and Content
provided through or in connection with the Website and the Apps, collectively, the “Platform”),
you are entering into direct contractual relationships with Robinhood Financial and Robinhood
Securities. “Website” means the robinhood.com website, and any others through which
Robinhood offers services.

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2.2.
To be eligible to open or have an Account you must be at least 18 years old, and otherwise
be legally permitted to have an Account and in compliance with the terms and conditions of this
Agreement and Applicable Law, as well as any other eligibility criteria we may implement from
time to time. “Applicable Law” includes all federal securities laws and regulations, the
applicable laws and regulations of any state or jurisdiction, the rules of any applicable self-
regulatory organization of which Robinhood is a member and rules, regulations, customs, and
usages of the exchange or market or clearing house, if any, where transactions are executed.

2.3.
Your Account is self-directed and, except as provided in Section 2.4 below, you are solely
responsible for any and all orders placed in your Account, for your investment decisions, and for
determining the suitability of any particular transaction, security, or investment strategy. You
agree that all orders entered by you (or placed on your behalf) are based on your own
investment decisions.

2.4.
You agree and understand that Robinhood or persons acting on Robinhood’s behalf does not
provide any investment advice or recommend any particular security, transaction, or order, or
other matter connected with your Account, nor will they advise you about the merits of any
action or investment decision relating to your Account or any security you hold, unless
specifically agreed upon in writing and clearly identified by Robinhood as an individualized
investment recommendation for you.

2.5.
You appoint Robinhood Financial as your agent for the purposes of carrying out your directions
and instructions to Robinhood Financial in accordance with this Agreement, including all
instructions you input or deliver via the Platform. You authorize Robinhood Financial to open or
close your Account, place and withdraw orders and take such other steps as are reasonable to
carry out your instructions or directions. You understand Robinhood Financial provides trading
and brokerage services through the Platform and you agree to receive and transmit financial
information and instructions through electronic means via the Platform.

2.6.
Robinhood Securities. Robinhood Financial has entered into a clearing agreement with
Robinhood Securities whereby Robinhood Financial will introduce your Account to Robinhood
Securities, and Robinhood Securities will clear all transactions, on a fully- disclosed basis. You
understand that Robinhood Securities carries your Account and is responsible for the clearing
and bookkeeping of transactions, but is not otherwise responsible for the conduct of Robinhood
Financial. You agree that until receipt of written notice from you to the contrary, Robinhood
Securities may accept from Robinhood Financial, without inquiry or investigation, (i) orders for
the purchase or sale of securities for your Account, (ii) any other instructions concerning your
Account or any securities or other assets in your Account, or (iii) any instructions for the
purchase of securities or other property on margin, if you have a Margin Account. Robinhood
Securities shall look solely to Robinhood Financial unless otherwise directed by Robinhood
Financial, and not to you, with respect to any such orders or instructions; except that Robinhood
Securities will deliver confirmations, statements, and all written or other notices with respect to
an Account directly to you with copies to or made available to Robinhood Financial, and that
Robinhood Securities will look directly to you or Robinhood Financial for delivery of margin,
payment, or securities. You agree to hold Robinhood Securities harmless from and against any
Losses arising in connection with the delivery or receipt of any such communication(s), provided
Robinhood Securities has acted in accordance with the above.

3.
Market Data.
We may provide or make available to you certain content, information, or data that may include information
or data relating to securities and the securities markets, including last sale transaction data, bid and asked
quotations, fundamental information, and other security information or data (collectively, “Market Data”).
We obtain Market Data from securities exchanges and markets, third party information providers, and
other third parties that distribute or transmit Market Data (collectively, “Third Party Providers”). For
certain types of Market Data, we are required to include specific terms and conditions in our agreements
with you, or procure that you enter into specific agreements, prior to you obtaining or being provided
access to that Market Data. We do this in the “Market Data Addendum” which you can find at the end of
this Agreement. Receipt and use of Market Data are subject to the terms of this Agreement as well as to
the Market Data Addendum that supplements and forms part of this Agreement, and is incorporated by
reference. By agreeing to this Agreement, opening an Account, or accessing any services from
Robinhood, you agree to the Market Data Addendum.
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If we provide or make Market Data available to you, this does not grant you any rights over or in that
Market Data except those rights (if any) expressly granted to you in the Market Data Addendum.
Market Data is provided to you solely on the basis that you represent and warrant that you are a Non-
professional (as defined in the Market Data Addendum) and that you will use any Market Data solely for
your personal non-business use.

4.
Customer Representations and Responsibilities.
4.1.
Information Accuracy.

Where you provide Robinhood with any information in any form from time to time in connection with your
Account or your application for an Account or any services, you represent and warrant that such
information is complete, true, accurate, and correct. You acknowledge that knowingly giving false
information for the purpose of inducing Robinhood to extend credit is a federal crime.

If any information that you have provided to Robinhood changes, you agree to promptly notify Robinhood
of such changes in writing within ten days. You agree that this Agreement, the account application, and
any other document you furnish in connection with your Account is Robinhood’s property.

4.2.
About You.

You represent and warrant that:
(a)
You are at least 18 years old, and you are of legal age under the laws of the jurisdiction where you
reside.
(b)
You are authorized to enter into this Agreement.
(c)
You are the sole owner of the Account. No other person has any interest in the Account opened
pursuant to this Agreement.
(d)
Except as otherwise disclosed to Robinhood in writing, neither you nor any member of your
immediate family is an employee of any exchange, any corporation of which any exchange owns a
majority of the capital stock, a member of any exchange or self-regulatory organization, a member
of any firm or member corporation registered on any exchange, a bank, trust company, insurance
company or any corporation, firm or individual engaged in the business of dealing either as a
broker-dealer or as principal in securities. You agree to promptly notify Robinhood in writing if you
or a member of your immediate family becomes registered or employed in any of the above-
described capacities.
(e)
You are not a “Securities Professional” (as defined in the Market Data Addendum), and you are
using the Account for your own personal, non-business, use.
(f)
You are not an officer, director, or 10% stockholder of any publicly traded company.

4.3.
Risks.

You acknowledge and understand that all investments involve risk, that losses may exceed the principal
invested, and that the past performance of a security, industry, sector, market, or financial product does
not guarantee future results or returns. You are solely responsible for all investment decisions
associated with your Account including any risks in connection with the purchase or sale of securities
(which includes the risk of loss).

You acknowledge and agree to the Risk Disclosures. “Risk Disclosures” means the risk disclosure
documentation available or referenced on the Website or the Disclosure Library from time to time.
“Disclosure Library” means the disclosure library available on the Website, currently at
robinhood.com/us/en/about/legal, as supplemented from time to time. As of the date of this Agreement,
Risk Disclosures include (without limitation) the RHF Use and Risk Disclosures, Robinhood Financial
Product Features Disclosures, Day Trading Risk Disclosure, Extended Hours Trading Disclosure, ETF
Disclosure, the Characteristics and Risks of Standardized Options, and the Margin Disclosure
Statement.

4.4.
Account Defaults.

Your Account comes with many defaulted service instruction features and preferences. You understand
that you are not required to use these defaulted options or preferences and that once your Account is
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approved and opened, you have the sole discretion to control and adjust such defaulted service
preferences that relate to your account.

4.5.
Knowledge of Account.

You are solely responsible for knowing the rights and terms for all securities purchased, sold and
maintained in your Account including mergers, reorganizations, stock splits, name changes or symbol
changes, dividends, option symbols, and option deliverables. Certain securities – including bonds,
convertible securities, warrants, stock rights and securities subject to exchange offers or tenders - may
grant you valuable rights that may expire unless you take specific action, and you are solely responsible
for knowing all expiration dates, redemption dates, and the circumstances under which rights associated
with your securities or Property may expire or be called, cancelled, or modified. Robinhood may, but is
not obligated to, notify you of any upcoming expiration or redemption dates, or take any action on your
behalf without specific instructions, except as required by law and the rules of regulatory authorities.

4.6.
Review of Confirmations and Statements.

You agree that it is your responsibility to review order execution confirmations and statements of your
Account promptly upon receipt. These documents will be considered binding on you unless you notify us
of an objection within two days from the date confirmations are sent or within ten days after Account
statements are sent.

Such objection may be oral or in writing, but any oral objection must be immediately confirmed in writing.
In all cases, Robinhood reserves the right to determine the validity of your objection. If you object to a
transaction for any reason, you understand and agree that you are obligated to take action to limit any
losses that may result from such transaction and that you will bear sole responsibility for any losses
relating to the transaction, even if your objection to the transaction is ultimately determined to be valid.
Nothing in this clause shall limit your other responsibilities in this Agreement.

4.7.
Orders and instructions.

Any instruction or order given for your Account, including via the Platform or using your Account
username or password, will be treated as being from you and fully authorized by you. You agree that
Robinhood shall be entitled (but not required) to act upon any oral instructions given by you so long as
Robinhood reasonably believes such instruction was actually given by you. You instruct and authorize
Robinhood to rely on such instruction or order without further inquiry, and agree that Robinhood will not
be liable for doing so.

You agree not to allow any person access to your Account, your Account username or password, or
permit any other person to give orders or instructions on your Account to Robinhood, without the prior
consent of Robinhood. If any other person has access to your Account, your Device, your Account
username or password, that is solely at your own risk. Robinhood may execute your orders on any
exchange or market.

Robinhood reserves the right to require full payment in cleared funds prior to the acceptance of any
order. You agree to pay for purchases immediately or on Robinhood’s demand. In the event that you fail
to provide sufficient funds, Robinhood may, at its option and without notice, (i) charge a reasonable rate
of interest, (ii) liquidate the Property subject of the buy order, or (iii) sell other Property owned by you and
held in your Account. Robinhood may also charge any consequential Loss to your Account. “Property”
includes all monies, securities, contracts, investments, and options, whether for present or future
delivery, and all related distributions, proceeds, products, and accessions.

4.8.
Assistance by Robinhood.

On your request, Robinhood may provide support, and you understand that when you request support,
help, or assistance from Robinhood in any form orally, electronically, or in writing (each, a
“Support Request”) in using the Platform, any of Robinhood’s services, any investment tools available
on the Platform, or any other information or thing or service provided by Robinhood, that Support
Request and assistance provided relating to it will be limited to functional or operational explanation or
assistance and, if requested by you, to the entry or correction by Robinhood or its Representatives of
information or variables provided by you, and that such assistance and any communication from
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Robinhood or its Representatives in connection with a Support Request does not constitute investment
advice, an opinion with respect to the suitability of any transaction, or solicitation of any orders.

4.9.
No Advice.

You understand that Robinhood does not provide any advice to you, and in particular Robinhood does not
provide any tax, legal, financial, or accounting advice. You are encouraged to consult your own tax advisor
or attorney.

4.10.
Discontinuation of Services.

You understand that Robinhood may discontinue your Account or any services related to your Account
immediately by providing written notice to you.

Robinhood will not tolerate any foul or abusive language, physical violence, threatening behavior, or
other inappropriate conduct directed toward Robinhood or its or its Affiliates’ officers, employees,
contractors, or customers. Any such behavior, as determined by Robinhood in its sole discretion, may
result in the discontinuation of your Account.

If Robinhood discontinues your Account or any services related to your Account, you agree that
Robinhood is authorized to (i) liquidate any Property in your Account and send you any net proceeds
(after satisfying any Obligations), and (ii) close your Account. This is without limitation to Robinhood’s
other rights under this Agreement or otherwise. “Obligations” includes all indebtedness, debit balances,
liabilities, or other obligations of any kind of you to Robinhood, whether now existing or hereafter arising.

Robinhood will not be responsible for any Losses caused by Robinhood discontinuing your Account or
any services, or any liquidation of your Property, or closure of your Account, including any tax liabilities.

4.11.
No Business Use

You may only use the Platform for your own personal, non-business, non-commercial use.

4.12.
Promotions Programs

You agree to the terms or conditions of any Robinhood promotions programs that you participate in,
including but not limited to the Robinhood Stock Referral Program. You understand that any such
promotions may have significant limitations on eligibility or rewards.

4.13.
Third Party Authorized Representatives.

You agree not to allow any person access to your Account, or your Account username or password, or
permit any other person to give orders or instructions on your Account to Robinhood, without the prior
consent of Robinhood.

Robinhood may in its sole discretion from time to time permit you to appoint your duly authorized
representative or agent to act on your behalf with respect to your Account (your “Third Party Authorized
Representative”), subject to any conditions that Robinhood may require. You are solely responsible for
any risks associated with your Third Party Authorized Representative, including any actions, decisions,
or conduct of your Third Party Authorized Representative. You instruct Robinhood to treat any order or
instruction from your Third Party Authorized Representative as if that order or instruction was directly
from you for the purposes of this Agreement, and to assume that such order and instruction is valid and
authorized without further inquiry.

Robinhood is not responsible for determining and will not determine whether any Third Party Authorized
Representative has authority to perform any actions generally or specifically with respect to your Account
or your Property, and does not determine the validity of your Third Party Authorized Representative’s
status or capacity. You will be bound by any order or instruction given by your Third Party Authorized
Representative, and irrevocably ratify any action taken by your Third Party Authorized Representative
connected with your Account.

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4.14.
Duty to Update Software.

From time to time, Robinhood will release software updates for the Apps. You understand and agree that
you are responsible for upgrading your software and maintaining the latest version of the App on your
mobile device. Failing to do so may result in you encountering content that contains out-of-date, missing
or incorrect information including, among other things, important disclosures and agreement updates.
Robinhood will not be responsible for any Losses caused by your use of outdated software.

5.
Account Security.
In order to set up and access your Account, you will be required to create or will be given security details,
including an Account username and password. You are solely responsible for monitoring and
safeguarding your Account and access to your Account. You are solely responsible for keeping your
Account username, password, your PIN, and other Account details safe, and for the safety and security
of any electronic devices through which you access your Account (which may include your phone, tablet,
computer, or any similar device) (a “Device”). “PIN” means your Card PIN number. This includes taking
all reasonable steps to avoid the loss, theft, or misuse of such Device, for instance engaging available
protections provided by your Device, such as passcodes, biometric login (such as via a fingerprint or a
face-scan), or similar, and keeping your Account username, password, PIN, and other Account details
safe and secret at all times. Any loss or compromise of your Device, your email account, your Account
username or password, your PIN, or other security details, may result in unauthorized access to your
Account by third parties.

You agree to immediately notify Robinhood immediately and in any event within 24 hours if you
become aware of: (i) any loss, theft, or unauthorized use of your Account, Account username or
password, your PIN, or your Card; (ii) any failure by you to receive any Account communication
such as confirmation of an order or a statement; (iii) any receipt by you of an Account
communication that you do not recognize such as a confirmation of an order that you did not
place; (iv) any inaccurate information in or relating to your orders, trades, margin status, Account
balances, deposits, withdrawals, securities positions or transaction history; (v) any receipt by
you of a security notification concerning your Account that notifies you of an event or action that
you do not recognize; or (vi) any other unauthorized use or access of your Account. Each of the
events described in (i)-(vi) of this clause will be a “Potential Fraudulent Event”.

Upon request by Robinhood, you agree to report any Potential Fraudulent Event promptly to legal
authorities and provide Robinhood a copy of any report prepared by such legal authorities. You agree to
cooperate fully with the legal authorities and Robinhood in any investigation of any Potential Fraudulent
Event, and to complete any required affidavits promptly, accurately, and thoroughly. You agree to allow
Robinhood access to your Device, and your network in connection with Robinhood’s investigation of any
Potential Fraudulent Event. You acknowledge that if you fail to do any of these things, you may
encounter delays in regaining access to the funds in your Account. You agree to indemnify and hold
Robinhood, its Affiliates, and their respective officers, directors, and employees harmless from and
against any Losses arising out of or relating to any Potential Fraudulent Event. You understand that,
pursuant to FINRA regulations, Robinhood is authorized to contact the
“Trusted Contact Person” (as defined by FINRA Rule 4512) designated for your Account and to
disclose information about your account to address possible financial exploitation, to confirm the
specifics of your current contact information, health status, or the identity of any legal guardian, executor,
trustee or holder of a power of attorney, or as otherwise permitted by Rule 2165.

6. Important Information About Procedures for Opening a New Account or
Maintaining an Account.

To help the government fight the funding of terrorism and money laundering activities, federal law
requires Robinhood to obtain, verify, and record information that identifies each person who opens an
account.
What this means for you: When you open or apply to open an Account, Robinhood will ask for your
name, U.S. residential address, date of birth, social security number, telephone number, citizenship, and
other identifying information that will allow Robinhood to identify you. Robinhood may also ask for copies
of your driver’s license, passport, other unexpired, government-issued identifying documents with a
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photograph, or other identifying documents. From time to time, Robinhood may ask you to confirm or
reverify your identity, or may require that you provide certain additional documents, as necessary.

You understand that Robinhood may take steps to verify the accuracy of the information you provide to
Robinhood relating to your Account in your application or otherwise. You authorize Robinhood or its
agents or third-party vendors to contact any person or firm noted therein or in any other information you
may provide to Robinhood from time to time, or any other normal sources of debit or credit information
and other similar databases, and authorize any such person or entity to furnish such information about
you as may be requested or required by Robinhood. You acknowledge that Robinhood may restrict your
access to your Account pending such verification. You will provide prompt notification to Robinhood of
any changes in the information including your name, address, e- mail address, and telephone number.

You authorize Robinhood Financial to obtain reports and provide information to others concerning your
creditworthiness and business conduct. Upon your request, Robinhood Financial agrees to provide you a
copy of any report so obtained. Robinhood may retain this Agreement, the Account application, and all
other such documents and their respective records at its sole discretion, whether or not credit is
extended.

U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) Certification. You
acknowledge that you are aware that Robinhood has OFAC sanctions compliance obligations. You also
acknowledge that this Agreement, your Account, and any sub-accounts are subject to U.S. sanctions laws,
rules, and regulations where you will not permit your Account or sub-accounts to be used in a manner that
would cause a violation of the above referenced laws, rules, and regulations. You also specifically represent
and warrant that you have not been designated by OFAC as a Specially Designated National (“SDN”), that
you have no reason to believe that you would be considered a blocked person by OFAC, and that you are
not acting as an agent of any such person. To the extent that OFAC, via laws, rules, regulations, or
Executive Order, has promulgated restrictive measures against a government or regime (“sanctioned
regime”), you further represent and warrant that you are not employed by or acting as an agent of (1) an
entity owned or controlled by a sanctioned regime, (2) a government-controlled entity of a sanctioned
regime, or (3) a government corporation of a sanctioned regime.

Further, you acknowledge and consent to Robinhood restricting your Account and/or any sub-accounts and
canceling any pending orders to the extent Robinhood believes you are accessing these from (1) a
jurisdiction that is subject to comprehensive sanctions by OFAC or (2) any jurisdiction Robinhood has made
a risk-based decision to restrict access to use of its application and website. If this happens, please contact
help@robinhood.com, and you may be asked to provide supplemental information as part of this process.
Additionally, you agree that you will notify Robinhood and close your Account and/or any subaccounts before
establishing residency in any jurisdiction subject to U.S. sanctions. Robinhood is not liable for any Losses,
including any trading losses, that you may suffer as a result of the foregoing.

Politically Exposed Person (“PEP”) Certification. You represent and warrant that you are not a PEP. To
the extent you are or become a PEP in the future while you hold your Account or any subaccounts at
Robinhood, you represent and warrant that you will immediately notify Robinhood and subject yourself to
any due diligence measures deemed appropriate by Robinhood.

A PEP is an individual who is/was or is an immediate family member (spouse, parent, sibling, children, in-
law, or dependent) or close associate (someone who is closely connected to the individual either socially or
professionally) of (1) a senior official in the executive, legislative, administrative, military, or judicial branches
of a non-U.S. government (whether elected or not); (2) a senior official of a major nonU.S. political party; (3)
a senior executive of a non-U.S. government-owned entity; or (4) a foreign individual who was or has been
entrusted with a prominent public function. A senior official or executive includes an individual with
substantial authority over policy, operations, or the use of government-owned resources.

7.
Applicable Laws and Regulations.
All transactions in your Account will be subject to all Applicable Laws. In no event will Robinhood be
obligated to effect any transaction or provide any service or take any action that it believes would or
might violate or be contrary to any applicable laws.

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8.
Erroneous Distributions
You agree to promptly return to Robinhood any assets erroneously distributed to you. In the event that
you sell a security prior to its ex-dividend/distribution date, and you receive the related cash/stock
dividend or distribution in error, you irrevocably direct Robinhood on your behalf to pay such
dividend/distribution to the entitled purchaser of the securities, and guarantee to promptly reimburse
Robinhood for, or deliver to Robinhood, said dividend or distribution.

9.
Residual Funds

In the event Your Account is cancelled, closed, or terminated for any reason and thereafter Robinhood
receives funds to be applied to your Account, Robinhood reserves the right to apply the funds to any
obligations you may have in your Account and/or transfer the funds to the balance of any active account
you may own with a Robinhood Affiliate.

10.
Market Volatility; Market Orders; Limit Orders; and Queued Orders.

You understand that, whether you place a market or limit order, you will receive the price at which your
order is executed in the marketplace, subject to any clarification stated below. Particularly during periods
of high volume, illiquidity, fast movement or volatility in the marketplace, the execution price received
may differ from the quote provided on entry of an order, and you may receive partial executions of an
order at different prices. You understand that Robinhood Financial is not liable for any price fluctuations.
You also understand that price quotes generally are for only a small number of shares as specified by
the marketplace, and larger orders are relatively more likely to receive executions at prices that vary from
the quotes or in multiple lots at different prices.

If your equity orders are subject to price collaring (and so, e.g., “Market Order” is included in the order
type menu accessible when entering orders via the Platform), you understand that (1) Robinhood
Financial collars all share-based market buy orders during the normal market trading session of 9:30
a.m. to 4:00 p.m. ET (“Market Hours”), all market buy and sell orders during the pre-market hours of
7:00 a.m. to 9:30 a.m. ET or, if trading during those hours is not yet available to all customers and you
are not yet able to do so, 9:00 a.m. to 9:30 a.m. ET (“PreMarket Hours”), and all market buy and sell
orders during the after-hours trading session of 4:00 p.m. to 8:00 p.m. ET or, if trading during those
hours is not yet available to all customers and you are not yet able to do so, 4:00 p.m. to 6:00 p.m. ET
(“After Hours” and, collectively with Pre-Market Hours, “Extended Hours”), by converting each such
order to a limit order with a limit price set at 5% away from the last reported trade price for the security on
a Nasdaq exchange (i.e., The Nasdaq Stock Market, NASDAQ OMX BX, or NASDAQ OMX PHLX) at the
time the order was entered (i.e., 5% higher than the last reported trade price on a Nasdaq exchange for
buy orders and 5% lower than the last reported trade price on a Nasdaq exchange for sell orders); (2)
during Market Hours, dollar-based market orders (whether buy or sell) and share-based market sell
orders are not collared; (3) Robinhood Financial’s collaring will vary depending on prices of instruments,
market conditions, and other factors; and (4) Robinhood Financial will use the following rounding
formulas to determine the limit price of a converted order: the last trade price for the security is (i)
multiplied by 1.05 (for buy orders) or .95 (for sell orders); and (ii) if the last trade price is over $1.00,
rounded down to two decimal places (for buy orders) or rounded up to two decimal places (for sell
orders); otherwise, rounded down to four decimal places (for buy orders) or rounded up to four decimal
places (for sell orders). You understand that securities may open for trading at prices substantially higher
or lower than the previous closing price or the anticipated price. If you place a market order (irrespective
of whether you place it during Market Hours, during Extended Hours, or when markets are closed), you
agree to pay or receive the prevailing market price at the time your market order is executed, which
execution may occur on a subsequent trading day. You understand that the price you pay or receive may
be significantly higher or lower than anticipated at the time you placed the order. To avoid buying a
security at a higher price and possibly exceeding your purchasing power, you understand your option to
enter a limit order with a limit price. You also understand that limit orders, including those that originate
as market buy orders or market sell orders as discussed above, may not be executed within a particular
period of time, or at all, if there is not sufficient trading at or better than the limit price you specify, and
are subject to any applicable time-in-force restrictions. The Website contains further information
regarding order types and limitations, which you agree to read and understand before placing such
orders. If your equity orders are not subject to price collaring (and so, e.g., “Market Order” is not included
in the order type menu accessible when entering orders via the Platform), the default order type when
entering an equity order via the Platform may be, as disclosed during the order entry process, either a
market order or a limit order with a limit price set at 5% above (if a buy order) or 5% below (if a sell order)
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the last reported trade price for the security on a Nasdaq exchange (i.e., The Nasdaq Stock Market,
NASDAQ OMX BX, or NASDAQ OMX PHLX) at the time the order was entered, subject to the rounding
methodology described in (4) above.

As a customer of Robinhood Financial, you understand that after the market has closed for the day,
including the end of Extended Hours, you have the ability to place in a queue order requests for
execution the following trading day (“Queued Order”). You understand that your Queued Order request
is prioritized based on the order in which it is received by Robinhood Financial, and that any order based
on a Queued Order request is sent out to be executed after the opening of Market Hours or Extended
Hours, depending on your instruction, on the next day of trading. You further understand that orders
based on Queued Order requests with fractional share components may be aggregated with other such
orders. Orders placed during Extended Hours are subject to the Extended Hours Trading Disclosure.
A limit order may be designated as “good-’til-cancelled” (“GTC”), which means the order remains valid
until (A) it is executed; (B) you cancel the order; (C) 90 days from when the order is placed; or (D) the
contract to which it relates is closed. You understand that a GTC order placed with an instruction to
execute only during Market Hours, if not executed or cancelled, will stand only through Market Hours
sessions. A GTC order placed with an instruction to allow execution during Extended Hours will stand
through all trading sessions until executed or cancelled. GTC Orders that are unexecuted at the end of
the trading day are re-routed at the start of the appropriate session on the following trading day. This
process will be repeated every day for as long as the GTC order remains valid or expires unexecuted.
You further agree that any GTC orders you place should be treated as “do not reduce” orders.

Robinhood may in its discretion cancel any open orders for the purchase or sale of any securities without
notice.

11.
Bulletin Board/Pink Sheet Stocks.
Bulletin board, pink sheet and other thinly-traded securities (collectively “Bulletin Board Stocks”)
present particular trading risks, in part because they are relatively less liquid and more volatile than
actively traded securities listed on a major exchange. You understand that Bulletin Board Stocks may
be subject to different trading rules and systems than other securities and that you may encounter
significant delays in executions, reports of executions, and updating of quotations in trading Bulletin
Board Stocks. Robinhood Financial in its sole discretion may require limit orders on certain Bulletin
Board Stock transactions.

12.
Content.
We may provide or make available to you certain content or information which may include news,
articles, commentary, research, links to outside websites, and other information accessible through the
Platform, but excluding brokerage services (such content or information, “Content”). Content may be
prepared by third parties and independent external providers not affiliated with Robinhood
(“Providers”). If we provide or make Content available to you, this does not grant you any rights over or in
that Content. You may not and agree that you will not reproduce, sell, market, distribute, or otherwise
commercially use the Content in any manner. Robinhood may terminate your access to the Content at any
time.

Content is provided or made available to you on an “as is” and on an “as available” basis and should not
be considered as any form of advice or recommendation for you or your Account, or a recommendation
by Robinhood to buy or sell any securities or to engage in any investment strategy. Your use of any
Content is at your own risk. We do not make any warranty of any kind, express or implied, regarding the
Content or the accuracy, completeness, timeliness, or otherwise of the Content.

Robinhood does not produce or provide first-party research providing specific investment strategies such
as buy, sell, or hold recommendations, first-party ratings, or price targets. To the extent any Content is
prepared by Robinhood or its associated persons and made available via that Platform or by other
means, that Content is intended for informational and educational purposes only and does not constitute
either research or a recommendation to enter into any securities transactions or to engage in any
investment strategies.

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Any views expressed in any third-party Content are not the views of Robinhood. Robinhood is not
responsible for any third-party website or anything contained on or connected with any third-party
website.

13.
Restrictions on Trading, Deposits, Withdrawals and Use of Services.
You understand that Robinhood may at any time, at its sole discretion and without prior notice to you: (i)
prohibit or restrict your access to the use of the Platform or related services; (ii) restrict your ability to
deposit or withdrawal funds, or trade securities in your Account, or (iii) terminate your Account. The closing
of your Account will not affect the rights or obligations of either party that are incurred prior to the date your
Account is closed.

Robinhood may restrict your Account from withdrawals or trading for, but not limited to, the following
reasons: if there is a reasonable suspicion of fraud, diminished capacity, inappropriate activity, or if
Robinhood receives reasonable notice that ownership of some or all of the assets in your Account are in
dispute. Robinhood shall not be liable for any loss that you may incur due to Robinhood’s refusal to
permit any deposit, withdrawal or transaction.

In the event of a breach or default by you under this Agreement, Robinhood shall have all rights and
remedies available to a secured creditor under all applicable laws and in addition to the rights and
remedies provided herein.

14.
Use of the Platform, Market Data and Electronic Services.
14.1
Warranties.
You agree that your use of the Platform or any other service provided by Robinhood or its Affiliates is at
your sole risk. The Robinhood services (including the Platform, the provision of Market Data, Content, or
any other information provided by Robinhood, any of its Affiliates, or any third-party content provider or
market data provider) is provided on an "as is," "as available" basis without warranties of any kind, either
express or implied, statutory (including without limitation, timeliness, truthfulness, sequence,
completeness, accuracy, freedom from interruption), implied warranties arising from trade usage, course
of dealing, course of performance, or the implied warranties of merchantability or fitness for a particular
purpose or application, other than those warranties which are implied by and incapable of exclusion,
restriction or modification under the laws applicable to this Agreement.

14.2
Limitation of Liability.

Although considerable effort is expended to make the Platform and other operational and communications
channels available around the clock, Robinhood does not guarantee that these channels will be available
and error free every minute of the day. Interruptions of service due to maintenance, Platform changes or
system failures may occur. ROBINHOOD, ITS AFFILIATES, THEIR RESPECTIVE OFFICERS,
DIRECTORS, EMPLOYEES AND AGENTS, AND THE PROVIDERS (COLLECTIVELY, THE
“ROBINHOOD PARTIES”) WILL NOT BE RESPONSIBLE TO YOU OR TO THIRD PARTIES FOR ANY
LOSSES YOU INCUR (MEANING CLAIMS, DAMAGES, ACTIONS, DEMANDS, INVESTMENT LOSSES,
OR OTHER LOSSES, AS WELL AS ANY COSTS, CHARGES, ATTORNEYS' FEES, OR OTHER FEES
OR EXPENSES) BY REASON OF SUCH INTERRUPTIONS OF SERVICE, EXCEPT WHERE SUCH
LOSS RESULTS FROM VIOLATION OF THIS AGREEMENT, APPLICABLE RULES, OR APPLICABLE
STANDARDS OF CONDUCT. THIS PROVISION DOES NOT RESTRICT OR LIMIT IN ANY WAY YOUR
ABILITY TO BRING ANY CLAIM IN ANY FORUM, INCLUDING IN ARBITRATION, AGAINST
ROBINHOOD PARTIES THAT YOU WOULD OTHERWISE BE ENTITLED TO BRING.

14.3
Operational Interruption and Extraordinary Events.

TO THE EXTENT PERMITTED BY APPLICABLE LAW, THE ROBINHOOD PARTIES WILL NOT BE
RESPONSIBLE TO YOU OR TO THIRD PARTIES FOR ANY LOSSES YOU INCUR (MEANING
CLAIMS, DAMAGES, ACTIONS, DEMANDS, INVESTMENT LOSSES, OR OTHER LOSSES, AS WELL
AS ANY COSTS, CHARGES, ATTORNEYS' FEES, OR OTHER FEES OR EXPENSES) BY REASON
OF EXTRAORDINARY EVENTS OUTSIDE OF THEIR CONTROL OR THAT THEY DID NOT CAUSE
INCLUDING, BUT NOT LIMITED TO, INTERRUPTIONS OF SERVICE DUE TO GOVERNMENT OR
MARKET RESTRICTIONS, SUSPENSIONS OF TRADING, THE ACTION OF ANY EXCHANGE OR
OTHER SELF-REGULATORY ORGANIZATION, HIGH MARKET VOLATILITY OR TRADING VOLUME,
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ARMED CONFLICTS, NATURAL DISASTERS, FORCES OF NATURE (INCLUDING EARTHQUAKES
AND STORMS), POWER OUTAGES, NETWORK OR SYSTEM FAILURES, UNFORSEEABLE
SOFTWARE OR HARDWARE MALFUNCTIONS, COMPUTER VIRUSES, MESSAGE INTERRUPTION,
AND INSTANCES OF UNAUTHORIZED ACCESS OR BREACH OF SECURITY.
Laws can differ jurisdiction by jurisdiction. Robinhood’s responsibility provided for in this
section shall not be construed as limiting your rights under FINRA rules or regulations or under
applicable law to (i) bring a claim against Robinhood in any forum, including arbitration, that you
would be entitled to bring under applicable law or (ii) receive an award or judgment from
Robinhood that you would be entitled to receive under FINRA rules or regulations or under
applicable law.

14.4 Indemnification.

Except as otherwise provided by law, Robinhood or any of its affiliates or respective partners, officers,
directors, employees or agents (collectively, “Indemnified Parties”) shall have no liability for, and you
agree to indemnify, defend and hold harmless the Indemnified Parties from all Losses that result from: (i)
any noncompliance by you with any of the terms and conditions of this Agreement; (ii) any third-party
actions related to your receipt and use of any Market Data, Content, market analysis, other third-party
content, or other such information obtained on the Platform, whether authorized or unauthorized under this
Agreement; (iii) any third- party actions related to your use of the Platform; (iv) your or your agent’s
misrepresentation or alleged misrepresentation, or act or omission; (v) Indemnified Parties following your
or your agent’s directions or instructions, or failing to follow your or your agent’s unlawful or unreasonable
directions or instructions; (vi) any activities or services of the Indemnified Parties in connection with your
Account (including any technology services, reporting, trading, research or capital introduction services); or
(vii) the failure by any person not controlled by the Indemnified Parties and their affiliates to perform any
obligations to you, except to the extent such Losses result from the Indemnified Parties’ violation of this
Agreement, Applicable Rules, or applicable standards of conduct. Further, if you authorize or allow third
parties to gain access to Robinhood's services, including your Account, you will indemnify, defend and
hold harmless the Indemnified Parties against any Losses arising out of claims or suits by such third
parties based upon or relating to such access and use. Robinhood does not warrant against loss of use or
any direct, indirect or consequential damages or Losses to you caused by your assent, expressed or
implied, to a third party accessing your Account or information, including access provided through any
other third-party systems or sites.
You consent to the use of automated systems or service bureaus by Robinhood and its respective
affiliates in conjunction with your Account, including automated order entry and execution, record keeping,
reporting and account reconciliation and risk management systems (collectively "Automated Systems").
You understand that the use of Automated Systems entails risks, such as interruption or delays of service,
errors or omissions in the information provided, system failure, and errors in the design or functioning of
such Automated Systems (collectively, a "System Failure") that could cause substantial damage,
expense, or liability to you. As set forth in Section 14.2, you understand and agree that Indemnified
Parties will not be responsible for any of your Losses arising out of or relating to a System Failure, except
to the extent such Losses result from the Indemnified Parties’ violation of this Agreement, Applicable
Rules, or applicable standards of conduct.
You also agree that Indemnified Parties will have no responsibility to you in connection with the
performance or non-performance by any exchange, clearing organization, market data provider, or other
third party (including other broker-dealers and clearing firms, and banks) or any of their respective agents
or affiliates, of its or their obligations relative to any securities. You agree that Indemnified Parties will not
be responsible to you or to third parties for: any Losses (including special, indirect, incidental,
consequential, punitive or exemplary (including lost profits, trading losses and damages)) resulting from a
cause outside the control of the Indemnified Parties, including the failure of mechanical equipment,
unauthorized access, theft, operator errors, government restrictions, force majeure (as defined in this
Agreement), market data availability or quality, exchange rulings or suspension of trading. This Agreement
does not seek indemnification for costs or penalties resulting from the Indemnified Parties’ own violation of
the securities laws or FINRA Rules.
Laws can differ jurisdiction by jurisdiction. The indemnity provided for in this section shall not be
construed as limiting your rights under FINRA rules or regulations or under applicable law to (i)
bring a claim against Robinhood, in any forum, including arbitration, that you would be entitled to
bring under applicable law or (ii) receive an award or judgment from Robinhood that you would be
entitled to receive under FINRA rules or regulations or under applicable law.
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Exchange Traded Funds.
You understand that you should consider the investment objectives and unique risk profile of Exchange
Traded Funds (“ETFs”) carefully before investing, and that ETFs are subject to risks similar to those of
other diversified portfolios. You further understand that leveraged and inverse ETFs may not be suitable
for all investors and may increase exposure to volatility through the use of leverage, short sales of
securities, derivatives, and other complex investment strategies, and that although ETFs are designed to
provide investment results that generally correspond to the performance of their respective underlying
indices, they may not be able to exactly replicate the performance of the indices because of expenses
and other factors. You further understand that ETFs are required to distribute portfolio gains to
shareholders at year end, which may be generated by portfolio rebalancing or the need to meet
diversification requirements, and that ETF trading will also generate tax consequences.
You understand that you can obtain prospectuses from issuers or their third-party agents who
distribute and make prospectuses available for review. Additional regulatory guidance on ETFs can be
found here.

16.
Effect of Attachment or Sequestration of Accounts.
Robinhood shall not be liable for refusing to obey any orders given by or for you with respect to your
Account that has or have been subject to an attachment or sequestration in any legal proceeding against
you, and Robinhood shall be under no obligation to contest the validity of any such attachment or
sequestration.

17.
Event of Death.
It is agreed that in the event of your death, the representative of your estate or the survivor or survivors
shall immediately give Robinhood written notice thereof, and Robinhood may, before or after receiving
such notice, take such proceedings, require such papers and inheritance or estate tax waivers, retain
such portion of, or restrict transactions in the Account as Robinhood may deem advisable to protect
Robinhood against any tax, liability, penalty or loss under any present or future laws or otherwise.

Notwithstanding the above, in the event of your death, Robinhood may cancel all open orders, but
Robinhood shall not be responsible for any action taken on such orders prior to the actual receipt of
notice of death. Further, Robinhood may in its discretion close out any or all of the Account without
awaiting the appointment of a personal representative for your estate and without demand upon or notice
to any such personal representative. The estate of any of the Account holders who have died shall be
liable and each survivor shall continue to be liable, jointly and severally, to Robinhood for any net debit
balance or loss in said account in any way resulting from the completion of transactions initiated prior to
the receipt by Robinhood of the written notice of the death of the decedent or incurred in the liquidation
of the Account or the adjustment of the interests of the respective parties, and for all other obligations
pursuant to this Agreement. Such notice shall not affect Robinhood’s rights under this Agreement to take
any action that Robinhood could have taken if you had not died.

18.
Tax; Tax Reporting; Tax Withholding.
18.1.
Tax.

You acknowledge that it is your responsibility to declare and pay any income, gains, or similar to all
applicable tax authorities, make any tax filings, and to pay any and all taxes, duties, or similar (“tax”)
when due in all applicable jurisdictions. You undertake and warrant to Robinhood that you will do so and
will comply in full with all applicable tax laws and obligations to which you are subject.

18.2.
Reporting.

The proceeds of sale transactions and dividends (and substitute payments in lieu of dividends) paid will
be reported to the Internal Revenue Service (“IRS”) in accordance with applicable law.

18.3.
U.S. Persons.

This subsection is applicable if you are a U.S. person. Under penalties of perjury, you certify that the
taxpayer identification number that you have provided or will provide to Robinhood (including any
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taxpayer identification number on any Form W-9 that you have provided or will provide to Robinhood) is
your correct taxpayer identification number. You certify that you are not subject to backup withholding
and you are a United States Person (including a U.S. resident alien) as such term is defined in section
7701(a)(30) of the Internal Revenue Code of 1986, as amended (“U.S. Person”). If a correct Taxpayer
Identification Number is not provided Robinhood Financial, you understand you may be subject to
backup withholding tax at the appropriate rate on all dividends, interest and gross proceeds paid to you.
Backup withholding taxes are sent to the IRS and cannot be refunded by Robinhood Financial. You
further understand that if you waive tax withholding and fail to pay sufficient estimated taxes to the IRS,
you may be subject to tax penalties.

18.4.
Non-U.S. Persons.

This subsection is applicable if you are not a U.S. Person. You certify that you fully understand all the
information on any Form W-8BEN that you have submitted or will submit to Robinhood. Under penalties
of perjury, you declare that (i) you have examined all the information (including all the information in the
English language) on any Form W-8BEN that you have submitted or will submit to Robinhood and (ii) to
the best of your knowledge and belief all such information is true, correct, and complete. You authorize
Robinhood to provide any such Form W-8BEN to Robinhood Securities or any withholding agent that has
control, receipt, or custody of the income of which you are the beneficial owner or any withholding agent
that can disburse or make payments of the income of which you are the beneficial owner. You agree that
you will submit a new Form W-8BEN to Robinhood within 30 days if any certification made on any
previously submitted Form W-8BEN becomes incorrect. You understand that the IRS does not require
your consent to any provisions of such Form W-8BEN other than the certifications required to establish
your status as a non-U.S. Person and, if applicable, obtain a reduced rate of withholding.

19.
Equity Orders and Payment For Order Flow.

SEC Rule 607 requires registered broker-dealers to disclose their policies regarding the receipt of
“payment for order flow” in connection with the routing of certain customer orders. “Payment for order flow”
includes, among other things, any monetary payment, service, property, or other benefit that results in
remuneration, compensation, or consideration to a broker-dealer from any broker-dealer or exchange in
return for routing orders. Robinhood Financial routes customer orders in stock and option securities to
Robinhood Securities, which routes orders in options and whole-share orders in stocks to market centers,
including other broker-dealers and one or more national securities exchanges. Robinhood Securities
receives payment for order flow from those market centers and shares revenue with Robinhood Financial.
The broker-dealers pay for order flow at the same rate and generally pay Robinhood Securities (i) for
orders in stocks, a percentage of the spread between the execution price of an executed order and either
the National Best Bid (for sell orders) or National Best Offer (for buy orders), and (ii) for orders in options,
a flat rate based on the underlying symbol.

Under applicable exchange fee schedules, Robinhood Securities generally pays an exchange when taking
liquidity on it and is paid by an exchange when providing liquidity to it. Robinhood Securities transmits
customer orders for execution to market centers based on several factors depending in part on the type of
security, including: size of order, trading characteristics of the security, favorable execution price (including
the expected opportunity for price improvement based on historical performance), and the likelihood of a
fill. The market centers to which Robinhood Securities routes customer orders may execute orders at
prices superior to the publicly quoted market. While a customer may not specify that an order be directed
to a particular market center for execution, Robinhood’s order-routing policies, taking into consideration
the factors referenced above, are designed to seek favorable transaction processing for customers. The
nature and source of any payments or credits received by Robinhood Securities in connection with any
specific transactions will be furnished upon written request.

20.
Fees and Charges.
You understand that Robinhood does not charge fees or commissions for executing buy and sell orders.
However, you understand that other fees may apply. The current fees are included in the Fee Schedule
available on the Platform. You agree to pay any such fees at the then-prevailing rate. You acknowledge
that the prevailing fees may change and that change may occur without notice. You agree to be bound
by such changes once they are posted in the fee schedule available on the Platform. Robinhood
reserves the right to vary rates and fees among customers in connection with special offers, promotions,
arrangements, or account criteria such as account value/balance or customer loyalty. You also agree to
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pay all applicable federal, state, local, and foreign taxes, and any fees, costs, or expenses incurred by
Robinhood in connection with collection of any unpaid balance due on your Account, including attorney’s
fees allowed by law.

You authorize Robinhood to automatically debit your Account for any fees, charges or other amounts
owed to Robinhood by you, and for any taxes owed by you.

21.
ACH Transactions.
21.1.
Debit Transactions.

Robinhood will initiate an ACH debit at your request to debit funds from an account that you own at
another financial institution (“External Account”) for deposit into your Account. You understand that in
order for Robinhood to initiate an ACH debit, the financial institution holding your External Account must
participate in the ACH system. You understand that for the ACH transfers to be established, at least one
common name must match exactly between your Account and your External Account. You authorize
Robinhood to take such steps as it deems appropriate to verify your ownership of External Account,
including by telling the bank at which such External Account is held that you have authorized and
consented to such bank disclosing to Robinhood any information that Robinhood may request about you
or your External Account. You also agree to cooperate with Robinhood’s verification of your ownership of
such External Account by promptly providing any identification or other documentation that Robinhood
may request regarding such External Account. You represent and warrant that there are sufficient funds
in your External Account to cover the amount of the deposit to your Account. Robinhood will initiate the
ACH debit to your External Account on the Business Day or next Business Day after you request the
transfer. A transfer request will be deemed to have been made on a Business Day if it is received by
Robinhood by 7:00 p.m. Eastern on such Business Day; if received after that time, the transfer request
will be deemed to have been made on the next Business Day. “Business Days” are Monday through
Friday, excluding U.S. federal holidays.

Within 60 days of the date of your ACH deposit, your funds may only be withdrawn to the External
Account from which such funds were debited.

You understand that an ACH debit transfer may be reversed or rejected if: (A) there are insufficient funds
in your External Account; (B) there is a duplicate transaction; (C) the transaction is denied by the bank
holding your External Account; (D) your External Account does not support ACH transfers; or (E)
suspected fraud or other potential illicit activity. You acknowledge that in the event of an ACH reversal,
you will incur a fee. Before initiating making an ACH debit transfer, you agree to check the most recent
Robinhood Financial Fee Schedule available in the Disclosure Library. You agree that you are solely
liable and responsible for any ACH reversal fees that you incur.

21.2.
Credit Transactions.

Robinhood will initiate an ACH credit at your request to transfer funds from your Account to an External
Account; provided, however, that funds deposited by ACH within the previous 60 days, may only be
credited to the External Account from which such funds were debited. You agree that you will have
sufficient Available Funds in your Account to cover the amount of any ACH credit that you ask
Robinhood to initiate. Robinhood will debit the amount of such request from your Account on the
Business Day or next Business Day after you request the transfer. A transfer request will be deemed to
have been made on a Business Day if it is received by Robinhood on such Business Day; if received
after that time, the transfer request will be deemed to have been made on the next Business Day.

You agree that Robinhood may use any means which Robinhood, in its sole discretion, considers suitable
to execute your ACH credit transfers, and that Robinhood may reject any ACH credit request in the event
of suspected fraud or other potential illicit activity.

22.
Fractional Shares.

Robinhood may facilitate the holding or trading of a fraction of a share of a security (“Fractional
Shares”) in your Account.

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You acknowledge and understand that Robinhood rounds all holdings of Fractional Shares to the sixth
decimal place, the value of Fractional Shares to the nearest cent, and any dividends paid on Fractional
Shares to the nearest cent. You understand that Robinhood will not accept dollar-based purchases or
sales of less than $1.00 and that you will receive proceeds from the sale of any whole or Fractional Shares
rounded to the nearest cent.

You understand that if you enter repeated Fractional Share orders with individual notional values of less
than $0.01, your Account may be restricted.

You understand that a vendor employed by Robinhood will aggregate any proxy votes for Fractional
Shares of Robinhood’s customers with all votes reported to the issuer or issuer’s designated vote
tabulator and that, while Robinhood’s vendor will report such proxy votes on Fractional Shares, the
issuer or tabulator may not fully count such votes.

Robinhood Financial deems each of the following equity orders entered by or on behalf of a customer to
be a not held order, i.e., an order with respect to which the customer has granted Robinhood Financial
discretion with respect to the price and time of execution (a “Fractional Order”): orders (i) for a share
quantity that includes a Fractional Share (fractional share-based orders), (ii) for a dollar amount (dollar-
based orders), (iii) to invest in a portfolio of exchange traded funds (ETFs) pursuant to a
recommendation from Robinhood Financial, or (iv) to invest in a security pursuant to a customer
instruction provided in connection with the customer’s participation in the Paycheck Recurring
Investment (split-your-paycheck) program or the Robinhood Stock Round-ups Reward (weekly round-
ups and bonus) program, both offered by Robinhood Money, LLC and certain of its affiliates. As
described in Sections 23 and 24 below, orders to invest in a security pursuant to customer instructions
provided in connection with the customer’s participation in the Recurring Investment program and the
Dividend Reinvestment Program, each offered by Robinhood Financial, will be routed by Robinhood
Financial to a bulk order engine that is operated by Robinhood Securities and was incrementally rolled
out to customers in 2022; Robinhood Financial will deem each order that it routes to the bulk order
engine to be a not held order.

You understand that when Robinhood executes Fractional Orders utilizing inventory held in its principal
account, the portions of such Fractional Orders that execute against inventory are executed in a principal
capacity. To the extent that Robinhood must purchase or sell whole shares in the market to fill any
portion of your Fractional Order, that portion of the order will be executed in a riskless principal capacity
and will be filled at the execution price Robinhood received for the corresponding whole shares it
purchased and sold in the market. To the extent that Robinhood fills any portion of your Fractional Order
for a national exchange-listed security (“NMS Securities”) out of inventory rather than by purchasing or
selling shares in the market (“Inventory Fulfillment”), Robinhood will endeavor to price that portion of
your Fractional Order at a price (i) between the National Best Bid and the National Best Offer (“NBBO”)
at the time of execution for orders executed during Market Hours, or (ii) between the best bid and the
best offer as reported by an external vendor at the time of execution (“Vendor BBO”), for orders
executed during Extended Hours. For Inventory Fulfillment of any portion of your Fractional Order for a
security not listed on a national exchange (“Non-NMS Security”), executed during Market Hours or
Extended Hours, Robinhood will endeavor to price that portion of your Fractional Order between the
Vendor BBO. Robinhood may execute a Fractional Order in a security as principal while in receipt of a
not held order from you that is in the same security and on the same side of the market as Robinhood; in
such cases, Robinhood may receive the same price as or a better price than the price you receive.
Robinhood generally cancels Fractional Orders, or unexecuted portions of Fractional Orders, if they are
not executed after five minutes of being eligible for execution.

If your equity orders are subject to price collaring, Fractional Orders can only be entered by you as market
orders, which may be converted to limit orders with preset limit prices during Market Hours and will be
converted to limit orders with preset limit prices during Extended Hours, as described in Section 10 above.
If your equity orders are not subject to price collaring, a Fractional Order you enter can be either a market
order or a limit order with a preset limit price, as described in Section 10 above. Robinhood generally
cancels Fractional Orders that are limit orders with preset limit prices, or the unexecuted portions of such
orders, if they are unmarketable. Certain securities are not eligible for fractional trading during Extended
Hours. During Extended Hours, orders in such securities may be placed for whole shares or queued for
the opening of Market Hours. Trades outside of Market Hours are subject to Robinhood’s Extended Hours
Trading Disclosure.

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You understand that Fractional Shares within your Account (i) are unrecognized, unmarketable, and
illiquid outside the Robinhood platform, (ii) are not transferable in-kind, and (iii) may only be liquidated
and the proceeds withdrawn or transferred out. You acknowledge that, subject to applicable
requirements, Robinhood may report holdings and transactions in your Account in terms of either U.S.
Dollars, shares, or both.

Because Fractional Share positions cannot be transferred, reorganized, or issued in certificate form,
your partial interest will be liquidated, without commission charges to you, at prevailing market prices in
the event your Account is transferred or closed, the stock is reorganized, or stock certificates are
ordered out of your Account. The timing of such liquidations will be at the discretion of Robinhood.

23.
Dividend Reinvestment Program.
Except as expressly stated otherwise, the provisions of this Section will only apply if you are enrolled in
Robinhood’s Dividend Reinvestment Program (“DRIP”). Your enrollment in the DRIP will be activated
within three Business Days after you notify Robinhood of your intention to enroll an eligible security
through the Platform. “Eligible Security” means all shares available for fractional investing through
Robinhood. You understand that in order to be eligible for dividend reinvestment, the securities must be
held in your Account.

You may specify individual securities or have all Eligible Securities in your Account enrolled for dividend
reinvestment. If you choose to reinvest dividends from all Eligible securities, you understand that
individual securities could subsequently no longer be Eligible Securities at Robinhood’s discretion or
under applicable law. In those cases, only those securities will be discontinued from the DRIP. If you
specify individual securities, you may add additional Eligible Securities to the DRIP at any time if you
hold a position in those securities. Enrollment with respect to these additional Eligible Securities will be
effective within three Business Days after Robinhood receives notification from you through the Platform.
If you maintain open orders for securities you do not already hold, you may not enroll those securities for
dividend reinvestment until your open orders are executed. If your entire Account is set up for dividend
reinvestment, any Eligible Securities you purchase in the future will automatically participate in the DRIP.

As described below, Eligible Cash Distributions will be reinvested in securities you have selected in the
DRIP, provided that you owned the securities on the record date for determining shareholders eligible to
receive dividends, and continue to hold the securities through the payable date. “Eligible Cash
Distributions” means most cash distributions, including regular and optional dividends, cash-in-lieu
payments, and capital gains distributions. Special dividends, late ex-date, liquidation, and miscellaneous
payments may not be eligible distributions. Optional dividends will be processed in accordance with
dividend reinvestment instructions. Robinhood is permitted to borrow a dividend paying stock in the
normal course of business under certain circumstances and, as a result, in such situations instead of a
dividend payment you may receive a cash in lieu payment. If you receive a cash in lieu payment, you
authorize Robinhood to treat such payment as if it was not “in lieu” and reinvest it accordingly.

Robinhood will credit your Account upon completion of the dividend reinvestment. Robinhood will
reinvest dividends on the Business Day following receipt of funds. In the rare instance in which
Robinhood is unable to reinvest all dividends on the Business Day following receipt, it may reinvest the
remaining funds as soon as reasonably possible thereafter, which may take up to five Business Days.
You will not have use of the funds prior to reinvestment.

You understand that your participation in the DRIP is voluntary and that Robinhood has not made any
recommendation that you should participate. You further understand that Robinhood is not
recommending or offering any advice regarding the purchase of any security included as an Eligible
Security in the DRIP. You further understand that dividend reinvestment does not assure profits on your
investments, nor does it protect against losses in declining markets. Robinhood does not intend to
charge a fee for transactions executed pursuant to the DRIP.

You may terminate your participation in the DRIP, or the enrollment of individual securities in the
DRIP, at any time by giving notice through the Platform. Termination will take effect prior to the next
Eligible Cash Distribution provided your notice to terminate was received at least three Business Days
prior to the record date of that distribution. You understand that your notice to terminate your
participation in the DRIP will not affect any obligations that may result from transactions initiated prior to
Robinhood’s receipt and processing of your notice.

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Orders to invest in a security pursuant to your instructions provided in connection with your participation
in the DRIP generally will be routed as dollar-based orders by Robinhood Financial to a bulk order
engine operated by Robinhood Securities (“BOE”), which was incrementally rolled out to customers in
2022. The BOE will aggregate the orders it receives in a given security on a given day in connection with
the DRIP into one or more bulk orders. Each bulk order may represent orders from multiple customers.
The BOE will convert each bulk order to one or more share-based child orders that the BOE will route to
the market for execution. Robinhood Securities will allocate executions received by the BOE to
customers on a riskless principal basis. The allocations may include Fractional Shares, rounded to six
decimal places. If the BOE routes multiple child orders to execute a single bulk order, each customer
order represented by the bulk order will receive a share allocation based on the weighted average price
per share of the child order executions. If a bulk order is not fully executed, the customers whose orders
are represented by the bulk order will be refunded the dollar amount corresponding to the unfilled portion
of the bulk order on a pro rata basis. Robinhood Financial will deem each order that it routes to the BOE
to be a not held order, i.e., an order with respect to which the customer has granted Robinhood Financial
discretion with respect to the price and time of execution.

If you participate in the DRIP and the BOE is not utilized (because, e.g., the BOE is not available), you
understand Robinhood will reinvest the dividends of a particular stock at or near the opening price on the
trading day following receipt of the dividend. Robinhood will combine Eligible Cash Distributions from
your Account with those from other Robinhood clients requesting dividend reinvestment in the same
security and use these combined funds to purchase securities on your behalf and on behalf of these
other clients. If the combined reinvested funds do not total the purchase price of at least one share, the
distribution will be invested in Fractional Shares. On that same day, Robinhood will credit your Account
with that number of shares, including Fractional Shares, equal to your Eligible Cash Distribution divided
by the purchase price per share.

Dividend reinvestment may result in your owning interests in Fractional Shares of a security. You will be
entitled to receive future dividend payments on your Fractional Shares, although other corporate actions
may result in allocation of only whole shares and cash in lieu of Fractional Shares as determined by the
issuer. In mandatory corporate reorganizations, your partial interest will be handled according to the
specific terms of the reorganization. In voluntary corporate reorganizations, Robinhood will act on your
instructions with respect only to your whole shares.

Because Fractional Share positions cannot be transferred, reorganized, or issued in certificate form, your
partial interest will be liquidated, without commission charges to you, at prevailing market prices in the
event your Account is transferred or closed, the stock is reorganized, or stock certificates are ordered out
of your Account. The timing of such liquidations will be at the discretion of Robinhood.

Reinvestment of dividends may result in your owning a Fractional Share position in securities that are
callable in part. In the event of a call, Fractional Shares to be called will be determined through a random
selection process. The probability of your fractional share holdings being called will be proportional to the
holdings of all Robinhood clients who own a fractional share position in that security. Prior to the
publication date of such a call, you have the right to withdraw from your Account cash in lieu of your
uncalled, fully paid partial holdings. Once a call is announced, however, all shares, whether registered or
held in street name, participate in the random selection process. If your Fractional Shares are selected
and you no longer hold the shares that you held on the publication date of the call, you will be
responsible for covering those shares.

24.
Recurring Investments

Except as expressly stated otherwise, the provisions of this Section will only apply if you are enrolled in
Robinhood’s Recurring Investments (“RI”). As it relates to this Section, “Recurring Eligible Security”
means all shares available for fractional investing through Robinhood that Robinhood supports for
Recurring Investments.

Robinhood will process RI orders on the schedule that you choose for a Recurring Eligible Security. If
Robinhood is unable to process an RI order on the specified day, it will process the order as soon as
reasonably possible thereafter, which may take up to five Business Days. If your RI order falls on a day
that the market is closed, like a weekend or holiday, it will be scheduled for the next trading day. On
partial market holidays, recurring orders will process earlier in the day to accommodate for the early
market close.

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You understand that your participation in RI is voluntary and that Robinhood has not made any
recommendation that you should participate. You further understand that Robinhood is not
recommending or offering any advice regarding the purchase of any security included as a Recurring
Eligible Security in RI. You further understand that recurring investment does not assure profits on your
investments, nor does it protect against losses in declining markets.

You may delete your recurring investments at any time by giving notice through the Platform. Deleting
a recurring investment will take effect prior to the next scheduled RI order, unless the request to delete
is made fewer than two Business Days prior to the next recurring investment, in which case the request
to delete will take effect prior to the following RI order. If the Platform makes this option available, you
may also pause or skip a specific RI order. You understand that your notice to delete recurring
investments will not affect any obligations that may result from transactions initiated prior to
Robinhood’s receipt and processing of your notice.

Orders to invest in a security pursuant to your instructions provided in connection with your participation
in RI generally will be routed as dollar-based orders by Robinhood Financial to Robinhood Securities’
BOE, a bulk order engine that was incrementally rolled out to customers in 2022. The BOE will
aggregate the orders it receives in a given security on a given day in connection with RI into one or more
bulk orders. Each bulk order may represent orders from multiple customers. The BOE will convert each
bulk order to one or more share-based child orders that the BOE will route to the market for
execution. Robinhood Securities will allocate executions received by the BOE to customers on a riskless
principal basis. The allocations may include Fractional Shares, rounded to six decimal places. If the BOE
routes multiple child orders to execute a single bulk order, each customer order represented by the bulk
order will receive a share allocation based on the weighted average price per share of the child order
executions. If a bulk order is not fully executed, the customers whose orders are represented by the bulk
order will be refunded the dollar amount corresponding to the unfilled portion of the bulk order on a pro
rata basis. Robinhood Financial will deem each order that it routes to the BOE to be a not held order, i.e.,
an order with respect to which the customer has granted Robinhood Financial discretion with respect to
the price and time of execution.

If you participate in RI and the BOE is not utilized (because, e.g., the BOE is not available), you
understand Robinhood will place an order in the amount specified. RI orders will typically be processed
between 12:00 PM ET and market close on the scheduled date. Robinhood may combine RI orders from
your Account with those from other Robinhood customers requesting recurring investments in the same
security and use these combined funds to purchase securities on your behalf and on behalf of these
other customers. If the combined investing funds do not total the purchase price of at least one share,
the funds will be invested in Fractional Shares. On that same day, Robinhood will credit your Account
with that number of shares, including Fractional Shares, equal to your recurring investment divided by
the purchase price per share.

RI orders may result in your owning interests in Fractional Shares of a security. You will be entitled to
receive future dividend payments on your Fractional Shares, although other corporate actions may
result in allocation of only whole shares and cash in lieu of fractions as determined by the issuer. In
mandatory corporate reorganizations, your partial interest will be handled according to the specific
terms of the reorganization. In voluntary corporate reorganizations, Robinhood will act on your
instructions with respect only to your whole shares.

Because fractional share positions cannot be transferred, reorganized, or issued in certificate form, your
partial interest will be liquidated, without commission charges to you, at prevailing market prices in the
event your Account is transferred or closed, the stock is reorganized, or stock certificates are ordered out
of your Account. The timing of such liquidations will be at the discretion of Robinhood.

Recurring investments may result in you owning a fractional share position in securities that are callable
in part. In the event of a call, Fractional Shares to be called will be determined through a random
selection process. The probability of your fractional share holdings being called will be proportional to the
holdings of all Robinhood customers who own a fractional share position in that security. Prior to the
publication date of such a call, you have the right to withdraw from your Account cash in lieu of your
uncalled, fully paid partial holdings. Once a call is announced, however, all shares, whether registered or
held in street name, participate in the random selection process. If your Fractional Shares are selected
and you no longer hold the shares that you held on the publication date of the call, you will be
responsible for covering those shares.
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25.
Disclosure of Information.
You agree and understand that all disclosures of your non-public personal information shall be made in
accordance with the terms of this Agreement or the Robinhood Privacy Policy (available in the
Disclosure Library), as applicable. You agree that your consent to sharing certain types of non-public
personal information will remain in effect until you revoke such consent by updating your settings.

In addition, you understand and agree that Robinhood may disclose information about your Account and
your related activities to third parties under the following circumstances: (i) As necessary to complete
your Payment transactions; (ii) to investigate any complaint, disputed transaction, transaction inquiry, or
request you make or as necessary to investigate potential fraud, money laundering, or other misuse
related to your Account; (iii) to respond to requests from credit bureaus, creditors, or other third parties
for account-related information, to the extent such inquiries are necessary for processing your
transactions or are usual and customary in the course of servicing similar products or accounts; (iv) as
necessary to comply with any applicable law, regulation, government, or court order or subpoena; or (v)
in accordance with your written permission or as otherwise permitted under the Robinhood Privacy
Policy.

26.
Deposits.
26.1.
General; Holds.

You acknowledge and agree that funds that you deposit to your Account may be subject to one or more
hold periods, which are described in the RHF Funds Availability schedule available in the Disclosure
Library. You understand and agree that Robinhood reserves the right to modify the RHF Funds
Availability schedule at any time by posting an updated schedule in the Disclosure Library or otherwise
providing notice to you. During the applicable hold period, your funds will not be available for Payments,
withdrawal, or the settling of securities transactions, in each case as described in the RHF Funds
Availability schedule. You further understand and agree that Robinhood reserves the right to further
delay making deposited funds available for periods longer than the hold periods specified in the RHF
Funds Availability schedule to the extent Robinhood determines that additional time is needed to verify
information about the item deposited or the sender or if Robinhood otherwise believes there is a risk of
fraud or other unlawful activity with respect to your Account.

26.2.
Mistaken Deposits.

If funds are deposited or transferred into your Account by mistake or otherwise, you agree that
Robinhood may correct the situation and deduct any interest paid by Program Banks (as such term is
defined in Section 27), if applicable, without prior notice to you.

26.3.
Returned Funds.

You acknowledge and agree that you are responsible for returned transactions. If you have funds
transferred into your Account and that transfer is returned for any reason, Robinhood may charge the
transfer and interest paid by Program Banks, if applicable, against your Account, without prior notice to
you.

27.
Robinhood Debit Card and Brokerage Cash Sweep Program.

27.1. Free Credit Balances and Brokerage Cash Sweep Program.

If you enroll in the IntraFi Network Deposit (“IND”) Sweep Program (the “Brokerage Cash Sweep
Program”) you understand that the free credit balances in your Account will be deposited into interest-
bearing accounts at one or more banks (“Program Banks”), in accordance with the IntraFi Network
Deposit Sweep Program Agreement (“IND Disclosures”) available in the Disclosure Library and on the
Platform. By enrolling in the Brokerage Cash Sweep Program, you represent and warrant that you have
reviewed the IND Disclosures and agree to the terms set forth in the IND Disclosures. If you are not
enrolled in the Brokerage Cash Sweep Program, free credit balances in your Account will remain in your
Account, will not earn interest and will not be eligible for FDIC insurance, but will be eligible for SIPC
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protection as described in the IND Disclosures. You understand that Robinhood may terminate your
participation in the Brokerage Cash Sweep Program for any reason, upon notice to you.

27.2
The Robinhood Debit Card.

(a) General. You understand and agree that your Robinhood- branded debit card is issued by the bank
identified in your Robinhood Debit Card Agreement (“Card”). You further understand and agree that
by using your Card, exercising your electronic fund transfer (“EFT”) privileges offered in connection
with your Account, or by successfully completing a request using Pay by Check, you authorize
Robinhood to debit your Account immediately whenever an electronic draft or Card transaction is
presented for payment on your behalf, when an EFT transaction is effected, when a Pay by Check
request is successfully completed on your Account or when any fee or charge is due (collectively
“Payment” or “Payments”). You understand and agree that your use of the Robinhood Debit Card is
subject to the disclosures set forth in The Electronic Fund Transfer Disclosures Addendum located at
the end of this Agreement in Appendix A, and acknowledge that you have received and reviewed such
disclosures. You further understand and agree that when you request a Payment or withdrawal or
instruct Robinhood to make a purchase of securities from your Account, Robinhood is authorized to
place a block on the amount of the transaction (“Blocked Amounts”) prior to the settlement date of
the Payment, withdrawal or trade, and that the Blocked Amounts will not be available for use for
additional Payments or the purchase of securities. You agree to maintain Available Funds sufficient to
pay for Payments made by you or any Authorized Card User (as defined below) and to pay for any
securities trades and for interest on any margin loans and other transaction fees. For this purpose,
“Available Funds” in your Account will fluctuate daily and means the sum of (i) free credit balances,
(ii) deposits to Program Banks through the Brokerage Cash Sweep Program, and (iii) available margin
loan value if your Account has margin privileges, minus (x) uncleared funds, (y) Blocked Amounts, and
(z) deposits subject to a hold. The loan value of eligible securities (for the purpose of margin) is
subject to regulatory requirements and Robinhood credit policies then in effect.

(b) Payments and Withdrawals. You agree that any Payments that you make from your Account will be
lawful. You agree that Payments will be deducted from the Available Funds in your Account in the
following order: first, from free credit balances; second, by withdrawal of funds deposited to Program
Banks as part of the Brokerage Cash Sweep Program; and third, if your Account has margin
privileges, from margin loans on the eligible securities (for the purpose of margin) in your margin
Account. Robinhood will debit your Account only up to an amount equal to the Available Funds. You
understand and agree that (i) if there are insufficient Available Funds in your Account to cover
Payments when they become due, Robinhood has no obligation to make such Payments, and (ii)
Robinhood has no obligation to make partial Payments. Robinhood will not charge a fee with respect
to any declined Payment for which there were insufficient Available Funds. You acknowledge and
agree, however, that Robinhood will not be responsible for any costs or losses that you may incur
(including fees, costs, charges, attorneys’ fees, investment losses, claims, demands, or liability
resulting from any litigation or other actions) as a result of Robinhood’s decision to decline any
Payment or withdrawal or other transaction because your Account has insufficient Available Funds.

You understand that if a Payment is funded by a margin loan, you will incur interest until the margin
loan is repaid.

You agree that if your Available Funds at any time falls below zero, Robinhood may suspend your
ability to make Payments and terminate your Card. If this occurs, you agree to immediately pay all
amounts owed to Robinhood, including any purchases on your Card which will be immediately
charged to your Account.

You acknowledge and agree that Robinhood reserves the right to decline any Payments at any time
for any reason with or without notice to you. If Robinhood decides to take such action, you understand
and agree that you are responsible for any pending debits, which will be processed and deducted from
your Account.

You understand that transactions will post to your Account in any order determined by Robinhood and
that Robinhood may change that order without prior notice to you. Robinhood will comply with
requirements of applicable law regarding the order of posting transactions.

(c) Limitation of Liability. You agree that, subject to any limitations imposed by applicable law, and
except as otherwise set forth in this Agreement or in the disclosures contained in the Robinhood Debit
Card Agreement, which has been provided to you or made available to you in connection with the
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opening of your Account, Robinhood, Robinhood’s agents, any processing bank, and the Card issuer
will not be liable for any loss you incur in connection with your Account and any Payments or other
features of your Account unless Robinhood is grossly negligent in fulfilling this Agreement. In no event
will Robinhood, Robinhood’s agents, any processing bank, or the Card issuer be liable for
consequential, special or indirect damages or losses unless applicable law requires otherwise. You
also agree that liability regarding online services or use of the Platform is further limited by the
Robinhood Terms and Conditions, available in the Disclosure Library. To the extent you utilize online
services or the Platform, you acknowledge that you are bound by such Robinhood Terms and
Conditions.

(d)
Robinhood Debit Card Agreement. You understand and agree that your use of the Card is subject
to the terms, conditions, and disclosures set forth in the Robinhood Debit Card Agreement, which
has been provided to you in connection with the opening of your Account and which you may access
on the Website.

You understand and agree that you cannot request a Card for another person to use. You agree,
however, that if you authorize another person to have access to use your Card or Card number (an
“Authorized Card User”), you are authorizing all Card transactions by such person and you agree
that there are no limits to your authorization. You accept all liability with respect to the Card
transactions effected by you and any Authorized Card Users. You further agree that you may
terminate the authority of an Authorized Card User only by contacting Robinhood as provided in
Appendix A below, to cancel your Card. You agree that the cancellation of your Card is effective only
after Robinhood has a reasonable period to act on your notice.

If your Card is cancelled, you agree to destroy, or if requested by Robinhood, return the Card to
Robinhood. You acknowledge that you will be responsible for any Card transactions that are
processed because of your failure to destroy or return the Card following cancellation.

If your Account includes margin privileges, you agree that transactions that exceed your free credit
balances and deposits in the Brokerage Cash Sweep Program may result in margin credit being
extended to your Account, for which you will be charged interest. You agree to review the Margin
Disclosure Statement, which is available in the Disclosure Library.

(e) Security. You agree to protect your Card, PINs, and Account username and password from access by
anyone not authorized by you to use them. You acknowledge that you will be liable for all Card and
online transactions conducted by anyone to whom you have given access or who has obtained access
even if not authorized by you, up to applicable legal limits. You understand that you are responsible for
reviewing your Account statement promptly to discover and report unauthorized activity, including use
of your Card, PIN, Account username and password. You agree to notify Robinhood as provided in
The Electronic Fund Transfer Disclosures Addendum (located at the end of this Agreement) if you
believe or have reason to believe that there has been unauthorized activity in your Account or that
your Card, PIN, Account username or password has been lost, stolen or may be used by an
unauthorized person. Unless limited by law or as otherwise set forth in this Agreement or in the
disclosures contained in Robinhood Debit Card Agreement, which is provided to you as part of the
Account opening process and is available on the Website, you agree that you will be responsible for
losses that arise from your failure to (i) safeguard your Card, PINs, Account username and password;
(ii) review your monthly statement for possible unauthorized activity; and (iii) report any unauthorized
activity to Robinhood as provided herein or in the Robinhood Debit Card Agreement.

(f) No Illegal Purpose. You agree and understand that you may not use your debit card or any
Payments on your Account for any illegal purpose. You agree and understand that Robinhood may, in
its discretion, deny any transactions that appear to be made for an illegal purpose.

(g) Pay by Check. You agree and understand that if you try to stop payment on a check after it has been
mailed to the payee, Robinhood will attempt to but cannot guarantee that payment on the check will be
stopped. You understand that a stop payment order on a check is valid for six months. You
understand that if you wish to renew a stop payment on a check after the six-month period, you must
contact Robinhood to request another stop payment. You agree and understand that you may still be
liable to the holder of the check even if you have requested a stop payment for the amount of the
check. You agree and understand that Robinhood may deduct your Account for the amount on the
check if the stop payment request is unsuccessful.
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(h) Termination. You understand that Robinhood may terminate your Card for any reason, upon notice to
you.

28.
Consent to Redeem Shares.
You understand and agree that whenever it is necessary for Robinhood’s protection or to satisfy a
margin call, deficiency, debit or other obligation owed to Robinhood, Robinhood may (but is not required
to) sell, assign and deliver all or any part of the securities in your Account, or close any or all transactions
in your Account. You understand that Robinhood may, but is not obligated to, attempt to contact you
before taking any such action. You understand and agree that Robinhood reserves the right to take any
such action without prior notice or demand for additional collateral, and free of any right of redemption,
and that any prior demand, call or notice will not be considered a waiver of our right to sell or buy without
demand, call or notice.

You further understand that Robinhood may choose which securities to buy or sell, which transactions to
close, and the sequence and timing of liquidation, and may take such actions on whatever exchange or
market and in whatever manner (including public auction or private sale) that Robinhood chooses in the
exercise of its business judgment. You agree not to hold Robinhood liable for the choice of which
securities to buy or sell or of which transactions to close or for the timing or manner of the liquidation.
You also agree not to hold Robinhood liable for taking such action.

You understand and agree that Robinhood is entitled to exercise the rights described in this Section in its
sole discretion, including, but not limited to, whenever any of the following occurs:

•
The equity level in your Account falls below required minimums;
•
Sufficient funds or securities are not deposited to pay for transactions in your Account;
•
You reverse any ACH debit transfer to your Account;
•
A petition of bankruptcy or for the appointment of a receiver is filed by or against you;
•
An attachment is levied against your Account;
•
You die or become incapacitated or incompetent; or
•
Your Account is closed.

29.
API.
29.1.
Overview; Definitions.

Robinhood may, in Robinhood’s sole discretion, provide third parties with an application programming
interface and other materials in accordance with any accompanying documentation (collectively, the “API
Package”) (such third parties, “API Licensees”), to make available certain features and functionality of
Robinhood’s mobile applications, websites, or technology platform via the API Licensees’ products (such
products, the “Licensee Products”). The API Package and the Licensee Products are collectively
referred to as the “API Products”. You may not use the API Package or develop Licensee Products
without Robinhood’s express written consent (and Robinhood may decline any such request for use or
development in its sole discretion).

29.2.
Access to Your Personal Information.

Through your use of any API Products, you may be providing API Licensees with access to your Account
and Personal Information. “Personal Information” means any information that identifies, describes, or is
capable of being associated with an individual (including username, logon password, financial
information, trade data, and other financial information). By using any API Products, you acknowledge
that such API Products may employ security, policies, procedures, and systems of API Licensees which
may or may not be less stringent and secure than Robinhood’s. You agree that your use of any API
Products shall be subject to this Agreement, in addition to any other agreements which you executed
with respect to any such API Products. You understand and agree that any end user agreement that you
executed with any API Licensee is concluded between you and such API Licensee only, and not with
Robinhood; and such API Licensee, not Robinhood, is solely responsible for such Licensee Product and
the content thereof. You understand and agree that the API Products may deliver Personal Information
to Robinhood, and that Robinhood is authorized to receive and store such Personal Information
consistent with Robinhood’s then-in-effect policies and procedures. Further, you agree that the API
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Products may request Personal Information stored by Robinhood, and you consent to Robinhood’s
disclosure of such Personal Information to the API Products.

29.3.
No Recommendations.

To the extent the Licensee Products or API Licensees express opinions or make recommendations, you
understand that such opinions and recommendations are expressed solely by API Licensees and are not
the opinions or recommendations of Robinhood. The existence of any API Products and Robinhood’s
consent to any connectivity between any Licensee Products and Robinhood’s technology, the Platform,
or trading platform(s) does not constitute (i) any recommendation by Robinhood to invest in any security
or utilize any investment strategy; or (ii) any representation, warranty, or other guarantee by Robinhood
as to the present or future value or suitability of any sale, trade, or other transaction involving any
particular security or any other investments. The existence of any and all information, tools and services
provided by API Licensees or by the Licensee Products shall not constitute Robinhood’s endorsement of
API Licensees or the Licensee Products.

29.4.
Data Provided by Robinhood to API.

From time to time, and subject to then-in-effect agreements between Robinhood and API Licensees,
Robinhood may, in its own discretion, make market data feeds received from third parties available via
the API Products. Robinhood does not make any guarantees in regard to such market data feeds.
Furthermore, API Licensees or Licensee Products may make available to you market data feeds
independent of Robinhood. You acknowledge that from time to time that there may be discrepancy
between the market data presented on the Platform and information provided by any API Products due
to a variety of reasons, including the time to update and transmit such data to a mobile application or
website and latency caused by such API Product’s or your local environment (such as computer set up,
connection speed, etc.). Robinhood is not responsible for the accuracy of any market data displayed on
any API Products or otherwise made available by API Licensees.

29.5.
Risks; No Liability.

You acknowledge that there may be latency between the time an order (or other Personal Information) is
submitted from the API Products and the time such order or Personal Information is received by
Robinhood. Latency may also affect order modification and order cancellation requests. The time an
order or a request is actually received by Robinhood (including for execution) will be the official time,
including for the purposes of routing the order to the market for execution. In addition, all orders
submitted to Robinhood are subject to order vetting by Robinhood. Orders created and submitted
through any API Products are not vetted until they are received by Robinhood. It is possible that
Robinhood may reject an order placed through any API Products. Robinhood cannot guarantee that any
order will be accepted when such order is routed to the market for execution, and Robinhood cannot
guarantee that notifications and Personal Information provided to you by Robinhood will be successfully
delivered to or displayed by any API Products.

Without limiting the generality of any other terms in this Agreement, you agree that:
(a)
Robinhood or its Affiliates shall not be liable for any Losses as a result of any issues addressed in
this Section, nor shall Robinhood or its Affiliates be liable for any Losses realized for technical
issues involving any API Products or API Licensee technology or product offerings (including
system outages or downtime).
(b)
Robinhood or its Affiliates shall not be responsible for any investment research provided by any
API Licensee or any Licensee Products.
(c)
Robinhood or its Affiliates makes no representations, warranties or other guarantees as to the
accuracy, timeliness or efficacy of any market data, information, or other functionality made
available by any API Licensee or any API Products.

29.6.
Intellectual Property.

Your use of any API Products will not confer to you any title, ownership interest, or intellectual property
rights that otherwise belongs to Robinhood or any of its affiliates. The API Package, including content, is
protected under U.S. patent, copyright laws, international treaties or conventions, and other laws and will
remain Robinhood’s exclusive property, as applicable. Names, logos, and all related product and service
names, design marks, and slogans displayed by or relating to Robinhood or any of its Affiliates or API
Licensees in the context of the API Products shall remain the property of the respective owner, and use
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of such property by Robinhood or any API Licensee in marketing or provision of any API Products does
not grant ownership of or entitle you to use any such name or mark in any manner.

29.7.
Customer API Representations and Warranties.

You represent and warrant that:
(a)
By virtue of utilizing any API Products, you consent to and accept any risk associated with
Robinhood’s sharing of Personal Information with any API Licensee and shall not hold Robinhood,
its Affiliates, or their respective officers, directors, or employees responsible for any Losses
resulting from the sharing of such Personal Information.
(b)
You agree that your use of any API Products or API Licensee’s content, information, technology,
or functionality is at your own risk.
(c)
You agree that Robinhood may revoke any API Licensee or API Products’ authorization at any
time, for any reason, with or without cause and without prior notice to you.

30.
Electronic Signatures; Modifications to the Agreement.
You agree to transact business with Robinhood electronically. By electronically signing an application for
an Account, you acknowledge and agree that such electronic signature is valid evidence of your consent
to be legally bound by this Agreement and such subsequent terms as may govern the use of
Robinhood’s services. The use of an electronic version of any document fully satisfies any requirement
that the document be provided to you in writing. You accept notice by electronic means as reasonable
and proper notice, for the purpose of any and all laws, rules and regulations. You acknowledge and
agree that Robinhood may modify this Agreement from time to time and you agree to consult the
Website from time to time for the most up-to-date Agreement. The electronically stored copy of this
Agreement is considered to be the true, complete, valid, authentic and enforceable record of the
Agreement, admissible in judicial or administrative proceedings to the same extent as if the documents
and records were originally generated and maintained in printed form. You agree to not contest the
admissibility or enforceability of Robinhood’s electronically stored copy of the Agreement.

31.
Margin Accounts; Margin.
This Section applies to your Account to the extent you elect and are approved for a margin account,
which includes a Robinhood Instant or a Robinhood Gold margin account (each, a “Margin Account”).
31.1.
Margin Account

Any margin extended to you in connection with your Account is provided by Robinhood Securities.

You understand that you are liable for the full amount of funds borrowed in your Margin Account and will
be liable to repay this amount in full on demand.

31.2.
Margin Risks.

Margin Accounts – whether Robinhood Instant or Robinhood Gold – are not necessarily appropriate for
everyone. Nothing in this Agreement, any application, or any communication or other statement by
Robinhood or its Representatives constitutes any form of recommendation to open a Margin Account or
make any specific investment or strategy.

You understand that margin trading involves interest charges and risks, including the potential to lose
more than deposited or the need to deposit additional collateral in a falling market. Before applying for a
Margin Account and before using margin, you must determine whether this type of account or trading
strategy is right for you given your specific investment objectives, experience, risk tolerance, and
financial situation.

If you have, or have applied or elected to have, a Margin Account, you represent that you have
read and understand the Margin Disclosure Statement, Day Trading Risk Disclosure, and FINRA
Investor Information and that you fully understand the risks involved in borrowing margin and
trading securities on margin. These disclosures contain information on Robinhood’s lending
policies, interest charges, and certain risks associated with Margin Accounts.

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31.3.
Hypothecation.

Within the limitations imposed by applicable laws, rules and regulations, all securities now or hereafter
held by Robinhood, or carried by Robinhood in any account for you (either individually or jointly with
others), or deposited to secure same, may from time to time, without any notice, be carried in your
general loans and may be pledged, repledged, hypothecated or re-hypothecated, separately or in
common with other securities for the sum due to you thereon or for a greater sum and without retaining
in your possession or control for delivery a like amount of similar securities. The IRS requires Broker
Dealers to treat dividend payments on loaned securities positions as payments received in lieu of
dividends for 1099 tax reporting purposes. Taxation of substitute dividend payments may be greater than
the rate of taxation on qualified dividends. It is understood, however, that you agree to deliver to you
upon your demand and upon payment of the full amount due thereon, all securities in such accounts, but
without obligation to deliver the same certificates or securities deposited by you originally. Any securities
in your margin or short account may be borrowed by you, or lent to others.

31.4.
Interest.

Debit balances in your Account shall be charged with interest in accordance the Margin Disclosure
Statement (available in the Disclosure Library).

31.5.
Margin Requirements.

You agree to maintain in your Account with Robinhood such positions and margin as required by all
applicable statutes, rules, regulations, procedures and custom, or as Robinhood deems necessary or
advisable. You agree to promptly satisfy all margin and maintenance calls.

31.6.
Breach; Security Interest

Whenever in its discretion Robinhood Securities considers it necessary for Robinhood’s or your protection
or in the event of, but not limited to; (i) any breach by you of this or any other agreement with Robinhood
or its Affiliates or (ii) your failure to pay for securities and other property purchased or to deliver securities
and other property sold, Robinhood Securities may sell any or all securities and other Property held in any
of your Accounts or accounts held with any of our Affiliates (either individually or jointly with others), cancel
or complete any open orders for the purchase or sale of any securities and other Property, or borrow or
buy any securities and other Property required to make delivery against any sale, including a short sale,
effected for you, all without notice or demand for deposit of collateral, other notice of sale or purchase, or
other notice or advertisement, each of which you expressly waive, and Robinhood Securities may require
you to deposit cash or adequate collateral to your Account prior to any settlement date in order to assure
the performance or payment of any open contractual commitments or unsettled transactions. Robinhood
has the right to refuse to execute securities transactions for you at any time and for any reason.

Any and all securities and other Property now or hereafter held, carried or maintained by Robinhood in or
for any of your Accounts(either individually or jointly with others), now or hereafter opened, including any
accounts in which you may have an interest, shall be subject to a first and prior lien and security interest
for the discharge of all of your Obligations to Robinhood, whenever or however arising and without regard
to whether or not Robinhood have made advances with respect to such securities and other Property, and
Robinhood Securities is hereby authorized to sell or purchase any and all securities and other Property in
any of your Accounts, or to transfer any such securities and other Property among any of your Accounts,
to the fullest extent allowed by law and without notice where allowed by law. Robinhood shall have the
right to transfer securities and other Property so held by Robinhood from or to any other of your Accounts
whenever Robinhood so determines.

31.7.
Liquidation

In the event of your death, or in the event the margin in any account in which you have an interest shall
in either Robinhood Securities’ or Robinhood Financial’s discretion become unsatisfactory or be deemed
insufficient, Robinhood is hereby authorized; (a) to sell any or all securities or other Property which
Robinhood may hold for you (either individually or jointly with others); (b) to buy any or all securities and
other Property which may be short in such accounts; or (c) to cancel any open orders and to close any or
all outstanding contracts; all without demand for margin or additional margin, notice of sale or purchase,
or other notice or advertisement, and that any prior demand or notice shall not be a waiver of
Robinhood’s rights provided herein. Robinhood Securities may likewise accept and rely upon instructions
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which Robinhood Securities receives from Robinhood Financial to take, make, or effect any of the
aforementioned actions or transactions. Robinhood Securities shall have the discretion to determine
which securities and other Property are to be sold and which orders or contracts are to be closed. Any
such sales or purchases may be made at Robinhood’s discretion on any exchange, the over-the-counter
market or any other market where such business is usually transacted, or at public auction or private
sale, and Robinhood Securities may be the purchaser for its own account.

31.8.
Payment of Indebtedness Upon Demand; Right of Offset.

You shall at all times be liable for the payment upon demand of any Obligations owing from you to
Robinhood, and you shall be liable to Robinhood for any deficiency remaining in any such accounts in the
event of the liquidation thereof (as contemplated in this Section or otherwise), in whole or in part, by
Robinhood or by you; and you shall make payment of such Obligations upon demand. You authorize
Robinhood to recover amounts you owe, and to debit, charge or otherwise exercise a right of offset to
recover funds from the balance in your Account, your external bank account, any Account you own with an
Affiliate of Robinhood, or any other payment instrument linked to your Account. This authorization and/or
right of offset shall survive termination of your Account and this Agreement. If Robinhood’s attempt to
recover funds is not successful, you agree that the authorization and/or right of offset hereunder includes
a grant to Robinhood of any additional authorizations and/or rights of offset required to recover the amount
you owe to Robinhood in complete compliance with any applicable laws, rules or industry regulations.
Robinhood may take these actions without prior notice to you.

31.9.
Sales/Short Sales.

You promise to deliver all securities sold in your Account and to provide collateral of a type and
amount acceptable to Robinhood for all short sales in your Account. Robinhood requires that a
security be held in your Account prior to the acceptance of a sell order with respect to such security
unless the order is specifically designated as a “short sale.” If a security is not held in your Account
and a sell order is processed, you must promptly deliver such security to Robinhood for receipt in good
deliverable form on or before the settlement date. Any order accepted without negotiable certificates or
positions in your Account will be subject, at Robinhood’s sole discretion, to cancellation or buy-in. To
ensure this will not occur, you agree to only place sell orders for securities owned by you and held in
your Account at the time your order is placed.

Proceeds of a sale will not be paid to you or released into your Account until Robinhood has received the
security in good deliverable form, whether from a transfer agent or from you and the settlement of the
security is complete. If the security is not received on or before settlement date, or as market conditions
warrant, Robinhood may in its sole discretion purchase the security on the open market for your Account
and may liquidate and close out any and all securities in your Account in order to pay for such purchase.
In the event a security is bought in, you will be responsible for all resulting Losses incurred by
Robinhood.

You understand that you may execute short sales only in a margin Account and that such execution must
comply with applicable short sales rules. You agree to specifically designate any order to sell a security,
which you do not own as a short sale, and understand that Robinhood will mark such order as a short
sale. You agree that any order which is not specifically designated as a short sale is a sale of securities
owned by you, and that you will deliver the securities on or before settlement date, if not already in the
account. If you should fail to make such delivery in the time required, Robinhood is authorized to borrow
such securities as necessary to make delivery for the sale, and you agree to be responsible for any loss
you may thereby sustain, or which you may sustain as a result of your inability to borrow such securities.

31.10.
Costs of Collection

Without limitation to any other indemnities in this Agreement, all Losses, including but not limited to
reasonable attorneys’ fees and expenses, incurred and payable or paid by Robinhood in the (i)
collection of a debit balance or any unpaid deficiency in any of your Accounts with Robinhood or (ii)
defense of any matter arising out of your securities transactions, shall be payable to Robinhood by you.

31.11.
Pattern Day Trader

Robinhood Financial will monitor trading activities and alert or restrict those customers at risk of
qualifying as “pattern day traders.” A pattern day trader, as defined under FINRA Rule 4210(f)(8)(B), is
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any customer who executes four or more day trades within five Business Days, provided the number of
day trades is more than six percent of the total trades in the account during that period. All Accounts
designated as a pattern day trading accounts will be required to maintain $25,000 equity at all times in
order to continue day trading. It is important that you fully understand the risks involved in day trading
securities, as described in the Day Trading Risk Disclosure.

32.
Extended Trading Hours
In certain circumstances, you may be able to engage in Extended Hours trading, meaning, for purposes
of this section, trading outside of the regular trading hours of 9:30 a.m. and 4:00 p.m. Eastern. This
ability may be limited to certain account types or other eligibility criteria, and the order types available for
Extended Hours trading may be limited. You may not execute Extended Hours trades in an IPO on its
first day of trading. There are unique risks to Extended Hours trading and by participating in this type of
trading, you are deemed to understand and agree to accept such risks, including those set out in the
Extended Hours Trading Disclosure available in the Disclosure Library.

33.
Phone Calls.
You agree that, by providing information Robinhood requests, opening or applying to open, or
maintaining an Account, or by downloading any App, Robinhood and its third-party service providers may
contact you either (i) via mail, phone, or email, or other details you have provided, or (ii) via any other
form of electronic or other communications facility available via the Platform or a third party service
provider such as “chat”, “voice”, or messaging functionality.

Specifically, if you provide us with a phone number: (a) you represent and warrant that the number you
provide is your phone number, and you will promptly notify us if that changes, and (b) you consent to
receive calls (including text messages) made to that phone number that may be prerecorded or
completed with an automatic telephone dialing system (automated calls) for purposes including but not
limited to providing account-related communications (including security alerts), telemarketing,
investigating or preventing fraud, or collecting amounts owed to Robinhood. We may share your
number with third parties that provide services to us in connection with any of the foregoing purposes,
including but not limited to debt collectors. You understand that message, telephone minute and data
rates may apply for calls made to a mobile phone number. You may opt out at any time from receiving
these types of calls orally or in writing to privacy@robinhood.com. Please note, even if you opt out, we
may still make other calls as permitted by law.

34.
Consent to Electronic Delivery of Documents.
34.1.
Consent.

By agreeing to electronic delivery, you are giving your informed consent to electronic delivery of
all Account Documents. “Account Documents” include notices, disclosures, current and future
account statements, regulatory and shareholder communications (such as prospectuses, proxy
solicitations, and privacy notices), trade confirmations, tax-related documents, and any other information,
documents, data, and records regarding your Account, this Agreement (including amendments to this
Agreement), and the agreements and disclosures governing the services delivered or provided to you by
Robinhood, the issuers of the securities or other property in which you invest, and any other parties. You
agree that you can access, view, download, save, and print any Account Documents you receive via
electronic delivery for your records.

34.2.
Electronic Delivery System.

You acknowledge that Robinhood’s primary methods of communication with you include (A) posting
information on the Website, (B) providing information via the App, (C) sending email(s) to your email
address of record, and, to the extent required by law, (D) providing you with notice(s) that will direct you
to the Platform where you can read and print such information. Unless otherwise required by law,
Robinhood reserves the right to post Account Documents on the Website without providing notice to you.
Further, Robinhood reserves the right to send Account Documents to your postal or email address of
record, or via the Platform. You agree that all Account Documents provided to you in any of the foregoing
manners are considered delivered to you personally when sent or posted by Robinhood, whether you
receive it or not.

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All email notifications regarding Account Documents will be sent to your e-mail address of record. You
agree to maintain the email address that you have provided Robinhood until you provide Robinhood with
a new one. You understand that email messages may fail to transmit promptly or properly, including
being delivered to SPAM folders. You further understand that it is your sole responsibility to ensure that
any emails from Robinhood or its Affiliates are not marked as SPAM. If a notification cannot be delivered
to you because you failed to maintain a valid and/or deliverable email address with Robinhood, such
notification will be sent to you via postal mail for a fee, as described in Section 34.3, below, and in the
Fee Schedule. Regardless of whether or not you receive an email notification, you agree to check the
Website regularly to avoid missing any information, including amendments or supplements to this
Agreement, or time-sensitive or otherwise important communications. If you authorize someone else to
access the email account you have provided Robinhood, you agree to tell them to share the Account
Documents with you promptly, and you accept the risk that they will see your sensitive information. You
understand that if you use a work email address or computing or communications device, your employer
or other employees may have access to the Account Documents.

Additionally, you acknowledge that the Internet is not a secure network and agree that you will not send
any confidential information, including Account numbers or passwords, in any unencrypted emails. You
also understand that communications transmitted over the Internet may be accessed by unauthorized or
unintended third parties and agree to hold Robinhood, its Affiliates, and Robinhood and its Affiliates’
respective officers and employees harmless for any such access regardless of the cause.

You agree to promptly and carefully review all Account Documents when they are delivered and notify
Robinhood Financial in writing within five days of delivery if you object to the information provided (or other
such time specified therein). If you fail to object in writing within such time, Robinhood is entitled to treat
such information as accurate and conclusive. You will contact Robinhood to report any problems with
accessing the Account Documents.

34.3.
Costs and Fees.
Potential costs associated with electronic delivery of Account Documents may include charges from
Internet access providers and telephone companies, and you agree to bear these costs. Robinhood
Financial will not charge you additional online access fees for receiving electronic delivery of Account
Documents.

Additionally, if you fail to maintain a valid and/or deliverable email address of record on your Account,
Robinhood reserves the right to charge you a fee for certain documents that must be re-delivered via
postal mail. You will incur such fee for each instance of postal mail delivery until such time as you update
your email address. The types of Account Documents that are subject to these fees and the current fee
amounts are detailed in the Fee Schedule. You agree that Robinhood may deduct these fees from your
Account consistent with the terms of this Agreement, including but not limited to the provisions in Section
28 of this Agreement.

34.4.
Archival.

Upon your request, you may obtain electronic copies of account statements and trade confirmations,
subject to availability.

34.5.
Revocation of Consent.

Consent to electronic delivery of documents is required to establish and maintain an Account with
Robinhood Financial. Subject to the terms of this Agreement, you may revoke or restrict your consent to
electronic delivery of Account Documents at any time by notifying Robinhood Financial in writing of your
intention to do so. However, you understand that if you revoke or restrict your consent to electronic
delivery of Account Documents, Robinhood Financial has the right to restrict and/or close your Account,
and terminate your access to Robinhood’s services. Robinhood may elect to deliver Account Documents
by other means, including paper delivery via postal mail, which will not revoke or otherwise affect your
consent. You understand that neither your revocation or restriction of consent nor Robinhood Financial’s
delivery of paper copies of Account Documents will affect the legal effectiveness or validity of any
electronic communication provided while your consent was in effect.

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34.6.
Duration of Consent.

Your consent to receive electronic delivery of Account Documents will be effective immediately and will
remain in effect unless and until either you or Robinhood Financial revokes it. You understand that it may
take up to three Business Days to process a revocation of consent to electronic delivery, and that you
may receive electronic notifications until such consent is processed.

34.7.
Hardware and Software Requirements.

You understand that in order to receive electronic deliveries, you must have access to a computer or
Mobile Device with Internet access, a valid e-mail address, and the ability to download such applications
as Robinhood Financial may specify and to which you have access. You also understand that if you wish
to download, print, or save any information you wish to retain, you must have access to a printer or other
device in order to do so.

34.8.
Consent and Representations.

You hereby agree that you have carefully read the above information regarding informed consent to
electronic delivery and fully understand the implications thereof. Additionally, you hereby agree to all
conditions outlined above with respect to electronic delivery of any Account Document. You will maintain
a valid email address and continue to have access to the Internet. If your email address changes, you
agree to immediately notify Robinhood Financial of your new email address in writing.

35.
Recording and Monitoring of Communications.
You understand and agree that Robinhood may record and monitor any telephone or electronic
communications with you. Unless otherwise agreed in writing in advance, Robinhood does not consent
to the recording of telephone conversations by any third party or by you. You acknowledge and
understand that not all telephone or electronic communications are recorded by Robinhood, and
Robinhood does not guarantee that recordings of any particular telephone or electronic communications
will be retained or capable of being retrieved.

36.
Rule 14b-1(c)
You acknowledge that Rule 14b-1(c) of the Securities Exchange Act, unless you object, requires
Robinhood to disclose to an issuer, upon its request, the names, addresses, and securities positions of
your customers who are beneficial owners of the issuer’s securities held by us in nominee name.
The issuer would be permitted to use your name and other related information for corporation
communication only. If you wish to object, you agree to send an email to support@robinhood.com with
“Rule 14b-1(c) objection” in the subject.

37.
Miscellaneous Provisions.

37.1.
Contact Information.

Robinhood Customer Service may be contacted by visiting support.robinhood.com or by email at
help@robinhood.com.

37.2.
Interpretation.

The heading of each provision hereof is for descriptive purposes only and shall not be (1) deemed to
modify or qualify any of the rights or obligations set forth herein or (2) used to construe or interpret any of
the provisions hereunder. When a reference is made in this Agreement to a Section, such reference shall
be to a Section of this Agreement unless otherwise indicated. Whenever the words “include,” “includes”
or “including” are used in this Agreement, they shall be deemed to be followed by the words “without
limitation.” The word “or,” when used in this Agreement, has the inclusive meaning represented by the
phrase “and/or.” Unless the context of this Agreement otherwise requires: (i) words using the singular or
plural number also include the plural or singular number, respectively; and (ii) the terms “hereof,”
“herein,” “hereunder” and derivative or similar words refer to this entire Agreement. References to any
law shall be deemed to refer to such law as amended from time to time and to any rules or regulations
promulgated thereunder. References to “days” means calendar days unless indicated otherwise.
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37.3.
Binding Effect; Assignment.

This Agreement shall bind your heirs, assigns, executors, successors, conservators and administrators.
You may not assign this Agreement or any rights or obligations under this Agreement without first
obtaining Robinhood’s prior written consent. Robinhood may assign, sell, or transfer your Account and
this Agreement, or any portion thereof, at any time, without your prior consent.

37.4.
Severability.

If any provisions or conditions of this Agreement are or become inconsistent with any present or future
law, rule, or regulation of any applicable government, regulatory or self-regulatory agency or body, or are
deemed invalid or unenforceable by any court of competent jurisdiction, such provisions shall be deemed
rescinded or modified, to the extent permitted by applicable law, to make this Agreement in compliance
with such law, rule or regulation, or to be valid and enforceable, but in all other respects, this Agreement
shall continue in full force and effect.

37.5.
Website Postings.

You agree and understand that Robinhood may post other specific agreements, disclosures, policies,
procedures, terms, and conditions that apply to your use of the Platform or your Account, on the Website
from time to time including in the Disclosure Library, and that this includes updates or amendments to this
Agreement or other agreements or Risk Disclosures incorporated in or referenced in this Agreement
(“Website Postings”). You understand that it is your continuing obligation to monitor the Website and the
Disclosure Library for Website Postings and to understand the terms of the Website Postings. You agree
to be bound by the Website Postings (and the most current version of this Agreement) as are in effect at
the time of your access or use of the Platform or the giving of any order or instruction relating to your
Account.

37.6.
Entirety of Agreement.

This Agreement, any attachments hereto, other agreements and policies referred to in this Agreement
(including the Website Postings and Risk Disclosures), and the terms and conditions contained in your
Account statements and confirmations, contain the entire agreement between Robinhood and you and
supersede all prior or contemporaneous communications and proposals, whether electronic, oral, or
written, between Robinhood and you, provided, however, that any and all other agreements between
Robinhood and you, not inconsistent with this Agreement, will remain in full force and effect.

37.7.
Amendment.

Robinhood may at any time amend this Agreement and any other agreement or document incorporated
or referenced in this Agreement without prior notice to you. The current version of the Agreement will be
posted in the Disclosure Library, and your continued Account activity (including accessing the Platform or
submitting an order or instruction) after such amendment constitutes your agreement to be bound by all
then-in-effect amendments to the Agreement, regardless of whether you have actually reviewed them.
Continued use of the Platform or any other Robinhood services after such posting will constitute your
acknowledgment and acceptance of such amendment. You agree to regularly consult the Website and
the Disclosure Library for up-to-date information about Robinhood services and any modifications to this
Agreement, Risk Disclosures, or any other agreement incorporated or referenced in this Agreement or
related to services provided to you by Robinhood. Robinhood is not bound by any verbal statements that
seek to amend the Agreement. Any communication from you that purports to amend or supplement the
terms of this Agreement or impose other terms on Robinhood will only take effect if agreed to in writing
and signed by one of our authorized signatories.

37.8.
Termination.

Robinhood may terminate this Agreement, or close, deactivate, or block access to your Account at any
time in its sole discretion. You will remain liable to Robinhood for all obligations incurred in your Account,
pursuant to this Agreement, or otherwise, whether arising before or after termination. You may terminate
this Agreement after paying any Obligations owed upon written notice. This Agreement survives
termination of your Account.
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If Robinhood terminates this Agreement or closes or deactivates your Account or any services related to
your Account, you agree that Robinhood is authorized to (i) liquidate any Property in your Account and
send you any net proceeds (after satisfying any Obligations), and (iii) close your Account. This is without
limitation to Robinhood’s other rights under this Agreement or otherwise.

Robinhood will not be responsible for any Losses caused by Robinhood discontinuing or closing your
Account or any services, or any liquidation of your Property or closure of your Account, including any tax
liabilities.

37.9.
No Waiver; Cumulative Nature of Rights and Remedies.

You understand that Robinhood’s failure to insist at any time upon strict compliance with any term
contained in this Agreement, or any delay or failure on Robinhood’s part to exercise any power or right
given to Robinhood in this Agreement, or a continued course of such conduct on Robinhood’s part, shall
at no time operate as a waiver of such power or right, nor shall any single or partial exercise preclude
any other further exercise. All rights and remedies given to Robinhood in this Agreement are cumulative
and not exclusive of any other rights or remedies to which Robinhood is entitled.

37.10.
International Customers.

The products and services described on the Website are offered only to customers located in the United
States. The Platform shall not be considered a solicitation for or offering of any investment product or
service to any person outside the United States. You understand that Robinhood is based in the United
States and that Robinhood accepts only U.S. currency in Robinhood’s customer accounts.

38.
Governing Law.
This Agreement and all transactions made in your Account shall be governed by the laws of the State of
California (regardless of the choice of law rules thereof), except to the extent governed by the federal
securities laws, FINRA Rules, and the regulations, customs and usage of the exchanges or market (and
its clearing house) on which transactions are executed.

39.
Arbitration.
A. This Agreement contains a pre-dispute arbitration clause. By signing an arbitration agreement,
the parties agree as follows: (1) All parties to this Agreement are giving up the right to sue each
other in court, including the right to a trial by jury, except as provided by the rules of the
arbitration forum in which a claim is filed. (2) Arbitration awards are generally final and binding; a
party’s ability to have a court reverse or modify an arbitration award is very limited. (3) The ability
of the parties to obtain documents, witness statements and other discovery is generally more
limited in arbitration than in court proceedings. (4) The arbitrators do not have to explain the
reason(s) for their award unless, in an eligible case, a joint request for an explained decision has
been submitted by all parties to the panel at least 20 days prior to the first scheduled hearing date.
(5) The panel of arbitrators will typically include a minority of arbitrators who were or are affiliated
with the securities industry. (6) The rules of some arbitration forums may impose time limits for
bringing a claim in arbitration. In some cases, a claim that is ineligible for arbitration may be
brought in court. (7) The rules of the arbitration forum in which the claim is filed, and any
amendments thereto, shall be incorporated into this Agreement.
B. Any controversy or claim arising out of or relating to this Agreement, any other agreement
between you and Robinhood, any Account established hereunder, any transaction therein, shall
be settled by arbitration before FINRA Dispute Resolution, Inc. (“FINRA DR”) in accordance with
the rules of FINRA DR.

C. If you are a foreign national, non-resident alien, or if you do not reside in the United States, you
agree to waive your right to file an action against Robinhood in any foreign venue.

32
any claims encompassed by the putative class action until: (1) the class certification is denied; or
(2) the class is decertified; or (3) the customer is excluded from the class by the court. Such
forbearance to enforce an agreement to arbitrate shall not constitute a waiver of any rights under
this Agreement except to the extent stated herein.

ACCEPTED AND AGREED: You acknowledge that you have read the preceding terms and conditions of
this Agreement, that you understand them and that you hereby manifest your assent to, and your
agreement to comply with, those terms and conditions by accepting this agreement. YOU ALSO
UNDERSTAND THAT BY ACCEPTING THIS AGREEMENT YOU HAVE ACKNOWLEDGED THAT
THIS AGREEMENT CONTAINS A PREDISPUTE ARBITRATION CLAUSE IN SECTION 39
HEREIN. YOU ALSO AGREE THAT (1) ANY OF YOUR MARGIN ACCOUNT SECURITIES MAY BE
BORROWED BY ROBINHOOD OR LOANED TO OTHERS; (2) YOU HAVE RECEIVED OF A COPY
OF THIS AGREEMENT AND (3) YOU HAVE REVIEWED A COPY OF THE MARGIN DISCLOSURE
STATEMENT, (4) YOU HAVE BEEN PROVIDED WITH AND AGREE TO THE ROBINHOOD
FINANCIAL LLC FORM CRS, ROBINHOOD TERMS AND CONDITIONS, RHF USE AND RISK
DISCLOSURES, ROBINHOOD FINANCIAL PRODUCT FEATURES DISCLOSURES, DAY TRADING
RISK DISCLOSURE, EXTENDED HOURS TRADING DISCLOSURE, ETF DISCLOSURE, RHF FUNDS
AVAILABILITY, RHF BUSINESS CONTINUITY PLAN SUMMARY, AND FINRA PUBLIC DISCLOSURE
PROGRAM, WHICH ARE INCORPORATED BY REFERENCE INTO THIS AGREEMENT.

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Appendix A: Electronic Fund Transfer Services Disclosures
Addendum

The following disclosures apply to your use of the Robinhood Debit Card services.

Solely for purposes of these disclosures: (i) references to the Bank shall include any financial institution that
issues the Card or provides services in connection with ACH, Move Money, or other EFT transactions; (ii)
“you” and “your” mean the owner of the Account; and (iii) “we” and “us” means Robinhood and the Bank
collectively.

1.
Your Liability.
Tell us AT ONCE if you believe your Card or PIN has been lost or stolen, or if you believe that
an electronic fund transfer has been made without your permission. Telephoning is the best
way of keeping your possible losses down. You could lose all the Available Funds in your
Account. If you tell us within two Business Days after you learn of the loss or theft of your Card
or PIN, you can lose no more than $50 if someone used your Card or PIN without your
permission.

If you do NOT tell us within two Business Days after you learn of the loss or theft of your Card or PIN, and
we can prove that it could have stopped someone from using your Card or PIN without your permission if
you had told us, you could lose as much as $500.

Also, if your statement shows transfers that you did not make, including those made by Card, PIN or
other means, tell us at once. If you do not tell us within 60 days after the statement was mailed to you, or
otherwise made available to you, you may not get back any money you lost after the 60 days if we can
prove that we could have stopped someone from taking the money if you had told us in time. If a good
reason (such as a long trip or a hospital stay) kept you from telling us, we will extend the time periods.

2.
Contact in event of unauthorized transfer.

If you believe your Card or PIN has been lost or stolen, call: 888-275-8523 or write: Robinhood at 85
Willow Road, Menlo Park, CA 94025 or contact us by visiting support.robinhood.com or email us at
help@robinhood.com.

You should also call the number listed above, visit support.robinhood.com, email us at
help@robinhood.com or write to us at the address above if you believe a transfer has been made without
your permission.

3.
Business Days

For purposes of these disclosures, our business days are Monday through Friday, excluding U.S.
Federal Holidays.

4.
Transfer Types and Limitations.
You may use your Card to make purchases at any merchant that accepts Mastercard debit cards or
debit cards of other networks in which the Bank participates, and to make ATM withdrawals, in each
case subject to the Available Funds in your Account, the transaction limits described below, and the
other terms and conditions of this Agreement. You acknowledge and agree that the value available to
you for use with the Card is limited to the Available Funds in your Account. So long as you do not
exceed the Available Funds in your Account, you may use the Card to purchase goods or services
wherever the Card is honored, and to obtain cash by initiating cash withdrawal transactions through the
Card from any financial institution or ATM that accepts the Card. Each time you use the Card, you
authorize us to reduce the Available Funds in your Account by the amount of the purchase or withdrawal
and any applicable fees, costs, or holdings. Nevertheless, if you exceed the Available Funds in your
Account you shall remain fully liable to us for the amount of the transactions and any applicable fees
and charges.

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You may also make ACH withdrawals from your Account, either originated through us or originated by
a third party (a “non-originated” withdrawal), subject to the Available Funds in your Account, the
transaction limits described below, and the other terms and conditions of this Agreement. You also may
make ACH deposits to your Account, either originated through us or originated by a third party (a “non-
originated” deposit), subject to the transaction limits described below.

There are limitations on the frequency and dollar amount of transfers you may make. Transfer limits for
Originated ACH, Debit Card Funding, and Instant Bank Transfers are calculated by aggregating the
amount of such transactions in your brokerage Account as well as the amount of such transactions
originated in any other accounts you may hold with Robinhood affiliate companies. I understand and
agree Robinhood may change these limits at any time in its sole discretion and without advance notice to
Me, except as otherwise required by law. Higher limits may be available to Me, as determined by
Robinhood in its sole discretion, and will be set forth in the App, if applicable. I understand and agree
that Robinhood reserves the right to restrict, limit or delay any transfer or attempted transfer, for any
purpose including, but not limited to, suspected fraud or other illicit activity and for purposes of
maintaining account security. The following lists the limitations for each type of transaction:

Originated ACH Withdrawals:
Daily Limit: $50,000.00 and maximum of 5 withdrawals // Weekly Limit: N/A // Monthly Limit: N/A
Originated ACH Withdrawals submitted before 7 p.m. Eastern Time will be counted towards that
business day’s limits, otherwise, they will count towards the next business day’s limits.

Originated ACH Deposits:
Daily Limit: $50,000.00 and maximum of 5 deposits // Weekly Limit: N/A // Monthly Limit: N/A
Originated ACH Deposits submitted before 7 p.m. Eastern Time will be counted towards that business
day’s limits, otherwise, they will count towards the next business day’s limits.

Non-Originated ACH Withdrawals:
Daily Limit: $250,000.00 // Weekly Limit: N/A // Monthly Limit: N/A

Non-Originated ACH Deposits:
Daily Limit: $250,000.00 // Weekly Limit: N/A // Monthly Limit: N/A

Point of Sale Purchases with the Card:
Daily Limit: $5,000.00 // Weekly Limit: N/A // Monthly Limit: $15,000.00

ATM Withdrawals:
Daily Limit: $1010.00 // Weekly Limit: N/A // Monthly Limit: $5,000.00

Originated ACH:
Daily Limit: N/A, subject to the Weekly Limit // Weekly Limit: $2,999 // Monthly Limit: N/A

Debit Card Funding (“DCF”):
Daily Limit: $1,000 for deposits (maximum of 5 deposits) // $5,000 for withdrawals

Instant Bank Transfers (“IBT”):
Daily Limit: $5,000 withdrawals // Weekly Limit: N/A // Monthly Limit: N/A
IBT withdrawals and deposits submitted on or before 11:59 p.m. Eastern Time will be counted towards
that day’s limits, otherwise, they will count towards the next day’s limits.

If you make external transfers of funds from your Account via DCF or IBT, you will be charged a fee, as
outlined in the Fee Schedule.

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6.
Confidentiality.
We may disclose information to third parties about you, your Card, or the transfers you make:

1.
Where it is necessary or helpful for completing or correcting transactions and resolving claims
regarding transactions;
2.
In order to verify the existence and condition of your Card or your Account for a third party, such
as a credit bureau or merchant;
3.
In order to comply with a valid request by a government agency, a court order, or other legal or
administrative reporting requirements;
4.
If you consent by giving us your written permission;
5.
To our employees, auditors, affiliates, service providers, or attorneys as needed;
6.
In order to prevent, investigate or report possible illegal activity;
7.
In order to issue authorizations for transactions on the Card;
8.
As permitted by applicable law; or
9.
Otherwise as necessary to fulfill our obligations under this Agreement and the terms applicable
to the EFT service you are using.

Please see the Robinhood Privacy Policy, available in the Disclosure Library, and the applicable
Bank’s privacy policy, available at https://www.suttonbank.com/_/kcms-doc/85/49033/WK-Privacy-
Disclosure-1218.pdf, for further details. (The Robinhood Privacy Policy and the applicable Bank’s privacy
policy are referred to collectively as the “Privacy Policies”). You hereby agree to Robinhood’s and the
Bank’s collection, use, and sharing of information about you and the Card as provided in the Privacy
Policies, which are made a part of this Agreement. The Privacy Policies also tell you how you can (i) limit
the ways in which Bank and Robinhood share information about you, or (ii) request corrections to the
information that Bank or Robinhood maintain about you. You agree that information you provide in
connection with your Card or other EFT services you use is being provided directly to both Robinhood as
the holder of the Account associated with the service and the Bank as the Card issuer or provider of the
EFT service, as applicable.

7.
Documentation.
Terminal Transfers. You can get a receipt at the time you make any transfer to or from your Account
using an ATM from the AllPoint or MoneyPass ATM networks or at the point of sale.

Periodic Statements. You will get a monthly Account statement (unless there are no transfers in a
particular month). In any case you will get the statement at least quarterly. You may obtain information
about the Available Funds in your Account and a history of your Card transactions on the Platform.

Right to stop payment: If you have automatic recurring payments taken out of your Account, you can
stop any of these payments. Here’s how:

Call us at 888-275-8523, email us at help@robinhood.com, or write us at 85 Willow Road, Menlo
Park, CA 94025, in time for us to receive your request 3 Business Days or more before the payment
is scheduled to be made. If you call, we may also require you to put your request in writing and get it
to us within 14 days after you call.

Notice of varying amounts: If these regular payments vary in amount, the party you are going to pay is
responsible for telling you, 10 days before each payment, when it will be made and how much it will be.
(The party you are going to pay may allow you to choose to get this notice only when the payment would
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36
differ by more than a certain amount from the previous payment, or when the amount would fall outside
certain limits that you set.)

Liability for failure to stop payment of a preauthorized transfer: If you order us to stop a payment at
least three Business Days before the transfer is scheduled and we do not do so, we will be liable for your
losses or damages.

9.
Our Liability.
If we do not complete a transaction to or from your Account on time or in the correct amount according to
our Agreement with you, we will be liable for your losses or damages. However, there are some
exceptions. We will not be liable, for instance:

1. If through no fault of Robinhood or the Bank, you do not have enough Available Funds in your
Account to complete the transaction;

2. If a merchant refuses to accept your Card;

3. If the automated teller machine where you are making the transfer does not have enough cash;

4. If an electronic terminal where you are making a transaction does not operate properly, and you
knew about the problem when you initiated the transaction;

5. If access to your Card has been blocked after you reported your Card lost or stolen;

6. If there is a hold or your funds are subject to legal or administrative process or other
encumbrance restricting their use;

7. If Robinhood or the Bank have reason to believe the requested transaction is unauthorized;
8. If circumstances beyond the control of Robinhood or the Bank (such as fire, flood, or computer
or communication failure) prevent the completion of the transaction, despite reasonable
precautions that Robinhood or the Bank have taken; or

9. For any other exception stated in this Agreement with you or by applicable law.

10.
ATM Fees

If you withdraw funds from ATMs outside of the AllPoint or MoneyPass ATM networks, you may be
charged a fee by the ATM owner or operator or any network used (and you may be charged a fee for a
balance inquiry even if you do not complete a fund transfer).

11.
Errors or Questions About Electronic Transfers.

In case of errors or questions about your electronic transfers, including your Card transactions, telephone
us at 888-275-8523, write us at 85 Willow Road, Menlo Park, CA 94025, or email us at
help@robinhood.com as soon as you can, if you think your statement or receipt is wrong or if you need
more information about a transfer listed on the statement or receipt. We must hear from you no later than
60 days after you were sent the FIRST statement on which the problem or error appeared.

1. Tell us your name and account number.

2. Describe the error or the transfer you are unsure about, and explain as clearly as you can why
you believe it is an error or why you need more information.

3. Tell us the dollar amount of the suspected error.

If you tell us orally, we may require that you send us your complaint or question in writing within 10
Business Days.

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We will determine whether an error occurred within 10 Business Days after we hear from you and will
correct any error promptly. If we need more time, however, we may take up to 45 days to investigate
your complaint or question. If we decide to do this, we will credit your Account within 10 Business Days
for the amount you think is in error, so that you will have the use of the money during the time it takes us
to complete our investigation.

For errors involving new accounts, point-of-sale, or foreign-initiated transactions, we may take up to 90
days to investigate your complaint or question. For new accounts, we may take up to 20 Business Days
to credit your Account for the amount you think is in error.

We will tell you the results within three Business Days after completing our investigation. If we decide
that there was no error, we will send you a written explanation. You may ask for copies of the documents
that we used in our investigation.
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Revised June 9, 2021
Robinhood Market Data Addendum

This agreement (the “Market Data Addendum” or the “Addendum”) supplements and forms part of the
Robinhood Financial LLC & Robinhood Securities, LLC Customer Agreement (as supplemented,
updated and amended from time to time, the “Customer Agreement”). This is the “Market Data
Addendum” referred to in the Customer Agreement and incorporated by reference therein. Capitalized
terms used in this Market Data Addendum and not otherwise defined have the meanings given to
them in the Customer Agreement. This Market Data Addendum may be amended or supplemented
from time to time by notice, as set out in section 4 below.

AS SET OUT BELOW AND WITHOUT LIMITATION, TO RECEIVE NYSE MARKET DATA YOU
AGREE TO THE AGREEMENT FOR MARKET DATA DISPLAY SERVICES AT SECTION 3(A) AND
APPENDIX 1 OF THIS MARKET DATA ADDENDUM, TO RECEIVE NASDAQ MARKET DATA
YOU AGREE TO THE NASDAQ MARKET DATA AGREEMENT AT SECTION 3(B) OF THIS
MARKET DATA ADDENDUM, AND TO RECEIVE OTC MARKETS DATA YOU AGREE TO THE OTC
MARKETS SUBSCRIBER AGREEMENT REFERENCED AT SECTION 3(C)OF THIS MARKETS DATA
ADDENDUM.

1. No warranty; limitation of liability
Robinhood and/or its affiliates receive Market Data from industry sources and Third Party Providers.
Market Data is provided or made available to you on an "as is" and on an "as available" basis and should
not be considered as any form of advice or recommendation for you or your Account. Robinhood does
not endorse, approve, or provide any view or opinion on any Market Data. Neither Robinhood nor any
Third Party Provider (i) warrants or guarantees the accuracy, timeliness, completeness or correctness of
any Market Data, or (ii) warrants any results or interpretations from any use or reliance upon Market Data
for any purpose. Your use of any Market Data is at your own risk. Past performance is no guarantee of
future results.

NEITHER THE ROBINHOOD PARTIES NOR ANY THIRD PARTY PROVIDER SHALL BE LIABLE IN
ANY WAY FOR (A) ANY INACCURACY, ERROR OR DELAY IN, INTERRUPTION OR OMISSION
OF, ANY MARKET DATA, INFORMATION OR MESSAGE, OR THE TRANSMISSION OR
DELIVERY THEREOF; OR (B) ANY LOSSES (AS DEFINED IN THE CUSTOMER AGREEMENT)
OR DAMAGE ARISING FROM OR IN CONNECTION WITH MARKET DATA OR ANY SUCH
INACCURACY, ERROR, DELAY, INTERRUPTION OR OMISSION, WHETHER DUE TO ANY ACT
OR OMISSION BY ROBINHOOD OR A THIRD PARTY PROVIDER, OR OTHERWISE. ROBINHOOD
AND THE THIRD PARTY PROVIDER(S) ARE NOT RESPONSIBLE FOR, AND YOU AGREE NOT
TO HOLD ANY OF THEM LIABLE FOR, ANY LOSSES, LOST PROFITS, TRADING LOSSES OR
OTHER DAMAGES RESULTING FROM OR IN CONNECTION WITH YOUR USE OF ANY MARKET
DATA, OR FROM OR IN CONNECTION WITH ANY INACCURATE, DEFECTIVE OR UNAVAILABLE
MARKET DATA. THE LIMITATIONS OF LIABILITY IN THIS MARKET DATA ADDENDUM ARE IN
ADDITION TO AND WITHOUT PREJUDICE TO ANY OTHER LIMITATIONS OF LIABILITY IN THE
CUSTOMER AGREEMENT OR OTHER AGREEMENTS YOU MAY HAVE FROM TIME TO TIME WITH
ANY OTHER ROBINHOOD ENTITY OR WITH ANY THIRD PARTY PROVIDER.

We may remove, restrict or terminate access to or provision of any Market Data at any time, or change
any relevant Third Party Provider or any Market Data (and thereby the precise Market Data provided or
made available, or the manner in which any Market Data is provided or made available) at any time.

2.
Non-Professional; Restrictions on Use
You may only use (and represent to us that you will only use) Market Data provided to you in connection
with the Platform for your own personal, non-business use, and subject to the terms of the Customer
Agreement including this Market Data Addendum and the agreements constituted hereby.
You must not use Market Data for any purpose not directly related to the Platform or your Account,
and you must not provide, retransmit, redistribute or publish any Market Data to any other person or
entity.

Unless and until you have expressly notified us in writing to the contrary, you represent and warrant to us
on a continuing basis that you qualify as a “Non-professional”. If you think you are or might be a
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“Securities Professional” or if you think that you do not or might not qualify as a “Non-professional”, you
must contact us immediately at support@robinhood.com.

If you have told us in writing that you are a “Securities Professional” then you represent and warrant to us
that you are a Securities Professional, until you notify us in writing to the contrary.

For these purposes:

“Non-professional” means any natural person who receives market data solely for their own personal,
non-business use and who is not a “Securities Professional.”

A “Securities Professional” for these purposes includes an individual who, if working in the United
States, is:

(a) registered or qualified in any capacity with the Securities and Exchange Commission (the "SEC"),
the Commodities Futures Trading Commission, any state securities agency, any securities
exchange or association, or any commodities or futures contract market or association, or self-
regulatory body;

(b) engaged as an "investment advisor" as that term is defined in Section 202 (a)(11) of the
Investment Advisor's Act of 1940 (whether or not registered or qualified under that Act), or

(c) employed by a bank or other organization exempt from registration under Federal and/or state
securities laws to perform functions that would require that individual to be so registered or
qualified if they were to perform such functions for an organization not so exempt.

A person who works outside of the United States will be considered a “Securities Professional” if they
perform the same function(s) as a person who would be considered a “Securities Professional” in the
United States. Any use of Market Data for business, professional or other commercial purpose is not
compatible with Non-Professional status, even if the commercial use is on behalf of an organization that
is not in the securities industry.

You undertake to continually assess your status as to whether you are a Non-Professional or whether
you are a Securities Professional, and undertake to promptly notify us if your classification as a “Non-
professional” or a “Securities Professional” changes at any time whilst you have an Account. You
acknowledge that we have provided you with an Account and with Market Data in reliance on your
representations and warranties to us as to your status. You indemnify Robinhood for any fees, costs,
losses, liabilities or expenses that Robinhood may incur or suffer, directly or indirectly, in connection
with any such representation or warranty being incorrect or inaccurate in any respect when given or
repeated.

3.
Specific Terms required by certain Third Party Data Providers

A.
NYSE Market Data

Robinhood may provide or make available to you through the Platform certain Market Data being (a) last
sale information and quotation information relating to securities that are admitted to dealings on the New
York Stock Exchange, (b) such bond and other equity last sale and quotation information, and such
index and other market information, as United States-registered national securities exchanges and
national securities associations may make available and as the New York Stock Exchange may from
time to time designate as "Market Data"; and (c) all information that derives from any such information
(such data or information from time to time being “NYSE Market Data”).
To receive or have made available to you any NYSE Market Data, you enter into the “Agreement for
Market Data Display Services” in the form attached at Appendix 1 to this Market Data Addendum (the
“NYSE Market Data Agreement”) with Robinhood Financial.

The NYSE Market Data Agreement will be deemed to have been executed and entered into by you by
your agreement to the Customer Agreement and this Market Data Addendum, and in addition to being
incorporated into the Customer Agreement by virtue of this Market Data Addendum, constitutes a separate
agreement between you and Robinhood Financial. You acknowledge and agree that the NYSE Market
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Data Agreement is a legal, valid and binding contract between you (as Subscriber) and Robinhood
Financial, LLC (as Vendor).

B.
NASDAQ Market Data

Robinhood Financial may provide or may make available to you through the Platform certain Market Data
that consists of or includes Information owned or provided by NASDAQ (each as defined in paragraph 12
below). You agree to the terms set out in paragraphs 1-13 below (the “Nasdaq Market Data Agreement”),
which constitute a legally binding agreement between you and Robinhood Financial. Certain defined terms
are set out in paragraph 12.

1. Use of Data. You are only permitted to access, view, or use any Information for your personal,
non-business, use. You undertake to only use Information for your personal, non- business,
purposes. You agree not to sell, lease, furnish or otherwise permit or provide access to the
Information to any other Person or to any other office or place. You agree not to engage in the
operation of any illegal business use or permit anyone else to use the Information, or any part
thereof, for any illegal purpose or violate any NASDAQ or SEC Rule or other applicable law, rule
or regulation. You agree not to present the Information rendered in any unfair, misleading or
discriminatory format. to take reasonable security precautions to prevent unauthorized Persons
from gaining access to the Information.
2. Proprietary Data. You acknowledge and agree that (i) NASDAQ has proprietary rights to the
Information that originates on or derives from markets regulated or operated by NASDAQ, and
compilation or other rights to Information gathered from other sources; and (ii) NASDAQ's third-
party information providers have exclusive proprietary rights to their respective Information. In
the event of any misappropriation or misuse by you of any Information, NASDAQ or its third-
party information providers shall have the right to obtain injunctive relief for its respective
materials.
3. Modifications. NASDAQ may from time to time, in its sole discretion, make modifications to its
system or the Information. Such modifications may require corresponding changes to be made in
Robinhood's service or in the way Information is provided or presented to you, and may affect
your access to or use of some or all of the Information. Neither NASDAQ nor Robinhood shall
not be responsible for such effects.
4. Reporting and Audit. If requested by Robinhood Financial or NASDAQ, you undertake to
provide reasonable cooperation including: (i) promptly providing information or materials in
response to any reasonable request; and (ii) making available for examination all records,
reports, payments, and supporting documentation, in each case relating to the Information,
necessary to reach a conclusion as to your compliance with these terms.
5. System. You acknowledge that NASDAQ, in its sole discretion, may from time-to-time make
modifications to its system or the Information. Such modifications may require corresponding
changes to be made in the way Information may be displayed or provided to you. NASDAQ shall
not be responsible for such effects.
6. No endorsement. NASDAQ does not endorse or approve any equipment, Robinhood, or
Robinhood’s service. Robinhood makes no representations or warranties in connection with
NASDAQ or Information.
7. Limitations of Liability.
a. Except as may otherwise be set forth herein, NASDAQ shall not be liable to you or any
other Person for indirect, special, punitive, consequential or incidental loss or damage
(including, but not limited to, trading losses, loss of anticipated profits, loss by reason of
shutdown in operation or increased expenses of operation, cost of cover or other indirect
loss or damage) of any nature arising from any cause whatsoever, even if NASDAQ has
been advised of the possibility of such damages.
b. NASDAQ shall not be liable to you or any other Person for any unavailability,
interruption, delay, incompleteness or inaccuracy of the Information. This section shall
not relieve NASDAQ, you, or any other Person from liability for damages that result from
their own gross negligence or willful tortious misconduct or from personal injury or
wrongful death claims. You understand and agree that the terms of this section reflect a
reasonable allocation of risk and limitation of liability.
8. Disclaimers of Warranties. NASDAQ and its third-party information providers make no
warranties of any kind — express, implied or statutory (including without limitation, timeliness,
truthfulness, sequence, completeness, accuracy, freedom from interruption), any implied
warranties arising from trade usage, course of dealing, course of performance or the implied
warranties of merchantability or fitness for a particular use or purpose or noninfringement.
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9. Third-Party Information Providers’ limitation of liability. NASDAQ’s third-party information
providers shall have no liability for any damages for the accuracy of or for delays or omissions in
any of the Information provided by them, whether direct or indirect, lost profits, special or
consequential damages of you or any other Person seeking relief through you, even if the third-
party information providers have been advised of the possibility of such damages. In no event
will the liability of the third-party information providers or their affiliates to you or any other
Person seeking relief through you pursuant to any cause of action, whether in contract, tort or
otherwise, exceed the fee paid by you or any other Person seeking relief through you, as
applicable.
10. Claims and Losses. You will indemnify NASDAQ and hold NASDAQ and its employees,
officers, directors and other agents harmless from any and all Claims or Losses imposed on,
incurred by or asserted as a result of or relating to: (a) any noncompliance by you with the terms
and conditions hereof; (b) any third-party actions related to your receipt and use of the
Information, whether authorized or unauthorized; (c) a claim of infringement or other violation of
an intellectual property right by you or your actions or omissions, equipment or other property.
11. Termination. You acknowledge that NASDAQ, when required to do so in fulfillment of statutory
obligations, may by notice to Distributor unilaterally limit or terminate the right of any or all
Persons to receive or use the Information and that Distributor will immediately comply with any
such notice and will terminate or limit the furnishing of the Information and confirm such
compliance by notice to NASDAQ. Any affected Person will have available to it such procedural
protections as are provided by the Act and applicable rules thereunder. In the event of your
breach, discovery of the untruth of any of your representations, or where directed by the SEC in
its regulatory authority, NASDAQ may terminate this Nasdaq Market Data Agreement with not
less than three (3) days written notice to you provided either by NASDAQ or Robinhood.
12. Definitions. The following terms have the following meanings:
a. “Act” shall mean the Securities Exchange Act of 1934, applicable only to Information
disseminated from a NASDAQ Market in the United States.
b. “Information” means certain market data and other data disseminated that has been
collected, validated, processed, and recorded by the System or other sources made
available for transmission to and receipt from either a Vendor or from NASDAQ relating
to: (a) eligible securities or other financial instruments, markets, products, vehicles,
indicators, or devices; (b) activities of NASDAQ; (c) other information and data from
NASDAQ. Information also includes any element of Information as used or processed in
such a way that the Information can be identified, recalculated or re- engineered from
the processed Information or that the processed Information can be used as a substitute
for Information.
c. “NASDAQ” means collectively NASDAQ, Inc., a Delaware limited liability company and
its subsidiaries and Affiliates.
d. “NASDAQ Markets” shall mean the regulated securities and options exchange
subsidiaries of NASDAQ and other regulated market subsidiaries of NASDAQ, including,
but not limited to, The NASDAQ Stock Market.
e. “Person” means any natural person, proprietorship, corporation, partnership or other
entity whatsoever.
f.
“SEC” means the U.S. Securities and Exchange Commission.
g. “System” means any system NASDAQ has developed for the creation and/or
dissemination of Information.
13. Amendments. This Nasdaq Market Data Agreement may be amended or modified as set out in
section 4 of this Market Data Addendum.

C.
OTC Markets Data

Robinhood may provide or make available to you through the Platform certain Market Data that is
provided directly or indirectly by OTC Market Group, Inc. and its affiliates (“OTC Markets Data”). As a
condition of receiving any OTC Markets Data, you are deemed to enter into an agreement with
Robinhood Financial in the form of the OTC Markets Subscriber Agreement, as defined below, as
amended from time to time.

The OTC Markets Group Market Data Subscriber Agreement in the form attached as Appendix A to the
OTC Markets Group Market Data Distribution Agreement (the “OTC Markets Subscriber Agreement”)
(which may be described as the ‘Market Data Distribution Agreement Subscriber
Addendum’) is incorporated by reference into this Market Data Addendum. For the purposes of the OTC
Markets Subscriber Agreement Robinhood Financial is the “Vendor”, and you are the
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“Subscriber”. The current version of the OTC Markets Subscriber Agreement is available on the OTC
Markets Group website (https://www.otcmarkets.com/market-data/agreements-and-forms) or on request
from Robinhood Financial.

By opening an Account or accessing the Platform you expressly acknowledge that (i) you have read and
understood the OTC Markets Subscriber Agreement, and (ii) that OTC Markets Group and its affiliates
are a third party beneficiary of the agreement between you and Robinhood in the form of the OTC
Markets Subscriber Agreement. The OTC Markets Subscriber Agreement (and therefore the agreement
in the form of the OTC Markets Subscriber Agreement between you and Robinhood Financial constituted
by this Market Data Addendum) may be amended by OTC Markets Group from time to time.

D.
FactSet Market Data
Robinhood may provide or make available to you through the Platform certain Market Data that is
provided directly or indirectly by FactSet Research Systems, Inc. or its affiliates (“FactSet”) (such Market
Data, “FactSet Market Data”). In respect of any FactSet Market Data that is provided or made available
to you, you will receive only a limited right to use that FactSet Market Data for your own non- commercial
use. FactSet Market Data is copyrighted works of FactSet and must not be reproduced, republished,
retransmitted, or redistributed in any form. Neither Robinhood nor FactSet makes any warranty, express
or implied, as to the accuracy of the FactSet Market Data or results obtained from any use of the FactSet
Market Data. FactSet does not make any express or implied warranties of any kind regarding the
FactSet Market Data, including, without limitation, any warranty of merchantability or fitness for a
particular purpose or use. FactSet will not be liable for any lost profits or other incidental or consequential
damages in connection with Your use of the FactSet Market Data. Copyright © 2020 FactSet Research
Systems Inc. All rights reserved.

E.
Morningstar Market Data

Robinhood may provide or make available to you through the Platform certain Market Data that is
provided directly or indirectly by Morningstar, Inc. or its affiliates (“Morningstar”) (such Market Data,
“Morningstar Market Data”) ©2020 Morningstar. All Rights Reserved. The Morningstar Market Data: (1)
is proprietary to Morningstar Research Services LLC, Morningstar, Inc. and/or their content providers; (2)
may not be copied or distributed; and (3) is not warranted to be accurate, complete or timely. Neither
Morningstar Research Services, Morningstar nor their content providers are responsible for any
damages or losses arising from any use of this information. Morningstar does not make any express or
implied warranties of any kind regarding the Morningstar Market Data, including, without limitation, any
warranty of merchantability or fitness for a particular purpose or use. Access to or use of any Morningstar
Market Data does not establish an advisory or fiduciary relationship with Morningstar Research Services,
Morningstar, Inc. or their content providers. Past performance is no guarantee of future results.

4. Amendments and Modifications
THIS MARKET DATA ADDENDUM AND ITS TERMS AND ANY AND ALL AGREEMENTS
CONSTITUTED BY IT MAY BE SUPPLEMENTED OR AMENDED FROM TIME TO TIME BY
ROBINHOOD BY NOTICE TO YOU, AND SUCH NOTICE REQUIREMENT MAY BE SATISFIED BY
THE REVISED MARKET DATA ADDENDUM BEING POSTED ON THE ROBINHOOD WEBSITE. BY
CONTINUING TO MAINTAIN ANY ACCOUNT OR ACCESS THE PLATFORM OR ANY MARKET
DATA, YOU ARE DEEMED TO ACCEPT THE TERMS OF THE REVISED MARKET DATA ADDENDUM
AND WILL BE LEGALLY BOUND BY ITS TERMS.

5. Governing Law and Jurisdiction
Section 38 (Governing Law) and Section 39 (Arbitration) of the Customer Agreement apply to and are
incorporated into this Addendum as if set out in full.

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APPENDIX 1: NYSE Market Data Agreement

AGREEMENT FOR MARKET DATA DISPLAY SERVICES
(Usage-Based Services/Nonprofessional Subscriber Status) (Electronic Version)

Robinhood Financial, LLC (“Robinhood Financial”) agrees to make certain data (referred to in this
agreement as "Market Data") available to you pursuant to the terms and conditions set forth in this
agreement. By agreeing to the Customer Agreement and the Market Data Addendum you agree to
comply with the terms and conditions of this agreement. References to “Subscriber” or “you” in this
agreement means the Customer under the Customer Agreement, and references to “this agreement”
means the agreement between you and Robinhood Financial constituted by these terms.

1. Market Data Definition – For all purposes of this agreement, "Market Data" means (a) last
sale information and quotation information relating to securities that are admitted to dealings on the
New York Stock Exchange ("NYSE"), (b) such bond and other equity last sale and quotation
information, and such index and other market information, as United States-registered national
securities exchanges and national securities associations (each, an "Authorizing SRO") may make
available and as the NYSE may from time to time designate as "Market Data"; and (c) all information
that derives from any such information.

2. Proprietary Nature of Data – Subscriber understands and acknowledges that each
Authorizing SRO and Other Data Disseminator has a proprietary interest in the Market Data that
originates on or derives from it or its market(s).

3. Enforcement – Subscriber understands and acknowledges that (a) the Authorizing SROs
are third-party beneficiaries under this Agreement and (b) the Authorizing SROs or their authorized
representative(s) may enforce this Agreement, by legal proceedings or otherwise, against
Subscriber or any person that obtains Market Data that is made available pursuant to this
Agreement other than as this Agreement contemplates. Subscriber shall pay the reasonable
attorney's fees that any Authorizing SRO incurs in enforcing this Agreement against Subscriber.

4. Data Not Guaranteed – Subscriber understands that no Authorizing SRO, no other entity
whose information is made available over the Authorizing SROs' facilities (an "Other Data
Disseminator") and no information processor that assists any Authorizing SRO or Other Data
Disseminator in making Market Data available (collectively, the "Disseminating Parties") guarantees
the timeliness, sequence, accuracy or completeness of Market Data or of other market information or
messages disseminated by any Disseminating Party. Neither Subscriber nor any other person shall
hold any Disseminating Party liable in any way for (a) any inaccuracy, error or delay in, or omission of,
(i) any such data, information or message or (ii) the transmission or delivery of any such data,
information or message, or (b) any loss or damage arising from or occasioned by (i) any such
inaccuracy, error, delay or omission, (ii) non- performance or (iii) interruption in any such data,
information or message, due either to any negligent act or omission by any Disseminating Party, to any
"force majeure" (e.g., flood, extraordinary weather conditions, earthquake or other act of God, fire, war,
insurrection, riot, labor dispute, accident, action of government, communications or power failure,
equipment or software malfunction) or to any other cause beyond the reasonable control of any
Disseminating Party.

5. Permitted Use – Subscriber shall not furnish Market Data to any other person or entity.
Subscriber has represented and warranted to If Subscriber is a Nonprofessional Subscriber, he or she
shall receive Market Data solely for his or her personal, non-business use. If Subscriber receives
Market Data other than as a Nonprofessional Subscriber, it shall use Market Data only for its individual
use in its business.

6. Dissemination Discontinuance or Modification – Subscriber understands and
acknowledges that, at any time, the Authorizing SROs may discontinue disseminating any category of
Market Data, may change or eliminate any transmission method and may change transmission speeds
or other signal characteristics. The Authorizing SROs shall not be liable for any resulting liability, loss or
damages that may arise therefrom.
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7. Duration; Survival – This Agreement remains in effect for so long as Subscriber has the
ability to receive Market Data as contemplated by this Agreement. In addition, Robinhood Financial may
terminate this Agreement at any time, whether at the direction of the Authorizing SROs or otherwise.
Paragraphs 2, 3 and 4, and the first two sentences of Paragraph 8, survive any termination of this
Agreement.

8. Miscellaneous – The laws of the State of New York shall govern this Agreement and it shall
be interpreted in accordance with those laws. This Agreement is subject to the Securities Exchange Act
of 1934, the rules promulgated under that act, and the joint-industry plans entered into pursuant to that
act. This writing contains the entire agreement between the parties in respect of its subject matter.
Subscriber may not assign all or any part of this Agreement to any other person. The person executing
this Agreement below represents and warrants that he or she has legal capacity to contract and, if that
person is executing this Agreement on behalf of a proprietorship or a business, partnership or other
organization, represents and warrants that he or she has actual authority to bind the organization.
By agreeing to this agreement, you acknowledge that you have read the preceding terms and
conditions of this agreement, that you understand them and that you manifest your assent to, and your
agreement to comply with, those terms and conditions by agreeing to this agreement.

9. Nonprofessional Subscriber definition -"Nonprofessional Subscriber" means any natural
person who receives market data solely for his/her personal, non- business use and who is not a
“Securities Professional.” A “Securities Professional” includes an individual who, if working in the United
States, is:

(a)
registered or qualified with the Securities and Exchange Commission (the "SEC"), the
Commodities Futures Trading Commission, any state securities agency, any securities
exchange or association, or any commodities or futures contract market or association.

(b)
engaged as an "investment advisor" as that term is defined in Section 202 (a) (11) of
the Investment Advisor's Act of 1940 (whether or not registered or qualified under that
Act), or

(c)
employed by a bank or other organization exempt from registration under Federal
and/or state securities laws to perform functions that would require him or her to be so
registered or qualified if he or she were to perform such functions for an organization
not so exempt.

A person who works outside of the United States will be considered a “Securities Professional” if he or
she performs the same functions as someone who would be considered a “Securities Professional” in the
United States.

Subscriber may not receive Market Data as a “Nonprofessional Subscriber” unless they fall within
Paragraph 9’s definition of “Nonprofessional Subscriber.”

10.
Permitted Receipt - Subscriber may not receive Market Data from Robinhood
Financial, and Robinhood Financial may not provide Market Data to Subscriber, on a
“Nonprofessional Subscriber” basis unless Robinhood Financial first properly determines that
Subscriber qualifies as a “Nonprofessional Subscriber” as defined in Paragraph 9 and Subscriber in
fact qualifies as a “Nonprofessional Subscriber.”

11.
Permitted Use – If Subscriber is a Nonprofessional Subscriber, he or she shall
receive Market Data solely for his or her personal, non-business use.

12.
About you - in connection with your Account and the Customer Agreement you
have provided to Robinhood Financial the following information, and you represent and warrant that
such information continues to be true, complete and accurate in all respects:
●
Your name
●
Your address
●
Your employer
●
Your occupation and job description

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In connection with your Account and the Customer Agreement you have confirmed to
Robinhood Financial that you are not a Securities Professional, and in particular you confirm and
warrant as follows:
●
You use Market Data solely for your personal, non-business use
●
You do not receive Market Data for your business or any other entity
●
You are not currently registered or qualified with the SEC or the CFTC
●
You are not currently registered or qualified with any securities agency, any securities
exchange, association or regulatory body, or any commodities or futures contract
market, association or regulatory body, in the United States or elsewhere
●
Whether you are located within or outside the United States, you do not perform any
functions that are similar to those that require an individual to register or qualify with the
SEC, the CFTC, any other securities agency or regulatory body, any securities
exchange or association, or any commodities or futures contract market, association or
regulatory body
●
You are not engaged to provide investment advice to any individual or entity
●
You are not engaged as an asset manager
●
You do not use the capital of any other individual or entity in the conduct of your trading
●
You do not conduct trading for the benefit of a corporation, partnership, or other entity
●
You have not entered into any agreement to share the profit of your trading or receive
compensation for your trading activities
●
You are not receiving office space, and equipment or other benefits in exchange for
your trading or work as a financial consultant to any person, firm, or business entity.
●
You will notify and update Robinhood Financial promptly in writing of any change in
your circumstances that may cause you to cease to qualify as a Nonprofessional
Subscriber or that may change your responses to any of the following statements or
may cause any of them to be untrue in respect of you.

13.
Certification. By executing this agreement, Subscriber hereby certifies that he or
she falls within Paragraph 9's definition of "Nonprofessional Subscriber" and that the personal and
employment information that he or she has provided to Robinhood Financial in connection with their
Account and confirmed in Paragraph 12 is truthful and accurate.
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Exhibit 3

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Revised June 22, 2020
Robinhood Financial LLC & Robinhood Securities, LLC Customer Agreement
In consideration of Robinhood Financial LLC, Robinhood Securities, LLC, and their agents and assigns
(collectively, "Robinhood") opening one or more accounts on my behalf ("My Account(s)" or the
"Account(s)") for the purchase, sale or carrying of securities or contracts relating thereto and/or the
borrowing of funds, which transactions are cleared through Robinhood Securities, I represent and agree
with respect to all Accounts, whether margin or cash, to the terms set forth below (the "Agreement").
When used in this Agreement, the words "I", "Me", "My", "We", or "Us" mean the owner(s) of the
Account. For purposes of this Agreement, Business Days are Monday through Friday, excluding federal
holidays. Any references to "days" found in this Agreement are calendar days unless indicated
otherwise.
I UNDERSTAND THAT THE TERMS AND CONDITIONS OF THIS AGREEMENT GOVERN ALL
ASPECTS OF MY RELATIONSHIP WITH ROBINHOOD REGARDING MY ACCOUNTS. I WILL
CAREFULLY READ, UNDERSTAND AND ACCEPT THE TERMS AND CONDITIONS OF THIS
AGREEMENT BEFORE I CLICK "SUBMIT APPLICATION" OR OTHER SIMILARLY WORDED
BUTTON. IF I HAVE ANY QUESTIONS ABOUT ANY OF THE PROVISIONS IN THIS AGREEMENT,
I WILL EMAIL HELP@ROBINHOOD.COM. I UNDERSTAND THAT CLICKING "SUBMIT
APPLICATION" IS THE LEGAL EQUIVALENT OF MY MANUALLY SIGNING THIS AGREEMENT
AND I WILL BE LEGALLY BOUND BY ITS TERMS AND CONDITIONS. BY ENTERING INTO
THIS AGREEMENT, I ACKNOWLEDGE RECEIPT OF THE ROBINHOOD PRIVACY POLICY AND
PRIVACY AND SECURITY STATEMENT. I UNDERSTAND THAT THIS AGREEMENT MAY BE
AMENDED FROM TIME TO TIME BY ROBINHOOD, WITH REVISED TERMS POSTED ON THE
ROBINHOOD WEBSITE. I AGREE TO CHECK FOR UPDATES TO THIS AGREEMENT. I
UNDERSTAND THAT BY CONTINUING TO MAINTAIN MY SECURITIES BROKERAGE
ACCOUNT WITHOUT OBJECTING TO ANY REVISED TERMS OF THIS AGREEMENT, I AM
ACCEPTING THE TERMS OF THE REVISED AGREEMENT AND I WILL BE LEGALLY BOUND
BY ITS TERMS AND CONDITIONS. IF I REQUEST OTHER SERVICES PROVIDED BY
ROBINHOOD THAT REQUIRE ME TO AGREE TO SPECIFIC TERMS AND CONDITIONS
ELECTRONICALLY (THROUGH CLICKS OR OTHER ACTIONS) OR OTHERWISE, SUCH TERMS
AND CONDITIONS WILL BE DEEMED AN AMENDMENT AND WILL BE INCORPORATED INTO
AND MADE PART OF THIS AGREEMENT. I ALSO UNDERSTAND THAT BY CLICKING "SUBMIT
APPLICATION" I HAVE ACKNOWLEDGED THAT THIS AGREEMENT CONTAINS A PREDISPUTE
ARBITRATION CLAUSE IN SECTION 38 HEREIN.
1. Capacity and Status.
If an individual, I am of legal age under the laws of the state where I reside and authorized to enter into
this Agreement. If an entity, I am duly formed, validly existing and in good standing in My state of
organization, have full power and authority to enter and perform this Agreement, and the persons signing
the account application are fully authorized to act on My behalf. No person, except Myself, has any
interest in the Account opened pursuant to this Agreement. I acknowledge that unless Robinhood
receives written objection from Me, Robinhood may provide My name, address, and securities positions
to requesting companies in which I hold securities. Except as otherwise disclosed to Robinhood in
writing, neither I nor any member of My immediate family is an employee of any exchange, any
corporation of which any exchange owns a majority of the capital stock, a member of any exchange or
self-regulatory organization, a member of any firm or member corporation registered on any exchange, a
bank, trust company, insurance company or any corporation, firm or individual engaged in the business
of dealing either as a broker-dealer or as principal in securities. I understand and agree that I am
obligated to promptly notify Robinhood in writing if I or a member of My immediate family becomes
registered or employed in any of the above-described capacities. Except as otherwise disclosed to
Robinhood in writing, I am not a Professional (as defined below). I further agree to promptly notify
Robinhood in writing if I am now or if I become a Professional or an officer, director or 10% stockholder
of any publicly traded company.
2. Market Data.
Robinhood may choose to make certain market data available to Me pursuant to the terms and
conditions set forth in this Agreement. By executing this Agreement, I agree to comply with those terms
and conditions.
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A. Definitions.
"Market Data" means (a) last sale information and quotation information relating to securities that
are admitted to dealings on the New York Stock Exchange ("NYSE"), (b) such bond and other
equity last sale and quotation information, and such index and other market information, as United
States-registered national securities exchanges and national securities associations (each, an
"Authorizing SRO") may make available and as the NYSE may from time to time designate as
"Market Data"; and (c) all information that derives from any such information.
"Nonprofessional" means any natural person who receives market data solely for his/her
personal, non- business use and who is not a "Professional." A "Professional" includes an
individual who, if working in the United States, is: (i) registered or qualified with the Securities and
Exchange Commission (the "SEC"), the Commodity Futures Trading Commission (the "CFTC"),
any state securities agency, any securities exchange or association, or any commodities or
futures contract market or association; (ii) engaged as an "investment advisor" as that term is
defined in Section 202 (a) (11) of the Investment Advisers Act of 1940 (whether or not registered
or qualified under that Act), or (iii) employed by a bank or other organization exempt from
registration under federal and/or state securities laws to perform functions that would require him
or her to be so registered or qualified if he or she were to perform such functions for an
organization not so exempt. A person who works outside of the United States will be considered a
"Professional" if he or she performs the same functions as someone who would be considered a
"Professional" in the United States.
B. Provisions Applicable to All Users.
Proprietary Nature of Data. I understand and acknowledge that each Authorizing SRO and Other
Data Disseminator (as defined below) has a proprietary interest in the Market Data that originates
on or derives from it or its market(s). I agree not to reproduce, distribute, sell or commercially
exploit the Market Data in any manner.
Enforcement. I understand and acknowledge that (a) the Authorizing SROs are third-party
beneficiaries under this Agreement and (b) the Authorizing SROs or their authorized
representative(s) may enforce this Agreement, by legal proceedings or otherwise, against Me or
any person that obtains Market Data that is made available pursuant to this Agreement other than
as this Agreement contemplates.
Data Not Guaranteed. I understand that neither Robinhood nor any Authorizing SRO, other entity
whose information is made available over the Authorizing SROs' facilities (an "Other Data
Disseminator"), or information processor that assists any Authorizing SRO or Other Data
Disseminator in making Market Data available (collectively, the "Disseminating Parties")
guarantees the timeliness, sequence, accuracy, completeness, reliability, or content of Market
Data or of other market information or messages disseminated to or by any Disseminating Party. I
understand that neither Robinhood Financial nor any Disseminating Party guarantees the
timeliness, sequence, accuracy, completeness, reliability or content of market information, or
messages disseminated to or by any party. I understand that neither Robinhood Financial nor any
Disseminating Party warrants that the service provided by any such entity will be uninterrupted or
error-free. I further understand that Market Data by Xignite provides market data to Robinhood
Financial customers. NEITHER ROBINHOOD FINANCIAL, ANY OF ITS AFFILIATES, THEIR
RESPECTIVE OFFICERS OR EMPLOYEES, NOR ANY DISSEMINATING PARTY SHALL BE
LIABLE IN ANY WAY FOR (A) ANY INACCURACY, ERROR OR DELAY IN, OR OMISSION
OF, (I) ANY MARKET DATA, INFORMATION OR MESSAGE, OR (II) THE TRANSMISSION
OR DELIVERY OF ANY SUCH DATA, INFORMATION OR MESSAGE; OR (B) ANY LOSS (AS
DEFINED IN THIS AGREEMENT) OR DAMAGE ARISING FROM OR OCCASIONED BY (I)
ANY SUCH INACCURACY, ERROR, DELAY OR OMISSION, (II) NON-PERFORMANCE OR
III) INTERRUPTION IN ANY SUCH MARKET DATA, INFORMATION, OR MESSAGE,
WHETHER DUE TO ANY ACT OR OMISSION BY ROBINHOOD FINANCIAL, ANY OF ITS
AFFILIATES, THEIR RESPECTIVE OFFICERS OR EMPLOYEES, OR ANY DISSEMINATING
PARTY, OR TO ANY "FORCE MAJEURE" (E.G., FLOOD, EXTRAORDINARY WEATHER
CONDITIONS, EARTHQUAKE OR OTHER ACT OF GOD, FIRE, WAR, INSURRECTION,
RIOT, LABOR DISPUTE, ACCIDENT, ACTION OF GOVERNMENT, OR COMMUNICATIONS
OR POWER FAILURE, EQUIPMENT OR SOFTWARE MALFUNCTION) OR ANY OTHER
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CAUSE BEYOND THE REASONABLE CONTROL OF ROBINHOOD FINANCIAL, ITS
AFFILIATES, THEIR RESPECTIVE OFFICERS AND EMPLOYEES, OR ANY
DISSEMINATING PARTY.
Permitted Use. I shall not furnish Market Data to any other person or entity. If I receive Market
Data other than as a Nonprofessional, I shall use Market Data only for My individual use.
Dissemination, Discontinuance, or Modification. I understand and acknowledge that, at any time,
the Authorizing SROs may discontinue disseminating any category of Market Data, may change
or eliminate any transmission method and may change transmission speeds or other signal
characteristics. The Authorizing SROs shall not be liable for any resulting liability, loss or
damages that may arise therefrom.
Duration; Survival. This Section 2 of this Agreement remains in effect for so long as I have the
ability to receive Market Data as contemplated by this Section 2. In addition, Sections 2(B)(1)-(3)
and the first two sentences of Section 2(B)(7), survive any termination of this Agreement.
Miscellaneous. The laws of the State of New York shall govern this Section 2 and it shall be
interpreted in accordance with those laws. This Subsection is subject to the Securities Exchange
Act of 1934, the rules promulgated under that act, and the joint-industry plans entered into
pursuant to that act.
C. Provisions Applicable to Nonprofessionals.
Permitted Receipt. I understand that I may not receive Market Data from Robinhood as a
Nonprofessional, and Robinhood may not provide Market Data to Me as a Nonprofessional,
unless Robinhood first properly determines that I qualify as a Nonprofessional as defined above
and I in fact qualify as a Nonprofessional. I agree that, as a prerequisite to Robinhood Financial
qualifying Me as a Nonprofessional, I will provide to Robinhood truthful and accurate information
about Me, such as: my occupation, employer, employment position and functions; my use of
Market Data; my registration status with any securities agency, exchange, association, or
regulatory body, or any commodities or future contract market, association, or regulatory body,
whether in the United States or elsewhere; and any compensation of any kind I may receive from
any individual or entity for my trading activities, asset management, or investment advice. Except
as otherwise declared to Robinhood in writing, by executing this Agreement, I certify that I meet
the definition of Nonprofessional as set forth in this Agreement.
Permitted Use. If I am a Nonprofessional, I agree to receive Market Data solely for my personal,
non-business use.
Notification. I shall notify Robinhood promptly in writing of any change in my circumstances that
may cause Me to cease to qualify as a Nonprofessional.
3. NASDAQ OMX Information.
A. Definitions.
"Information" means certain market data and other data disseminated that has been collected,
validated, processed, and recorded by any system NASDAQ OMX has developed for the creation
or dissemination of Information or other sources made available for transmission to and receipt
from either a distributor such as RHF or from NASDAQ OMX relating to: a) eligible securities or
other financial instruments, markets, products, vehicles, indicators, or devices; b) activities of a
NASDAQ OMX company; c) other information and data from a NASDAQ OMX company.
"Information" also includes any element of Information as used or processed in such a way that
the Information can be identified, recalculated or re-engineered from the processed Information or
that the processed Information can be used as a substitute for Information.
"NASDAQ OMX" means The NASDAQ OMX Group, Inc., a Delaware limited liability company
and its subsidiaries and Affiliates (collectively, "NASDAQ OMX").
4.
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B. Use of Data.
I understand that I may use the Information only for personal use and not for any business purpose. I
may not sell, lease, furnish or otherwise permit or provide access to the Information to any other natural
person or entity ("Person") or to any other office or place. I will not engage in the operation of any illegal
business use or permit anyone else to use the Information, or any part thereof, for any illegal purpose or
violate any NASDAQ OMX or SEC Rule or any FSA rule or other applicable law, rule or regulation. I may
not present the Information rendered in any unfair, misleading or discriminatory format. I shall take
reasonable security precautions to prevent any Person other than Myself from gaining access to the
Information.
C. Proprietary Data.
I acknowledge and agree that NASDAQ OMX has proprietary rights to the Information that originates on
or derives from markets regulated or operated by NASDAQ OMX, and compilation or other rights to
Information gathered from other sources. I further acknowledge and agree that NASDAQ OMX's third-
party information providers have exclusive proprietary rights to their respective Information. In the event
of any misappropriation or misuse by Me or anyone who accesses the Information through Me,
NASDAQ OMX or its third-party information providers shall have the right to obtain injunctive relief for its
respective materials.
D. System.
I acknowledge that NASDAQ OMX, in its sole discretion, may from time-to-time make modifications to
its system or the Information. Such modifications may require corresponding changes to be made in
Robinhood Financial's service. Changes or the failure to make timely changes by Me may sever or
affect My access to or use of the Information. I understand that neither NASDAQ OMX nor Robinhood
shall be responsible for such effects.
E. NASDAQ OMX Limitation of Liability.
Except as may otherwise be set forth herein, NASDAQ OMX shall not be liable to Me for indirect,
special, punitive, consequential or incidental loss or damage (including, but not limited to, trading losses,
lost profits, or other indirect loss or damage) of any nature arising from any cause whatsoever, even if
NASDAQ OMX has been advised of the possibility of such damages. NASDAQ OMX shall not be liable
to Me for any unavailability, interruption, delay, incompleteness or inaccuracy of the Information. This
Section shall not relieve NASDAQ OMX or Me from liability for damages that result from their own gross
negligence or willful tortious misconduct or from personal injury or wrongful death claims. I agree that the
terms of this Section reflect a reasonable allocation of risk and limitation of liability.
F. Disclaimers of Warranties.
NASDAQ OMX and its third-party information providers make no warranties of any kind with respect to
the Information---express, implied or statutory (including without limitation, timeliness, truthfulness,
sequence, completeness, accuracy, freedom from interruption), any implied warranties arising from trade
usage, course of dealing, course of performance or the implied warranties of merchantability or fitness
for a particular use or purpose or noninfringement.
G. Termination by NASDAQ OMX.
I acknowledge that NASDAQ OMX, when required to do so in fulfillment of statutory obligations, may by
notice to Robinhood unilaterally limit or terminate the right of any or all Persons to receive or use the
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Information and that Robinhood will comply with any such notice and will terminate or limit the furnishing
of the Information.
4. Authorization.
I understand that My Account is self-directed. Accordingly, I appoint Robinhood Financial as My agent for
the purpose of carrying out My directions to Robinhood Financial in accordance with the terms and
conditions of this Agreement and any attendant risks with respect to the purchase or sale of securities.
Robinhood Financial is authorized to open or close My Account(s), place and withdraw orders and take
such other steps as are reasonable to carry out My directions. All transactions will be effected only on
My order or the order of My authorized delegate, except as described in Section 10. I understand
Robinhood Financial provides trading and brokerage services through the Robinhood website (the
"Website") and the Robinhood mobile application (the "App"). I agree to receive and transmit financial
information through such electronic means. My use or My grant of access to My Account to any third
party to access information or place transactions in My Account is solely at My risk.
5. Customer Representations and Responsibilities.
A. Self-directed Account.
I understand that My Account is self-directed, and so that I am solely responsible for any and all orders
placed in My Account and that all orders entered by Me or on My behalf are unsolicited and based on My
own investment decisions or the investment decision of My duly authorized representative or agent.
Accordingly, I agree that neither Robinhood nor any of its employees, agents, principals, or
representatives:
provide investment advice in connection with this Account;
recommend any security, transaction or order;
solicit orders;
act as a market maker in any security;
make discretionary trades; and
produce or provide first-party research providing a specific investment strategies such as buy, sell
or hold recommendations, first-party ratings and/or price targets. To the extent research materials
or similar information are available through the App or the Website or the websites of any entity
controlled by, controlling, or under common control with Robinhood (such entity, an "Affiliate"), I
understand that these materials are intended for informational and educational purposes only and
they do not constitute a recommendation to enter into any securities transactions or to engage in
any investment strategies.
B. Information Accuracy.
I: (i) certify that the information contained in this Agreement, the account application, and any other
document that I furnish to Robinhood Financial in connection with My Account(s) is complete, true and
correct, and acknowledge that knowingly giving false information for the purpose of inducing Robinhood
Financial to extend credit is a federal crime; (ii) authorize Robinhood Financial to contact any individual
or firm noted herein or on the documents referred to in subsection (i) of this Section and any other normal
sources of debit or credit information; (iii) authorize anyone so contacted to furnish such information to
Robinhood Financial as Robinhood may request; and (iv) agree that this Agreement, the account
application and any other document I furnish in connection with My Account is Robinhood's property, as
the case may be. I shall promptly advise Robinhood Financial of any changes to the information in such
agreements and documents in writing within ten (10) calendar days. I authorize Robinhood Financial to
obtain reports and provide information to others concerning My creditworthiness and business conduct.
Upon My request, Robinhood agrees to provide Me a copy of any report so obtained. Robinhood may
1.
2.
3.
4.
5.
6.
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retain this Agreement, the Account application, and all other such documents and their respective
records at Its sole discretion, whether or not credit is extended.
C. Risks.
I understand that all investments involve risk, that losses may exceed the principal invested, and that
the past performance of a security, industry, sector, market, or financial product does not guarantee
future results or returns.
D. Account Defaults.
I understand that My Account comes with many defaulted service instruction features and preferences. I
further understand that I am not required to use these defaulted options or preferences and that once My
Account is approved and opened I have the sole discretion to control and adjust such defaulted service
preferences that relate to My account.
E. Knowledge of Account.
I understand that I am solely responsible for knowing the rights and terms for all securities purchased,
sold and maintained in My Account including mergers, reorganizations, stock splits, name changes or
symbol changes, dividends, option symbols, and option deliverables. I further understand that certain
securities may grant Me valuable rights that may expire unless I take specific action. These securities
include bonds, convertible securities, warrants, stock rights and securities subject to exchange offers or
tenders. I am responsible for knowing all expiration dates, redemption dates, and the circumstances
under which rights associated with My securities may be called, cancelled, or modified. Robinhood may,
but are not obligated to, notify Me of any upcoming expiration or redemption dates, or take any action on
My behalf without My specific instructions except as required by law and the rules of regulatory
authorities. I acknowledge that Robinhood may adjust My Account to correct any error. If My Account
has an option position on the last trading day prior to expiration, which is one cent or more in the money,
Robinhood Financial will generally exercise the option, on My behalf. However, Robinhood Financial
reserves the right at Its discretion to close any option position prior to expiration date or any position
resulting from the exercising/assignment after option expiration. I will be charged a commission for any
such transaction. Robinhood Financial is not obligated to take any of these actions and Robinhood
Financial is not liable for Losses should it not take them.
F. Purchases.
All orders for the purchase of securities given for My Account will be authorized by Me and executed in
reliance on My promise that an actual purchase is intended. It is My obligation to pay for purchases
immediately or on Robinhood's demand. I understand Robinhood may at any time, in its sole discretion
and without prior notice to Me, prohibit or restrict My ability to trade securities. I further agree not to
allow any person to trade for My Account unless a trading authorization for that person has been
received and approved by Robinhood. Robinhood reserve the right to require full payment in cleared
funds prior to the acceptance of any order. In the event that I fail to provide sufficient funds, Robinhood
may, at its option and without notice to Me, i) charge a reasonable rate of interest, ii) liquidate the
Property subject of the buy order, or iii) sell other Property owned by Me and held in any of My Accounts.
Robinhood may also charge any consequential Loss to My Account. For purposes of this Agreement,
"Property" shall mean all monies, contracts, investments and options, whether for present or future
delivery, and all related distributions, proceeds, products and accessions.
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G. Sales/Short Sales.
I promise to deliver all securities sold in My Account and to provide collateral of a type and amount
acceptable to Robinhood Financial for all short sales in My Account. Robinhood Financial requires that a
security be held in My Account prior to the acceptance of a sell order with respect to such security
unless the order is specifically designated as a "short sale." If a security is not held in My Account and a
sell order is processed, I must promptly deliver such security to Robinhood Financial for receipt in good
deliverable form on or before the settlement date. Any order accepted without negotiable certificates or
positions in My Account will be subject, at Robinhood Financial's sole discretion, to cancellation or buy-
in. To ensure this will not occur, I agree to only place sell orders for securities owned by Me and held in
My Account at the time My order is placed.
Proceeds of a sale will not be paid to Me or released into My Account until Robinhood Financial has
received the security in good deliverable form, whether from a transfer agent or from Me and the
settlement of the security is complete. If the security is not received on or before settlement date, or as
market conditions warrant, Robinhood Financial may in its sole discretion purchase the security on the
open market for My Account and may liquidate and close out any and all securities in My Account in
order to pay for such purchase. In the event a security is bought in, I will be responsible for all resulting
Losses incurred by Robinhood Financial.
I understand that I may execute short sales only in a margin Account and that such execution must
comply with applicable short sales rules.
H. Assistance by Robinhood.
I understand that when I request assistance from Robinhood or its employees in using the investment
tools available on the Website or the App, it will be limited to an explanation of the tool's functionality
and, if requested by Me, to the entry by Robinhood or its employees of variables provided by Me, and
that such assistance does not constitute investment advice, an opinion with respect to the suitability of
any transaction, or solicitation of any orders.
I. No Tax or Legal Advice.
I understand that Robinhood does not provide tax or legal advice.
J. Discontinuation of Services.
I understand that Robinhood may discontinue My Account and any services related to My Account
immediately by providing written notice to Me
K. Electronic Access.
I am solely responsible for keeping My Account numbers and PINs confidential and will not share
them with third parties. "PINs" shall mean My username and password.
I agree and accept full responsibility for monitoring and safeguarding My Accounts and access to
My Accounts.
I agree to immediately notify Robinhood in writing, delivered via e-mail and a recognized
international delivery service, if I become aware of: (i) any loss, theft, or unauthorized use of My
PINs or Account numbers; (ii) any failure by Me to receive any communication from Robinhood
indicating that an order was received, executed or cancelled, as applicable; (iii) any failure by Me
to receive an accurate written confirmation of an order, execution, or cancellation; (iv) any receipt
by Me of confirmation of an order, execution or cancellation, which I did not place; (v) any
1.
2.
3.
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inaccurate information in or relating to My orders, trades, margin status, Account balances,
deposits, withdrawals, securities positions or transaction history; or (vi) any other unauthorized
use or access of My Account.
Each of the events described in subsections (K)(3)(i)-(vi) shall be deemed a "Potential Fraudulent
Event". The use and storage of any information including My Account numbers, PINs, portfolio
information, transaction activity, account balances and any other information or orders available
on My wireless, web-enabled cellular telephone or similar wireless communications device
(collectively, "Mobile Device") or My personal computer is at My own risk and is My sole
responsibility. I represent that I am solely responsible for and have authorized any orders or
instructions appearing in, originating from, or associated with My Account, My Account number,
My username and password, or PINs. I agree to notify Robinhood immediately after I discover
any Potential Fraudulent Event, but in no event more than twenty-four (24) hours following
discovery. Upon request by Robinhood, I agree to report any Potential Fraudulent Event promptly
to legal authorities and provide Robinhood a copy of any report prepared by such legal authorities.
I agree to cooperate fully with the legal authorities and Robinhood in any investigation of any
Potential Fraudulent Event and I will complete any required affidavits promptly, accurately and
thoroughly. I also agree to allow Robinhood access to My Mobile Device, My computer, and My
network in connection with Robinhood's investigation of any Potential Fraudulent Event. I
understand that if I fail to do any of these things I may encounter delays in regaining access to
the funds in My Account. I agree to indemnify and hold Robinhood, its Affiliates, and Robinhood
and its Affiliates' respective officers, directors, and employees harmless from and against any
Losses arising out of or relating to any Potential Fraudulent Event. I acknowledge that Robinhood
does not know when a person entering orders with My username and password is Me.
Trusted Contact Person. I understand that, pursuant to FINRA regulations, Robinhood is
authorized to contact the Trusted Contact Person (as defined by FINRA Rule 4512) designated
for My Account and to disclose information about My account to address possible financial
exploitation, to confirm the specifics of My current contact information, health status, or the
identity of any legal guardian, executor, trustee or holder of a power of attorney, or as otherwise
permitted by Rule 2165.
6. Clearance of Trades.
I understand that Robinhood Financial has entered into a clearing agreement with Robinhood Securities
whereby Robinhood Financial will introduce My Account to Robinhood Securities, and Robinhood
Securities will clear all transactions, on a fully-disclosed basis. I understand that Robinhood Securities
carries My Account(s) and is responsible for the clearing and bookkeeping of transactions, but is not
otherwise responsible for the conduct of Robinhood Financial.
Until receipt from Me of written notice to the contrary, Robinhood Securities may accept from Robinhood
Financial, without inquiry or investigation, (i) orders for the purchase or sale of securities and other
property on margin, if I have elected to have a margin account, or otherwise, and (ii) any other
instructions concerning my Accounts. Robinhood Securities shall look solely to Robinhood Financial
unless otherwise directed by Robinhood Financial, and not to Me, with respect to any such orders or
instructions; except that I understand that Robinhood Securities will deliver confirmations, statements,
and all written or other notices with respect to My Account directly to Me with copies to Robinhood
Financial, and that Robinhood Securities will look directly to Me or Robinhood Financial for delivery of
margin, payment, or securities. I agree to hold Robinhood Securities harmless from and against any
Losses arising in connection with the delivery or receipt of any such communication(s), provided
Robinhood Securities has acted in accordance with the above. The foregoing shall be effective as to My
Account(s) until written notice to the contrary is received from Me by Robinhood Securities or Robinhood
Financial.
7. Review of Confirmations and Statements.
I agree that it is My responsibility to review order execution confirmations and statements of My
Account(s) promptly upon receipt. I agree to receive all confirmations and account statements, as well
as all tax related documents, in electronic format. I understand that account statements will evidence all
activity in My Account for the stated period, including securities transactions, cash balances, credits to
My Account and all fees paid from My Account. Notwithstanding Section 36.B, confirmations will be
considered binding on Me unless I notify Robinhood of any objections within two (2) calendar days from
the date confirmations are sent. Account statements will be considered binding on Me unless I notify you
4.
5.
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of any objections within ten (10) calendar days after My Account statements are posted online. Such
objection may be oral or in writing, but any oral objection must be immediately confirmed in writing. In all
cases, Robinhood reserves the right to determine the validity of My objection. If I object to a transaction
for any reason, I understand and agree that I am obligated to take action to limit any losses that may
result from such transaction or I will bear sole responsibility for any losses relating to the transaction,
even if My objection to the transaction is ultimately determined to be valid. Nothing in this Section 7
shall limit My responsibilities as described in Section 5 of this Agreement.
8. Important Information Needed to Open a New Account.
To help the government better detect the funding of terrorism and money laundering activities, federal
law requires all financial institutions to obtain, verify, and record information that identifies each person
who opens an account. Therefore, I understand that when I open My Account Robinhood will ask for My
name, address, date of birth and other identifying information. Robinhood may also ask copies of My
driver's license, passport or other identifying documents. I understand that Robinhood may take steps to
verify the accuracy of the information I provide to Robinhood in My Account application or otherwise, and
that Robinhood may restrict My access to My Account pending such verification. I will provide prompt
notification to Robinhood of any changes in the information including My name, address, e-mail address
and telephone number.
I further understand that if I attempt to access My Account from a jurisdiction subject to certain U.S.
sanctions or I am ordinarily resident in such a jurisdiction, or if you reasonably believe that I am
attempting such access or have become a resident in such a jurisdiction, you may restrict My Account,
and any pending orders may be cancelled. If this happens, I understand that I should contact
help@robinhood.com, and that I may be asked to provide supplemental information as part of this
process. I further understand that I must close My Account before establishing residency in any
jurisdiction subject to U.S. sanctions.
9. Telephone Conversations and Electronic Communications.
I understand and agree that Robinhood may record and monitor any telephone or electronic
communications with Me. Unless otherwise agreed in writing in advance, Robinhood does not consent
to the recording of telephone conversations by any third party or Me. I acknowledge and understand that
not all telephone or electronic communications are recorded by Robinhood, and Robinhood does not
guarantee that recordings of any particular telephone or electronic communications will be retained or
capable of being retrieved.
10. Oral Authorization.
I agree that Robinhood shall be entitled to act upon any oral instructions given by Me so long as
Robinhood reasonably believes such instruction was actually given by Me or My authorized agent.
11. Applicable Laws and Regulations.
All transactions in My Account will be subject to federal securities laws and regulations, the applicable
laws and regulations of any state or jurisdiction in which Robinhood Financial is registered, the rules of
any applicable self-regulatory organization of which Robinhood Financial is a member and the rules,
regulations, customs and usages of the exchange or market, and its clearing house, if any, where the
transactions are executed. In no event will Robinhood Financial be obligated to effect any transaction it
believes would violate any federal or state law, rule or regulation or the rules or regulations of any
regulatory or self-regulatory organization.
12. Erroneous Distributions.
I agree to promptly return to Robinhood any assets erroneously distributed to Me. In the event that I sell
a security prior to its ex-dividend/distribution date, and I receive the related cash/stock dividend or
distribution in error, I direct Robinhood on My behalf to pay such dividend/distribution to the entitled
purchaser of the securities I sold, and I guarantee to promptly reimburse Robinhood for, or deliver to
Robinhood, said dividend or distribution.
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13. Market Volatility; Market Orders; Limit Orders; and Queued Orders.
I understand that, whether I place a market or limit order, I will receive the price at which My order is
executed in the marketplace, subject to any clarification stated below. Particularly during periods of high
volume, illiquidity, fast movement or volatility in the marketplace, the execution price received may differ
from the quote provided on entry of an order, and I may receive partial executions of an order at different
prices. I understand that Robinhood Financial is not liable for any price fluctuations. I also understand
that price quotes generally are for only a small number of shares as specified by the marketplace, and
larger orders are relatively more likely to receive executions at prices that vary from the quotes or in
multiple lots at different prices.
I understand that Robinhood Financial does not currently support sending traditional market buy orders
and that Robinhood Financial collars all market buy orders (other than dollar-based buy orders executed
during market hours) by using limit orders priced up to 5% above the last trade price. This is not the
case for market sell orders. I further understand that when I send a market buy order through Robinhood
Financial's trading system, the trading system generates a limit order up to 5% above the last trade
price, and then Robinhood Financial sends the order to an executing broker. I understand that Robinhood
Financial's implementation of market buy orders may vary depending on prices of instruments, market
conditions, and other factors. I further understand that Robinhood Financial uses the following rounding
mechanics with respect to buy orders: the last trade price is (i) multiplied by 1.05; (ii) rounded down to
two decimal places if the last trade price is over $1.00; otherwise, rounded down to four decimal places;
and (iii) for securities included in the SEC's Tick Size Pilot Program, rounded down to the nearest $.05
increment. I understand that securities may open for trading at prices substantially higher or lower than
the previous closing price or the anticipated price. If I place a market order (whether during normal
market hours or when the market is closed), I agree to pay or receive the prevailing market price at the
time My market order is executed, subject to the specific clarification above relating to buy orders. I
understand that the price I pay may be significantly higher or lower than anticipated at the time I placed
the order. To avoid buying a security at a higher price and possibly exceeding My purchasing power, I
understand My option to enter a limit order. I also understand that limit orders may not be executed at
any particular time, or at all, if there is not sufficient trading at or better than the limit price I specify, and
are only good until the end of the trading day in which they are entered. The Website contains further
information regarding order types and limitations, which I agree to read and understand before placing
such orders.
As a customer of Robinhood Financial, I understand that after the market has closed for the day, I have
the ability to place in a queue order requests to be executed the following day upon the opening of the
market ("Queued Order"). I understand that My Queued Order request is prioritized based on the order in
which it is received by Robinhood Financial, and that the Queued Order requests are sent out for
execution shortly after the market opens on the next day of trading. I further understand that each
Queued Order request is sent out per customer and per security as Robinhood Financial market orders
(described above), and that they are not aggregated.
A limit order may be "good till cancelled" which means the order remains valid until (A) it is executed; (B)
I cancel the order; (C) approximately 90 days from when the order is placed; or (D) the contract to which
it relates is closed. I understand that Robinhood will cancel a "good till cancelled" order at the end of
every trading day (on the exchange on which the instrument to which the contract relates is traded) and
place such order again at the start of the following trading day. This process will be repeated every day
for as long as the "good till cancelled" order remains valid. I further agree that any "good till cancelled"
orders I place should be treated as "do not reduce" orders.
14. Bulletin Board/Pink Sheet Stocks.
Bulletin board, pink sheet and other thinly-traded securities (collectively "bulletin board stocks") present
particular trading risks, in part because they are relatively less liquid and more volatile than actively
traded securities listed on a major exchange. I understand that bulletin board stocks may be subject to
different trading rules and systems than other securities and that I may encounter significant delays in
executions, reports of executions, and updating of quotations in trading bulletin board stocks. Robinhood
Financial in its sole discretion may require limit orders on certain bulletin board stock transactions.
15. Research and Internet Links.
News, research, links to outside websites, and other information accessible through the App or Website
("Content") may be prepared by independent external providers not affiliated with Robinhood Financial,
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including Morningstar, Inc. (all such providers, the "Providers"). I agree not to distribute, reproduce, sell,
or otherwise commercially use the Content in any manner. I understand that Robinhood may terminate
My access to the Content. I understand that none of the Content is a recommendation by Robinhood to
buy or sell any securities or to engage in any investment strategy.
16. Restrictions on Trading.
I understand that Robinhood may, in its discretion, prohibit or restrict the trading of securities, or the
substitution of securities, in any of My Accounts. I understand that Robinhood may execute all orders by
Me on any exchange or market, unless I specifically instruct Robinhood to the contrary. In the event of a
breach or default by Me under this Agreement, Robinhood shall have all rights and remedies available to
a secured creditor under all applicable laws and in addition to the rights and remedies provided herein. I
understand that Robinhood may at any time, at its sole discretion and without prior notice to Me: (i)
prohibit or restrict My access to the use of the App or the Website or related services and My ability to
trade, (ii) refuse to accept any of My transactions, (iii) refuse to execute any of My transactions, or (iv)
terminate My Account. The closing of My Account will not affect the rights or obligations of either party
incurred prior to the date My Account is closed.
Further, Robinhood will not tolerate any foul or abusive language, physical violence, threatening behavior,
or other inappropriate conduct directed toward Robinhood, its Affiliates' officers, employees, contractors
or customers. If I engage in any such behavior, as determined by Robinhood in its sole discretion, I
agree that Robinhood is authorized to: (i) liquidate any securities, instruments or other property in My
Account, (ii) send Me the proceeds, and (iii) close My account. Robinhood will not be responsible for any
Losses caused by the liquidation of securities, instruments or other property pursuant to this paragraph,
including any tax liabilities.
17. Waiver; Limitation of Liability; Indemnification.
I agree that My use of the App or the Website or any other service provided by Robinhood Financial or
its Affiliates is at My sole risk. The Robinhood Financial service (including the App, the Website, the
provision of Market Data, Information, Content, or any other information provided by Robinhood
Financial, any of its Affiliates, or any third-party content provider or market data provider) is provided on
an "as is," "as available" basis without warranties of any kind, either express or implied, statutory
(including without limitation, timeliness, truthfulness, sequence, completeness, accuracy, freedom from
interruption), implied warranties arising from trade usage, course of dealing, course of performance, or
the implied warranties of merchantability or fitness for a particular purpose or application, other than
those warranties which are implied by and incapable of exclusion, restriction or modification under the
laws applicable to this Agreement.
Although considerable effort is expended to make the Website, App and other operational and
communications channels available around the clock, Robinhood does not warrant that these channels
will be available and error free every minute of the day. I agree that Robinhood will not be responsible for
temporary interruptions in service due to maintenance, Website or App changes, or failures, nor shall
Robinhood be liable for extended interruptions due to failures beyond our control, including but not limited
to the failure of interconnecting and operating systems, computer viruses, forces of nature, labor
disputes and armed conflicts.
EXCEPT AS OTHERWISE EXPRESSLY PROVIDED IN THIS AGREEMENT, I UNDERSTAND AND
AGREE THAT ROBINHOOD, ITS AFFILIATES, THEIR RESPECTIVE OFFICERS, DIRECTORS,
EMPLOYEES AND AGENTS, AND THE PROVIDERS (COLLECTIVELY THE "ROBINHOOD
PARTIES") WILL NOT BE LIABLE TO ME OR TO THIRD PARTIES UNDER ANY
CIRCUMSTANCES, OR HAVE ANY RESPONSIBILITY WHATSOEVER, FOR ANY SPECIAL,
INDIRECT, INCIDENTAL, PUNITIVE OR CONSEQUENTIAL DAMAGES (INCLUDING TRADING
LOSSES, DAMAGES, LOSS OF PROFITS, REVENUE, OR GOODWILL) THAT I MAY INCUR IN
CONNECTION WITH MY USE OF THE SERVICE PROVIDED BY ROBINHOOD OR ANY OF ITS
AFFILIATES UNDER THIS AGREEMENT (INCLUDING MY USE OF THE APP, THE WEBSITE, THE
MARKET DATA, THE INFORMATION, OR THE CONTENT), BREACH OF THIS AGREEMENT, OR
ANY TERMINATION OF THIS AGREEMENT, WHETHER SUCH LIABILITY IS ASSERTED ON THE
BASIS OF CONTRACT, TORT (INCLUDING NEGLIGENCE), OR OTHERWISE, AND WHETHER OR
NOT FORESEEABLE, EVEN IF ANY ROBINHOOD PARTY HAS BEEN ADVISED OR WAS AWARE
OF THE POSSIBILITY OF SUCH LOSS OR DAMAGES. THE ROBINHOOD PARTIES SHALL NOT
BE LIABLE BY REASON OF DELAYS OR INTERRUPTIONS OF THE SERVICE OR
TRANSMISSIONS, OR FAILURES OF PERFORMANCE OF THEIR RESPECTIVE SYSTEMS,
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REGARDLESS OF CAUSE, INCLUDING THOSE CAUSED BY GOVERNMENTAL OR
REGULATORY ACTION, THE ACTION OF ANY EXCHANGE OR OTHER SELF REGULATORY
ORGANIZATION, OR THOSE CAUSED BY SOFTWARE OR HARDWARE MALFUNCTIONS.
Except as otherwise provided by law, Robinhood or any of its affiliates or respective partners, officers,
directors, employees or agents (collectively, "Indemnified Parties") shall not be liable for any expenses,
losses, costs, damages, liabilities, demands, debts, obligations, penalties, charges, claims, causes of
action, penalties, fines and taxes of any kind or nature (including legal expenses and attorneys' fees)
(whether known or unknown, absolute or contingent, liquidated or unliquidated, direct or indirect, due or
to become due, accrued or not accrued, asserted or unasserted, related or not related to a third party
claim, or otherwise) (collectively, "Losses") by or with respect to any matters pertaining to My Account,
except to the extent that such Losses are actual Losses and are determined by a court of competent
jurisdiction or an arbitration panel in a final non-appealable judgment or order to have resulted solely from
Robinhood's or any of its affiliates' gross negligence or intentional misconduct. In addition, I agree that
the Indemnified Parties shall have no liability for, and I agree to indemnify, defend and hold harmless the
Indemnified Parties from all Losses that result from: (i) any noncompliance by Me with any of the terms
and conditions of this Agreement; (ii) any third-party actions related to My receipt and use of any
Information, Market Data, Content, market analysis, other third-party content, or other such information
obtained on the App or Website, whether authorized or unauthorized under this Agreement; (iii) any third-
party actions related to My use of the App or the Website; (iv) My or My agent's misrepresentation or
alleged misrepresentation, or act or omission; (v) Indemnified Parties following My or My agent's
directions or instructions, or failing to follow My or My agent's unlawful or unreasonable directions or
instructions; (vi) any activities or services of the Indemnified Parties in connection with My Account
(including any technology services, reporting, trading, research or capital introduction services); or (vii)
the failure by any person not controlled by the Indemnified Parties and their affiliates to perform any
obligations to Me. Further, if I authorize or allow third parties to gain access to Robinhood's services,
including My Accounts, I will indemnify, defend and hold harmless the Indemnified Parties against any
Losses arising out of claims or suits by such third parties based upon or relating to such access and
use. Robinhood does not warrant against loss of use or any direct, indirect or consequential damages or
Losses to Me caused by My assent, expressed or implied, to a third party accessing My Account or
information, including access provided through any other third party systems or sites.
I consent to the use of automated systems or service bureaus by Robinhood and its respective affiliates
in conjunction with My Account, including automated order entry and execution, record keeping, reporting
and account reconciliation and risk management systems (collectively "Automated Systems"). I
understand that the use of Automated Systems entails risks, such as interruption or delays of service,
errors or omissions in the information provided, system failure and errors in the design or functioning of
such Automated Systems (collectively, a "System Failure") that could cause substantial damage,
expense, or liability to Me. I understand and agree that Indemnified Parties will have no liability
whatsoever for any of my Losses arising out of or relating to a System Failure.
I also agree that Indemnified Parties will have no responsibility or liability to Me in connection with the
performance or non-performance by any exchange, clearing organization, market data provider, or other
third party (including other broker-dealers and clearing firms, and banks) or any of their respective agents
or affiliates, of its or their obligations relative to any securities. I agree that Indemnified Parties will have
no liability, to Me or to third parties, or responsibility whatsoever for: (i) any Losses resulting from a
cause over which Indemnified Parties do not have direct control, including the failure of mechanical
equipment, unauthorized access, theft, operator errors, government restrictions, force majeure (as
defined in this Agreement), market data availability or quality, exchange rulings or suspension of trading;
and (ii) any special, indirect, incidental, consequential, punitive or exemplary damages (including lost
profits, trading losses and damages) that I may incur in connection with My use of the App, the Website,
Robinhood's brokerage, and other services provided by Indemnified Parties under this Agreement.
18. Mutual Fund Transactions.
In the event that I purchase or hold a mutual fund, I agree to read and understand the terms of its
prospectus. I understand that certain mutual funds reserve the right to change their purchasing,
switching or redemption procedures or suspend or postpone redemptions under certain market
conditions. I further understand that any mutual fund order entered with Robinhood is placed by
Robinhood on a best efforts basis as prescribed and recognized by the individual fund, and that
Robinhood is not responsible for unexecuted orders due to the failure of any communication system. I
agree to be fully responsible for the information contained within the mutual fund prospectus and to hold
Robinhood, its Affiliates, and Robinhood and its Affiliates' respective officers and employees harmless
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for any deficiencies contained therein. I authorize Robinhood to act as My agent in the purchase and
redemption of fund shares.
19. Exchange Traded Funds.
I understand that I should consider the investment objectives and unique risk profile of Exchange Traded
Funds ("ETFs") carefully before investing, and that ETFs are subject to risks similar to those of other
diversified portfolios. I further understand that leveraged and inverse ETFs may not be suitable for all
investors and may increase exposure to volatility through the use of leverage, short sales of securities,
derivatives, and other complex investment strategies, and that although ETFs are designed to provide
investment results that generally correspond to the performance of their respective underlying indices,
they may not be able to exactly replicate the performance of the indices because of expenses and other
factors. I further understand that ETFs are required to distribute portfolio gains to shareholders at year
end, which may be generated by portfolio rebalancing or the need to meet diversification requirements,
and that ETF trading will also generate tax consequences. I understand that I can obtain prospectuses
from issuers or their third party agents who distribute and make prospectuses available for review.
Additional regulatory guidance on ETFs can be found here.
20. Effect of Attachment or Sequestration of Accounts.
Robinhood shall not be liable for refusing to obey any orders given by or for Me with respect to any of
My Accounts that has or have been subject to an attachment or sequestration in any legal proceeding
against Me, and Robinhood shall be under no obligation to contest the validity of any such attachment or
sequestration.
21. Event of Death.
It is agreed that in the event of My death, the representative of My estate or the survivor or survivors
shall immediately give Robinhood written notice thereof, and Robinhood may, before or after receiving
such notice, take such proceedings, require such papers and inheritance or estate tax waivers, retain
such portion of, or restrict transactions in the Account as Robinhood may deem advisable to protect
Robinhood against any tax, liability, penalty or loss under any present or future laws or otherwise.
Notwithstanding the above, in the event of My death, all open orders shall be canceled, but Robinhood
shall not be responsible for any action taken on such orders prior to the actual receipt of notice of death.
Further, Robinhood may in Its discretion close out any or all of the Accounts without awaiting the
appointment of a personal representative for My estate and without demand upon or notice to any such
personal representative. The estate of any of the Account holders who have died shall be liable and each
survivor shall continue to be liable, jointly and severally, to Robinhood for any net debit balance or loss in
said account in any way resulting from the completion of transactions initiated prior to the receipt by
Robinhood of the written notice of the death of the decedent or incurred in the liquidation of the Account
or the adjustment of the interests of the respective parties, and for all other obligations pursuant to this
Agreement. Such notice shall not affect Robinhood's rights under this Agreement to take any action that
Robinhood could have taken if I had not died.
22. Tax Reporting; Tax Withholding.
The proceeds of sale transactions and dividends paid will be reported to the Internal Revenue Service
("IRS") in accordance with applicable law.
A. U.S. Persons.
This subsection is applicable if I am a U.S. person. Under penalties of perjury, I certify that the taxpayer
identification number that I have provided or will provide to Robinhood (including any taxpayer
identification number on any Form W-9 that I have provided or will provide to Robinhood) is My correct
taxpayer identification number. I certify that I am not subject to backup withholding and I am a United
States Person (including a U.S. resident alien) as such term is defined in section 7701(a)(30) of the
Internal Revenue Code of 1986, as amended ("U.S. Person"). If a correct Taxpayer Identification
Number is not provided Robinhood Financial, I understand I may be subject to backup withholding tax at
the appropriate rate on all dividends, interest and gross proceeds paid to me. Backup withholding taxes
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are sent to the IRS and cannot be refunded by Robinhood Financial. I further understand that if I waive
tax withholding and fail to pay sufficient estimated taxes to the IRS, I may be subject to tax penalties.
B. Non-U.S. Persons.
This subsection is applicable if I am not a U.S. Person. I certify that I fully understand all the information
on any Form W-8BEN that I have submitted or will submit to Robinhood. Under penalties of perjury, I
declare that (i) I have examined all the information (including all the information in the English language)
on any Form W-8BEN that I have submitted or will submit to Robinhood and (ii) to the best of My
knowledge and belief all such information is true, correct, and complete. I authorize Robinhood to
provide any such Form W-8BEN to Robinhood Securities or any withholding agent that has control,
receipt, or custody of the income of which I am the beneficial owner or any withholding agent that can
disburse or make payments of the income of which I am the beneficial owner. I agree that I will submit a
new Form W-8BEN to Robinhood within 30 calendar days if any certification made on any previously
submitted Form W-8BEN becomes incorrect. I understand that the IRS does not require My consent to
any provisions of such Form W-8BEN other than the certifications required to establish My status as a
non-U.S. Person and, if applicable, obtain a reduced rate of withholding.
23. Equity Orders and Payment For Order Flow.
SEC rules require all registered broker-dealers to disclose their policies regarding any "payment for order
flow" arrangement in connection with the routing of customer orders. "Payment for order flow" includes,
among other things, any monetary payment, service, property, or other benefit that results in
remuneration, compensation, or consideration to a broker-dealer from any broker-dealer in return for
directing orders. I understand that Robinhood transmits customer orders for execution to various
exchanges or market centers based on a number of factors. These include: size of order, trading
characteristics of the security, favorable execution prices (including the opportunity for price
improvement), access to reliable market data, availability of efficient automated transaction processing
and reduced execution costs through price concessions from the market centers. I further understand
that certain of the exchanges or market centers may execute orders at prices superior to the publicly
quoted market in accordance with their rules or practices and that while a customer may specify that an
order be directed to a particular market center for execution, the order-routing policies, taking into
consideration all of the factors listed above, are designed to result in favorable transaction processing for
customers. The nature and source of any payments or credits received by Robinhood in connection with
any specific transactions will be furnished upon written request.
24. Free Credit Balances and Sweep Service.
If I enroll in Robinhood Financial Cash Management ("Cash Management"), I understand that I am
electing to participate in the Insured Network Deposit ("IND") sweep service (the "Sweep Service").
Under the Sweep Service, free credit balances in My Account will be deposited into interest-bearing
accounts at one or more banks ("Participating Depository Institutions"), in accordance with the Insured
Network Deposit Sweep Program Disclosures ("IND Disclosures") available on the Website and in the
App. By enrolling in Cash Management, I represent and warrant that I have reviewed the IND
Disclosures and agree to the terms set forth in the IND Disclosures. If I am not enrolled in Cash
Management, free credit balances in My Account will remain in My Account, will not earn interest and
will not be eligible for FDIC insurance, but will be eligible for SIPC protection as described in the IND
Disclosures.
25. Fees and Charges.
I understand that Robinhood does not charge fees or commissions for executing buy and sell orders.
However, I understand that other fees may apply. The current fees are included in the fee schedule
available in the App and on the Website. I agree to pay any such fees at the then-prevailing rate. I
acknowledge that the prevailing fees may change and that change may occur without notice. I agree to
be bound by such changes once they are posted in the fee schedule available in the App and on the
Website. I also agree to pay all applicable federal, state, local, and foreign taxes. I authorize Robinhood
Financial to automatically debit My Account for any such fees and taxes. I also agree to pay such
expenses incurred by Robinhood in connection with collection of any unpaid balance due on My
Accounts including attorney's fees allowed by law.
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26. ACH Transactions.
A. Debit Transactions.
Robinhood will initiate an ACH debit at My request to debit funds from an account that I own at another
financial institution ("External Account") for deposit into My Account. I understand that in order for
Robinhood to initiate an ACH debit, the financial institution holding my External Account must participate
in the ACH system. I understand that for the ACH transfers to be established, at least one common
name must match exactly between My Account and My External Account. I authorize Robinhood to take
such steps as it deems appropriate to verify my ownership of External Account, including by telling the
bank at which such External Account is held that I have authorized and consented to such bank
disclosing to Robinhood any information that Robinhood may request about Me or My External Account.
I also agree to cooperate with Robinhood's verification of my ownership of such External Account by
promptly providing any identification and/or other documentation that Robinhood may request regarding
such External Account. I represent and warrant that there are sufficient funds in My External Account to
cover the amount of the deposit to My Account. Robinhood will initiate the ACH debit to My External
Account on the Business Day or next Business Day after I request the transfer. A transfer request will be
deemed to have been made on a Business Day if it is received by Robinhood by 7:00 p.m. (Eastern
Time) on such Business Day; if received after that time, the transfer request will be deemed to have
been made on the next Business Day.
Within 60 days of the date of My ACH deposit, My funds may only be withdrawn to the External Account
from which such funds were debited.
I understand that an ACH debit transfer may be reversed or rejected if: (A) there are insufficient funds in
My External Account; (B) there is a duplicate transaction; (C) the transaction is denied by the bank
holding My External Account; or (D) My External Account does not support ACH transfers. I
acknowledge that in the event of an ACH reversal, I will incur a fee. Before initiating making an ACH
debit transfer, I agree to check Robinhood Financial's most recent Commissions and Fees Schedule. I
agree that I am solely liable and responsible for any ACH reversal fees that I incur.
B. Credit Transactions.
Robinhood will initiate an ACH credit at My request to transfer funds from My Account to a recipient that
I designate. I agree that I will have sufficient Available Funds in My Account to cover the amount of any
ACH credit that I ask Robinhood to initiate. Robinhood will debit the amount of such request from My
Account on the Business Day or next Business Day after I request the transfer. A transfer request will be
deemed to have been made on a Business Day if it is received by Robinhood on such Business Day; if
received after that time, the transfer request will be deemed to have been made on the next Business
Day.
I agree that Robinhood may use any means which Robinhood, in its sole discretion, considers suitable
to execute my ACH credit transfers.
27. Fractional Shares.
I acknowledge and understand that Robinhood rounds all holdings of fractional shares to the sixth
decimal place, the value of fractional shares to the nearest cent, and any dividends paid on fractional
shares to the nearest cent. I further understand that Robinhood will not accept dollar-based purchases or
sales of less than $1.00 and that I will receive proceeds from the sale of any whole or fractional shares
rounded to the nearest cent.
I understand that if I enter repeated fractional orders with individual notional values of less than $0.01,
my account may be restricted.
I understand that a vendor employed by Robinhood will aggregate any proxy votes for fractional shares
of Robinhood’s customers with all votes reported to the issuer or issuer’s designated vote tabulator and
that, while Robinhood’s vendor will report such proxy votes on fractional shares, the issuer or tabulator
may not fully count such votes.
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I understand that Robinhood will execute all orders that include fractional shares ("Fractional Orders") on
a principal basis. To the extent that Robinhood must purchase or sell shares in the market to fulfill any
part of my Fractional Order, the fractional component of that order will be fulfilled at the execution price
Robinhood received for the corresponding whole shares. To the extent that Robinhood fulfills my
Fractional Order for national exchange-listed securities ("NMS Securities") entirely out of its inventory
and without purchasing or selling shares in the market ("Inventory Fulfillment"), Robinhood will endeavor
to price such shares or fractional shares at a price between the National Best Bid and Offer (“NBBO”) at
the time of the order for orders made during market hours, or, for such orders made during extended
hours trading (9:00-9:30 a.m. and 4:00-6:00 p.m. Eastern), Robinhood will endeavor to price such orders
between the best bid and offer at the time of the order, as reported by an external vendor ("Vendor
BBO"). For Inventory Fulfillment of Fractional Orders for securities not listed on a national exchange
("Non-NMS Securities") made during market hours as well as extended hours trading, Robinhood will
endeavor to price such orders between Vendor BBO.
All non-market orders placed outside market hours and extended hours trading are queued and fulfilled
either at or near the beginning of extended hours trading (9:00 a.m. Eastern) or at or near market open
(9:30 a.m. Eastern), according to my instructions. All market orders placed outside market hours and
extended hours trading are queued and fulfilled at or near market open. To the extent that I trade outside
of market hours, these trades are subject to Robinhood’s Extended Hours Trading Disclosure.
I understand Robinhood only accepts market orders for fractional shares at this time and does not permit
limit orders for fractional shares. I understand that fractional shares within My Account (i) are
unrecognized, unmarketable, and illiquid outside the Robinhood platform, (ii) are not transferrable in-kind,
and (iii) may only be liquidated and the proceeds transferred out via a wire transfer. I acknowledge that,
subject to applicable requirements, Robinhood may report holdings and transactions in My Account in
terms of either U.S. Dollars, shares, or both.
28. Phone Calls.
You agree that, by providing information Robinhood requests, Robinhood and its third party services
providers may contact you via mail, phone or email.
Specifically, if you provide us with a phone number: (a) you represent and warrant that the number you
provide is your phone number, and you will promptly notify us if that changes, and (b) you consent to
receive calls (including text messages) made to that phone number that may be prerecroded and/or
completed with an automatic telephone dialing system (automated calls) for purposes including but not
limited to providing account-related communications (including security alerts), investigating or
preventing fraud, and/or collecting amounts owed to Robinhood. We may share your number with third
parties that provide services to us in connection with any of the foregoing purposes, including but not
limited to debt collectors. You understand that message, telephone minute and data rates may apply for
calls made to a mobile phone number. You may opt out at any time from receiving these types of calls
orally or in writing to limitsharing@robinhood.com. Please note, even if you opt out, we may still make
other calls as permitted by law.
You consent to our recording of phone calls, including calls we make to you or that we receive from you.
29. Dividend Reinvestment Program.
Except as expressly stated otherwise, the provisions of this Section 29 will only apply if I am enrolled in
Robinhood’s Dividend Reinvestment Program (“DRIP”). My enrollment in the DRIP will be activated
within three business days after I notify Robinhood of my intention to enroll an eligible security through
the App. “Eligible security” means all shares available for fractional investing through Robinhood. I
understand that in order to be eligible for dividend reinvestment, the securities must be held in My
Account.
I may specify individual securities or have all Eligible securities in My Account enrolled for dividend
reinvestment. If I choose to reinvest dividends from all Eligible securities, I understand that individual
securities could subsequently no longer be Eligible securities at Robinhood’s discretion or under
applicable law. In those cases, only those securities will be discontinued from the DRIP. If I specify
individual securities, I may add additional Eligible securities to the DRIP at any time if I hold a position
in those securities. Enrollment with respect to these additional Eligible securities will be effective within
three business days after Robinhood receives notification from me through the App. If I maintain open
orders for securities I do not already hold, I may not enroll those securities for dividend reinvestment
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until my open orders are executed. If my entire Account is set up for dividend reinvestment, any eligible
securities I purchase in the future will automatically participate in the DRIP.
All eligible cash distributions will be reinvested on all securities I have selected in the DRIP, provided
that I owned the securities on the record date for determining shareholders eligible to receive dividends,
and continue to hold the securities through payable date. “Eligible cash distributions” means most cash
distributions, including regular and optional dividends, cash-in-lieu payments, and capital gains
distributions. Special dividends, late ex-date, liquidation, and miscellaneous payments may not be
eligible distributions. Optional dividends will be processed in accordance with dividend reinvestment
instructions. If I have a margin account, Robinhood is permitted to borrow a dividend paying stock in the
normal course of business and, as a result, in such situations instead of a dividend payment I may
receive a cash in lieu payment. If I receive a cash in lieu payment, I authorize Robinhood to treat such
payment as if it was not “in lieu” and reinvest it accordingly.
Robinhood will credit My Account upon completion of the dividend reinvestment. Robinhood will reinvest
dividends on the business day following receipt of funds. In the rare instance in which Robinhood is
unable to reinvest all dividends on the business day following receipt, it will reinvest the remaining funds
as soon as reasonably possible thereafter, which may take up to five business days. I will not have use
of the funds prior to reinvestment.
I understand that my participation in the DRIP is voluntary and that Robinhood has not made any
recommendation that I should participate. I further understand that Robinhood is not recommending or
offering any advice regarding the purchase of any security included as an Eligible security in the DRIP. I
further understand that dividend reinvestment does not assure profits on my investments, nor does it
protect against losses in declining markets.
I may terminate my participation in the DRIP, or the enrollment of individual securities in the DRIP, at
any time by giving notice through the App. Termination will take effect prior to the next Eligible cash
distribution provided my notice to terminate was received at least three business days prior to the record
date of that distribution. I understand that my notice to terminate my participation in the DRIP will not
affect any obligations that may result from transactions initiated prior to Robinhood’s receipt and
processing of my notice.
If I participate in the DRIP, I understand Robinhood will reinvest the dividends of a particular stock at or
near the opening price on the trading day following receipt of the dividend. Robinhood will combine
Eligible cash distributions from My Account with those from other Robinhood clients requesting dividend
reinvestment in the same security and use these combined funds to purchase securities on my behalf
and on behalf of these other clients. If the combined reinvested funds do not total the purchase price of
at least one share, the distribution will be invested in fractional shares. On that same day, Robinhood will
credit My Account with that number of shares, including fractional shares, equal to my Eligible cash
distribution divided by the purchase price per share. Robinhood does not intend to charge a fee for
transactions executed pursuant to the DRIP.
Dividend reinvestment may result in my owning interests in fractional shares of a security. I will be
entitled to receive future dividend payments on my fractional shares, although other corporate actions
may result in allocation of only whole shares and cash in lieu of fractions as determined by the issuer. In
mandatory corporate reorganizations, my partial interest will be handled according to the specific terms
of the reorganization. In voluntary corporate reorganizations, Robinhood will act on my instructions with
respect only to my whole shares.
Because fractional share positions cannot be transferred, reorganized, or issued in certificate form, my
partial interest will be liquidated, without commission charges to me, at prevailing market prices in the
event My Account is transferred or closed, the stock is reorganized, or stock certificates are ordered out
of My Account. The timing of such liquidations will be at the discretion of Robinhood.
Reinvestment of dividends may result in my owning a fractional share position in securities that are
callable in part. In the event of a call, fractional shares to be called will be determined through a random
selection process. The probability of my fractional share holdings being called will be proportional to the
holdings of all Robinhood clients who own a fractional share position in that security. Prior to the
publication date of such a call, I have the right to withdraw from My Account cash in lieu of my uncalled,
fully paid partial holdings. Once a call is announced, however, all shares, whether registered or held in
street name, participate in the random selection process. If my fractional shares are selected and I no
longer hold the shares that I held on the publication date of the call, I will be responsible for covering
those shares.
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30. Cash Management Services.
Except as expressly stated otherwise, the provisions of this Section 30 will only apply if I am enrolled in
Cash Management.
A. General.
I understand and agree that by enrolling in Cash Management, I may apply for a Robinhood-branded
debit card issued by the bank identiﬁed in My Robinhood Debit Card Agreement ("Card"). I further
understand and agree that by using My Card, exercising My electronic fund transfer ("EFT") privileges
offered in connection with My Account, and/or by successfully completing a request using Pay by
Check, I authorize Robinhood to debit My Account immediately whenever an electronic draft or Card
transaction is presented for payment on My behalf, when an EFT transaction is effected, when a Pay by
Check request is successfully completed on My Account and/or when any fee or charge is due
(collectively "Payment" or “Payments”). I further understand and agree that when I request a Payment or
withdrawal or instruct Robinhood to make a purchase of securities from My Account, Robinhood is
authorized to place a block on the amount of the transaction ("Blocked Amounts") prior to the settlement
date of the Payment, withdrawal or trade, and that the Blocked Amounts will not be available for use for
additional Payments or the purchase of securities. I agree to maintain Available Funds sufﬁcient to pay
for Payments made by Me or any Authorized Card User (as deﬁned below) and to pay for any securities
trades and for interest on any margin loans and other transaction fees. For this purpose, "Available
Funds" in My Account will ﬂuctuate daily and means the sum of (i) free credit balances, (ii) deposits to
Participating Depository Institutions through the Sweep Service, and (iii) available margin loan value if
My Account has margin privileges, minus (x) uncleared funds, (y) Blocked Amounts, and (z) deposits
subject to a hold. The loan value of eligible securities for the purpose of margin is subject to regulatory
requirements and Robinhood credit policies then in effect.
B. Payments and Withdrawals.
I agree that any Payments that I make from My Account will be lawful. I agree that Payments will be
deducted from the Available Funds in My Account in the following order: ﬁrst, from free credit balances;
second, by withdrawal of funds deposited to Participating Depository Institutions as part of the Sweep
Service; and third, if My Account has margin privileges, from margin loans on the eligible securities in
My margin Account. Robinhood will debit My Account only up to an amount equal to the Available Funds.
I understand and agree that (i) if there are insufﬁcient Available Funds in My Account to cover Payments
when they become due, Robinhood has no obligation to make such Payments, and (ii) Robinhood has
no obligation to make partial Payments. Robinhood will not charge a fee with respect to any declined
Payment for which there were insufﬁcient Available Funds. I acknowledge and agree, however, that
Robinhood will not be responsible for any costs or losses that I may incur (including fees, costs,
charges, attorneys' fees, investment losses, claims, demands, or liability resulting from any litigation or
other actions) as a result of Robinhood's decision to decline any Payment or withdrawal or other
transaction because My Account has insufﬁcient Available Funds.
I understand that if a Payment is funded by a margin loan, I will incur interest until the margin loan is
repaid.
I agree that if my Available Funds at any time falls below zero, Robinhood may suspend my ability to
make Payments and terminate My Card. If this occurs, I agree to immediately pay all amounts owed to
Robinhood, including any purchases on My Card which will be immediately charged to My Account.
I acknowledge and agree that Robinhood reserves the right to decline any Payments at any time for any
reason with or without notice to Me. If Robinhood decides to take such action, I understand and agree
that I am responsible for any pending debits, which will be processed and deducted from My Account.
I understand that transactions will post to My Account in any order determined by Robinhood and that
Robinhood may change that order without prior notice to Me. Robinhood will comply with requirements of
applicable law regarding the order of posting transactions.
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C. Limitation of Liability.
I agree that, subject to any limitations imposed by applicable law, and except as otherwise set forth in
this Agreement or in the disclosures contained in the Robinhood Debit Card Agreement, which has been
provided to Me or made available to me in connection with the opening of My Account, Robinhood,
Robinhood’s agents, any processing bank, and the Card issuer will not be liable for any loss I incur in
connection with My Account and any Payments or other features of My Account unless Robinhood is
grossly negligent in fulﬁlling this Agreement. In no event will Robinhood, Robinhood’s agents, any
processing bank, and the Card issuer shall not be liable for consequential, special or indirect damages or
losses unless applicable law requires otherwise. I also agree that liability regarding online services or
use of the App is further limited by the Robinhood Terms and Conditions, available at https://
about.robinhood.com/legal/. To the extent I utilize online services or the App I acknowledge that I am
bound by such Robinhood Terms and Conditions.
D. Debit Cards.
I understand and agree that My use of the Card is subject to the terms, conditions and disclosures set
forth in the Robinhood Debit Card Agreement, which has been provided to Me in connection with the
opening of My Account and which I may access on the Website.
I understand and agree that I cannot request a Card for another person to use. I agree, however, that if I
permit another person to have access to use My Card or Card number (an "Authorized Card User"), I am
authorizing all Card transactions by such person and I agree that there are no limits to my authorization.
I accept all liability with respect to the Card transactions effected by Me and any Authorized Card Users.
I further agree that I may terminate the authority of an Authorized Card User only by contacting
help@robinhood.com, to cancel my Card. I agree that the cancellation of My Card is effective only after
Robinhood has a reasonable period to act on My notice.
If My Card is cancelled, I agree to destroy, or if requested by Robinhood, return the Card to Robinhood. I
acknowledge that I will be responsible for any Card transactions that are processed because of My
failure to destroy or return the Card following cancellation.
If My Account includes margin privileges, I agree that transactions that exceed My free credit balances
and deposits in the Sweep Service may result in margin credit being extended to My Account, for which
I will be charged interest. I agree to review the Margin Disclosure Statement, which is available at
https://about.robinhood.com/legal/.
E. Deposits.
The provisions in this Section 30.E shall apply to My Account whether or not I am enrolled in Cash
Management.
General; Holds. I acknowledge and agree that funds that I deposit to My Account may be subject to one
or more hold periods, which are described in the RHF Funds Availability schedule available at https://
about.robinhood.com/legal/. I understand and agree that Robinhood reserves the right to modify the RHF
Funds Availability schedule at any time by posting an updated schedule at https://about.robinhood.com/
legal/, or otherwise providing notice to me. During the applicable hold period, My funds will not be
available for Payments, withdrawal, or the settling of securities transactions, in each case as described
in the RHF Funds Availability schedule. I further understand and agree that Robinhood reserves the right
to further delay making deposited funds available for periods longer than the hold periods specified in the
RHF Funds Availability schedule to the extent Robinhood determines that additional time is needed to
verify information about the item deposited or the sender or if Robinhood otherwise believes there is a
risk of fraud or other unlawful activity with respect to My Account.
Mistaken Deposits. If funds are deposited or transferred into My Account by mistake or otherwise, I
agree that Robinhood may correct the situation and deduct any interest paid by Participating Depository
Institutions, if applicable, without prior notice to Me.
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Returned Funds. I acknowledge and agree that I am responsible for returned transactions. If I have
funds transferred into My Account and that transfer is returned for any reason, Robinhood may charge
the transfer and interest paid by Participating Depository Institutions, if applicable, against My Account,
without prior notice to Me.
F. Electronic Fund Transfers.
The provisions in this Section 30.F relating to EFTs other than Card transactions shall apply to My
Account whether or not I am enrolled in Cash Management.
I understand that My Account may be eligible for a variety of EFTs, which may be subject to separate
agreements, terms and conditions. These services may include use of the Card, and the "Move Money"
functionality of the App. I understand that I may be required to agree to separate terms and conditions
governing the particular service I use to initiate EFTs. In addition, I understand and agree that my use of
EFT services are subject to the disclosures set forth in Appendix A (Electronic Fund Transfer
Disclosures), and acknowledge that I have received and reviewed such disclosures.
G. Security.
I agree to protect My Card, and My PINs, from access by anyone not authorized by Me to use them. I
acknowledge that I will be liable for all Card and online transactions conducted by anyone to whom I
have given access or who has obtained access even if not authorized by Me, up to applicable legal
limits. I understand that I am responsible for reviewing My Account statement promptly to discover and
report unauthorized activity, including use of My Card, Card number or PIN. I agree to notify Robinhood
as provided in Appendix A (Electronic Fund Transfer Disclosures) if I believe or have reason to believe
that there has been unauthorized activity in My Account or that My Card, Card number or PIN has been
lost, stolen or may be used by an unauthorized person. Unless limited by law or as otherwise set forth in
this Agreement or in the disclosures contained in Robinhood Debit Card Agreement, which is provided to
Me as part of the Account opening process and is available on the Website, I agree that I will be
responsible for losses that arise from My failure to (i) safeguard My Card and PINs, (ii) review My
monthly statement for possible unauthorized activity and (iii) report any unauthorized activity to
Robinhood as provided herein or in the Robinhood Debit Card Agreement.
H. No Illegal Purpose.
I agree and understand that I may not use my debit card or any Payments on My Account for any illegal
purpose. I agree and understand that Robinhood may, in its discretion, deny any transactions that appear
to be made for an illegal purpose.
I. Pay by Check.
I agree and understand that if I try to stop payment on a check after it has been mailed to the payee,
Robinhood will attempt to but cannot guarantee that payment on the check will be stopped. I understand
that a stop payment order on a check is valid for six months. I understand that if I wish to renew a stop
payment on a check after the six month period, I must contact Robinhood to request another stop
payment. I agree and understand that I may still be liable to the holder of the check even if I have
requested a stop payment for the amount of the check. I agree and understand that Robinhood may
deduct My Account for the amount on the check if the stop payment request is unsuccessful.
J. Disclosure of Information.
I agree and understand that all disclosures of My non-public personal information shall be made in
accordance with the terms of the this Agreement or the Robinhood Privacy Policy (available on the
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Website at https://about.robinhood.com/legal/, as applicable. I agree that My consent to sharing non-
public personal information will remain in effect until I revoke such consent by updating My settings and
visibility, which I may do at any time through the App.
In addition, I understand and agree that Robinhood may disclose information about My Account and My
related activities to third parties under the following circumstances: - As necessary to complete My
Payment transactions; - To investigate any complaint, disputed transaction, transaction inquiry or
request I make or as necessary to investigate potential fraud or misuse related to My Account; - To
respond to requests from credit bureaus, creditors or other third parties for account-related information, to
the extent such inquiries are necessary for processing My transactions or are usual and customary in
the course of servicing similar products or accounts; - As necessary to comply with any applicable law,
government or court order or subpoena; or - In accordance with My written permission or as otherwise
permitted under the Robinhood Privacy Policy.
I. Termination.
I understand that Robinhood may terminate my participation in Cash Management or in specific features
of Cash Management for any reason, upon notice to me.
31. Consent to Redeem Shares.
I understand and agree that whenever it is necessary for Robinhood's protection or to satisfy a margin
call, deficiency, debit or other obligation owed to Robinhood, Robinhood may (but is not required to) sell,
assign and deliver all or any part of the securities in My Account, or close any or all transactions in My
Account. I understand that Robinhood may, but is not obligated to, attempt to contact Me before taking
any such action. I understand and agree that Robinhood reserves the right to take any such action
without prior notice or demand for additional collateral, and free of any right of redemption, and that any
prior demand, call or notice will not be considered a waiver of our right to sell or buy without demand,
call or notice.
I further understand that Robinhood may choose which securities to buy or sell, which transactions to
close, and the sequence and timing of liquidation, and may take such actions on whatever exchange or
market and in whatever manner (including public auction or private sale) that Robinhood chooses in the
exercise of its business judgment. I agree not to hold Robinhood liable for the choice of which securities
to buy or sell or of which transactions to close or for the timing or manner of the liquidation. I also agree
not to hold Robinhood liable for taking such action.
I understand and agree that Robinhood is entitled to exercise the rights described in this section in its
sole discretion, including, but not limited to, whenever any of the following occurs:
The equity level in My Account falls below required minimums;
Sufficient funds or securities are not deposited to pay for transactions in My Account;
I reverse any ACH debit transfer to My Account;
A petition of bankruptcy or for the appointment of a receiver is filed by or against Me;
An attachment is levied against My Account;
I die or become incapacitated or incompetent; or
My Account is closed.
32. Electronic Delivery of Trade and Account Information; Notice.
All communications, notices, legal disclosures, and other materials related to My Account or this
Agreement, including account statements, trade confirmations, margin calls, notices, disclosures,
regulatory communications and other information, documents, data and records regarding My Account
(the "Communications"), or an alert that any such Communication has been posted to the secure section
of the Website or the App, and is available for viewing, may be sent to Me at the mailing address for My
Account or the e-mail address that I have given to Robinhood in My account application or at such other
address as I may hereafter give Robinhood in writing or by e-mail at least ten (10) calendar days prior to
delivery, and all communications so sent, whether in writing or otherwise, shall be deemed given to Me
personally, whether actually received or not.
•
•
•
•
•
•
•
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33. API.
A. Overview; Definitions.
Robinhood may, in Robinhood's sole discretion, provide third parties with an application programming
interface and other materials in accordance with any accompanying documentation (collectively, the "API
Package") (such third parties, "API Licensees"), to make available certain features and functionality of
Robinhood's mobile applications, websites, or technology platform via the API Licensees' products (such
products, the "Licensee Products"). The API Package and the Licensee Products are collectively
referred to as the "API Products". "Personal Information" means My personally identifiable information
(including username, logon password, financial information, trade data, and other financial information)
and all data exchanged between Robinhood and the API Products.
B. Access to My Personal Information.
Through My use of any API Products, I may be providing API Licensees with access to My Account and
Personal Information. By using any API Products, I acknowledge that such API Products may employ
security, policies, procedures and systems of API Licensees which may or may not be less stringent and
secure than Robinhood's policies, procedures and systems. I agree that My use of any API Products
shall be subject to the terms and conditions of this Agreement, in addition to any other agreements
which I executed with respect to any such API Products. I understand and agree that any end user
agreement that I executed with any API Licensee is concluded between Me and such API Licensee only,
and not with Robinhood; and such API Licensee, not Robinhood, is solely responsible for such Licensee
Product and the content thereof. I understand and agree that the API Products may deliver Personal
Information to Robinhood, and that Robinhood is authorized to receive and store such Personal
Information consistent with Robinhood's then-in-effect policies and procedures. Further, I agree that the
API Products may request Personal Information stored by Robinhood, and I consent to Robinhood's
disclosure of such Personal Information to the API Products.
C. No Recommendations.
To the extent the Licensee Products or API Licensees express opinions or make recommendations, I
understand that such opinions and recommendations are expressed solely by API Licensees and are not
the opinions or recommendations of Robinhood. The existence of the API Products and Robinhood's
consent to any connectivity between any Licensee Products and Robinhood's technology, the App, the
Website, or trading platform(s) does not constitute (i) any recommendation by Robinhood to invest in any
security or utilize any investment strategy; or (ii) any representation, warranty, or other guarantee by
Robinhood as to the present or future value or suitability of any sale, trade, or other transaction involving
any particular security or any other investments. The existence of any and all information, tools and
services provided by API Licensees or by the Licensee Products shall not constitute Robinhood's
endorsement of API Licensees or the Licensee Products.
D. Data Provided by Robinhood to API.
From time to time, and subject to then-in-effect agreements between Robinhood and API Licensees,
Robinhood may, in its own discretion, make market data feeds received from third parties available via
the API Products. Robinhood does not make any guarantees in regard to such market data feeds.
Furthermore, API Licensees or Licensee Products may make available to Me market data feeds
independent of Robinhood. I am aware that from time to time that there may be discrepancy between the
market data presented on the App or Website and information provided by any API Products due to a
variety of reasons, including the time to update and transmit such data to a mobile application or website
and latency caused by such API Product's or My local environment (such as computer set up,
connection speed, etc.). Robinhood is not responsible for the accuracy of any market data displayed on
any API Products or otherwise made available by API Licensees.
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E. Risks; No Liability.
I acknowledge that there may be latency between the time an order (or other Personal Information) is
submitted from the API Products and the time such order or Personal Information is received by
Robinhood. Latency may also affect order modification and order cancellation requests. The time an
order or a request is actually received by Robinhood (including for execution) will be the official time,
including for the purposes of routing the order to the market for execution. In addition, all orders
submitted to Robinhood are subject to order vetting by Robinhood. Orders created and submitted through
any API Products are not vetted until they are received by Robinhood. It is possible that Robinhood may
reject an order placed through any API Products. Robinhood cannot guarantee that any order will be
accepted when such order is routed to the market for execution, and Robinhood cannot guarantee that
notifications and Personal Information provided to Me by Robinhood will be successfully delivered to or
displayed by any API Products.
Without limiting the generality of any other terms in this Agreement, I agree that:
Robinhood or its Affiliates shall not be liable for any Losses as a result of any issues addressed
in this Section 33 of this Agreement, nor shall Robinhood or its Affiliates be liable for any Losses
realized for technical issues involving any API Products or API Licensee technology or product
offerings (including system outages or downtime).
Robinhood or its Affiliates shall not be responsible for any investment research provided by any
API Licensee or any Licensee Products.
Robinhood or its Affiliates makes no representations, warranties or other guarantees as to the
accuracy, timeliness or efficacy of any market data, information, or other functionality made
available by any API Licensee or any API Products.
F. Intellectual Property.
My use of any API Products will not confer to Me any title, ownership interest or intellectual property
rights that otherwise belongs to Robinhood or any of its affiliates. The API Package, including content, is
protected under U.S. patent, copyright laws, international treaties or conventions, and other laws and will
remain Robinhood's exclusive property, as applicable. Names, logos, and all related product and service
names, design marks, and slogans displayed by or relating to Robinhood or any of its Affiliates or API
Licensees in the context of the API Products shall remain the property of the respective owner, and use
of such property by Robinhood or any API Licensee in marketing or provision of any API Products does
not grant ownership of or entitle Me to use any such name or mark in any manner.
G. User's Representations and Warranties.
I represent and warrant that:
By virtue of utilizing any API Products, I consent to and accept any risk associated with
Robinhood's sharing of Personal Information with any API Licensee and shall not hold Robinhood,
its Affiliates, or their respective officers, directors, or employees responsible for any Losses
resulting from the sharing of such Personal Information.
I agree that My use of any API Products or API Licensee's content, information, technology, or
functionality is at My own risk.
I agree that Robinhood may revoke any API Licensee or API Products' authorization at any time,
for any reason, with or without cause and without prior notice to Me.
34. Electronic Signatures; Modifications to the Agreement.
I agree to transact business with Robinhood electronically. By electronically signing an application for an
Account, I acknowledge and agree that such electronic signature is valid evidence of My consent to be
1.
2.
3.
1.
2.
3.
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legally bound by this Agreement and such subsequent terms as may govern the use of Robinhood's
services. The use of an electronic version of any document fully satisfies any requirement that the
document be provided to Me in writing. I accept notice by electronic means as reasonable and proper
notice, for the purpose of any and all laws, rules and regulations. I acknowledge and agree that
Robinhood Financial may modify this Agreement from time to time and I agree to consult the Website
from time to time for the most up-to-date Agreement. The electronically stored copy of this Agreement is
considered to be the true, complete, valid, authentic and enforceable record of the Agreement,
admissible in judicial or administrative proceedings to the same extent as if the documents and records
were originally generated and maintained in printed form. I agree to not contest the admissibility or
enforceability of Robinhood Financial's electronically stored copy of the Agreement.
35. Margin Accounts.
A. Election.
This numbered section applies to my account to the extent I elect and am approved for a Robinhood
Gold margin account.
B. Margin Trading.
I understand that margin trading involves interest charges and risks, including the potential to lose more
than deposited or the need to deposit additional collateral in a falling market. Before using margin,
customers must determine whether this type of trading strategy is right for them given their specific
investment objectives, experience, risk tolerance, and financial situation. If I have elected to have a
margin Account, I represent that I have read the Margin Disclosure Statement, Day Trading Risk
Disclosure, and FINRA Investor Information. These disclosures contain information on Robinhood's
lending policies, interest charges, and the risks associated with margin accounts.
C. Hypothecation.
Within the limitations imposed by applicable laws, rules and regulations, all securities now or hereafter
held by Robinhood, or carried by Robinhood in any account for Me (either individually or jointly with
others), or deposited to secure same, may from time to time, without any notice, be carried in your
general loans and may be pledged, repledged, hypothecated or re-hypothecated, separately or in
common with other securities for the sum due to you thereon or for a greater sum and without retaining
in your possession or control for delivery a like amount of similar securities. The IRS requires Broker
Dealers to treat dividend payments on loaned securities positions as payments received in lieu of
dividends for 1099 tax reporting purposes. Taxation of substitute dividend payments may be greater than
ordinary on qualified dividends. It is understood, however, that you agree to deliver to Me upon My
demand and upon payment of the full amount due thereon, all securities in such accounts, but without
obligation to deliver the same certificates or securities deposited by Me originally. Any securities in My
margin or short account may be borrowed by you, or lent to others.
D. Interest.
Debit balances in My Accounts shall be charged with interest in accordance with your established
custom, as disclosed to Me in the Customer Information Brochure pursuant to the provisions of the
Securities Exchange Act.
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E. Margin.
I agree to maintain in all accounts with Robinhood such positions and margins as required by all
applicable statutes, rules, regulations, procedures and custom, or as you deem necessary or advisable. I
agree to promptly satisfy all margin and maintenance calls.
F. Sales.
I agree to specifically designate any order to sell a security, which I do not own as a short sale, and
understands that Robinhood will mark such order as a short sale. I agree that any order which is not
specifically designated as a short sale is a sale of securities owned by me, and that I will deliver the
securities on or before settlement date, if not already in the account. If I should fail to make such
delivery in the time required, Robinhood is authorized to borrow such securities as necessary to make
delivery for the sale, and I agree to be responsible for any loss you may thereby sustain, or which you
may sustain as a result of your inability to borrow such securities.
36. Consent to Electronic Delivery of Documents.
A. Consent.
By agreeing to electronic delivery, I am giving My informed consent to electronic delivery of all
Account Documents, as defined below, other than those I have specifically requested to be
delivered in paper form. "Account Documents" include notices, disclosures, current and future account
statements, regulatory communications (such as prospectuses, proxy solicitations, and privacy notices),
trade confirmations, tax-related documents, and any other information, documents, data, and records
regarding My Account, this Agreement (including amendments to this Agreement), and the agreements
and disclosures governing the services delivered or provided to Me by Robinhood Financial, the issuers
of the securities or other property in which I invest, and any other parties. I agree that I can access,
view, download, save, and print any Account Documents I receive via electronic delivery for My records.
B. Electronic Delivery System.
I acknowledge that Robinhood's primary methods of communication with Me include (A) posting
information on the Website, (B) providing information via the App, (C) sending email(s) to My email
address of record, and, to the extent required by law, (D) providing Me with notice(s) that will direct Me
to the App or the Website where I can read and print such information. Unless otherwise required by law,
Robinhood reserves the right to post Account Documents on the Website without providing notice to Me.
Further, Robinhood reserves the right to send Account Documents to My postal or email address of
record, or via the App or Website. I agree that all Account Documents provided to Me in any of the
foregoing manner is considered delivered to Me personally when sent or posted by Robinhood, whether I
receive it or not.
All e-mail notifications regarding Account Documents will be sent to My e-mail address of record. I agree
to maintain the e-mail address that I have provided Robinhood until I provide Robinhood with a new one.
I understand that e-mail messages may fail to transmit promptly or properly, including being delivered to
SPAM folders. I further understand that it is My sole responsibility to ensure that any emails from
Robinhood or its Affiliates are not marked as SPAM. Regardless of whether or not I receive an e-mail
notification, I agree to check the Website regularly to avoid missing any information, including time-
sensitive or otherwise important communication. If I authorize someone else to access the e-mail
account I have provided Robinhood, I agree to tell them to share the Account Documents with Me
promptly, and I accept the risk that they will see My sensitive information. I understand that if I use a
work e-mail address or computing or communications device, My employer or other employees may
have access to the Account Documents.
Additionally, I acknowledge that the Internet is not a secure network and agree that I will not send any
confidential information, including Account numbers or passwords, in any unencrypted e-mails. I also
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understand that communications transmitted over the Internet may be accessed by unauthorized or
unintended third parties and agree to hold Robinhood, its Affiliates, and Robinhood and its Affiliates'
respective officers and employees harmless for any such access regardless of the cause.
I agree to promptly and carefully review all Account Documents when they are delivered and notify
Robinhood Financial in writing within five (5) calendar days of delivery if I object to the information
provided (or other such time specified herein). If I fail to object in writing within such time, Robinhood
Financial is entitled to treat such information as accurate and conclusive. I will contact Robinhood to
report any problems with accessing the Account Documents.
C. Costs.
Potential costs associated with electronic delivery of Account Documents may include charges from
Internet access providers and telephone companies, and I agree to bear these costs. Robinhood
Financial will not charge Me additional online access fees for receiving electronic delivery of Account
Documents.
D. Archival.
Upon My request, I may obtain copies of up to six (6) prior years of account statements, and three (3)
prior years of trade confirmations.
E. Revocation of Consent.
Subject to the terms of this Agreement, I may revoke or restrict My consent to electronic delivery of
Account Documents at any time by notifying Robinhood Financial in writing of My intention to do so. I
also understand that I have the right to request paper delivery of any Account Document that the law
requires Robinhood Financial to provide Me in paper form. Robinhood Financial will not treat My request
for paper copies as a withdrawal of My consent to electronic delivery of Account Documents. I
understand that if I revoke or restrict My consent to electronic delivery of Account Documents or request
paper delivery of same, Robinhood Financial, in its sole discretion, may charge Me a reasonable service
fee for the delivery of any Account Document that would otherwise be delivered to Me electronically,
restrict or close My account, or terminate My access to Robinhood Financial's services. I understand
that neither My revocation or restriction of consent, My request for paper delivery, nor Robinhood
Financial's delivery of paper copies of Account Documents will affect the legal effectiveness or validity
of any electronic communication provided while My consent was in effect.
F. Duration of Consent.
My consent to receive electronic delivery of Account Documents will be effective immediately and will
remain in effect unless and until either I or Robinhood Financial revokes it. I understand that it may take
up to three (3) Business Days to process a revocation of consent to electronic delivery, and that I may
receive electronic notifications until such consent is processed.
G. Hardware and Software Requirements.
I understand that in order to receive electronic deliveries, I must have access to a computer or Mobile
Device with Internet access, a valid e-mail address, and the ability to download such applications as
Robinhood Financial may specify and to which I have access. I also understand that if I wish to
download, print, or save any information I wish to retain, I must have access to a printer or other device
in order to do so.
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H. Consent and Representations.
I hereby agree that I have carefully read the above information regarding informed consent to electronic
delivery and fully understand the implications thereof. Additionally, I hereby agree to all conditions
outlined above with respect to electronic delivery of any Account Document. I will maintain a valid e-mail
address and continue to have access to the Internet. If My e-mail address changes, I agree to
immediately notify Robinhood Financial of My new e-mail address in writing.
37. Miscellaneous Provisions.
The following provisions shall also govern this Agreement:
A. Contact Information.
Robinhood Customer Service may be contacted by visiting support.robinhood.com or by email at
help@robinhood.com.
B. Interpretation.
The heading of each provision hereof is for descriptive purposes only and shall not be (1) deemed to
modify or qualify any of the rights or obligations set forth herein or (2) used to construe or interpret any of
the provisions hereunder. When a reference is made in this Agreement to a Section, such reference shall
be to a Section of this Agreement unless otherwise indicated. Whenever the words "include," "includes"
or "including" are used in this Agreement, they shall be deemed to be followed by the words "without
limitation." The word "or," when used in this Agreement, has the inclusive meaning represented by the
phrase "and/or." Unless the context of this Agreement otherwise requires: (i) words using the singular or
plural number also include the plural or singular number, respectively; and (ii) the terms "hereof,"
"herein," "hereunder" and derivative or similar words refer to this entire Agreement. References to any
law shall be deemed to refer to such law as amended from time to time and to any rules or regulations
promulgated thereunder.
C. Binding Effect; Assignment.
This Agreement shall bind My heirs, assigns, executors, successors, conservators and administrators. I
may not assign this Agreement or any rights or obligations under this Agreement without first obtaining
Robinhood's prior written consent. Robinhood may assign, sell, or transfer My Account and this
Agreement, or any portion thereof, at any time, without My prior consent.
D. Severability.
If any provisions or conditions of this Agreement are or become inconsistent with any present or future
law, rule, or regulation of any applicable government, regulatory or self-regulatory agency or body, or are
deemed invalid or unenforceable by any court of competent jurisdiction, such provisions shall be deemed
rescinded or modified, to the extent permitted by applicable law, to make this Agreement in compliance
with such law, rule or regulation, or to be valid and enforceable, but in all other respects, this Agreement
shall continue in full force and effect.
E. Website Postings.
I agree and understand that Robinhood Financial may post other specific agreements, disclosures,
policies, procedures, terms, and conditions that apply to My use of the App, the Website, or My Account
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on the Website ("Website Postings"). I understand that it is My continuing obligation to understand the
terms of the Website Postings, and I agree to be bound by the Web Postings as are in effect at the time
of My use.
F. Entirety of Agreement.
This Agreement, any attachments hereto, other agreements and policies referred to in this Agreement
(including the Website Postings), and the terms and conditions contained in My Account statements and
confirmations, contain the entire agreement between Robinhood and Me and supersede all prior or
contemporaneous communications and proposals, whether electronic, oral, or written, between
Robinhood and Me, provided, however, that any and all other agreements between Robinhood and Me,
not inconsistent with this Agreement, will remain in full force and effect.
G. Amendment.
Robinhood may at any time amend this Agreement without prior notice to Me. The current version of the
Agreement will be posted on the Website and My continued Account activity after such amendment
constitutes My agreement to be bound by all then-in-effect amendments to the Agreement, regardless of
whether I have actually reviewed them. Continued use of the App, the Website or any other Robinhood
Financial services after such posting will constitute My acknowledgment and acceptance of such
amendment. I agree to regularly consult the Website for up-to-date information about Robinhood
Financial services and any modifications to this Agreement. Robinhood is not bound by any verbal
statements that seek to amend the Agreement.
H. Termination.
Robinhood may terminate this Agreement, or close, deactivate, or block access to My Account at any
time in its sole discretion. I will remain liable to Robinhood for all obligations incurred in My Account,
pursuant to this Agreement, or otherwise, whether arising before or after termination. I may terminate this
Agreement after paying any obligations owed upon written notice. This Agreement survives termination
of My Account.
I. No Waiver; Cumulative Nature of Rights and Remedies.
I understand that Robinhood's failure to insist at any time upon strict compliance with any term
contained in this Agreement, or any delay or failure on Robinhood's part to exercise any power or right
given to Robinhood in this Agreement, or a continued course of such conduct on Robinhood's part, shall
at no time operate as a waiver of such power or right, nor shall any single or partial exercise preclude
any other further exercise. All rights and remedies given to Robinhood in this Agreement are cumulative
and not exclusive of any other rights or remedies to which Robinhood is entitled.
J. International Customers.
The products and services described on the Website are offered only in jurisdictions where they may be
legally offered. Neither the Website nor the App shall be considered a solicitation for or offering of any
investment product or service to any person in any jurisdiction where such solicitation or offering would
be illegal. I understand that Robinhood, in its sole discretion, may accept unsolicited accounts from non-
U.S. residents, depending on the country of residence and other factors. I understand that Robinhood is
based in the United States and that Robinhood accepts only U.S. currency in Robinhood's customer
accounts.
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K. Governing Law.
This Agreement and all transactions made in My Account shall be governed by the laws of the State of
California (regardless of the choice of law rules thereof), except to the extent governed by the federal
securities laws, FINRA Rules, and the regulations, customs and usage of the exchanges or market (and
its clearing house) on which transactions are executed.
38. Arbitration.
A. This Agreement contains a pre-dispute arbitration clause. By signing an arbitration agreement,
the parties agree as follows: (1) All parties to this Agreement are giving up the right to sue each
other in court, including the right to a trial by jury, except as provided by the rules of the
arbitration forum in which a claim is filed. (2) Arbitration awards are generally final and binding; a
party's ability to have a court reverse or modify an arbitration award is very limited. (3) The ability
of the parties to obtain documents, witness statements and other discovery is generally more
limited in arbitration than in court proceedings. (4) The arbitrators do not have to explain the
reason(s) for their award unless, in an eligible case, a joint request for an explained decision has
been submitted by all parties to the panel at least 20 days prior to the first scheduled hearing
date. (5) The panel of arbitrators will typically include a minority of arbitrators who were or are
affiliated with the securities industry. (6) The rules of some arbitration forums may impose time
limits for bringing a claim in arbitration. In some cases, a claim that is ineligible for arbitration
may be brought in court. (7) The rules of the arbitration forum in which the claim is filed, and any
amendments thereto, shall be incorporated into this Agreement. B. Any controversy or claim
arising out of or relating to this Agreement, any other agreement between Me and Robinhood, any
Account(s) established hereunder, any transaction therein, shall be settled by arbitration in
accordance with the rules of FINRA Dispute Resolution, Inc. ("FINRA DR"). I agree to arbitrate
any controversy or claim before FINRA DR in the State of California. C. This agreement to
arbitrate constitutes a waiver of the right to seek a judicial forum unless such a waiver would be
void under the federal securities laws. If I am a foreign national, non-resident alien, or if I do not
reside in the United States, I agree to waive My right to file an action against Robinhood in any
foreign venue. D. No person shall bring a putative or certified class action to arbitration, nor seek
to enforce any pre-dispute arbitration agreement against any person who has initiated in court a
putative class action; or who is a member of a putative class who has not opted out of the class
with respect to any claims encompassed by the putative class action until: (1) the class
certification is denied; or (2) the class is decertified; or (3) the customer is excluded from the
class by the court. Such forbearance to enforce an agreement to arbitrate shall not constitute a
waiver of any rights under this Agreement except to the extent stated herein.
ACCEPTED AND AGREED: I acknowledge that I have read the preceding terms and conditions of this
Agreement, that I understand them and that I hereby manifest my assent to, and my agreement to
comply with, those terms and conditions by accepting this agreement. I ALSO UNDERSTAND THAT
BY ACCEPTING THIS AGREEMENT I HAVE ACKNOWLEDGED THAT THIS AGREEMENT
CONTAINS A PREDISPUTE ARBITRATION CLAUSE IN SECTION 38 HEREIN. I ALSO AGREE (1)
THAT ANY OF MY MARGIN ACCOUNT SECURITIES MAY BE BORROWED BY ROBINHOOD OR
LOANED TO OTHERS; (2) I HAVE RECEIVED OF A COPY OF THIS AGREEMENT AND (3) I HAVE
REVIEWED A COPY OF THE MARGIN DISCLOSURE STATEMENT.
Appendix A
Electronic Fund Transfer Services Disclosures
The following disclosures apply to the use of any EFT services offered by Robinhood, including the
Card, ACH transactions and the Move Money functionality of the App.
Solely for purposes of these disclosures: (i) references to the Bank shall include any financial institution
that issues the Card or provides services in connection with ACH, Move Money or other EFT
transactions; (ii) "you" and "your" mean the owner of the Account; and (iii) "we" and "us" means
Robinhood and the Bank collectively.
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1. Your Liability.
Contact Robinhood Customer Service AT ONCE if you believe your Card or PIN has been lost or stolen
or if you believe that an electronic fund transfer has been made without your permission. Telephoning is
the best way of keeping your losses down. You could lose all the Available Funds in your Account (plus
your maximum overdraft line of credit). If you tell Robinhood within 2 business days after you learn of
the loss or theft of your Card or PIN, you can lose no more than $50 if someone used your Card or PIN
without your permission.
If you do NOT tell Robinhood within 2 business days after you learn of the loss or theft of your Card or
PIN, and Robinhood can prove that it could have stopped someone from using your Card or PIN without
your permission if you had told Robinhood, you could lose as much as $500.
Also, if your statement shows transfers that you did not make, including those made by Card or using
your PIN, tell Robinhood at once. If you do not tell Robinhood within sixty (60) days after the statement
was mailed to you, or otherwise made available to you, you may not get back any money you lost after
the sixty (60) days if Robinhood can prove that Robinhood could have stopped someone from taking the
money if you had told Robinhood in time. If a good reason (such as a long trip or a hospital stay) kept
you from telling Robinhood, Robinhood will extend the time periods.
2. Contact in event of unauthorized transfer.
If you believe your Card or PIN has been lost or stolen, contact Robinhood by emailing
help@robinhood.com,.
3. Business Days.
Business Days are Monday through Friday, excluding federal holidays.
4. Transfer Types and Limitations.
You may use your Card to make purchases at any merchant that accepts Mastercard debit cards or
debit cards of other networks in which the Bank participates, and to make ATM withdrawals, in each
case subject to the Available Funds in your Account, the transaction limits described below, and the
other terms and conditions of this Agreement. You acknowledge and agree that the value available to
you for use with the Card is limited to the Available Funds in your Account. So long as you do not
exceed the Available Funds in your Account, you may use the Card to purchase goods or services
wherever the Card is honored, and to obtain cash by initiating cash withdrawal transactions through the
Card from any financial institution or ATM that accepts the Card. Each time you use the Card, you
authorize Robinhood to reduce the Available Funds in your Account by the amount of the purchase or
withdrawal and any applicable fees, costs, or holdings. Nevertheless, if you exceed the Available Funds
in your Account you shall remain fully liable to Robinhood for the amount of the transactions and any
applicable fees and charges.
You may also make ACH withdrawals from your Account, either originated through Robinhood or
originated by a third party (a "non-originated" withdrawal), subject to the Available Funds in your Account,
the transaction limits described below, and the other terms and conditions of this Agreement. You also
may make ACH deposits to your Account, either originated through Robinhood or originated by a third
party (a "non-originated" deposit), subject to the transaction limits described below.
There are limits on the dollar amount of transactions you can make with your Card each day and each
month, and limits on the amount of ACH withdrawals and deposits you can make each day. The
following lists the limits for each type of transaction:
Originated ACH Withdrawals* Daily Limit: $50,000.00
Weekly Limit: N/A Monthly Limit: N/A
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Originated ACH Deposits* Daily Limit: $50,000.00
Weekly Limit: N/A Monthly Limit: N/A
Non-Originated ACH Withdrawals* Daily Limit: $250,000.00
Weekly Limit: N/A Monthly Limit: N/A
Non-Originated ACH Deposits* Daily Limit: $250,000.00
Weekly Limit: N/A Monthly Limit: N/A
Point of Sale Purchases with the Card* Daily Limit: $5,000.00 Weekly Limit: N/A Monthly Limit:
$15,000.00
ATM Withdrawals* Daily Limit: $510.00 Weekly Limit: N/A Monthly Limit: $5,000.00
Originated ACH* Daily Limit: N/A, subject to the Weekly Limit Weekly Limit: $2,999 Monthly Limit: N/A
5. Fees.
We will not charge you any fees for use of ATMs that are part of the AllPoint or MoneyPass ATM
networks, or for point of sale transactions using the Card, or for initiating other EFTs on your behalf. If
you withdraw funds from ATMs outside of the AllPoint or MoneyPass ATM networks, you may be
separately assessed fees by those ATM owners or operators.
6. Confidentiality.
We may disclose information to third parties about you, your Card, or the transactions you make using
any of the EFT services we provide:
Where it is necessary or helpful for completing or correcting transactions and resolving claims
regarding transactions;
In order to verify the existence and condition of your Card or your Account for a third party, such
as a merchant;
In order to comply with a valid request by a government agency, a court order, or other legal or
administrative reporting requirements;
If you consent by giving us your written permission;
To our employees, auditors, affiliates, service providers, or attorneys as needed;
In order to prevent, investigate or report possible illegal activity;
In order to issue authorizations for transactions on the Card;
As permitted by applicable law; or
Otherwise as necessary to fulfill our obligations under this Agreement and the terms applicable to
the EFT service you are using.
Please see Robinhood's privacy policy, available at about.robinhood.com/legal, and the applicable
Bank's privacy policy, available at https://www.suttonbank.com/_/kcms-doc/85/49033/WK-Privacy-
Disclosure-1218.pdf, for further details. (The Robinhood privacy policy and the applicable Bank's privacy
policy are referred to collectively as the "Privacy Policies"). You hereby agree to Robinhood's and the
Bank's collection, use and sharing of information about you and the Card as provided in the Privacy
Policies, which are made a part of this Agreement. The Privacy Policies also tell you how you can (i)
limit the ways in which Bank and Robinhood share information about you, or (ii) request corrections to
the information that Bank or Robinhood maintain about you. You agree that information you provide in
connection with your Card or other EFT services you use is being provided directly to both Robinhood as
the holder of the Account associated with the service and the Bank as the Card issuer or provider of the
EFT service, as applicable.
7. Documentation.
Terminal Transfers. You can get a receipt at the time you make any transfer to or from your Account
using an ATM from the AllPoint or MoneyPass ATM networks or at the point of sale.
1.
2.
3.
4.
5.
6.
7.
8.
9.
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Preauthorized Credits. If you have arranged to have direct deposits made to your Account at least once
every 60 days from the same person or company, the person or company making the deposit will tell you
every time they send us the money. You can also check your Account online to see if a deposit has been
received.
Periodic Statements. You will get a monthly Account statement, unless there are no transfers in a
particular month. In any case you will get the statement at least quarterly. You may obtain information
about the Available Funds in your Account and a history of your Cash Management transactions on the
App.
8. Preauthorized Payments/Stop Payment Procedure and Notice of Varying
Amounts.
You do not have the right to request that Robinhood in advance make regular payments out of your
Account, although you may ask third parties to initiate regular payments out of your Account.
Right to stop payment: If you have automatic recurring payments taken out of your Account, you can
stop any of these payments by contacting us at help@robinhood.com,. You must contact us in time for
us to receive your request at least three business days before the payment is scheduled to be made.
Notice of varying amounts: If these regular payments vary in amount, the party you are going to pay will
tell you, 10 days before each payment, when the payment will be made and how much it will be. (The
party you are going to pay may allow you to choose to get this notice only when the payment would
differ by more than a certain amount from the previous payment, or when the amount would fall outside
certain limits that you set.)
Liability for failure to stop payment of a preauthorized transfer: If you order us to stop a payment at least
three business days before the transfer is scheduled and we do not do so, we will be liable for your
losses or damages.
9. Our Liability.
If we do not complete a transaction to or from your Account on time or in the correct amount according
to our Agreement with you, we will be liable for your losses or damages. However, there are some
exceptions. We will not be liable, for instance:
If through no fault of Robinhood or the Bank, you do not have enough Available Funds in your
Account to complete the transaction;
If a merchant refuses to accept your Card;
If an electronic terminal where you are making a transaction does not operate properly, and you
knew about the problem when you initiated the transaction;
If access to your Card has been blocked after you reported your Card lost or stolen;
If there is a hold or your funds are subject to legal or administrative process or other encumbrance
restricting their use;
If Robinhood or the Bank have reason to believe the requested transaction is unauthorized;
If circumstances beyond the control of Robinhood or the Bank (such as fire, flood, or computer or
communication failure) prevent the completion of the transaction, despite reasonable precautions
that Robinhood or the Bank have taken; or
For any other exception stated in this Agreement with you or by applicable law.
1.
2.
3.
4.
5.
6.
7.
8.
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10. Errors or Questions About Electronic Transfers.
In case of errors or questions about your electronic transfers, including your Card transactions, or if you
think your statement or receipt is wrong or if you need more information about a transaction listed on the
statement or receipt, contact Robinhood by emailing help@robinhood.com,. Robinhood must hear from
you no later than sixty (60) days after you were sent the FIRST statement on which the problem or error
appeared.
Tell Robinhood your name and account number.
Describe the error or the transfer you are unsure about, and explain as clearly as you can why
you believe it is an error or why you need more information.
Tell Robinhood the dollar amount of the suspected error.
Robinhood will determine whether an error occurred within ten (10) business days after Robinhood hears
from you and will correct any error promptly. If Robinhood needs more time, however, it may take up to
forty-five (45) days to investigate your complaint or question. If Robinhood decides to do this, Robinhood
will credit your Account within ten (10) business days for the amount you think is in error, so that you will
have the use of the money during the time it takes Robinhood to complete our investigation.
For errors involving new accounts, point of sale, or foreign initiated transactions, Robinhood may take up
to ninety (90) days to investigate your complaint or question. For new accounts, Robinhood may take up
to twenty (20) business days to credit your Account for the amount you think is in error.
Robinhood will tell you the results of our investigation within three (3) business days after completing the
investigation. If Robinhood decides that there was no error, Robinhood will send you a written
explanation. You may ask for copies of the documents that Robinhood used in our investigation.
1.
2.
3.
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Exhibit 4

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Rhfv1.15 2016 0801

Robinhood Financial Customer Agreement

In consideration of Robinhood Financial, LLC ("Robinhood Financial") and its agents and assigns
(collectively "You" and/or "Your") opening one or more accounts (“My Account(s)” or the
"Account(s)”) on my behalf, I represent and agree with respect to all Accounts, whether upon
margin or cash, to the terms set forth below (the “Agreement”). When used in this Agreement, the
words "I", "Me", "My", “Mine”, “We” and/or “Us” mean the owner(s) of the Account.

I UNDERSTAND THAT THE TERMS AND CONDITIONS OF THIS AGREEMENT GOVERN
ALL ASPECTS OF MY RELATIONSHIP WITH YOU REGARDING MY ACCOUNTS. I WILL
CAREFULLY READ, UNDERSTAND AND ACCEPT THE TERMS AND CONDITIONS OF THIS
AGREEMENT BEFORE I CLICK "SUBMIT APPLICATION" OR OTHER SIMILARLY WORDED
BUTTON. IF I HAVE ANY QUESTIONS ABOUT ANY OF THE PROVISIONS IN THIS
AGREEMENT, I WILL EMAIL AT SUPPORT@ROBINHOOD.COM OR CALL ROBINHOOD
FINANCIAL AT 650-940-2700. I UNDERSTAND THAT CLICKING "SUBMIT APPLICATION"
IS THE LEGAL EQUIVALENT OF MY MANUALLY SIGNING THIS AGREEMENT AND I WILL
BE LEGALLY BOUND BY ITS TERMS AND CONDITIONS. BY ENTERING INTO THIS
AGREEMENT, I ACKNOWLEDGE RECEIPT OF THE ROBINHOOD FINANCIAL PRIVACY
AND SECURITY STATEMENT. I UNDERSTAND THAT THIS AGREEMENT MAY BE
AMENDED FROM TIME TO TIME BY ROBINHOOD FINANCIAL, WITH REVISED TERMS
POSTED ON THE ROBINHOOD FINANCIAL WEB SITE. I AGREE TO CHECK FOR
UPDATES TO THIS AGREEMENT. I UNDERSTAND THAT BY CONTINUING TO MAINTAIN
MY SECURITIES BROKERAGE ACCOUNT WITHOUT OBJECTING TO ANY REVISED
TERMS OF THIS AGREEMENT, I AM ACCEPTING THE TERMS OF THE REVISED
AGREEMENT AND I WILL BE LEGALLY BOUND BY ITS TERMS AND CONDITIONS. IF I
REQUEST OTHER SERVICES PROVIDED BY ROBINHOOD FINANCIAL THAT REQUIRE ME
TO AGREE TO SPECIFIC TERMS AND CONDITIONS ELECTRONICALLY (THROUGH
CLICKS OR OTHER ACTIONS) OR OTHERWISE, SUCH TERMS AND CONDITIONS WILL BE
DEEMED AN AMENDMENT AND WILL BE INCORPORATED INTO AND MADE PART OF
THIS AGREEMENT. I ALSO UNDERSTAND THAT BY CLICKING "SUBMIT APPLICATION" I
HAVE ACKNOWLEDGED THAT THIS AGREEMENT CONTAINS A PREDISPUTE
ARBITRATION CLAUSE IN SECTION 29 HEREIN.

1. Capacity and Status. If an individual, I am of legal age under the laws of the State where I
reside and authorized to enter into this Agreement. If an entity, I am duly formed, validly
existing and in good standing in My state of organization, have full power and authority to
enter and perform this Agreement, and the persons signing the account application are fully
authorized to act on My behalf. No person, except Myself (or any person named in a
separate agreement or joint account), has any interest in the Account opened pursuant to this
Agreement. I acknowledge that unless You receive written objection from Me, You may
provide My name, address, and securities positions to requesting companies in which I hold
securities. Except as otherwise disclosed to You in writing, neither I nor any member of My
immediate family is an employee of any exchange, any corporation of which any exchange
owns a majority of the capital stock, a member of any exchange or self-regulatory
organization, a member of any firm or member corporation registered on any exchange, a
bank, trust company, insurance company or any corporation, firm or individual engaged in the
business of dealing either as a broker-dealer or as principal in securities. I understand and
Robinhood Financial, LLC
Member FINRA/SIPC
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Rhfv1.15 2016 0801

agree that I am obligated to promptly notify You in writing if I or a member of My immediate
family becomes registered or employed in any of the above-described capacities. I further
agree to promptly notify You in writing if I am now or if I become: (i) registered or qualified
with the Financial Industry Regulatory Authority, Inc. (“FINRA”), the SEC, the Commodities
Futures Trading Commission, any state securities agency, any securities exchange or
association, or any commodities or futures contract market or association; (ii) an “investment
adviser” as that term is defined in Section 201(11) of the Investment Advisers Act of 1940
(whether or not registered or qualified under that act); (iii) employed by a bank or other
organization exempt from registration under federal and state securities laws to perform
functions that would require Me to be so registered or qualified if I were to perform such
functions for an organization not so exempt; or (iv) an officer, director or 10% stockholder of
any publicly traded company.

2. Authorization. I understand that My brokerage account is self-directed. Accordingly, I
appoint You as My agent for the purpose of carrying out My directions to You in accordance
with the terms and conditions of this Agreement and any attendant risks with respect to the
purchase or sale of securities. You are authorized to open or close My Accounts, place and
withdraw orders and take such other steps as are reasonable to carry out My directions. All
transactions will be effected only on My order or the order of My authorized delegate, except
as described in Section 9. I understand Robinhood Financial provides trading and brokerage
services through the Robinhood Financial website (the “Website”) and the Robinhood
Financial mobile application (the “App”). I agree to receive and transmit financial information
through such electronic means. My use or My grant of access to My Account to any third
party to access information or place transactions in My Account is solely at My risk.

3. Customer Representations and Responsibilities.

(A)
Self-directed Account. I understand that My Account is self-directed, I am solely
responsible for any and all orders placed in My Account and all orders entered by me
or on My behalf are unsolicited and based on My own investment decisions or the
investment decision of My duly authorized representative or agent. Accordingly, I
agree that neither You nor any of Your employees, agents, principals or
representatives:

1)
provide investment advice in connection with this Account;
2)
recommend any security, transaction or order;
3)
solicit orders;
4)
act as a market maker in any security;
5)
make discretionary trades; and
6)
produce or provide research. To the extent research materials or similar
information is available through the App or the Website or the web sites of any of
its affiliates, I understand that these materials are intended for informational and
educational purposes only and they do not constitute a recommendation to enter
into any securities transactions or to engage in any investment strategies.

(B)
Information Accuracy. I: (i) certify that the information contained in this Agreement, the
account application, and any other document that I furnish to You in connection with My
Account(s) is complete, true and correct, and acknowledge that knowingly giving false
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information for the purpose of inducing You to extend credit is a federal crime; (ii)
authorize You to contact any individual or firm noted herein or on the documents
referred to in subsection (i) of this Section and any other normal sources of debit or
credit information; (iii) authorize anyone so contacted to furnish such information to You
as You may request; and (iv) agree that this Agreement, the account application and
any other document I furnish in connection with My Account is Your property, as the
case may be. I shall promptly advise You of any changes to the information in such
agreements and documents in writing within 10 calendar days. I authorize You to
obtain reports and provide information to others concerning My creditworthiness and
business conduct. Upon My request, You agree to provide Me a copy of any report so
obtained. You may retain this Agreement, the Account application, and all other such
documents and their respective records at Your sole discretion, whether or not credit is
extended.

(D)
Account Defaults. I understand that My Account comes with many defaulted service
instruction features and preferences. I further understand that I am not required to use
these defaulted options or preferences and that once My Account is approved and
opened I have the sole discretion to control and adjust such defaulted service
preferences that relate to my account.

(E)
Knowledge of Account. I understand that I am solely responsible for knowing the rights
and terms for all securities purchased, sold and maintained in My Account including,
but not limited to, mergers, reorganizations, stock splits, name changes and/or symbol
changes, dividends, option symbols, and option deliverables. I further understand that
certain securities may grant Me valuable rights that may expire unless I take specific
action. These securities include bonds, convertible securities, warrants, stock rights
and securities subject to exchange offers or tenders. I am responsible for knowing all
expiration dates, redemption dates, and the circumstances under which rights
associated with My securities may be called, cancelled, or modified. You may, but are
not obligated to, notify Me of any upcoming expiration or redemption dates, or take any
action on My behalf without My specific instructions except as required by law and the
rules of regulatory authorities. If My Account has an option position on the last trading
day prior to expiration, which is one cent or more in the money, You will generally
exercise the option, on My behalf. However, You reserve the right at Your discretion to
close any option position prior to expiration date or any position resulting from the
exercising/assignment after option expiration. I will be charged a commission for any
such transaction. You are not obligated to take any of these actions and You are not
liable for losses should You not take them.

(F)
Purchases. All orders for the purchase of securities given for My Account will be
authorized by Me and executed in reliance on My promise that an actual purchase is
intended. It is My obligation to pay for purchases immediately or on Robinhood
Financial’s demand. I understand Robinhood Financial may at any time, in its sole
discretion and without prior notice to Me, prohibit or restrict My ability to trade
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securities. I further agree not to allow any person to trade for My Account unless a
trading authorization for that person has been received and approved by Robinhood
Financial. You reserve the right to require full payment in cleared funds prior to the
acceptance of any order. In the event that I fail to provide sufficient funds, You may, at
Your option and without notice to Me, i) charge a reasonable rate of interest, ii)
liquidate the Property subject of the buy order, or iii) sell other Property owned by Me
and held in any of My Accounts. You may also charge any consequential loss to My
Account. For purposes of this Agreement, “Property” shall mean all monies, contracts,
investments and options, whether for present or future delivery, and all related
distributions, proceeds, products and accessions. This includes all such Property held,
maintained or carried by Apex Clearing Corp. in any manner for Me.

Proceeds of a sale will not be paid to me or released into My Account until Robinhood
Financial has received the security in good deliverable form, whether from a transfer
agent or from Me and the settlement of the security is complete. If the security is not
received on or before settlement date, or as market conditions warrant, Robinhood
Financial may in its sole discretion purchase the security on the open market for My
Account and may liquidate and close out any and all securities in My Account in order
to pay for such purchase. In the event a security is bought in, I will be responsible for all
resulting Losses incurred by Robinhood Financial.

I understand that I may execute short sales only in a Margin Account (See Margin
Agreement and Margin Disclosure Statement for more information) and that such
execution must comply with applicable short sales rules.

(H)
Assistance by Robinhood Financial. I understand that when I request assistance from
Your employees in using the investment tools available on the Website or the App, it
will be limited to an explanation of the tool’s functionality and, if requested by Me, to the
entry by Your employees of variables provided by Me, and that such assistance does
not constitute investment advice, an opinion with respect to the suitability of any
transaction, or solicitation of any orders.

(I)
No Tax or Legal Advice. I understand that Robinhood Financial does not provide tax or
legal advice and that You may discontinue this service for My Account immediately by
providing written notice to Me.

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(J)
Electronic Access.

1)
I am solely responsible for keeping My Account numbers and PINs confidential.
“PINs” shall mean My username and password.
2)
I agree and accept full responsibility for monitoring and safeguarding My
Accounts and access to My Accounts.
3)
I agree to immediately notify You in writing, delivered via e-mail and a recognized
international delivery service, if I become aware of: (i) any loss, theft, or
unauthorized use of My PINs or Account numbers; (ii) any failure by Me to
receive any communication from You indicating that an order was received,
executed or cancelled, as applicable; (iii) any failure by Me to receive an
accurate written confirmation of an execution; (iv) any receipt by Me of
confirmation of an order, execution or cancellation, which I did not place; (v) any
inaccurate information in or relating to My Account balances, deposits,
withdrawals, securities positions or transaction history; or (vi) any other
unauthorized use or access of My Account.
4)
Each of the events described in subsections (J)(3)(i)-(vi) shall be deemed a
“Potential Fraudulent Event”. The use and storage of any information including,
without limitation, My Account numbers, PINs, portfolio information, transaction
activity, account balances and any other information or orders available on My
wireless, web-enabled cellular telephone or similar wireless communications
device (collectively, “Mobile Device”) or My personal computer is at My own risk
and is My sole responsibility. I represent that I am solely responsible for and
have authorized any orders or instructions appearing in, originating from, or
associated with My Account, My Account number, and PINs. I agree to notify You
immediately after I discover any Potential Fraudulent Event, but in no event more
than twenty-four (24) hours following discovery. Upon request by You, I agree to
report any Potential Fraudulent Event promptly to legal authorities and provide
You a copy of any report prepared by such legal authorities. I agree to cooperate
fully with the legal authorities and You in any investigation of any Potential
Fraudulent Event and I will complete any required affidavits promptly, accurately
and thoroughly. I also agree to allow You access to My Mobile Device, My
computer, and My network in connection with Your investigation of any Potential
Fraudulent Event. I understand that if I fail to do any of these things I may
encounter delays in regaining access to the funds in My Account. I agree to
indemnify and hold You and Your parent company and affiliates harmless from
and against any losses arising out of or relating to any Potential Fraudulent
Event.

4. Clearance of Trades. I understand that You have entered into a clearing agreement with
Apex Clearing Corp. ("Apex") whereby You will introduce My Account to Apex, and Apex will
clear all transactions, on a fully-disclosed basis. I understand that Apex carries My
Account(s) and is responsible for the execution, clearing and bookkeeping of transactions,
but is not otherwise responsible for the conduct of Robinhood Financial.

Until receipt from Me of written notice to the contrary, Apex may accept from Robinhood
Financial, without inquiry or investigation, (i) orders for the purchase or sale of securities and
other property on margin, if I have elected to have a margin account, or otherwise, and (ii)
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any other instructions concerning said accounts. Apex shall look solely to Robinhood
Financial unless otherwise directed by Robinhood Financial, and not to Me with respect to
any such orders or instructions; except that I understand that Apex will deliver confirmations,
statements, and all written or other notices with respect to My Account directly to Me with
copies to Robinhood Financial, and that Apex will look directly to Me or Robinhood Financial
for delivery of margin, payment, or securities. I agree to hold Apex harmless from and
against any losses, costs or expenses arising in connection with the delivery or receipt of any
such communication(s), provided Apex has acted in accordance with the above. The
foregoing shall be effective as to My Account until written notice to the contrary is received
from Me by Apex or Robinhood Financial.

5. Review of Confirmations and Statements. I agree that it is My responsibility to review
order execution confirmations and statements of My Account promptly upon receipt. I agree
to receive all confirmations and account statements, as well as all tax related documents, in
electronic format. I understand that account statements will evidence all activity in My
Account for the stated period, including securities transactions, cash balances, credits to My
Account and all fees paid from My Account. These documents will be considered binding on
Me unless I notify You of any objections within two (2) days from the date confirmations are
sent and within ten (10) days after My Account statements are posted online. Such objection
may be oral or in writing, but any oral objection must be immediately confirmed in writing. In
all cases, You reserve the right to determine the validity of My objection. If I object to a
transaction for any reason, I understand and agree that I am obligated to take action to limit
any losses that may result from such transaction or I will bear sole responsibility for any
losses relating to the transaction, even if My objection to the transaction is ultimately
determined to be valid. Nothing in this Section 5 shall limit My responsibilities as described in
Section 3 of this Agreement.

6. Important Information Needed to Open a New Account. To help the government better
detect the funding of terrorism and money laundering activities, federal law requires all
financial institutions to obtain, verify, and record information that identifies each person who
opens an account. Therefore, I understand that when I open My Account You will ask for My
name, address, date of birth and other identifying information. You may also ask copies of
My driver's license, passport or other identifying documents. I understand that You may take
steps to verify the accuracy of the information I provide to You in My Account application or
otherwise, and that you may restrict My access to My Account pending such verification. I
will provide prompt notification to You of any changes in the information including, but not
limited to, My name, address, e-mail address and telephone number.

7. SIPC and Other Insurance Coverage. I understand that Robinhood Financial and Apex are
both members of the Securities Investor Protection Corporation (“SIPC”), which provides
protection for accounts up to $500,000 (including $250,000 for claims of cash) per client as
defined by SIPC rules. An explanatory brochure is available upon request via telephone at
(202) 371-8300 or at www.sipc.org. I also understand that Apex has purchased an additional
insurance policy through a group of London Underwriters (with Lloyd's of London Syndicates
as the Lead Underwriter) to supplement SIPC protection. The excess of SIPC coverage does
not protect against loss due to market fluctuation. An excess of SIPC claim would only arise
if Apex were to fail financially and customer assets for covered accounts, as defined by SIPC
(for Apex accounts), cannot be located due to theft, misplacement, destruction, burglary,
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robbery, embezzlement, abstraction, failure to obtain or maintain possession or control of
client securities, or to maintain the special reserve bank account required by applicable rules.
This additional insurance policy becomes available to customers in the event that SIPC limits
are exhausted.

The leader of the excess of SIPC coverage program is Lloyd's of London. Lloyd's currently
has an A ("Excellent") rating with "Stable Outlook" from A.M. Best and an A+ ("Strong") rating
with "Stable Outlook" from Fitch Ratings and Standard & Poor's® (S&P®). These ratings are
based on the financial strength of the company and are subject to change by the rating
agencies at any time. For more information about Lloyd's of London, please see
www.lloyds.com.

8. Telephone Conversations and Electronic Communications. I understand and agree that
You may record and monitor any telephone or electronic communications with Me. Unless
otherwise agreed in writing in advance, You do not consent to the recording of telephone
conversations by any third party or Me. I acknowledge and understand that not all telephone
or electronic communications are recorded by You, and You do not guarantee that recordings
of any particular telephone or electronic communications will be retained or capable of being
retrieved.

9. Oral Authorization. I agree that You shall be entitled to act upon any oral instructions given
by Me so long as You reasonably believe such instruction was actually given by Me or my
authorized agent.

10. Applicable Laws and Regulations. All transactions in My Account will be subject to federal
securities laws and regulations, the applicable laws and regulations of any state or
jurisdiction in which Robinhood Financial is registered, the rules of any applicable self-
regulatory organization of which Robinhood Financial is a member and the rules, regulations,
customs and usages of the exchange or market, and its clearing house, if any, where the
transactions are executed. In no event will Robinhood Financial be obligated to effect any
transaction it believes would violate any federal or state law, rule or regulation or the rules or
regulations of any regulatory or self-regulatory organization.

11. Distributions. In the event that I sell a security prior to its ex-dividend/distribution date, and I
receive the related cash/stock dividend or distribution in error, I direct You on My behalf to
pay such dividend/distribution to the entitled purchaser of the securities I sold, and I
guarantee to promptly reimburse You for, or deliver to You, said dividend or distribution.

12. Market Volatility; Market Orders; Limit Orders; and Queued Orders. I understand that,
whether I place a market or limit order, I will receive the price at which my order is executed
in the marketplace, subject to any clarification stated below. Particularly during periods of
high volume, illiquidity, fast movement or volatility in the marketplace, the execution price
received may differ from the quote provided on entry of an order, and I may receive partial
executions of an order at different prices. I understand that Robinhood Financial is not liable
for any price fluctuations. I also understand that price quotes generally are for only a small
number of shares as specified by the marketplace, and larger orders are relatively more likely
to receive executions at prices that vary from the quotes or in multiple lots at different prices.

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I understand that Robinhood Financial does not currently support sending traditional market
buy orders and that Robinhood Financial collars all market buy orders by using limit orders
priced up to 5% above the last trade price. This is not the case for market sell orders. I
further understand that when I send a market buy order through Robinhood Financial’s
trading system, the trading system generates a limit order up to 5% above the last trade
price, and then Robinhood Financial ships the order off to an executing broker. I understand
that Robinhood Financial’s market buy order collars may vary depending on prices of
instruments, market conditions, and other factors. I further understand that Robinhood
Financial uses the following rounding mechanics with respect to buy orders: Robinhood
Financial multiplies the last trade price by 1.05 and rounds down to two decimal places if the
last trade price is over $1.00; otherwise, Robinhood Financial rounds down to four decimal
places. I understand that securities may open for trading at prices substantially higher or
lower than the previous closing price or the anticipated price. If I place a market order
(whether during normal market hours or when the market is closed), I agree to pay or receive
the prevailing market price at the time My market order is executed, subject to the specific
clarification above relating to buy orders. I understand that the price I pay may be
significantly higher or lower than anticipated at the time I placed the order. To avoid buying a
security at a higher price and possibly exceeding My purchasing power, I understand My
option to enter a limit order. I also understand that limit orders may not be executed at any
particular time, or at all if there is not sufficient trading at or better than the limit price I
specify, and are only good until the end of the trading day in which they are entered. The
Website contains further information regarding order types and limitations, which I agree to
read and understand before placing such orders.
As a customer of Robinhood Financial, I understand that after the market has closed for the
day, I have the ability to place in a queue, order requests to be executed the following day
upon the opening of the market (“Queued Order”). I understand that my Queued Order
request is prioritized based on the order in which it is received by Robinhood Financial, and
that the Queued Order requests are sent out for execution shortly after the market opens on
the next day of trading. I further understand that each Queued Order request is sent out per
customer and per security as Robinhood Financial market orders (described above), and that
they are not aggregated.

A limit order may be “good till cancelled” which means the order remains valid until (A) it is
executed; (B) I cancel the order; or (C) the contract to which it relates is closed. I understand
that You will cancel a “good till cancelled” order at the end of every trading day (on the
exchange on which the instrument to which the contract relates is traded) and place such
order again at the start of the following trading day. This process will be repeated every day
for as long as the “good till cancelled” order remains valid.

13. Bulletin Board/Pink Sheet Stocks. Bulletin board, pink sheet and other thinly-traded
securities (collectively "bulletin board stocks") present particular trading risks, in part because
they are relatively less liquid and more volatile than actively traded securities listed on a
major exchange. I understand that bulletin board stocks may be subject to different trading
rules and systems than other securities and that I may encounter significant delays in
executions, reports of executions and updating of quotations in trading bulletin board stocks.
Robinhood Financial in its sole discretion may require limit orders on certain bulletin board
stock transactions.

14. Margin Trading. Margin trading involves interest charges and risks, including the potential to
lose more than deposited or the need to deposit additional collateral in a falling market.
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Before using margin, customers must determine whether this type of trading strategy is right
for them given their specific investment objectives, experience, risk tolerance, and financial
situation. For more information please see our Margin Agreement, Margin Disclosure
Statement, Day Trading Risk Disclosure, and FINRA Investor Information. These disclosures
contain information on our lending policies, interest charges, and the risks associated with
margin accounts.

15. Use of Market Data and Waiver or Limitation of Liability. I understand that each
participating national securities exchange or association asserts a proprietary interest in all of
the market data it furnishes to parties that disseminate said data. I understand that neither
Robinhood Financial nor any participating national securities exchange or association nor any
supplier of market data guarantees the timeliness, sequence, accuracy, completeness,
reliability or content of market information, or messages disseminated to or by any party. I
understand that neither Robinhood Financial nor any participating national securities
exchange or association nor any supplier of market data warrants that the service will be
uninterrupted or error-free. I further understand that Market Data by Xignite provides market
data to Robinhood Financial customers. I agree that My use of the App or the Website or any
other Robinhood Financial service is at My sole risk. I agree not to reproduce, distribute, sell
or commercially exploit the market data in any manner without written consent from
Robinhood Financial. The Robinhood Financial service is provided on an "as is," "as
available" basis without warranties of any kind, either express or implied, including, without
limitation, those of merchantability and fitness for a particular purpose, other than those
warranties which are implied by and incapable of exclusion, restriction or modification under
the laws applicable to this Agreement.

NEITHER I NOR ANY OTHER PERSON SHALL HOLD ANY DISSEMINATING PARTY
LIABLE IN ANY WAY, OR OMISSION FROM, I) ANY SUCH DATA, INFORMATION OR
MESSAGE OR II) THE TRANSMISSION OR DELIVERY OF ANY SUCH DATA
,INFORMATION OR MESSAGE, OR (B) ANY LOSS OR DAMAGE ARISING FROM OR
OCCASIONED BY I) ANY SUCH INACCURACY, ERROR, DELAY OR OMISSION, II) NON-
PERFORMANCE OR III) INTERRUPTION IN ANY SUCH DATA, INFORMATION OR
MESSAGE, WHETHER DUE TO ANY NEGLIGENT ACT OR OMISSION BY ANY
DISSEMINATING PARTY, OR TO ANY "FORCE MAJEURE" (E.G., FLOOD,
EXTRAORDINARY WEATHER CONDITIONS, EARTHQUAKE OR OTHER ACT OF GOD,
FIRE, WAR, INSURRECTION, RIOT, LABOR DISPUTE, ACCIDENT, ACTION OF
GOVERNMENT, OR COMMUNICATIONS OR POWER FAILURE, EQUIPMENT OR
SOFTWARE MALFUNCTION) OR OTHER CAUSE BEYOND THE REASONABLE
CONTROL OF ANY DISSEMINATING PARTY. NEITHER YOU NOR ANY DISSEMINATING
PARTY SHALL BE LIABLE, AND I AGREE TO INDEMNIFY AND HOLD HARMLESS
ROBINHOOD FINANCIAL AND SUCH DISSEMINATING PARTY, FOR ANY INACCURACY,
ERROR OR DELAY IN, OR OMISSION OF, (1) ANY SUCH DATA, INFORMATION OR
MESSAGE, OR (2) THE TRANSMISSION OR DELIVERY OF ANY SUCH DATA,
INFORMATION OR MESSAGE; OR ANY LOSS OR DAMAGE ARISING FROM OR
OCCASIONED BY (A) ANY SUCH INACCURACY, ERROR, DELAY OR OMISSION, (B)
NON-PERFORMANCE, OR (C) INTERRUPTION IN ANY SUCH DATA, INFORMATION OR
MESSAGE, DUE EITHER TO ANY ACT OR OMISSION BY ROBINHOOD FINANCIAL OR
ANY DISSEMINATING PARTY OR TO ANY "FORCE MAJEURE" (AS DEFINED ABOVE)
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OR ANY OTHER CAUSE BEYOND THE REASONABLE CONTROL OF ROBINHOOD
FINANCIAL OR ANY DISSEMINATING PARTY.

I UNDERSTAND AND AGREE THAT YOU WILL NOT BE LIABLE TO ME OR TO THIRD
PARTIES, OR HAVE ANY RESPONSIBILITY WHATSOEVER, FOR ANY SPECIAL,
INDIRECT, INCIDENTAL OR CONSEQUENTIAL DAMAGES (INCLUDING LOST PROFITS,
TRADING LOSSES AND DAMAGES) THAT I MAY INCUR IN CONNECTION WITH MY USE
OF THE SERVICE PROVIDED BY YOU UNDER THIS AGREEMENT.

16. Restrictions on Trading. I understand that You may, in Your discretion, prohibit or restrict
the trading of securities, or the substitution of securities, in any of My Accounts. I understand
that You may execute all orders by Me on any exchange or market, unless I specifically
instruct You to the contrary. In the event of a breach or default by Me under this Agreement,
You shall have all rights and remedies available to a secured creditor under all applicable
laws and in addition to the rights and remedies provided herein. I understand that You may at
any time, at Your sole discretion and without prior notice to Me: prohibit or restrict My access
to the use of the App or the Website or related services and My ability to trade, You may
refuse to accept any of My transactions, You may refuse to execute any of My transactions,
and/or You may terminate My Account. The closing of My Account will not affect the rights
and/or obligations of either party incurred prior to the date My Account is closed.

Further, You will not tolerate any foul or abusive language, physical violence, threatening
behavior, or other inappropriate conduct directed toward Your officers, employees,
contractors or customers. If I engage in any such behavior, as determined by You in Your
sole discretion, I agree that You are authorized to: (i) liquidate any securities, instruments or
other property in My Account, (ii) send Me the proceeds, and (iii) close My account. You will
not be responsible for any losses caused by the liquidation of securities, instruments or other
property pursuant to this paragraph, including but not limited to any tax liabilities.

17. Disclaimer of Liability; Indemnification. Except as otherwise provided by law, You, Apex
or any of Your or Apex’s affiliates shall not be liable for any expenses, losses, damages,
liabilities, demands, charges, claims, penalties, fines and excise taxes of any kind or nature
(including legal expenses and reasonable attorneys’ fees) (“Losses”) by or with respect to
any matters pertaining to My Account, except to the extent that such Losses are actual
Losses and are determined by a court of competent jurisdiction or an arbitration panel in a
final non-appealable judgment or order to have resulted solely from Your, Apex’s or any of
Your or Apex’s affiliates’ gross negligence or willful misconduct. In addition, I agree that You,
Apex and Your or Apex’s affiliates and respective partners, managing directors, officers,
directors, employees and agents (collectively, “Indemnified Parties”) shall have no liability for,
and I agree to indemnify, defend and hold harmless Indemnified Parties from, all Losses that
result from: (i) My or My agent’s misrepresentation or alleged misrepresentation, or act or
omission, (ii) Indemnified Parties following My or My agent’s directions or failing to follow My
or My agent’s unlawful or unreasonable directions, (iii) any activities or services of the
Indemnified Parties in connection with the My Account (including, without limitation, any
technology services, reporting, trading, research or capital introduction services), or (iv) the
failure by any person not controlled by the Indemnified Parties and their affiliates to perform
any obligations to Me.

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I consent to the use of automated systems or service bureaus by You and Apex and Your
and Apex Clearing Corp.’s affiliates in conjunction with My Account, including, but not limited
to, automated order entry and execution, record keeping, reporting and account reconciliation
and risk management systems (collectively “Automated Systems”). I understand that the use
of Automated Systems entails risks, such as interruption or delays of service, errors or
omissions in the information provided, system failure and errors in the design or functioning
of such Automated Systems (collectively, a “System Failure”) that could cause substantial
damage, expense or liability to Me. I understand and agree that Indemnified Parties will have
no liability whatsoever for any claim, loss, cost, expense, damage or liability of Me arising out
of or relating to a System Failure.

I also agree that Indemnified Parties will have no responsibility or liability to Me in connection
with the performance or non-performance by any Exchange, clearing organization, or other
third party (including, without limitation, other clearing firms, banks and International
Executing Brokers as defined infra) or any of their respective agents or affiliates, of its or their
obligations relative to any Securities. I agree that Indemnified Parties will have no liability, to
Me or to third parties, or responsibility whatsoever for: (i) any Losses resulting from a cause
over which Indemnified Parties do not have direct control, including but not limited to the
failure of mechanical equipment, unauthorized access, theft, operator errors, government
restrictions, force majeure (as defined in Section 15), Exchange rulings or suspension of
trading; and (ii) any special, indirect, incidental, consequential, punitive or exemplary
damages (including lost profits, trading losses and damages) that I may incur in connection
with My use of the brokerage and other services provided by Indemnified Parties under this
Agreement. Further, if I authorize or allow third parties to gain access to Your services,
including My Accounts, I will defend and indemnify You against any Losses arising out of
claims or suits by such third parties based upon or relating to such access and use.
Robinhood Financial does not warrant against loss of use or any direct, indirect or
consequential damages or losses to Me caused by My assent, expressed or implied, to a
third party accessing My Account or information, including access provided through any other
third party systems or sites.

18. Mutual Fund Transactions. In the event that I purchase or hold a mutual fund, I agree to
read and understand the terms of its prospectus. I understand that certain mutual funds
reserve the right to change their purchasing, switching or redemption procedures and/or
suspend or postpone redemptions under certain market conditions. I further understand that
any mutual fund order entered with You is placed by You on a best efforts basis as
prescribed and recognized by the individual fund, and that You are not responsible for
unexecuted orders due to the failure of any communication system. I agree to be fully
responsible for the information contained within the mutual fund prospectus and to hold You
harmless for any deficiencies contained therein. I authorize You to act as My agent in the
purchase and redemption of fund shares.

19. Exchange Traded Funds. Investors should consider the investment objectives and unique
risk profile of Exchange Traded Funds (ETFs) carefully before investing. ETFs are subject to
risks similar to those of other diversified portfolios. Leveraged and Inverse ETFs may not be
suitable for all investors and may increase exposure to volatility through the use of leverage,
short sales of securities, derivatives and other complex investment strategies. Although
ETFs are designed to provide investment results that generally correspond to the
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performance of their respective underlying indices, they may not be able to exactly replicate
the performance of the indices because of expenses and other factors. A prospectus
contains this and other information about the ETF and should be read carefully before
investing. Customers should obtain prospectuses from issuers and/or their third party agents
who distribute and make prospectuses available for review. ETFs are required to distribute
portfolio gains to shareholders at year end. These gains may be generated by portfolio
rebalancing or the need to meet diversification requirements. ETF trading will also generate
tax consequences. Additional regulatory guidance on Exchange Traded Products can be
found by clicking here

20. Joint Accounts. Where I open a joint account, it shall be held by You in joint tenancy with
rights of survivorship, unless I notify You otherwise and provide the required documentation.
For tenants in common, the interest in the tenancy shall be equal, unless we notify you
otherwise. If the Account is a joint account, then in consideration of Your carrying a joint
account for the undersigned persons, we jointly and severally agree to be fully and
completely responsible and liable for the Account and to pay on demand any balance due.
Each of us, or any person authorized to act on behalf of the Account under a separate
agreement, has full power and authority to make purchases and sales, withdraw funds and
securities from, or to do anything else with reference to the Account. You are authorized and
directed to act upon instructions received from any of us. We understand that tax reporting
information is processed using the social security number of the person first named in the
registration. Each of us agrees to hold harmless You and Your employees and agents from
and indemnify them against any losses, causes of action, damages and expenses (including
attorney's fees) arising from or as the result of You, Your employees or agents following the
instructions of any of us. You in Your sole discretion may at any time suspend all activity in
the Account pending instructions from a court of competent jurisdiction or require that
instructions pertaining to the Account or the Property therein be in writing, signed by all of us.
You may recover from the Account or from any of us such costs as You may incur, including
reasonable attorney's fees, as the result of any dispute among us relating to or arising from
the Account. Upon any event that causes a change in the ownership of the Account (divorce,
death, assignment, etc.), all remaining accountholders or survivors shall immediately notify
You in writing. You may take such actions in the Account as You deem advisable to protect
against any tax, liability, penalty or loss under any present or future laws or otherwise. The
estate of the decedent or departing accountholder shall be liable together with each of the
remaining or surviving accountholders, jointly and severally, to You for any net debit balance
or loss in the Account in any way resulting from any transactions initiated prior to notification
to You or incurred in the liquidation of the Account or the adjustment of the interests of the
respective parties. I understand that Legal ownership of our Accounts shall be governed by
the internal laws of the state of residence. I also understand that Laws covering joint or
community property vary by state and that I am responsible for verifying that the joint
registration I choose is valid in my state. Accordingly, You have encouraged me to consult
my own attorney for this purpose.

In the event of a dispute between or among account holders of which Robinhood Financial
has notice, Robinhood Financial reserves the right, but is not obligated, to place restrictions
on the Account. For example, if an account holder requests a restriction be placed on access
to funds in the Account because of a pending litigation or dispute between account holders,
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Robinhood Financial may prohibit all transfers of funds from the Account, with such
restrictions to remain in place until Robinhood Financial actually receives and has a
reasonable amount of time to act on appropriate court documentation or a written, notarized
instruction signed by all account holders. In such a case, all account holders remain liable for
any pending settlements at the time of the restriction. Robinhood Financial also may, at the
expense of the account holders, commence or defend any action or proceeding for or in the
nature of interpleader to have the dispute resolved judicially. If a suit or proceeding for or in
the nature of interpleader is brought by or against it, Robinhood Financial may deliver the
Account into the registry of the court, at which time Robinhood Financial will be deemed to be
and will be released and discharged from all further obligations and responsibilities under this
Agreement.

21. Effect of Attachment or Sequestration of Accounts. You shall not be liable for refusing to
obey any orders given by or for Me with respect to any of My Accounts that has or have been
subject to an attachment or sequestration in any legal proceeding against Me, and You shall
be under no obligation to contest the validity of any such attachment or sequestration.

22. Event of Death. It is agreed that in the event of My death or the death of one of the joint
account holders, the representative of My estate or the survivor or survivors shall
immediately give You written notice thereof, and You may, before or after receiving such
notice, take such proceedings, require such papers and inheritance or estate tax waivers,
retain such portion of and/or restrict transactions in the Account as You may deem advisable
to protect You against any tax, liability, penalty or loss under any present or future laws or
otherwise. Notwithstanding the above, in the event of My death or the death of one of the
joint account holders, all open orders shall be canceled, but You shall not be responsible for
any action taken on such orders prior to the actual receipt of notice of death. Further, You
may in Your discretion close out any or all of the Accounts without awaiting the appointment
of a personal representative for My estate and without demand upon or notice to any such
personal representative. The estate of any of the account holders who have died shall be
liable and each survivor shall continue to be liable, jointly and severally, to You for any net
debit balance or loss in said account in any way resulting from the completion of transactions
initiated prior to the receipt by You of the written notice of the death of the decedent or
incurred in the liquidation of the Account or the adjustment of the interests of the respective
parties. Such notice shall not affect Your rights under this Agreement to take any action that
You could have taken if I had not died.

23. Tax Reporting; Tax Withholding. The proceeds of sale transactions and dividends paid will
be reported to the Internal Revenue Service in accordance with applicable law.

A. U.S. Persons. This section is applicable if I am a U.S. person. Under penalties of
perjury, I certify that the taxpayer identification number that I have provided or will
provide to You (including, without limitation, any taxpayer identification number on
any Form W-9 that I have provided or will provide to You) is My correct taxpayer
identification number. I certify that I am not subject to backup withholding and I am a
U.S. Person (including a U.S. resident alien). If a correct Taxpayer Identification
Number is not provided Robinhood Financial, I understand I may be subject to
backup withholding tax at the appropriate rate on all dividends, interest and gross
proceeds paid to me. Backup withholding taxes are sent to the IRS and cannot be
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refunded by Robinhood Financial. I further understand that if I waive tax withholding
and fail to pay sufficient estimated taxes to the IRS, I may be subject to tax penalties.

B. Non-U.S. Persons. This section is applicable if I am not a U.S. person. I certify that I
fully understand all the information on any Form W-8BEN that I have submitted or will
submit to You. Under penalties of perjury, I declare that (i) I have examined all the
information (including, without limitation, all the information in the English language)
on any Form W-8BEN that I have submitted or will submit to You and (ii) to the best
of my knowledge and belief all such information is true, correct, and complete. I
authorize You to provide any such Form W-8BEN to Apex or any withholding agent
that has control, receipt, or custody of the income of which I am the beneficial owner
or any withholding agent that can disburse or make payments of the income of which
I am the beneficial owner. I agree that I will submit a new Form W-8BEN to You
within 30 days if any certification made on any previously submitted Form W-8BEN
becomes incorrect. I understand that the Internal Revenue Service does not require
My consent to any provisions of such Form W-8BEN other than the certifications
required to establish My status as a non-U.S. individual and, if applicable, obtain a
reduced rate of withholding.

24. Equity Orders and Payment For Order Flow. SEC rules require all registered broker-
dealers to disclose their policies regarding any "payment for order flow" arrangement in
connection with the routing of customer orders. "Payment for order flow" includes, among
other things, any monetary payment, service, property, or other benefit that results in
remuneration, compensation, or consideration to a broker-dealer from any broker-dealer in
return for directing orders. You transmit customer orders for execution to various exchanges
or market centers based on a number of factors. These include: size of order, trading
characteristics of the security, favorable execution prices (including the opportunity for price
improvement), access to reliable market data, availability of efficient automated transaction
processing and reduced execution costs through price concessions from the market centers.
Certain of the market centers may execute orders at prices superior to the publicly quoted
market in accordance with their rules or practices. While a customer may specify that an
order be directed to a particular market center for execution, the order-routing policies, taking
into consideration all of the factors listed above, are designed to result in favorable
transaction processing for customers. The nature and source of any payments and /or
credits received by You in connection with any specific transactions will be furnished upon
written request.

25. Free Credit Balances. I authorize You and/or Apex to invest the free credit balances in My
Account in money market funds as I may instruct you and as specified on the account
application and, without notice, to redeem My money market fund shares to the extent
necessary to satisfy any debits arising in any of My Accounts. Amounts not invested may
accrue and may be paid interest on the free credit balances. Any interest paid will be
calculated on a 365-day year and actual days elapsed. The interest rate may vary from time
to time without prior notice and may be equal to zero. . I understand that Robinhood Financial
and Apex shall not be obligated to pay interest on any free credit balance in my Account. I
further understand that Robinhood Financial receives from Apex Clearing Corp., its clearing
agent, rebates derived from customer margin debt balances, money market accounts, and
customer free credit balances.
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26. Fees and Charges. I understand that there are charges for executing buy and sell orders
and for other services provided under this Agreement. I understand that the commissions
and fees for trade executions and other services in accounts assigned to a registered
representative may be different from the commissions and fees charged to Robinhood
Financial’s self-directed customers. I also agree to pay all applicable federal, state and local
taxes. I authorize Robinhood Financial to automatically debit My Account for any such
brokerage commissions, charges, fees and taxes. I agree to pay such commissions and fees
at the then prevailing rate. I acknowledge that the prevailing rate of commissions and fees
may change and that change may occur without notice. I agree to be bound by such
changes. I specifically agree to pay a reasonable rate of interest on the principal amount of
any debit balance carried with respect to My Account. Interest may be charged against My
Account in connection with cash withdrawals, if the proceeds from a security sale are
disbursed before the regular settlement date of the sale transaction and late payments. If
Robinhood Financial receives My payment for securities purchases in a cash account after
the settlement date, I shall be charged a late payment fee of $25 plus a daily interest charge
on the debit balance until Robinhood Financial is fully paid. Charges will be calculated using
a prevailing interest rate, currently set to the daily rate of "Broker's Call" + 1%. The charges
shall accrue until paid and posted to My Account on the day following payment of the debit
balance. Interest due on My Account is payable on demand. I also agree to pay such
expenses incurred by You in connection with collection of any unpaid balance due on My
Accounts including, but not limited to, attorney's fees allowed by law.

27. ACH and International Wire Transfers.

A. ACH Transfers. I authorize Robinhood Financial, at its discretion and without further
prior notice, to utilize an electronic check process or Automated Clearing House
(“ACH”) facility to draft funds in the amount of any of My checks payable to
Robinhood Financial, its agents or assigns. Money deposited via ACH is normally
not available for withdrawal for 5 to 10 business days. Within 63 days of the date of
My ACH deposit, My funds may only be withdrawn to the bank account from which
such funds were deposited. I understand that for the ACH transfers to be
established, at least one common name must match exactly between My Robinhood
Financial and bank accounts. To send and receive ACHs My bank must be a
member of the ACH system. For ACH transactions, I hereby grant You limited power
of attorney for purposes of redeeming any shares in My Account and direct You to
accept any orders to make payments to an authorized bank account and to fulfill
these orders through the redemption of shares in My Account. In addition, if I or any
joint account owner decides to rescind an ACH transfer, I hereby direct and grant
You power of attorney to redeem any shares necessary to fulfill and make such
rescission regardless if I incur any loss.

An ACH bank reversal may occur when (A) there are insufficient funds in My bank
account, (B) there is a duplicate transaction, (C) the transaction is denied, or (D) the
type of account is incorrect. I acknowledge that in the event of an ACH bank
reversal, I will incur a fee. Before making an ACH transfer, I agree to check
Robinhood Financial’s most recent Commissions and Fees Schedule, available at
https://brokerage-
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static.s3.amazonaws.com/assets/robinhood/legal/RHF%20Retail%20Commisions%2
0and%20Fees%20Schedule.pdf. I agree that I am solely liable and responsible for
any ACH reversal fees that I incur.

B. International Wire Transfers.

If I arrange for a wire transfer to be directed to My Account, I am responsible for
ensuring that such wire is initiated properly, addressed properly, and bears
appropriate wire instructions in exactly the form required by You for identification of
Me and My Account. I understand that any erroneous, mismatched or incomplete
identifying information on an incoming wire transfer may result in such wire being
rejected, lost, posted to an incorrect Account or returned to the originating bank
without notice to Me and I agree to indemnify and hold You and Your affiliates
harmless from any Losses arising out of or relating to any erroneous, mismatched or
incomplete identifying information on an incoming wire.

By sending You a wire transfer request, I authorize You and Your bank service
provider to act on my behalf to initiate the wire transfer or check disbursement. It is
My responsibility to ensure that My instructions are accurate before requesting You to
initiate a wire transfer. In order to complete My wire transfer request, My name and
My address on file in My Account must match what I have on file at the recipient
bank; and I must provide the correct recipient bank’s name, recipient bank’s address,
recipient bank account number, and BIC/SWIFT code.

In accepting wire transfer requests, You may rely upon the identifying number (such
as routing number, account number and BIC/SWIFT code) of the recipient, the
recipient’s financial institution or any intermediary bank, as instructed. Also, the
recipient’s bank in the wire transfer requests may make payment on the basis of the
identifying number even if it identifies a person or entity different from the named
recipient. If I provided You with incorrect instructions or recipient information I may
lose the amount of the wire transfer. I agree to indemnify and hold You and Your
affiliates harmless from any Losses arising out of or relating to any erroneous,
mismatched or incomplete identifying information on an outgoing wire.

I must have sufficient available balance in My Account to cover the wire transfer
amount and the wire transfer fee at the time I send You the wire transfer request. You
will not be obligated to make any wire transfer unless I have sufficient available
balance in My Account to cover the wire transfer amount and the wire transfer fee at
the time I send You the wire transfer request. You have the right to neither send nor
process any wire transfer request without notice in the event of insufficient available
funds. You also may reject any wire transfer request for any reason or no reason.

All wire transfer requests provided to You are subject to Your review and acceptance.
Your confirmation, if any, of the receipt of My wire transfer request is an indication
only that You have received My wire transfer request. You reserve the right to refuse
to pay any wire transfer recipient whom I designate in the wire transfer request.

A wire transfer request cannot be amended or canceled after You receive it. You may
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in Your sole discretion attempt to abide by a subsequent request for a change, but
You are not obligated to do so. Any acceptance by You of a request by Me to amend,
recall, or trace a wire transfer is made conditionally upon the express understanding
by Me that You cannot guarantee fulfillment of such a request and that You are not
responsible for any failure to change, recall, or trace such wire transfer. I agree to
indemnify and hold You and Your affiliates harmless from any Losses arising out of
or relating to an attempt to amend or cancel a wire transfer.

All wire transfer requests received by You after the cutoff time will be reviewed and
processed within a commercially reasonable time, generally within one business day.
Wire transfer requests entered after the cutoff time may start to process immediately,
in Your sole discretion. I understand that any cutoff times referenced in this
Agreement reflect the times displayed on Your internal system clocks and may not
necessarily be synchronized with the internal clock displayed on My personal device.
For this reason, You suggest that I send any wire transfer requests to You sufficiently
in advance of such cutoff times to eliminate the possibility of missing the cutoff.

Notwithstanding any information I provide on My wire transfer request to the contrary,
You reserve the right to use any funds transfer system and intermediary bank in the
execution of My wire transfer request, and You may use any means of executing wire
transfer requests that You deem reasonable in the circumstances. I authorize such
funds transfer systems and any intermediary or recipient banks to deduct fees from
the funds transferred. I understand that You or any intermediary or recipient banks
may apply their prevailing currency exchange rate(s) in the conversion and payment
of funds. I am aware that currency exchange rates fluctuate over time and I accept
the risks of such fluctuation. I also understand that all incoming and outgoing wire
transfers must be in U.S. dollars.

I agree that I will not hold You liable for any damages resulting from an intermediary
or recipient bank’s decision not to accept any wire transfer. You are not responsible
for any fees, delay, misplacement, loss, errors, any act or failure to act by You or an
intermediary or recipient bank or any other third party. I agree that My wire transfers
are subject to the fees set forth in Your Commissions and Fees schedule, available at
https://brokerage-
static.s3.amazonaws.com/assets/robinhood/legal/RHF%20Retail%20Commisions%2
0and%20Fees%20Schedule.pdf. I also agree that I am solely responsible for all such
fees, including, without limitation, wire transfer reversal fees for both incoming and
outgoing wire transfer requests. Additionally, I agree that I am solely responsible for
any additional fees that any originating, intermediary, or recipient banks may charge.

28. Electronic Delivery of Trade and Account Information; Notice. All communications,
including account statements, trade confirmations, margin calls, notices, disclosures,
regulatory communications and other information, documents, data and records regarding My
Account, or an alert that such communication has been posted to the secure section of the
Website or the App, and is available for viewing, may be sent to Me at the mailing address for
My Account or the e-mail address that I have given to You in My account application (to
either e-mail address in the case of joint accounts where each account holder has given an e-
mail address; notice to both e-mail addresses is not required) or at such other address as I
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may hereafter give You in writing or by e-mail at least 10 calendar days prior to delivery, and
all communications so sent, whether in writing or otherwise, shall be deemed given to Me
personally, whether actually received or not.

29. Arbitration.
A. This Agreement contains a pre-dispute arbitration clause. By signing an arbitration
agreement, the parties agree as follows:

(1) All parties to this Agreement are giving up the right to sue each other in court,
including the right to a trial by jury, except as provided by the rules of the arbitration
forum in which a claim is filed.
(2) Arbitration awards are generally final and binding; a party’s ability to have a court
reverse or modify an arbitration award is very limited.
(3) The ability of the parties to obtain documents, witness statements and other discovery
is generally more limited in arbitration than in court proceedings.
(4) The arbitrators do not have to explain the reason(s) for their award unless, in an
eligible case, a joint request for an explained decision has been submitted by all parties to
the panel at least 20 calendar days prior to the first scheduled hearing date.
(5) The panel of arbitrators will typically include a minority of arbitrators who were or are
affiliated with the securities industry.
(6) The rules of some arbitration forums may impose time limits for bringing a claim in
arbitration. In some cases, a claim that is ineligible for arbitration may be brought to
court.
(7) The rules of the arbitration forum in which the claim is filed, and any amendments
thereto, shall be incorporated into this Agreement.

B. Any controversy or claim arising out of or relating to this Agreement shall be settled by
arbitration in accordance with the rules of FINRA Dispute Resolution, Inc. (“FINRA DR”). I
agree to arbitrate any controversy or claim before FINRA DR in the State of California.

C. This agreement to arbitrate constitutes a waiver of the right to seek a judicial forum
unless such a waiver would be void under the federal securities laws. If I am a foreign
national, non-resident alien, or if I do not reside in the United States, I agree to waive My
right to file an action against You in any foreign venue.

D. No person shall bring a putative or certified class action to arbitration, nor seek to
enforce any pre-dispute arbitration agreement against any person who has initiated in
court a putative class action; or who is a member of a putative class who has not opted
out of the class with respect to any claims encompassed by the putative class action until:
(1) the class certification is denied; (2) the class is decertified; or (3) the customer is
excluded from the class by the court. Such forbearance to enforce an agreement to
arbitrate shall not constitute a waiver of any rights under this Agreement except to the
extent stated herein.

30. API

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A. Overview; Definitions. Robinhood Financial, LLC and Robinhood Markets, Inc.
(collectively, “Robinhood”) may, in Robinhood’s sole discretion, provide third parties with
an application programming interface and other materials in accordance with any
accompanying documentation (collectively, the “API Package”) (such third parties, “API
Licensees”), to make available certain features and functionality of Robinhood’s mobile
applications, websites, or technology platform via the API Licensees’ products (such
products, the “Licensee Products”). The API Package and the Licensee Products are
collectively referred to as the “API Products”.

“Information” means My personally identifiable information (including, without limitation,
username, logon password, financial information, trade data, and other financial
information) and all data exchanged between Robinhood and the API Products.

B. Access to My Personal Information. Through My use of any API Products, I may be
providing API Licensees with access to My Account and Information. By using any API
Products, I acknowledge that such API Products may employ security, policies,
procedures and systems of API Licensees which may or may not be less stringent and
secure than Robinhood’s policies, procedures and systems. I agree that My use of any
API Products shall be subject to the terms and conditions of this Agreement, in addition
to any other agreements which I executed with respect to any such API Products. I
understand and agree that any end user agreement that I executed with any API
Licensee is concluded between Me and such API Licensee only, and not with Robinhood;
and such API Licensee, not Robinhood, is solely responsible for such Licensee Product
and the content thereof. I understand and agree that the API Products may deliver
Information to Robinhood, and that Robinhood is authorized to receive and store such
Information consistent with Robinhood’s then in effect policies and procedures. Further, I
agree that the API Products may request Information stored by Robinhood, and I consent
to Robinhood’s disclosure of such Information to the API Products.

C. No Recommendations. To the extent the Licensee Products or API Licensees express
opinions or make recommendations, I understand that such opinions and
recommendations are expressed solely by API Licensees and are not the opinions or
recommendations of Robinhood. The existence of the API Products and Robinhood’s
consent to any connectivity between any Licensee Products and Robinhood’s
technology, the App, the Website or trading platform(s) does not constitute (i) any
recommendation by Robinhood to invest in any security or utilize any investment
strategy; or (ii) any representation, warranty or other guarantee by Robinhood as to the
present or future value or suitability of any sale, trade or other transaction involving any
particular security or any other investments. The existence of any and all information,
tools and services provided by API Licensees and/or by the Licensee Products shall not
constitute Robinhood’s endorsement of API Licensees and/or the Licensee Products.

D. Data Provided by Robinhood to API. From time to time, and subject to then in effect
agreements between Robinhood and API Licensees, Robinhood may, in its own
discretion, make market data feeds received from third parties available via the API
Products. Robinhood does not make any guarantees in regards to such market data
feeds. Furthermore, API Licensees and/or Licensee Products may make available to Me
market data feeds independent of Robinhood. I am aware that from time to time that
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there may be discrepancy between the market data presented on the App and
information provided by any API Products due to a variety of reasons, including, without
limitation, the time to update and transmit such data to a mobile application or web site
and latency caused by such API Product’s and/or My local environment (computer set up,
connection speed, etc.). Robinhood is not responsible for the accuracy of market data
displayed on any API Products or otherwise made available by API Licensees.

E. Risks; No Liability. I acknowledge that there may be latency between the time an order
(or other Information) is submitted from the API Products and the time such order or
Information is received by Robinhood. Latency may also affect order modification and
order cancellation requests. The time an order or a request is actually received by
Robinhood (including for execution) will be the official time, including for the purposes of
routing the order to the market for execution. In addition, all orders submitted to
Robinhood are subject to order vetting by Robinhood. Orders created and submitted
through any API Products are not vetted until they are received by Robinhood. It is
possible that Robinhood may reject an order placed through any API Products.
Robinhood cannot guarantee that any order will be accepted when such order is routed
to the market for execution, and Robinhood cannot guarantee that notifications and
Information provided to Me by Robinhood will be successfully delivered to or displayed by
any API Products.

Without limiting the generality of any other terms in this Agreement, I agree that:

(i) Robinhood shall not be liable for any losses as a result of any issues addressed in this
Section 30 of this Agreement nor shall Robinhood be liable for any losses realized for
technical issues involving any API Products and/or API Licensee technology or product
offerings (including, but not limited to, system outages or downtime).

(ii) Robinhood shall not be responsible for any investment research provided by any API
Licensee or any Licensee Products.

(iii) Robinhood makes no representations, warranties or other guarantees as to the
accuracy, timeliness or efficacy of any market data, information, or other functionality
made available by any API Licensee or any API Products.

F. Intellectual Property. My use of any API Products will not confer to Me any title,
ownership interest or intellectual property rights that otherwise belongs to Robinhood or
any of its affiliates. The API Package, including content, is protected under U.S. patent,
copyright laws, international treaties or conventions and other laws and will remain
Robinhood’s exclusive property, as applicable. Names, logos and all related product and
service names, design marks and slogans displayed by or relating to Robinhood or any of
its affiliates or API Licensees in the context of the API Products shall remain the property
of the respective owner and use of such property by Robinhood or any API Licensee in
marketing or provision of any API Products does not grant ownership of or entitle Me to
use any such name or mark in any manner.

G. User’s Representations and Warranties. I represent and warrant that:
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(i)
By virtue of utilizing any API Products, I consent to and accept any risk
associated with Robinhood’s sharing of Information with any API Licensee and
shall not hold Robinhood and/or its affiliates, subsidiaries, officers, and
employees responsible for any damages or losses resulting from the sharing of
such Information.
(ii)
I agree that My use of any API Products or API Licensee’s content, information,
technology, or functionality is at My own risk.
(iii)
I agree that Robinhood may revoke any API Licensee or API Products’
authorization at any time, for any reason, with or without cause and without prior
notice to Me.

31. FDIC-Insured Sweep Program. If I elect to have dormant cash in My Account “swept” into
and out of an interest-bearing FDIC-insured deposit account opened by Apex at a
participating bank (“Program Bank”) by participating in the Apex FDIC-Insured Sweep
Program (the “FDIC-Insured Sweep Program”), I agree to the terms of this Agreement
(including, without limitation, this Section 31). I also agree to the Robinhood Sweep Program
Disclosure Document and the Apex Sweep Program Terms and Conditions which are
incorporated by reference and constitute part of this Section 31.

Without limiting the generality of any other terms in this Agreement, I agree that:

(A) I shall hold harmless You for any results that may occur from participation in FDIC-
Insured Sweep Program, including, without limitation, specifically My receiving smaller
payment than I could in a different type of account or had My excess cash balance been
swept into a different Program Bank.
(B) You shall not be liable or responsible for (i) any failure to invest or deposit free credit
balances according to this Agreement or the Apex Sweep Program Terms and
Conditions; (ii) the financial condition of any Program Bank; or (iii) any non FDIC-Insured
Sweep Program funds I may have at any Program Bank.
(C) EXCEPT AS SPECIFICALLY SET FORTH IN THIS AGREEMENT, NO
REPRESENTATIONS OR WARRANTIES (ORAL OR WRITTEN, STATUTORY,
EXPRESS, IMPLIED, OR OTHERWISE) ARE MADE TO ME REGARDING THE FDIC-
INSURED SWEEP PROGRAM, INCLUDING, WITHOUT LIMITATION, AS TO
MERCHANTABILITY, FITNESS FOR ANY PURPOSE, CONFORMITY TO ANY
DESCRIPTION OR REPRESENTATION, NON-INTERFERENCE, OR
NONINFRINGEMENT.

32. Electronic Signatures and Modifications to the Agreement. I agree to transact business
with You electronically. By electronically signing an application for an account, I
acknowledge and agree that such electronic signature is valid evidence of My consent to be
legally bound by this Agreement and such subsequent terms as may govern the use of Your
services. The use of an electronic version of any document fully satisfies any requirement
that the document be provided to Me in writing. I accept notice by electronic means as
reasonable and proper notice, for the purpose of any and all laws, rules and regulations. I
acknowledge and agree that Robinhood Financial may modify this Agreement from time-to-
time and I agree to consult the Website from time-to-time for the most up-to-date Agreement.

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The electronically stored copy of this Agreement is considered to be the true, complete, valid,
authentic and enforceable record of the Agreement, admissible in judicial or administrative
proceedings to the same extent as if the documents and records were originally generated
and maintained in printed form. I agree to not contest the admissibility or enforceability of
Robinhood Financial’s electronically stored copy of the Agreement.

A. Consent to Electronic Delivery of Documents. By agreeing to electronic delivery, I am
giving My informed consent to electronic delivery of all Account Documents, as defined
below, other than those I have specifically requested to be delivered in paper form.
“Account Documents” include notices, disclosures, current and future account
statements, regulatory communications (such as prospectuses, proxy solicitations, and
privacy notices), trade confirmations, and any other information, documents, data, and
records regarding My Account and the services (including amendments to this
Agreement) delivered or provided to me by Robinhood Financial, the issuers of the
securities and/or other property in which I invest, and any other parties. I agree that I can
download, save, and/or print any Account Documents I receive via electronic delivery for
my records.

B. Electronic Delivery System. I acknowledge that Your primary methods of communication
with Me include, without limitation, (A) posting information on the Website, (B) providing
information via the App, and (C) sending email(s) to My email address of record, and, to
the extent required by law, (D) providing Me with notice(s) that will direct Me to the App or
the Website where I can read and print such information. Unless otherwise required by
law, You reserve the right to post Account Documents on the Website without providing
notice to Me. Further, You reserve the right to send Account Documents to My postal or
email address of record, or via the App. I agree that all Account Documents provided to
Me in any of the foregoing manner is considered delivered to Me personally when sent or
posted by Robinhood Financial, whether I receive it or not.

All e-mail notifications regarding Account Documents will be sent to My e-mail address of
record. I understand that e-mail messages may fail to transmit promptly or properly,
including being delivered to SPAM folders. I further understand that it is my sole
responsibility to ensure that any emails from Robinhood Financial are not marked as
SPAM. Regardless of whether or not I receive an e-mail notification, I agree to check the
Website regularly to avoid missing any information, including, without limitation, time-
sensitive or otherwise important communication.

Additionally, I acknowledge that the Internet is not a secure network and agree that I will
not send any confidential information, including, without limitation, Account numbers or
passwords, in any unencrypted e-mails. I also understand that communications
transmitted over the Internet may be accessed by unauthorized or unintended third
parties and agree to hold You and Your parent company and affiliates harmless for any
such access regardless of the cause.

I agree to promptly and carefully review all Account Documents when they are delivered
and notify Robinhood Financial in writing within five (5) calendar days of delivery if I
object to the information provided. If I fail to object in writing within five (5) calendar days
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of delivery, Robinhood Financial is entitled to treat such information as accurate and
conclusive.

C. Costs. Potential costs associated with electronic delivery of Account Documents may
include charges from Internet access providers and telephone companies, and I agree to
bear these costs. Robinhood Financial will not charge Me additional online access fees
for receiving electronic delivery of Account Documents.

D. Archival. Through the Website, I will have access to an archive of all documents I
received via electronic delivery for a period of [one (1) year]. Upon My request, I may
obtain copies of earlier documents for up to six (6) years for account statements, and
three (3) years for trade confirmations.

E. Revocation of Consent. Subject to the terms of this Agreement, I may revoke or restrict
My consent to electronic delivery of Account Documents at any time by notifying
Robinhood Financial in writing of my intention to do so. I also understand that I have the
right to request paper delivery of any Account Document that the law requires Robinhood
Financial to provide Me in paper form. I understand that if I revoke or restrict My consent
to electronic delivery of Account Documents or request paper delivery of same,
Robinhood Financial, in its sole discretion, may charge Me a reasonable service fee for
the delivery of any Account Document that would otherwise be delivered to Me
electronically, restrict or close My account, and/or terminate My access to Robinhood
Financial’s services. I understand that neither My revocation or restriction of consent, My
request for paper delivery, nor Robinhood Financial’s delivery of paper copies of Account
Documents will affect the legal effectiveness or validity of any electronic communication
provided while My consent was in effect.

F. Duration of Consent. My consent to receive electronic delivery of Account Documents
will be effective immediately and will remain in effect unless and until either I or
Robinhood Financial revokes it. I understand that it may take up to three (3) business
days to process a revocation of consent to electronic delivery, and that I may receive
electronic notifications until such consent is processed.

G. Hardware and Software Requirements. I understand that in order to receive electronic
deliveries, I must have access to the Internet, a valid e-mail address, and the ability to
download such applications as Robinhood Financial may specify and to which I have
access. I also understand that if I wish to download, print, and/or save any information I
wish to retain, I must have access to a printer or other device in order to do so.

33. Miscellaneous Provisions. The following provisions shall also govern this Agreement:

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A. Headings. The heading of each provision hereof is for descriptive purposes only and
shall not be (1) deemed to modify or qualify any of the rights or obligations set forth
herein or (2) used to construe or interpret any of the provisions hereunder.

B. Binding Effect; Assignment. This Agreement shall bind My heirs, assigns, executors,
successors, conservators and administrators. I may not assign this Agreement or any
rights or obligations under this Agreement without first obtaining your prior written
consent. You may assign, sell or transfer My Account and this Agreement, or any portion
thereof, at any time, without My prior consent.

C. Severability. If any provisions or conditions of this Agreement are or become inconsistent
with any present or future law, rule or regulation of any applicable government, regulatory
or self-regulatory agency or body, or are deemed invalid or unenforceable by any court of
competent jurisdiction, such provisions shall be deemed rescinded or modified, to the
extent permitted by applicable law, to make this Agreement in compliance with such law,
rule or regulation, or to be valid and enforceable, but in all other respects, this Agreement
shall continue in full force and effect.

D. Entirety of Agreement. This Agreement, any attachments hereto, other agreements and
policies referred to in this Agreement (including, but not limited to, the Website postings),
and the terms and conditions contained in My Account statements and confirmations,
contain the entire agreement between Robinhood Financial and Me and supersedes all
prior or contemporaneous communications and proposals, whether electronic, oral or
written, between Robinhood Financial and Me, provided, however, that any and all other
agreements between Robinhood Financial and Me, not inconsistent with this Agreement,
will remain in full force and effect.

E. Website Postings. I agree and understand that Robinhood Financial may post other
specific agreements, disclosures, policies, procedures, terms and conditions that apply to
My use of the App, the Website or My Account on the Website. I understand that it is My
continuing obligation to understand the terms of such postings, and I agree to be bound
by such postings as are in effect at the time of My use.

F. Amendment. You may at any time amend this Agreement without prior notice to Me. The
current version of the Agreement will be posted on the Website and My continued
Account activity after such amendment constitutes My agreement to be bound by all then
in effect amendments to the Agreement, regardless of whether I have actually reviewed
them. Continued use of the App, the Website or any other Robinhood Financial services
after such posting will constitute My acknowledgment and acceptance of such
amendment. I agree to regularly consult the Website for up-to-date information about
Robinhood Financial services and any modifications to this Agreement. You are not
bound by any verbal statements that seek to amend the Agreement.

G. Termination. You may terminate this Agreement, or close, deactivate or block access to
My Account at any time in Your sole discretion. I will remain liable to You for all
obligations incurred in My Account or otherwise, whether arising before or after
termination. I may terminate this Agreement after paying any obligations owed upon
written notice. This Agreement survives termination of My Account.
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H. No Waiver; Cumulative Nature of Rights and Remedies. I understand that Your failure to
insist at any time upon strict compliance with any term contained in this Agreement, or
any delay or failure on Your part to exercise any power or right given to You in this
Agreement, or a continued course of such conduct on Your part, shall at no time operate
as a waiver of such power or right, nor shall any single or partial exercise preclude any
other further exercise. All rights and remedies given to You in this Agreement are
cumulative and not exclusive of any other rights or remedies to which You are entitled.

I.
International Customers. The products and services described on the Website are
offered only in jurisdictions where they may be legally offered. Neither the Website nor
the App shall be considered a solicitation for or offering of any investment product or
service to any person in any jurisdiction where such solicitation or offering would be
illegal. I understand that You, at Your sole discretion may accept unsolicited accounts
from non-U.S. residents, depending on the country of residence and other factors. I
understand that You are based in the United States and that You accept only U.S.
currency in Your customer accounts.

J. Governing Law. This Agreement and all transactions made in My Account shall be
governed by the laws of the State of California (regardless of the choice of law rules
thereof), except to the extent governed by the federal securities laws, FINRA Rules, and
the regulations, customs and usage of the exchanges or market (and its clearing house)
on which transactions are executed.
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Exhibit 5

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Revised April 28, 2020
Robinhood Financial LLC & Robinhood Securities, LLC Customer Agreement
In consideration of Robinhood Financial LLC, Robinhood Securities, LLC, and their agents and assigns
(collectively, "Robinhood") opening one or more accounts on my behalf ("My Account(s)" or the
"Account(s)") for the purchase, sale or carrying of securities or contracts relating thereto and/or the
borrowing of funds, which transactions are cleared through Robinhood Securities, I represent and agree
with respect to all Accounts, whether margin or cash, to the terms set forth below (the "Agreement").
When used in this Agreement, the words "I", "Me", "My", "We", or "Us" mean the owner(s) of the
Account. For purposes of this Agreement, Business Days are Monday through Friday, excluding federal
holidays. Any references to "days" found in this Agreement are calendar days unless indicated
otherwise.
I UNDERSTAND THAT THE TERMS AND CONDITIONS OF THIS AGREEMENT GOVERN ALL
ASPECTS OF MY RELATIONSHIP WITH ROBINHOOD REGARDING MY ACCOUNTS. I WILL
CAREFULLY READ, UNDERSTAND AND ACCEPT THE TERMS AND CONDITIONS OF THIS
AGREEMENT BEFORE I CLICK "SUBMIT APPLICATION" OR OTHER SIMILARLY WORDED
BUTTON. IF I HAVE ANY QUESTIONS ABOUT ANY OF THE PROVISIONS IN THIS AGREEMENT,
I WILL EMAIL HELP@ROBINHOOD.COM. I UNDERSTAND THAT CLICKING "SUBMIT
APPLICATION" IS THE LEGAL EQUIVALENT OF MY MANUALLY SIGNING THIS AGREEMENT
AND I WILL BE LEGALLY BOUND BY ITS TERMS AND CONDITIONS. BY ENTERING INTO
THIS AGREEMENT, I ACKNOWLEDGE RECEIPT OF THE ROBINHOOD PRIVACY POLICY AND
PRIVACY AND SECURITY STATEMENT. I UNDERSTAND THAT THIS AGREEMENT MAY BE
AMENDED FROM TIME TO TIME BY ROBINHOOD, WITH REVISED TERMS POSTED ON THE
ROBINHOOD WEBSITE. I AGREE TO CHECK FOR UPDATES TO THIS AGREEMENT. I
UNDERSTAND THAT BY CONTINUING TO MAINTAIN MY SECURITIES BROKERAGE
ACCOUNT WITHOUT OBJECTING TO ANY REVISED TERMS OF THIS AGREEMENT, I AM
ACCEPTING THE TERMS OF THE REVISED AGREEMENT AND I WILL BE LEGALLY BOUND
BY ITS TERMS AND CONDITIONS. IF I REQUEST OTHER SERVICES PROVIDED BY
ROBINHOOD THAT REQUIRE ME TO AGREE TO SPECIFIC TERMS AND CONDITIONS
ELECTRONICALLY (THROUGH CLICKS OR OTHER ACTIONS) OR OTHERWISE, SUCH TERMS
AND CONDITIONS WILL BE DEEMED AN AMENDMENT AND WILL BE INCORPORATED INTO
AND MADE PART OF THIS AGREEMENT. I ALSO UNDERSTAND THAT BY CLICKING "SUBMIT
APPLICATION" I HAVE ACKNOWLEDGED THAT THIS AGREEMENT CONTAINS A PREDISPUTE
ARBITRATION CLAUSE IN SECTION 38 HEREIN.
1. Capacity and Status.
If an individual, I am of legal age under the laws of the state where I reside and authorized to enter into
this Agreement. If an entity, I am duly formed, validly existing and in good standing in My state of
organization, have full power and authority to enter and perform this Agreement, and the persons signing
the account application are fully authorized to act on My behalf. No person, except Myself, has any
interest in the Account opened pursuant to this Agreement. I acknowledge that unless Robinhood
receives written objection from Me, Robinhood may provide My name, address, and securities positions
to requesting companies in which I hold securities. Except as otherwise disclosed to Robinhood in
writing, neither I nor any member of My immediate family is an employee of any exchange, any
corporation of which any exchange owns a majority of the capital stock, a member of any exchange or
self-regulatory organization, a member of any firm or member corporation registered on any exchange, a
bank, trust company, insurance company or any corporation, firm or individual engaged in the business
of dealing either as a broker-dealer or as principal in securities. I understand and agree that I am
obligated to promptly notify Robinhood in writing if I or a member of My immediate family becomes
registered or employed in any of the above-described capacities. Except as otherwise disclosed to
Robinhood in writing, I am not a Professional (as defined below). I further agree to promptly notify
Robinhood in writing if I am now or if I become a Professional or an officer, director or 10% stockholder
of any publicly traded company.
2. Market Data.
Robinhood may choose to make certain market data available to Me pursuant to the terms and
conditions set forth in this Agreement. By executing this Agreement, I agree to comply with those terms
and conditions.
1
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A. Definitions.
"Market Data" means (a) last sale information and quotation information relating to securities that
are admitted to dealings on the New York Stock Exchange ("NYSE"), (b) such bond and other
equity last sale and quotation information, and such index and other market information, as United
States-registered national securities exchanges and national securities associations (each, an
"Authorizing SRO") may make available and as the NYSE may from time to time designate as
"Market Data"; and (c) all information that derives from any such information.
"Nonprofessional" means any natural person who receives market data solely for his/her
personal, non- business use and who is not a "Professional." A "Professional" includes an
individual who, if working in the United States, is: (i) registered or qualified with the Securities and
Exchange Commission (the "SEC"), the Commodity Futures Trading Commission (the "CFTC"),
any state securities agency, any securities exchange or association, or any commodities or
futures contract market or association; (ii) engaged as an "investment advisor" as that term is
defined in Section 202 (a) (11) of the Investment Advisers Act of 1940 (whether or not registered
or qualified under that Act), or (iii) employed by a bank or other organization exempt from
registration under federal and/or state securities laws to perform functions that would require him
or her to be so registered or qualified if he or she were to perform such functions for an
organization not so exempt. A person who works outside of the United States will be considered a
"Professional" if he or she performs the same functions as someone who would be considered a
"Professional" in the United States.
B. Provisions Applicable to All Users.
Proprietary Nature of Data. I understand and acknowledge that each Authorizing SRO and Other
Data Disseminator (as defined below) has a proprietary interest in the Market Data that originates
on or derives from it or its market(s). I agree not to reproduce, distribute, sell or commercially
exploit the Market Data in any manner.
Enforcement. I understand and acknowledge that (a) the Authorizing SROs are third-party
beneficiaries under this Agreement and (b) the Authorizing SROs or their authorized
representative(s) may enforce this Agreement, by legal proceedings or otherwise, against Me or
any person that obtains Market Data that is made available pursuant to this Agreement other than
as this Agreement contemplates.
Data Not Guaranteed. I understand that neither Robinhood nor any Authorizing SRO, other entity
whose information is made available over the Authorizing SROs' facilities (an "Other Data
Disseminator"), or information processor that assists any Authorizing SRO or Other Data
Disseminator in making Market Data available (collectively, the "Disseminating Parties")
guarantees the timeliness, sequence, accuracy, completeness, reliability, or content of Market
Data or of other market information or messages disseminated to or by any Disseminating Party. I
understand that neither Robinhood Financial nor any Disseminating Party guarantees the
timeliness, sequence, accuracy, completeness, reliability or content of market information, or
messages disseminated to or by any party. I understand that neither Robinhood Financial nor any
Disseminating Party warrants that the service provided by any such entity will be uninterrupted or
error-free. I further understand that Market Data by Xignite provides market data to Robinhood
Financial customers. NEITHER ROBINHOOD FINANCIAL, ANY OF ITS AFFILIATES, THEIR
RESPECTIVE OFFICERS OR EMPLOYEES, NOR ANY DISSEMINATING PARTY SHALL BE
LIABLE IN ANY WAY FOR (A) ANY INACCURACY, ERROR OR DELAY IN, OR OMISSION
OF, (I) ANY MARKET DATA, INFORMATION OR MESSAGE, OR (II) THE TRANSMISSION
OR DELIVERY OF ANY SUCH DATA, INFORMATION OR MESSAGE; OR (B) ANY LOSS (AS
DEFINED IN THIS AGREEMENT) OR DAMAGE ARISING FROM OR OCCASIONED BY (I)
ANY SUCH INACCURACY, ERROR, DELAY OR OMISSION, (II) NON-PERFORMANCE OR
III) INTERRUPTION IN ANY SUCH MARKET DATA, INFORMATION, OR MESSAGE,
WHETHER DUE TO ANY ACT OR OMISSION BY ROBINHOOD FINANCIAL, ANY OF ITS
AFFILIATES, THEIR RESPECTIVE OFFICERS OR EMPLOYEES, OR ANY DISSEMINATING
PARTY, OR TO ANY "FORCE MAJEURE" (E.G., FLOOD, EXTRAORDINARY WEATHER
CONDITIONS, EARTHQUAKE OR OTHER ACT OF GOD, FIRE, WAR, INSURRECTION,
RIOT, LABOR DISPUTE, ACCIDENT, ACTION OF GOVERNMENT, OR COMMUNICATIONS
OR POWER FAILURE, EQUIPMENT OR SOFTWARE MALFUNCTION) OR ANY OTHER
1.
2.
1.
2.
3.
2
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CAUSE BEYOND THE REASONABLE CONTROL OF ROBINHOOD FINANCIAL, ITS
AFFILIATES, THEIR RESPECTIVE OFFICERS AND EMPLOYEES, OR ANY
DISSEMINATING PARTY.
Permitted Use. I shall not furnish Market Data to any other person or entity. If I receive Market
Data other than as a Nonprofessional, I shall use Market Data only for My individual use.
Dissemination, Discontinuance, or Modification. I understand and acknowledge that, at any time,
the Authorizing SROs may discontinue disseminating any category of Market Data, may change
or eliminate any transmission method and may change transmission speeds or other signal
characteristics. The Authorizing SROs shall not be liable for any resulting liability, loss or
damages that may arise therefrom.
Duration; Survival. This Section 2 of this Agreement remains in effect for so long as I have the
ability to receive Market Data as contemplated by this Section 2. In addition, Sections 2(B)(1)-(3)
and the first two sentences of Section 2(B)(7), survive any termination of this Agreement.
Miscellaneous. The laws of the State of New York shall govern this Section 2 and it shall be
interpreted in accordance with those laws. This Subsection is subject to the Securities Exchange
Act of 1934, the rules promulgated under that act, and the joint-industry plans entered into
pursuant to that act.
C. Provisions Applicable to Nonprofessionals.
Permitted Receipt. I understand that I may not receive Market Data from Robinhood as a
Nonprofessional, and Robinhood may not provide Market Data to Me as a Nonprofessional,
unless Robinhood first properly determines that I qualify as a Nonprofessional as defined above
and I in fact qualify as a Nonprofessional. I agree that, as a prerequisite to Robinhood Financial
qualifying Me as a Nonprofessional, I will provide to Robinhood truthful and accurate information
about Me, such as: my occupation, employer, employment position and functions; my use of
Market Data; my registration status with any securities agency, exchange, association, or
regulatory body, or any commodities or future contract market, association, or regulatory body,
whether in the United States or elsewhere; and any compensation of any kind I may receive from
any individual or entity for my trading activities, asset management, or investment advice. Except
as otherwise declared to Robinhood in writing, by executing this Agreement, I certify that I meet
the definition of Nonprofessional as set forth in this Agreement.
Permitted Use. If I am a Nonprofessional, I agree to receive Market Data solely for my personal,
non-business use.
Notification. I shall notify Robinhood promptly in writing of any change in my circumstances that
may cause Me to cease to qualify as a Nonprofessional.
3. NASDAQ OMX Information.
A. Definitions.
"Information" means certain market data and other data disseminated that has been collected,
validated, processed, and recorded by any system NASDAQ OMX has developed for the creation
or dissemination of Information or other sources made available for transmission to and receipt
from either a distributor such as RHF or from NASDAQ OMX relating to: a) eligible securities or
other financial instruments, markets, products, vehicles, indicators, or devices; b) activities of a
NASDAQ OMX company; c) other information and data from a NASDAQ OMX company.
"Information" also includes any element of Information as used or processed in such a way that
the Information can be identified, recalculated or re-engineered from the processed Information or
that the processed Information can be used as a substitute for Information.
"NASDAQ OMX" means The NASDAQ OMX Group, Inc., a Delaware limited liability company
and its subsidiaries and Affiliates (collectively, "NASDAQ OMX").
4.
5.
6.
7.
1.
2.
3.
1.
2.
3
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B. Use of Data.
I understand that I may use the Information only for personal use and not for any business purpose. I
may not sell, lease, furnish or otherwise permit or provide access to the Information to any other natural
person or entity ("Person") or to any other office or place. I will not engage in the operation of any illegal
business use or permit anyone else to use the Information, or any part thereof, for any illegal purpose or
violate any NASDAQ OMX or SEC Rule or any FSA rule or other applicable law, rule or regulation. I may
not present the Information rendered in any unfair, misleading or discriminatory format. I shall take
reasonable security precautions to prevent any Person other than Myself from gaining access to the
Information.
C. Proprietary Data.
I acknowledge and agree that NASDAQ OMX has proprietary rights to the Information that originates on
or derives from markets regulated or operated by NASDAQ OMX, and compilation or other rights to
Information gathered from other sources. I further acknowledge and agree that NASDAQ OMX's third-
party information providers have exclusive proprietary rights to their respective Information. In the event
of any misappropriation or misuse by Me or anyone who accesses the Information through Me,
NASDAQ OMX or its third-party information providers shall have the right to obtain injunctive relief for its
respective materials.
D. System.
I acknowledge that NASDAQ OMX, in its sole discretion, may from time-to-time make modifications to
its system or the Information. Such modifications may require corresponding changes to be made in
Robinhood Financial's service. Changes or the failure to make timely changes by Me may sever or
affect My access to or use of the Information. I understand that neither NASDAQ OMX nor Robinhood
shall be responsible for such effects.
E. NASDAQ OMX Limitation of Liability.
Except as may otherwise be set forth herein, NASDAQ OMX shall not be liable to Me for indirect,
special, punitive, consequential or incidental loss or damage (including, but not limited to, trading losses,
lost profits, or other indirect loss or damage) of any nature arising from any cause whatsoever, even if
NASDAQ OMX has been advised of the possibility of such damages. NASDAQ OMX shall not be liable
to Me for any unavailability, interruption, delay, incompleteness or inaccuracy of the Information. This
Section shall not relieve NASDAQ OMX or Me from liability for damages that result from their own gross
negligence or willful tortious misconduct or from personal injury or wrongful death claims. I agree that the
terms of this Section reflect a reasonable allocation of risk and limitation of liability.
F. Disclaimers of Warranties.
NASDAQ OMX and its third-party information providers make no warranties of any kind with respect to
the Information---express, implied or statutory (including without limitation, timeliness, truthfulness,
sequence, completeness, accuracy, freedom from interruption), any implied warranties arising from trade
usage, course of dealing, course of performance or the implied warranties of merchantability or fitness
for a particular use or purpose or noninfringement.
G. Termination by NASDAQ OMX.
I acknowledge that NASDAQ OMX, when required to do so in fulfillment of statutory obligations, may by
notice to Robinhood unilaterally limit or terminate the right of any or all Persons to receive or use the
4
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Information and that Robinhood will comply with any such notice and will terminate or limit the furnishing
of the Information.
4. Authorization.
I understand that My Account is self-directed. Accordingly, I appoint Robinhood Financial as My agent for
the purpose of carrying out My directions to Robinhood Financial in accordance with the terms and
conditions of this Agreement and any attendant risks with respect to the purchase or sale of securities.
Robinhood Financial is authorized to open or close My Account(s), place and withdraw orders and take
such other steps as are reasonable to carry out My directions. All transactions will be effected only on
My order or the order of My authorized delegate, except as described in Section 10. I understand
Robinhood Financial provides trading and brokerage services through the Robinhood website (the
"Website") and the Robinhood mobile application (the "App"). I agree to receive and transmit financial
information through such electronic means. My use or My grant of access to My Account to any third
party to access information or place transactions in My Account is solely at My risk.
5. Customer Representations and Responsibilities.
A. Self-directed Account.
I understand that My Account is self-directed, and so that I am solely responsible for any and all orders
placed in My Account and that all orders entered by Me or on My behalf are unsolicited and based on My
own investment decisions or the investment decision of My duly authorized representative or agent.
Accordingly, I agree that neither Robinhood nor any of its employees, agents, principals, or
representatives:
provide investment advice in connection with this Account;
recommend any security, transaction or order;
solicit orders;
act as a market maker in any security;
make discretionary trades; and
produce or provide first-party research providing a specific investment strategies such as buy, sell
or hold recommendations, first-party ratings and/or price targets. To the extent research materials
or similar information are available through the App or the Website or the websites of any entity
controlled by, controlling, or under common control with Robinhood (such entity, an "Affiliate"), I
understand that these materials are intended for informational and educational purposes only and
they do not constitute a recommendation to enter into any securities transactions or to engage in
any investment strategies.
B. Information Accuracy.
I: (i) certify that the information contained in this Agreement, the account application, and any other
document that I furnish to Robinhood Financial in connection with My Account(s) is complete, true and
correct, and acknowledge that knowingly giving false information for the purpose of inducing Robinhood
Financial to extend credit is a federal crime; (ii) authorize Robinhood Financial to contact any individual
or firm noted herein or on the documents referred to in subsection (i) of this Section and any other normal
sources of debit or credit information; (iii) authorize anyone so contacted to furnish such information to
Robinhood Financial as Robinhood may request; and (iv) agree that this Agreement, the account
application and any other document I furnish in connection with My Account is Robinhood's property, as
the case may be. I shall promptly advise Robinhood Financial of any changes to the information in such
agreements and documents in writing within ten (10) calendar days. I authorize Robinhood Financial to
obtain reports and provide information to others concerning My creditworthiness and business conduct.
Upon My request, Robinhood agrees to provide Me a copy of any report so obtained. Robinhood may
1.
2.
3.
4.
5.
6.
5
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retain this Agreement, the Account application, and all other such documents and their respective
records at Its sole discretion, whether or not credit is extended.
C. Risks.
I understand that all investments involve risk, that losses may exceed the principal invested, and that
the past performance of a security, industry, sector, market, or financial product does not guarantee
future results or returns.
D. Account Defaults.
I understand that My Account comes with many defaulted service instruction features and preferences. I
further understand that I am not required to use these defaulted options or preferences and that once My
Account is approved and opened I have the sole discretion to control and adjust such defaulted service
preferences that relate to My account.
E. Knowledge of Account.
I understand that I am solely responsible for knowing the rights and terms for all securities purchased,
sold and maintained in My Account including mergers, reorganizations, stock splits, name changes or
symbol changes, dividends, option symbols, and option deliverables. I further understand that certain
securities may grant Me valuable rights that may expire unless I take specific action. These securities
include bonds, convertible securities, warrants, stock rights and securities subject to exchange offers or
tenders. I am responsible for knowing all expiration dates, redemption dates, and the circumstances
under which rights associated with My securities may be called, cancelled, or modified. Robinhood may,
but are not obligated to, notify Me of any upcoming expiration or redemption dates, or take any action on
My behalf without My specific instructions except as required by law and the rules of regulatory
authorities. I acknowledge that Robinhood may adjust My Account to correct any error. If My Account
has an option position on the last trading day prior to expiration, which is one cent or more in the money,
Robinhood Financial will generally exercise the option, on My behalf. However, Robinhood Financial
reserves the right at Its discretion to close any option position prior to expiration date or any position
resulting from the exercising/assignment after option expiration. I will be charged a commission for any
such transaction. Robinhood Financial is not obligated to take any of these actions and Robinhood
Financial is not liable for Losses should it not take them.
F. Purchases.
All orders for the purchase of securities given for My Account will be authorized by Me and executed in
reliance on My promise that an actual purchase is intended. It is My obligation to pay for purchases
immediately or on Robinhood's demand. I understand Robinhood may at any time, in its sole discretion
and without prior notice to Me, prohibit or restrict My ability to trade securities. I further agree not to
allow any person to trade for My Account unless a trading authorization for that person has been
received and approved by Robinhood. Robinhood reserve the right to require full payment in cleared
funds prior to the acceptance of any order. In the event that I fail to provide sufficient funds, Robinhood
may, at its option and without notice to Me, i) charge a reasonable rate of interest, ii) liquidate the
Property subject of the buy order, or iii) sell other Property owned by Me and held in any of My Accounts.
Robinhood may also charge any consequential Loss to My Account. For purposes of this Agreement,
"Property" shall mean all monies, contracts, investments and options, whether for present or future
delivery, and all related distributions, proceeds, products and accessions.
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G. Sales/Short Sales.
I promise to deliver all securities sold in My Account and to provide collateral of a type and amount
acceptable to Robinhood Financial for all short sales in My Account. Robinhood Financial requires that a
security be held in My Account prior to the acceptance of a sell order with respect to such security
unless the order is specifically designated as a "short sale." If a security is not held in My Account and a
sell order is processed, I must promptly deliver such security to Robinhood Financial for receipt in good
deliverable form on or before the settlement date. Any order accepted without negotiable certificates or
positions in My Account will be subject, at Robinhood Financial's sole discretion, to cancellation or buy-
in. To ensure this will not occur, I agree to only place sell orders for securities owned by Me and held in
My Account at the time My order is placed.
Proceeds of a sale will not be paid to Me or released into My Account until Robinhood Financial has
received the security in good deliverable form, whether from a transfer agent or from Me and the
settlement of the security is complete. If the security is not received on or before settlement date, or as
market conditions warrant, Robinhood Financial may in its sole discretion purchase the security on the
open market for My Account and may liquidate and close out any and all securities in My Account in
order to pay for such purchase. In the event a security is bought in, I will be responsible for all resulting
Losses incurred by Robinhood Financial.
I understand that I may execute short sales only in a margin Account and that such execution must
comply with applicable short sales rules.
H. Assistance by Robinhood.
I understand that when I request assistance from Robinhood or its employees in using the investment
tools available on the Website or the App, it will be limited to an explanation of the tool's functionality
and, if requested by Me, to the entry by Robinhood or its employees of variables provided by Me, and
that such assistance does not constitute investment advice, an opinion with respect to the suitability of
any transaction, or solicitation of any orders.
I. No Tax or Legal Advice.
I understand that Robinhood does not provide tax or legal advice.
J. Discontinuation of Services.
I understand that Robinhood may discontinue My Account and any services related to My Account
immediately by providing written notice to Me
K. Electronic Access.
I am solely responsible for keeping My Account numbers and PINs confidential and will not share
them with third parties. "PINs" shall mean My username and password.
I agree and accept full responsibility for monitoring and safeguarding My Accounts and access to
My Accounts.
I agree to immediately notify Robinhood in writing, delivered via e-mail and a recognized
international delivery service, if I become aware of: (i) any loss, theft, or unauthorized use of My
PINs or Account numbers; (ii) any failure by Me to receive any communication from Robinhood
indicating that an order was received, executed or cancelled, as applicable; (iii) any failure by Me
to receive an accurate written confirmation of an order, execution, or cancellation; (iv) any receipt
by Me of confirmation of an order, execution or cancellation, which I did not place; (v) any
1.
2.
3.
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inaccurate information in or relating to My orders, trades, margin status, Account balances,
deposits, withdrawals, securities positions or transaction history; or (vi) any other unauthorized
use or access of My Account.
Each of the events described in subsections (K)(3)(i)-(vi) shall be deemed a "Potential Fraudulent
Event". The use and storage of any information including My Account numbers, PINs, portfolio
information, transaction activity, account balances and any other information or orders available
on My wireless, web-enabled cellular telephone or similar wireless communications device
(collectively, "Mobile Device") or My personal computer is at My own risk and is My sole
responsibility. I represent that I am solely responsible for and have authorized any orders or
instructions appearing in, originating from, or associated with My Account, My Account number,
My username and password, or PINs. I agree to notify Robinhood immediately after I discover
any Potential Fraudulent Event, but in no event more than twenty-four (24) hours following
discovery. Upon request by Robinhood, I agree to report any Potential Fraudulent Event promptly
to legal authorities and provide Robinhood a copy of any report prepared by such legal authorities.
I agree to cooperate fully with the legal authorities and Robinhood in any investigation of any
Potential Fraudulent Event and I will complete any required affidavits promptly, accurately and
thoroughly. I also agree to allow Robinhood access to My Mobile Device, My computer, and My
network in connection with Robinhood's investigation of any Potential Fraudulent Event. I
understand that if I fail to do any of these things I may encounter delays in regaining access to
the funds in My Account. I agree to indemnify and hold Robinhood, its Affiliates, and Robinhood
and its Affiliates' respective officers, directors, and employees harmless from and against any
Losses arising out of or relating to any Potential Fraudulent Event. I acknowledge that Robinhood
does not know when a person entering orders with My username and password is Me.
Trusted Contact Person. I understand that, pursuant to FINRA regulations, Robinhood is
authorized to contact the Trusted Contact Person (as defined by FINRA Rule 4512) designated
for My Account and to disclose information about My account to address possible financial
exploitation, to confirm the specifics of My current contact information, health status, or the
identity of any legal guardian, executor, trustee or holder of a power of attorney, or as otherwise
permitted by Rule 2165.
6. Clearance of Trades.
I understand that Robinhood Financial has entered into a clearing agreement with Robinhood Securities
whereby Robinhood Financial will introduce My Account to Robinhood Securities, and Robinhood
Securities will clear all transactions, on a fully-disclosed basis. I understand that Robinhood Securities
carries My Account(s) and is responsible for the clearing and bookkeeping of transactions, but is not
otherwise responsible for the conduct of Robinhood Financial.
Until receipt from Me of written notice to the contrary, Robinhood Securities may accept from Robinhood
Financial, without inquiry or investigation, (i) orders for the purchase or sale of securities and other
property on margin, if I have elected to have a margin account, or otherwise, and (ii) any other
instructions concerning my Accounts. Robinhood Securities shall look solely to Robinhood Financial
unless otherwise directed by Robinhood Financial, and not to Me, with respect to any such orders or
instructions; except that I understand that Robinhood Securities will deliver confirmations, statements,
and all written or other notices with respect to My Account directly to Me with copies to Robinhood
Financial, and that Robinhood Securities will look directly to Me or Robinhood Financial for delivery of
margin, payment, or securities. I agree to hold Robinhood Securities harmless from and against any
Losses arising in connection with the delivery or receipt of any such communication(s), provided
Robinhood Securities has acted in accordance with the above. The foregoing shall be effective as to My
Account(s) until written notice to the contrary is received from Me by Robinhood Securities or Robinhood
Financial.
7. Review of Confirmations and Statements.
I agree that it is My responsibility to review order execution confirmations and statements of My
Account(s) promptly upon receipt. I agree to receive all confirmations and account statements, as well
as all tax related documents, in electronic format. I understand that account statements will evidence all
activity in My Account for the stated period, including securities transactions, cash balances, credits to
My Account and all fees paid from My Account. Notwithstanding Section 36.B, confirmations will be
considered binding on Me unless I notify Robinhood of any objections within two (2) calendar days from
the date confirmations are sent. Account statements will be considered binding on Me unless I notify you
4.
5.
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of any objections within ten (10) calendar days after My Account statements are posted online. Such
objection may be oral or in writing, but any oral objection must be immediately confirmed in writing. In all
cases, Robinhood reserves the right to determine the validity of My objection. If I object to a transaction
for any reason, I understand and agree that I am obligated to take action to limit any losses that may
result from such transaction or I will bear sole responsibility for any losses relating to the transaction,
even if My objection to the transaction is ultimately determined to be valid. Nothing in this Section 7
shall limit My responsibilities as described in Section 5 of this Agreement.
8. Important Information Needed to Open a New Account.
To help the government better detect the funding of terrorism and money laundering activities, federal
law requires all financial institutions to obtain, verify, and record information that identifies each person
who opens an account. Therefore, I understand that when I open My Account Robinhood will ask for My
name, address, date of birth and other identifying information. Robinhood may also ask copies of My
driver's license, passport or other identifying documents. I understand that Robinhood may take steps to
verify the accuracy of the information I provide to Robinhood in My Account application or otherwise, and
that Robinhood may restrict My access to My Account pending such verification. I will provide prompt
notification to Robinhood of any changes in the information including My name, address, e-mail address
and telephone number.
I further understand that if I attempt to access My Account from a jurisdiction subject to certain U.S.
sanctions or I am ordinarily resident in such a jurisdiction, or if you reasonably believe that I am
attempting such access or have become a resident in such a jurisdiction, you may restrict My Account,
and any pending orders may be cancelled. If this happens, I understand that I should contact
help@robinhood.com, and that I may be asked to provide supplemental information as part of this
process. I further understand that I must close My Account before establishing residency in any
jurisdiction subject to U.S. sanctions.
9. Telephone Conversations and Electronic Communications.
I understand and agree that Robinhood may record and monitor any telephone or electronic
communications with Me. Unless otherwise agreed in writing in advance, Robinhood does not consent
to the recording of telephone conversations by any third party or Me. I acknowledge and understand that
not all telephone or electronic communications are recorded by Robinhood, and Robinhood does not
guarantee that recordings of any particular telephone or electronic communications will be retained or
capable of being retrieved.
10. Oral Authorization.
I agree that Robinhood shall be entitled to act upon any oral instructions given by Me so long as
Robinhood reasonably believes such instruction was actually given by Me or My authorized agent.
11. Applicable Laws and Regulations.
All transactions in My Account will be subject to federal securities laws and regulations, the applicable
laws and regulations of any state or jurisdiction in which Robinhood Financial is registered, the rules of
any applicable self-regulatory organization of which Robinhood Financial is a member and the rules,
regulations, customs and usages of the exchange or market, and its clearing house, if any, where the
transactions are executed. In no event will Robinhood Financial be obligated to effect any transaction it
believes would violate any federal or state law, rule or regulation or the rules or regulations of any
regulatory or self-regulatory organization.
12. Erroneous Distributions.
I agree to promptly return to Robinhood any assets erroneously distributed to Me. In the event that I sell
a security prior to its ex-dividend/distribution date, and I receive the related cash/stock dividend or
distribution in error, I direct Robinhood on My behalf to pay such dividend/distribution to the entitled
purchaser of the securities I sold, and I guarantee to promptly reimburse Robinhood for, or deliver to
Robinhood, said dividend or distribution.
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13. Market Volatility; Market Orders; Limit Orders; and Queued Orders.
I understand that, whether I place a market or limit order, I will receive the price at which My order is
executed in the marketplace, subject to any clarification stated below. Particularly during periods of high
volume, illiquidity, fast movement or volatility in the marketplace, the execution price received may differ
from the quote provided on entry of an order, and I may receive partial executions of an order at different
prices. I understand that Robinhood Financial is not liable for any price fluctuations. I also understand
that price quotes generally are for only a small number of shares as specified by the marketplace, and
larger orders are relatively more likely to receive executions at prices that vary from the quotes or in
multiple lots at different prices.
I understand that Robinhood Financial does not currently support sending traditional market buy orders
and that Robinhood Financial collars all market buy orders by using limit orders priced up to 5% above
the last trade price. This is not the case for market sell orders. I further understand that when I send a
market buy order through Robinhood Financial's trading system, the trading system generates a limit
order up to 5% above the last trade price, and then Robinhood Financial sends the order to an executing
broker. I understand that Robinhood Financial's implementation of market buy orders may vary
depending on prices of instruments, market conditions, and other factors. I further understand that
Robinhood Financial uses the following rounding mechanics with respect to buy orders: the last trade
price is (i) multiplied by 1.05; (ii) rounded down to two decimal places if the last trade price is over $1.00;
otherwise, rounded down to four decimal places; and (iii) for securities included in the SEC's Tick Size
Pilot Program, rounded down to the nearest $.05 increment. I understand that securities may open for
trading at prices substantially higher or lower than the previous closing price or the anticipated price. If I
place a market order (whether during normal market hours or when the market is closed), I agree to pay
or receive the prevailing market price at the time My market order is executed, subject to the specific
clarification above relating to buy orders. I understand that the price I pay may be significantly higher or
lower than anticipated at the time I placed the order. To avoid buying a security at a higher price and
possibly exceeding My purchasing power, I understand My option to enter a limit order. I also understand
that limit orders may not be executed at any particular time, or at all, if there is not sufficient trading at or
better than the limit price I specify, and are only good until the end of the trading day in which they are
entered. The Website contains further information regarding order types and limitations, which I agree to
read and understand before placing such orders.
As a customer of Robinhood Financial, I understand that after the market has closed for the day, I have
the ability to place in a queue order requests to be executed the following day upon the opening of the
market ("Queued Order"). I understand that My Queued Order request is prioritized based on the order in
which it is received by Robinhood Financial, and that the Queued Order requests are sent out for
execution shortly after the market opens on the next day of trading. I further understand that each
Queued Order request is sent out per customer and per security as Robinhood Financial market orders
(described above), and that they are not aggregated.
A limit order may be "good till cancelled" which means the order remains valid until (A) it is executed; (B)
I cancel the order; (C) approximately 90 days from when the order is placed; or (D) the contract to which
it relates is closed. I understand that Robinhood will cancel a "good till cancelled" order at the end of
every trading day (on the exchange on which the instrument to which the contract relates is traded) and
place such order again at the start of the following trading day. This process will be repeated every day
for as long as the "good till cancelled" order remains valid. I further agree that any "good till cancelled"
orders I place should be treated as "do not reduce" orders.
14. Bulletin Board/Pink Sheet Stocks.
Bulletin board, pink sheet and other thinly-traded securities (collectively "bulletin board stocks") present
particular trading risks, in part because they are relatively less liquid and more volatile than actively
traded securities listed on a major exchange. I understand that bulletin board stocks may be subject to
different trading rules and systems than other securities and that I may encounter significant delays in
executions, reports of executions, and updating of quotations in trading bulletin board stocks. Robinhood
Financial in its sole discretion may require limit orders on certain bulletin board stock transactions.
15. Research and Internet Links.
News, research, links to outside websites, and other information accessible through the App or Website
("Content") may be prepared by independent external providers not affiliated with Robinhood Financial,
including Morningstar, Inc. (all such providers, the "Providers"). I agree not to distribute, reproduce, sell,
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or otherwise commercially use the Content in any manner. I understand that Robinhood may terminate
My access to the Content. I understand that none of the Content is a recommendation by Robinhood to
buy or sell any securities or to engage in any investment strategy.
16. Restrictions on Trading.
I understand that Robinhood may, in its discretion, prohibit or restrict the trading of securities, or the
substitution of securities, in any of My Accounts. I understand that Robinhood may execute all orders by
Me on any exchange or market, unless I specifically instruct Robinhood to the contrary. In the event of a
breach or default by Me under this Agreement, Robinhood shall have all rights and remedies available to
a secured creditor under all applicable laws and in addition to the rights and remedies provided herein. I
understand that Robinhood may at any time, at its sole discretion and without prior notice to Me: (i)
prohibit or restrict My access to the use of the App or the Website or related services and My ability to
trade, (ii) refuse to accept any of My transactions, (iii) refuse to execute any of My transactions, or (iv)
terminate My Account. The closing of My Account will not affect the rights or obligations of either party
incurred prior to the date My Account is closed.
Further, Robinhood will not tolerate any foul or abusive language, physical violence, threatening behavior,
or other inappropriate conduct directed toward Robinhood, its Affiliates' officers, employees, contractors
or customers. If I engage in any such behavior, as determined by Robinhood in its sole discretion, I
agree that Robinhood is authorized to: (i) liquidate any securities, instruments or other property in My
Account, (ii) send Me the proceeds, and (iii) close My account. Robinhood will not be responsible for any
Losses caused by the liquidation of securities, instruments or other property pursuant to this paragraph,
including any tax liabilities.
17. Waiver; Limitation of Liability; Indemnification.
I agree that My use of the App or the Website or any other service provided by Robinhood Financial or
its Affiliates is at My sole risk. The Robinhood Financial service (including the App, the Website, the
provision of Market Data, Information, Content, or any other information provided by Robinhood
Financial, any of its Affiliates, or any third-party content provider or market data provider) is provided on
an "as is," "as available" basis without warranties of any kind, either express or implied, statutory
(including without limitation, timeliness, truthfulness, sequence, completeness, accuracy, freedom from
interruption), implied warranties arising from trade usage, course of dealing, course of performance, or
the implied warranties of merchantability or fitness for a particular purpose or application, other than
those warranties which are implied by and incapable of exclusion, restriction or modification under the
laws applicable to this Agreement.
Although considerable effort is expended to make the Website, App and other operational and
communications channels available around the clock, Robinhood does not warrant that these channels
will be available and error free every minute of the day. I agree that Robinhood will not be responsible for
temporary interruptions in service due to maintenance, Website or App changes, or failures, nor shall
Robinhood be liable for extended interruptions due to failures beyond our control, including but not limited
to the failure of interconnecting and operating systems, computer viruses, forces of nature, labor
disputes and armed conflicts.
EXCEPT AS OTHERWISE EXPRESSLY PROVIDED IN THIS AGREEMENT, I UNDERSTAND AND
AGREE THAT ROBINHOOD, ITS AFFILIATES, THEIR RESPECTIVE OFFICERS, DIRECTORS,
EMPLOYEES AND AGENTS, AND THE PROVIDERS (COLLECTIVELY THE "ROBINHOOD
PARTIES") WILL NOT BE LIABLE TO ME OR TO THIRD PARTIES UNDER ANY
CIRCUMSTANCES, OR HAVE ANY RESPONSIBILITY WHATSOEVER, FOR ANY SPECIAL,
INDIRECT, INCIDENTAL, PUNITIVE OR CONSEQUENTIAL DAMAGES (INCLUDING TRADING
LOSSES, DAMAGES, LOSS OF PROFITS, REVENUE, OR GOODWILL) THAT I MAY INCUR IN
CONNECTION WITH MY USE OF THE SERVICE PROVIDED BY ROBINHOOD OR ANY OF ITS
AFFILIATES UNDER THIS AGREEMENT (INCLUDING MY USE OF THE APP, THE WEBSITE, THE
MARKET DATA, THE INFORMATION, OR THE CONTENT), BREACH OF THIS AGREEMENT, OR
ANY TERMINATION OF THIS AGREEMENT, WHETHER SUCH LIABILITY IS ASSERTED ON THE
BASIS OF CONTRACT, TORT (INCLUDING NEGLIGENCE), OR OTHERWISE, AND WHETHER OR
NOT FORESEEABLE, EVEN IF ANY ROBINHOOD PARTY HAS BEEN ADVISED OR WAS AWARE
OF THE POSSIBILITY OF SUCH LOSS OR DAMAGES. THE ROBINHOOD PARTIES SHALL NOT
BE LIABLE BY REASON OF DELAYS OR INTERRUPTIONS OF THE SERVICE OR
TRANSMISSIONS, OR FAILURES OF PERFORMANCE OF THEIR RESPECTIVE SYSTEMS,
REGARDLESS OF CAUSE, INCLUDING THOSE CAUSED BY GOVERNMENTAL OR
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REGULATORY ACTION, THE ACTION OF ANY EXCHANGE OR OTHER SELF REGULATORY
ORGANIZATION, OR THOSE CAUSED BY SOFTWARE OR HARDWARE MALFUNCTIONS.
Except as otherwise provided by law, Robinhood or any of its affiliates or respective partners, officers,
directors, employees or agents (collectively, "Indemnified Parties") shall not be liable for any expenses,
losses, costs, damages, liabilities, demands, debts, obligations, penalties, charges, claims, causes of
action, penalties, fines and taxes of any kind or nature (including legal expenses and attorneys' fees)
(whether known or unknown, absolute or contingent, liquidated or unliquidated, direct or indirect, due or
to become due, accrued or not accrued, asserted or unasserted, related or not related to a third party
claim, or otherwise) (collectively, "Losses") by or with respect to any matters pertaining to My Account,
except to the extent that such Losses are actual Losses and are determined by a court of competent
jurisdiction or an arbitration panel in a final non-appealable judgment or order to have resulted solely from
Robinhood's or any of its affiliates' gross negligence or intentional misconduct. In addition, I agree that
the Indemnified Parties shall have no liability for, and I agree to indemnify, defend and hold harmless the
Indemnified Parties from all Losses that result from: (i) any noncompliance by Me with any of the terms
and conditions of this Agreement; (ii) any third-party actions related to My receipt and use of any
Information, Market Data, Content, market analysis, other third-party content, or other such information
obtained on the App or Website, whether authorized or unauthorized under this Agreement; (iii) any third-
party actions related to My use of the App or the Website; (iv) My or My agent's misrepresentation or
alleged misrepresentation, or act or omission; (v) Indemnified Parties following My or My agent's
directions or instructions, or failing to follow My or My agent's unlawful or unreasonable directions or
instructions; (vi) any activities or services of the Indemnified Parties in connection with My Account
(including any technology services, reporting, trading, research or capital introduction services); or (vii)
the failure by any person not controlled by the Indemnified Parties and their affiliates to perform any
obligations to Me. Further, if I authorize or allow third parties to gain access to Robinhood's services,
including My Accounts, I will indemnify, defend and hold harmless the Indemnified Parties against any
Losses arising out of claims or suits by such third parties based upon or relating to such access and
use. Robinhood does not warrant against loss of use or any direct, indirect or consequential damages or
Losses to Me caused by My assent, expressed or implied, to a third party accessing My Account or
information, including access provided through any other third party systems or sites.
I consent to the use of automated systems or service bureaus by Robinhood and its respective affiliates
in conjunction with My Account, including automated order entry and execution, record keeping, reporting
and account reconciliation and risk management systems (collectively "Automated Systems"). I
understand that the use of Automated Systems entails risks, such as interruption or delays of service,
errors or omissions in the information provided, system failure and errors in the design or functioning of
such Automated Systems (collectively, a "System Failure") that could cause substantial damage,
expense, or liability to Me. I understand and agree that Indemnified Parties will have no liability
whatsoever for any of my Losses arising out of or relating to a System Failure.
I also agree that Indemnified Parties will have no responsibility or liability to Me in connection with the
performance or non-performance by any exchange, clearing organization, market data provider, or other
third party (including other broker-dealers and clearing firms, and banks) or any of their respective agents
or affiliates, of its or their obligations relative to any securities. I agree that Indemnified Parties will have
no liability, to Me or to third parties, or responsibility whatsoever for: (i) any Losses resulting from a
cause over which Indemnified Parties do not have direct control, including the failure of mechanical
equipment, unauthorized access, theft, operator errors, government restrictions, force majeure (as
defined in this Agreement), market data availability or quality, exchange rulings or suspension of trading;
and (ii) any special, indirect, incidental, consequential, punitive or exemplary damages (including lost
profits, trading losses and damages) that I may incur in connection with My use of the App, the Website,
Robinhood's brokerage, and other services provided by Indemnified Parties under this Agreement.
18. Mutual Fund Transactions.
In the event that I purchase or hold a mutual fund, I agree to read and understand the terms of its
prospectus. I understand that certain mutual funds reserve the right to change their purchasing,
switching or redemption procedures or suspend or postpone redemptions under certain market
conditions. I further understand that any mutual fund order entered with Robinhood is placed by
Robinhood on a best efforts basis as prescribed and recognized by the individual fund, and that
Robinhood is not responsible for unexecuted orders due to the failure of any communication system. I
agree to be fully responsible for the information contained within the mutual fund prospectus and to hold
Robinhood, its Affiliates, and Robinhood and its Affiliates' respective officers and employees harmless
for any deficiencies contained therein. I authorize Robinhood to act as My agent in the purchase and
redemption of fund shares.
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19. Exchange Traded Funds.
I understand that I should consider the investment objectives and unique risk profile of Exchange Traded
Funds ("ETFs") carefully before investing, and that ETFs are subject to risks similar to those of other
diversified portfolios. I further understand that leveraged and inverse ETFs may not be suitable for all
investors and may increase exposure to volatility through the use of leverage, short sales of securities,
derivatives, and other complex investment strategies, and that although ETFs are designed to provide
investment results that generally correspond to the performance of their respective underlying indices,
they may not be able to exactly replicate the performance of the indices because of expenses and other
factors. I further understand that ETFs are required to distribute portfolio gains to shareholders at year
end, which may be generated by portfolio rebalancing or the need to meet diversification requirements,
and that ETF trading will also generate tax consequences. I understand that I can obtain prospectuses
from issuers or their third party agents who distribute and make prospectuses available for review.
Additional regulatory guidance on ETFs can be found here.
20. Effect of Attachment or Sequestration of Accounts.
Robinhood shall not be liable for refusing to obey any orders given by or for Me with respect to any of
My Accounts that has or have been subject to an attachment or sequestration in any legal proceeding
against Me, and Robinhood shall be under no obligation to contest the validity of any such attachment or
sequestration.
21. Event of Death.
It is agreed that in the event of My death, the representative of My estate or the survivor or survivors
shall immediately give Robinhood written notice thereof, and Robinhood may, before or after receiving
such notice, take such proceedings, require such papers and inheritance or estate tax waivers, retain
such portion of, or restrict transactions in the Account as Robinhood may deem advisable to protect
Robinhood against any tax, liability, penalty or loss under any present or future laws or otherwise.
Notwithstanding the above, in the event of My death, all open orders shall be canceled, but Robinhood
shall not be responsible for any action taken on such orders prior to the actual receipt of notice of death.
Further, Robinhood may in Its discretion close out any or all of the Accounts without awaiting the
appointment of a personal representative for My estate and without demand upon or notice to any such
personal representative. The estate of any of the Account holders who have died shall be liable and each
survivor shall continue to be liable, jointly and severally, to Robinhood for any net debit balance or loss in
said account in any way resulting from the completion of transactions initiated prior to the receipt by
Robinhood of the written notice of the death of the decedent or incurred in the liquidation of the Account
or the adjustment of the interests of the respective parties, and for all other obligations pursuant to this
Agreement. Such notice shall not affect Robinhood's rights under this Agreement to take any action that
Robinhood could have taken if I had not died.
22. Tax Reporting; Tax Withholding.
The proceeds of sale transactions and dividends paid will be reported to the Internal Revenue Service
("IRS") in accordance with applicable law.
A. U.S. Persons.
This subsection is applicable if I am a U.S. person. Under penalties of perjury, I certify that the taxpayer
identification number that I have provided or will provide to Robinhood (including any taxpayer
identification number on any Form W-9 that I have provided or will provide to Robinhood) is My correct
taxpayer identification number. I certify that I am not subject to backup withholding and I am a United
States Person (including a U.S. resident alien) as such term is defined in section 7701(a)(30) of the
Internal Revenue Code of 1986, as amended ("U.S. Person"). If a correct Taxpayer Identification
Number is not provided Robinhood Financial, I understand I may be subject to backup withholding tax at
the appropriate rate on all dividends, interest and gross proceeds paid to me. Backup withholding taxes
are sent to the IRS and cannot be refunded by Robinhood Financial. I further understand that if I waive
tax withholding and fail to pay sufficient estimated taxes to the IRS, I may be subject to tax penalties.
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B. Non-U.S. Persons.
This subsection is applicable if I am not a U.S. Person. I certify that I fully understand all the information
on any Form W-8BEN that I have submitted or will submit to Robinhood. Under penalties of perjury, I
declare that (i) I have examined all the information (including all the information in the English language)
on any Form W-8BEN that I have submitted or will submit to Robinhood and (ii) to the best of My
knowledge and belief all such information is true, correct, and complete. I authorize Robinhood to
provide any such Form W-8BEN to Robinhood Securities or any withholding agent that has control,
receipt, or custody of the income of which I am the beneficial owner or any withholding agent that can
disburse or make payments of the income of which I am the beneficial owner. I agree that I will submit a
new Form W-8BEN to Robinhood within 30 calendar days if any certification made on any previously
submitted Form W-8BEN becomes incorrect. I understand that the IRS does not require My consent to
any provisions of such Form W-8BEN other than the certifications required to establish My status as a
non-U.S. Person and, if applicable, obtain a reduced rate of withholding.
23. Equity Orders and Payment For Order Flow.
SEC rules require all registered broker-dealers to disclose their policies regarding any "payment for order
flow" arrangement in connection with the routing of customer orders. "Payment for order flow" includes,
among other things, any monetary payment, service, property, or other benefit that results in
remuneration, compensation, or consideration to a broker-dealer from any broker-dealer in return for
directing orders. I understand that Robinhood transmits customer orders for execution to various
exchanges or market centers based on a number of factors. These include: size of order, trading
characteristics of the security, favorable execution prices (including the opportunity for price
improvement), access to reliable market data, availability of efficient automated transaction processing
and reduced execution costs through price concessions from the market centers. I further understand
that certain of the exchanges or market centers may execute orders at prices superior to the publicly
quoted market in accordance with their rules or practices and that while a customer may specify that an
order be directed to a particular market center for execution, the order-routing policies, taking into
consideration all of the factors listed above, are designed to result in favorable transaction processing for
customers. The nature and source of any payments or credits received by Robinhood in connection with
any specific transactions will be furnished upon written request.
24. Free Credit Balances and Sweep Service.
If I enroll in Robinhood Financial Cash Management ("Cash Management"), I understand that I am
electing to participate in the Insured Network Deposit ("IND") sweep service (the "Sweep Service").
Under the Sweep Service, free credit balances in My Account will be deposited into interest-bearing
accounts at one or more banks ("Participating Depository Institutions"), in accordance with the Insured
Network Deposit Sweep Program Disclosures ("IND Disclosures") available on the Website and in the
App. By enrolling in Cash Management, I represent and warrant that I have reviewed the IND
Disclosures and agree to the terms set forth in the IND Disclosures. If I am not enrolled in Cash
Management, free credit balances in My Account will remain in My Account, will not earn interest and
will not be eligible for FDIC insurance, but will be eligible for SIPC protection as described in the IND
Disclosures.
25. Fees and Charges.
I understand that Robinhood does not charge fees or commissions for executing buy and sell orders.
However, I understand that other fees may apply. The current fees are included in the fee schedule
available in the App and on the Website. I agree to pay any such fees at the then-prevailing rate. I
acknowledge that the prevailing fees may change and that change may occur without notice. I agree to
be bound by such changes once they are posted in the fee schedule available in the App and on the
Website. I also agree to pay all applicable federal, state, local, and foreign taxes. I authorize Robinhood
Financial to automatically debit My Account for any such fees and taxes. I also agree to pay such
expenses incurred by Robinhood in connection with collection of any unpaid balance due on My
Accounts including attorney's fees allowed by law.
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26. ACH Transactions.
A. Debit Transactions.
Robinhood will initiate an ACH debit at My request to debit funds from an account that I own at another
financial institution ("External Account") for deposit into My Account. I understand that in order for
Robinhood to initiate an ACH debit, the financial institution holding my External Account must participate
in the ACH system. I understand that for the ACH transfers to be established, at least one common
name must match exactly between My Account and My External Account. I authorize Robinhood to take
such steps as it deems appropriate to verify my ownership of External Account, including by telling the
bank at which such External Account is held that I have authorized and consented to such bank
disclosing to Robinhood any information that Robinhood may request about Me or My External Account.
I also agree to cooperate with Robinhood's verification of my ownership of such External Account by
promptly providing any identification and/or other documentation that Robinhood may request regarding
such External Account. I represent and warrant that there are sufficient funds in My External Account to
cover the amount of the deposit to My Account. Robinhood will initiate the ACH debit to My External
Account on the Business Day or next Business Day after I request the transfer. A transfer request will be
deemed to have been made on a Business Day if it is received by Robinhood by 7:00 p.m. (Eastern
Time) on such Business Day; if received after that time, the transfer request will be deemed to have
been made on the next Business Day.
Within 60 days of the date of My ACH deposit, My funds may only be withdrawn to the External Account
from which such funds were deposited.
I understand that an ACH debit transfer may be reversed or rejected if: (A) there are insufficient funds in
My External Account; (B) there is a duplicate transaction; (C) the transaction is denied by the bank
holding My External Account; or (D) My External Account does not support ACH transfers. I
acknowledge that in the event of an ACH reversal, I will incur a fee. Before initiating making an ACH
debit transfer, I agree to check Robinhood Financial's most recent Commissions and Fees Schedule. I
agree that I am solely liable and responsible for any ACH reversal fees that I incur.
B. Credit Transactions.
Robinhood will initiate an ACH credit at My request to transfer funds from My Account to a recipient that
I designate. I agree that I will have sufficient Available Funds in My Account to cover the amount of any
ACH credit that I ask Robinhood to initiate. Robinhood will debit the amount of such request from My
Account on the Business Day or next Business Day after I request the transfer. A transfer request will be
deemed to have been made on a Business Day if it is received by Robinhood on such Business Day; if
received after that time, the transfer request will be deemed to have been made on the next Business
Day.
I agree that Robinhood may use any means which Robinhood, in its sole discretion, considers suitable
to execute my ACH credit transfers.
27. Fractional Shares.
I acknowledge and understand that Robinhood rounds all holdings of fractional shares to the sixth
decimal place, the value of fractional shares to the nearest cent, and any dividends paid on fractional
shares to the nearest cent. I further understand that Robinhood will not accept dollar-based purchases or
sales of less than $1.00 and that I will receive proceeds from the sale of any whole or fractional shares
rounded to the nearest cent.
I understand that a vendor employed by Robinhood will aggregate any proxy votes for fractional shares
of Robinhood’s customers with all votes reported to the issuer or issuer’s designated vote tabulator and
that, while Robinhood’s vendor will report such proxy votes on fractional shares, the issuer or tabulator
may not fully count such votes.
I understand that Robinhood will execute all orders that include fractional shares ("Fractional Orders") on
a principal basis. To the extent that Robinhood must purchase or sell shares in the market to fulfill any
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part of my Fractional Order, the fractional component of that order will be fulfilled at the exercution price
Robinhood received for the corresponding whole shares. To the extent that Robinhood fulfills my
Fractional Order for national exchange-listed securities ("NMS Securities") entirely out of its inventory
and without purchasing or selling shares in the market ("Inventory Fulfillment"), Robinhood will endeavor
to price such shares or fractional shares at a price between the National Best Bid and Offer (“NBBO”) at
the time of the order for orders made during market hours, or, for such orders made during extended
hours trading (9:00-9:30 a.m. and 4:00-6:00 p.m. Eastern), Robinhood will endeavor to price such orders
between the best bid and offer at the time of the order, as reported by an external vendor ("Vendor
BBO"). For Inventory Fulfillment of Fractional Orders for securities not listed on a national exchange
("Non-NMS Securities") made during market hours as well as extended hours trading, Robinhood will
endeavor to price such orders between Vendor BBO.
All orders placed outside market hours and extended hours trading, whether they are Fractional Orders or
orders entirely of whole shares, are queued and fulfilled either at or near the beginning of extended hours
trading (9:00 a.m. Eastern) or at or near market open (9:30 a.m. Eastern), according to my instructions.
To the extent that I trade outside of market hours, these trades are subject to Robinhood’s Extended
Hours Trading Disclosure.
I understand Robinhood only accepts market orders for fractional shares at this time and does not permit
limit orders for fractional shares. I understand that fractional shares within My Account (i) are
unrecognized, unmarketable, and illiquid outside the Robinhood platform, (ii) are not transferrable in-kind,
and (iii) may only be liquidated and the proceeds transferred out via a wire transfer. I acknowledge that,
subject to applicable requirements, Robinhood may report holdings and transactions in My Account in
terms of either U.S. Dollars, shares, or both.
28. Phone Calls.
You agree that, by providing information Robinhood requests, Robinhood and its third party services
providers may contact you via mail, phone or email.
Specifically, if you provide us with a phone number: (a) you represent and warrant that the number you
provide is your phone number, and you will promptly notify us if that changes, and (b) you consent to
receive calls (including text messages) made to that phone number that may be prerecroded and/or
completed with an automatic telephone dialing system (automated calls) for purposes including but not
limited to providing account-related communications (including security alerts), investigating or
preventing fraud, and/or collecting amounts owed to Robinhood. We may share your number with third
parties that provide services to us in connection with any of the foregoing purposes, including but not
limited to debt collectors. You understand that message, telephone minute and data rates may apply for
calls made to a mobile phone number. You may opt out at any time from receiving these types of calls
orally or in writing to limitsharing@robinhood.com. Please note, even if you opt out, we may still make
other calls as permitted by law.
You consent to our recording of phone calls, including calls we make to you or that we receive from you.
29. Dividend Reinvestment Program.
Except as expressly stated otherwise, the provisions of this Section 29 will only apply if I am enrolled in
Robinhood’s Dividend Reinvestment Program (“DRIP”). My enrollment in the DRIP will be activated
within three business days after I notify Robinhood of my intention to enroll an eligible security through
the App. “Eligible security” means all shares available for fractional investing through Robinhood. I
understand that in order to be eligible for dividend reinvestment, the securities must be held in My
Account.
I may specify individual securities or have all Eligible securities in My Account enrolled for dividend
reinvestment. If I choose to reinvest dividends from all Eligible securities, I understand that individual
securities could subsequently no longer be Eligible securities at Robinhood’s discretion or under
applicable law. In those cases, only those securities will be discontinued from the DRIP. If I specify
individual securities, I may add additional Eligible securities to the DRIP at any time if I hold a position
in those securities. Enrollment with respect to these additional Eligible securities will be effective within
three business days after Robinhood receives notification from me through the App. If I maintain open
orders for securities I do not already hold, I may not enroll those securities for dividend reinvestment
until my open orders are executed. If my entire Account is set up for dividend reinvestment, any eligible
securities I purchase in the future will automatically participate in the DRIP.
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All eligible cash distributions will be reinvested on all securities I have selected in the DRIP, provided
that I owned the securities on the record date for determining shareholders eligible to receive dividends,
and continue to hold the securities through payable date. “Eligible cash distributions” means most cash
distributions, including regular and optional dividends, cash-in-lieu payments, and capital gains
distributions. Special dividends, late ex-date, liquidation, and miscellaneous payments may not be
eligible distributions. Optional dividends will be processed in accordance with dividend reinvestment
instructions. If I have a margin account, Robinhood is permitted to borrow a dividend paying stock in the
normal course of business and, as a result, in such situations instead of a dividend payment I may
receive a cash in lieu payment. If I receive a cash in lieu payment, I authorize Robinhood to treat such
payment as if it was not “in lieu” and reinvest it accordingly.
Robinhood will credit My Account upon completion of the dividend reinvestment. Robinhood will reinvest
dividends on the business day following receipt of funds. In the rare instance in which Robinhood is
unable to reinvest all dividends on the business day following receipt, it will reinvest the remaining funds
as soon as reasonably possible thereafter, which may take up to five business days. I will not have use
of the funds prior to reinvestment.
I understand that my participation in the DRIP is voluntary and that Robinhood has not made any
recommendation that I should participate. I further understand that Robinhood is not recommending or
offering any advice regarding the purchase of any security included as an Eligible security in the DRIP. I
further understand that dividend reinvestment does not assure profits on my investments, nor does it
protect against losses in declining markets.
I may terminate my participation in the DRIP, or the enrollment of individual securities in the DRIP, at
any time by giving notice through the App. Termination will take effect prior to the next Eligible cash
distribution provided my notice to terminate was received at least three business days prior to the record
date of that distribution. I understand that my notice to terminate my participation in the DRIP will not
affect any obligations that may result from transactions initiated prior to Robinhood’s receipt and
processing of my notice.
If I participate in the DRIP, I understand Robinhood will reinvest the dividends of a particular stock at or
near the opening price on the trading day following receipt of the dividend. Robinhood will combine
Eligible cash distributions from My Account with those from other Robinhood clients requesting dividend
reinvestment in the same security and use these combined funds to purchase securities on my behalf
and on behalf of these other clients. If the combined reinvested funds do not total the purchase price of
at least one share, the distribution will be invested in fractional shares. On that same day, Robinhood will
credit My Account with that number of shares, including fractional shares, equal to my Eligible cash
distribution divided by the purchase price per share. Robinhood does not intend to charge a fee for
transactions executed pursuant to the DRIP.
Dividend reinvestment may result in my owning interests in fractional shares of a security. I will be
entitled to receive future dividend payments on my fractional shares, although other corporate actions
may result in allocation of only whole shares and cash in lieu of fractions as determined by the issuer. In
mandatory corporate reorganizations, my partial interest will be handled according to the specific terms
of the reorganization. In voluntary corporate reorganizations, Robinhood will act on my instructions with
respect only to my whole shares.
Because fractional share positions cannot be transferred, reorganized, or issued in certificate form, my
partial interest will be liquidated, without commission charges to me, at prevailing market prices in the
event My Account is transferred or closed, the stock is reorganized, or stock certificates are ordered out
of My Account. The timing of such liquidations will be at the discretion of Robinhood.
Reinvestment of dividends may result in my owning a fractional share position in securities that are
callable in part. In the event of a call, fractional shares to be called will be determined through a random
selection process. The probability of my fractional share holdings being called will be proportional to the
holdings of all Robinhood clients who own a fractional share position in that security. Prior to the
publication date of such a call, I have the right to withdraw from My Account cash in lieu of my uncalled,
fully paid partial holdings. Once a call is announced, however, all shares, whether registered or held in
street name, participate in the random selection process. If my fractional shares are selected and I no
longer hold the shares that I held on the publication date of the call, I will be responsible for covering
those shares.
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30. Cash Management Services.
Except as expressly stated otherwise, the provisions of this Section 30 will only apply if I am enrolled in
Cash Management.
A. General.
I understand and agree that by enrolling in Cash Management, I am applying for a Robinhood-branded
debit card issued by the bank identified in My Robinhood Debit Card Agreement ("Card"). I further
understand and agree that by using My Card or exercising My electronic fund transfer ("EFT") privileges
offered in connection with My Account, I authorize Robinhood to debit My Account immediately
whenever an electronic draft or Card transaction is presented for payment on My behalf, when an EFT
transaction is effected, or when any fee or charge is due (collectively "Payments"). I further understand
and agree that when I request a Payment or withdrawal or instruct Robinhood to make a purchase of
securities from My Account, Robinhood is authorized to place a block on the amount of the transaction
("Blocked Amounts") prior to the settlement date of the Payment, withdrawal or trade, and that the
Blocked Amounts will not be available for use for additional Payments or the purchase of securities. I
agree to maintain Available Funds sufficient to pay for EFT transactions, Card transactions and
withdrawals made by Me or any Authorized Card User (as defined below) and to pay for any securities
trades and for interest on any margin loans and other transaction fees. For this purpose, "Available
Funds" in My Account will fluctuate daily and means the sum of (i) free credit balances, (ii) deposits to
Participating Depository Institutions through the Sweep Service, and (iii) available margin loan value if
My Account has margin privileges, minus (x) uncleared funds, (y) Blocked Amounts, and (z) deposits
subject to a hold. The loan value of eligible securities for the purpose of margin is subject to regulatory
requirements and Robinhood credit policies then in effect.
B. Payments and Withdrawals.
I agree that any Payments that I make from My Account will be lawful. I agree that Payments will be
deducted from the Available Funds in My Account in the following order: first, from free credit balances;
second, by withdrawal of funds deposited to Participating Depository Institutions as part of the Sweep
Service; and third, if My Account has margin privileges, from margin loans on the eligible securities in
My margin Account. Robinhood will debit My Account only up to an amount equal to the Available Funds.
I understand and agree that (i) if there are insufficient Available Funds in My Account to cover Payments
when they become due, Robinhood has no obligation to make such Payments, and (ii) Robinhood has
no obligation to make partial Payments. Robinhood will not charge a fee with respect to any declined
Payment for which there were insufficient Available Funds. I acknowledge and agree, however, that
Robinhood will not be responsible for any costs or losses that I may incur (including fees, costs,
charges, attorneys' fees, investment losses, claims, demands, or liability resulting from any litigation or
other actions) as a result of Robinhood's decision to decline any Payment or withdrawal or other
transaction because My Account has insufficient Available Funds.
I understand that if a Payment is funded by a margin loan, I will incur interest until the margin loan is
repaid.
I agree that if my Available Funds at any time falls below zero, Robinhood may suspend Card and EFT
privileges and terminate My Card. If this occurs, I agree to immediately pay all amounts owed to
Robinhood, including any purchases on My Card which will be immediately charged to My Account.
I acknowledge and agree that Robinhood reserves the right to decline any purchase or cancel My Card,
and EFT privileges at any time for any reason with or without notice to Me. If Robinhood decides to take
such action, I understand and agree that I am responsible for any pending debits, which will be
processed and deducted from My Account.
I understand that transactions will post to My Account in any order determined by Robinhood and that
Robinhood may change that order without prior notice to Me. Robinhood will comply with requirements of
applicable law regarding the order of posting transactions.
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C. Limitation of Liability.
I agree that, subject to any limitations imposed by applicable law, and except as otherwise set forth in
this Agreement or in the disclosures contained in the Robinhood Debit Card Agreement, which has been
provided to Me or made available to me in connection with the opening of My Account, neither
Robinhood, any processing bank, nor the Card issuer will be liable for any loss I incur in connection with
My Account, Card transactions, EFT transactions, or other features of My Account unless Robinhood is
grossly negligent in fulfilling this Agreement. In no event will Robinhood, any processing bank, or the
Card issuer be liable for consequential, special or indirect damages or losses unless applicable law
requires otherwise. I also agree that liability regarding online services or use of the App is further limited
by the Robinhood Terms and Conditions, available at https://about.robinhood.com/legal/. To the extent I
utilize online services or the App I acknowledge that I am bound by such Robinhood Terms and
Conditions.
D. Debit Cards.
I understand and agree that My use of the Card is subject to the terms, conditions and disclosures set
forth in the Robinhood Debit Card Agreement, which has been provided to Me in connection with the
opening of My Account and which I may access on the Website.
I understand and agree that I cannot request a Card for another person to use. I agree, however, that if I
permit another person to have access to use My Card or Card number (an "Authorized Card User"), I am
authorizing all Card transactions by such person and I agree that there are no limits to my authorization.
I accept all liability with respect to the Card transactions effected by Me and any Authorized Card Users.
I further agree that I may terminate the authority of an Authorized Card User only by contacting
help@robinhood.com to cancel my Card. I agree that the cancellation of My Card is effective only after
Robinhood has a reasonable period to act on My notice.
If My Card is cancelled, I agree to destroy, or if requested by Robinhood, return the Card to Robinhood. I
acknowledge that I will be responsible for any Card transactions that are processed because of My
failure to destroy or return the Card following cancellation.
If My Account includes margin privileges, I agree that transactions that exceed My free credit balances
and deposits in the Sweep Service may result in margin credit being extended to My Account, for which
I will be charged interest. I agree to review the Margin Disclosure Statement, which is available at
https://about.robinhood.com/legal/.
E. Deposits.
The provisions in this Section 30.E shall apply to My Account whether or not I am enrolled in Cash
Management.
General; Holds. I understand that I may deposit funds to My Account by ACH, direct deposit or EFT
(including deposits using the MoneySend service offered by Mastercard). I acknowledge and agree that
funds that I deposit may be subject to one or more hold periods, which are described in the RHF Funds
Availability schedule available at https://about.robinhood.com/legal/. I understand and agree that
Robinhood reserves the right to modify the RHF Funds Availability schedule at any time by posting an
updated schedule at https://about.robinhood.com/legal/, or otherwise providing notice to me. During the
applicable hold period, My funds will not be available for ACH transfers, Card transactions, withdrawal,
or the settling of securities transactions, in each case as described in the RHF Funds Availability
schedule. I further understand and agree that Robinhood reserves the right to further delay making
deposited funds available for periods longer than the hold periods specified in the RHF Funds Availability
schedule to the extent Robinhood determines that additional time is needed to verify information about
the item deposited or the sender or if Robinhood otherwise believes there is a risk of fraud or other
unlawful activity with respect to My Account.
Mistaken Deposits. If funds are deposited or transferred into My Account by mistake or otherwise, I
agree that Robinhood may correct the situation and deduct any interest paid by Participating Depository
Institutions, if applicable, without prior notice to Me.
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Returned Items. I acknowledge and agree that I am responsible for returned transactions. If I have funds
transferred into My Account and that transfer is returned for any reason, Robinhood may charge the
transfer and interest paid by Participating Depository Institutions, if applicable, against My Account,
without prior notice to Me. Robinhood may send the returned transfer back for collection a second time
without notifying Me, and I waive notice of dishonor and protest.
F. Electronic Fund Transfers.
The provisions in this Section 30.F relating to EFTs other than Card transactions shall apply to My
Account whether or not I am enrolled in Cash Management.
I understand that My Account may be eligible for a variety of EFTs, which may be subject to separate
agreements, terms and conditions. These services may include use of the Card, and the "Move Money"
functionality of the App. I understand that I may be required to agree to separate terms and conditions
governing the particular service I use to initiate EFTs. In addition, I understand and agree that my use of
EFT services are subject to the disclosures set forth in Appendix A (Electronic Fund Transfer
Disclosures), and acknowledge that I have received and reviewed such disclosures.
G. Security.
I agree to protect My Card, and My PINs, from access by anyone not authorized by Me to use them. I
acknowledge that I will be liable for all Card and online transactions conducted by anyone to whom I
have given access or who has obtained access even if not authorized by Me, up to applicable legal
limits. I understand that I am responsible for reviewing My Account statement promptly to discover and
report unauthorized activity, including use of My Card, Card number or PIN. I agree to notify Robinhood
as provided in Appendix A (Electronic Fund Transfer Disclosures) if I believe or have reason to believe
that there has been unauthorized activity in My Account or that My Card, Card number or PIN has been
lost, stolen or may be used by an unauthorized person. Unless limited by law or as otherwise set forth in
this Agreement or in the disclosures contained in Robinhood Debit Card Agreement, which is provided to
Me as part of the Account opening process and is available on the Website, I agree that I will be
responsible for losses that arise from My failure to (i) safeguard My Card and PINs, (ii) review My
monthly statement for possible unauthorized activity and (iii) report any unauthorized activity to
Robinhood as provided herein or in the Robinhood Debit Card Agreement.
H. Disclosure of Information.
I agree and understand that all disclosures of My non-public personal information shall be made in
accordance with the terms of the this Agreement or the Robinhood Privacy Policy (available on the
Website at https://about.robinhood.com/legal/, as applicable. I agree that My consent to sharing non-
public personal information will remain in effect until I revoke such consent by updating My settings and
visibility, which I may do at any time through the App.
In addition, I understand and agree that Robinhood may disclose information about My Account and My
related activities to third parties under the following circumstances: - As necessary to complete My
Payment transactions; - To investigate any complaint, disputed transaction, transaction inquiry or
request I make or as necessary to investigate potential fraud or misuse related to My Account; - To
respond to requests from credit bureaus, creditors or other third parties for account-related information, to
the extent such inquiries are necessary for processing My transactions or are usual and customary in
the course of servicing similar products or accounts; - As necessary to comply with any applicable law,
government or court order or subpoena; or - In accordance with My written permission or as otherwise
permitted under the Robinhood Privacy Policy.
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I. Termination.
I understand that Robinhood may terminate my participation in Cash Management or in specific features
of Cash Management for any reason, upon notice to me.
31. Consent to Redeem Shares.
I understand and agree that whenever it is necessary for Robinhood's protection or to satisfy a margin
call, deficiency, debit or other obligation owed to Robinhood, Robinhood may (but is not required to) sell,
assign and deliver all or any part of the securities in My Account, or close any or all transactions in My
Account. I understand that Robinhood may, but is not obligated to, attempt to contact Me before taking
any such action. I understand and agree that Robinhood reserves the right to take any such action
without prior notice or demand for additional collateral, and free of any right of redemption, and that any
prior demand, call or notice will not be considered a waiver of our right to sell or buy without demand,
call or notice.
I further understand that Robinhood may choose which securities to buy or sell, which transactions to
close, and the sequence and timing of liquidation, and may take such actions on whatever exchange or
market and in whatever manner (including public auction or private sale) that Robinhood chooses in the
exercise of its business judgment. I agree not to hold Robinhood liable for the choice of which securities
to buy or sell or of which transactions to close or for the timing or manner of the liquidation. I also agree
not to hold Robinhood liable for taking such action.
I understand and agree that Robinhood is entitled to exercise the rights described in this section in its
sole discretion, including, but not limited to, whenever any of the following occurs:
The equity level in My Account falls below required minimums;
Sufficient funds or securities are not deposited to pay for transactions in My Account;
I reverse any ACH debit transfer to My Account;
A petition of bankruptcy or for the appointment of a receiver is filed by or against Me;
An attachment is levied against My Account;
I die or become incapacitated or incompetent; or
My Account is closed.
32. Electronic Delivery of Trade and Account Information; Notice.
All communications, notices, legal disclosures, and other materials related to My Account or this
Agreement, including account statements, trade confirmations, margin calls, notices, disclosures,
regulatory communications and other information, documents, data and records regarding My Account
(the "Communications"), or an alert that any such Communication has been posted to the secure section
of the Website or the App, and is available for viewing, may be sent to Me at the mailing address for My
Account or the e-mail address that I have given to Robinhood in My account application or at such other
address as I may hereafter give Robinhood in writing or by e-mail at least ten (10) calendar days prior to
delivery, and all communications so sent, whether in writing or otherwise, shall be deemed given to Me
personally, whether actually received or not.
33. API.
A. Overview; Definitions.
Robinhood may, in Robinhood's sole discretion, provide third parties with an application programming
interface and other materials in accordance with any accompanying documentation (collectively, the "API
Package") (such third parties, "API Licensees"), to make available certain features and functionality of
Robinhood's mobile applications, websites, or technology platform via the API Licensees' products (such
products, the "Licensee Products"). The API Package and the Licensee Products are collectively
referred to as the "API Products". "Personal Information" means My personally identifiable information
(including username, logon password, financial information, trade data, and other financial information)
and all data exchanged between Robinhood and the API Products.
•
•
•
•
•
•
•
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B. Access to My Personal Information.
Through My use of any API Products, I may be providing API Licensees with access to My Account and
Personal Information. By using any API Products, I acknowledge that such API Products may employ
security, policies, procedures and systems of API Licensees which may or may not be less stringent and
secure than Robinhood's policies, procedures and systems. I agree that My use of any API Products
shall be subject to the terms and conditions of this Agreement, in addition to any other agreements
which I executed with respect to any such API Products. I understand and agree that any end user
agreement that I executed with any API Licensee is concluded between Me and such API Licensee only,
and not with Robinhood; and such API Licensee, not Robinhood, is solely responsible for such Licensee
Product and the content thereof. I understand and agree that the API Products may deliver Personal
Information to Robinhood, and that Robinhood is authorized to receive and store such Personal
Information consistent with Robinhood's then-in-effect policies and procedures. Further, I agree that the
API Products may request Personal Information stored by Robinhood, and I consent to Robinhood's
disclosure of such Personal Information to the API Products.
C. No Recommendations.
To the extent the Licensee Products or API Licensees express opinions or make recommendations, I
understand that such opinions and recommendations are expressed solely by API Licensees and are not
the opinions or recommendations of Robinhood. The existence of the API Products and Robinhood's
consent to any connectivity between any Licensee Products and Robinhood's technology, the App, the
Website, or trading platform(s) does not constitute (i) any recommendation by Robinhood to invest in any
security or utilize any investment strategy; or (ii) any representation, warranty, or other guarantee by
Robinhood as to the present or future value or suitability of any sale, trade, or other transaction involving
any particular security or any other investments. The existence of any and all information, tools and
services provided by API Licensees or by the Licensee Products shall not constitute Robinhood's
endorsement of API Licensees or the Licensee Products.
D. Data Provided by Robinhood to API.
From time to time, and subject to then-in-effect agreements between Robinhood and API Licensees,
Robinhood may, in its own discretion, make market data feeds received from third parties available via
the API Products. Robinhood does not make any guarantees in regard to such market data feeds.
Furthermore, API Licensees or Licensee Products may make available to Me market data feeds
independent of Robinhood. I am aware that from time to time that there may be discrepancy between the
market data presented on the App or Website and information provided by any API Products due to a
variety of reasons, including the time to update and transmit such data to a mobile application or website
and latency caused by such API Product's or My local environment (such as computer set up,
connection speed, etc.). Robinhood is not responsible for the accuracy of any market data displayed on
any API Products or otherwise made available by API Licensees.
E. Risks; No Liability.
I acknowledge that there may be latency between the time an order (or other Personal Information) is
submitted from the API Products and the time such order or Personal Information is received by
Robinhood. Latency may also affect order modification and order cancellation requests. The time an
order or a request is actually received by Robinhood (including for execution) will be the official time,
including for the purposes of routing the order to the market for execution. In addition, all orders
submitted to Robinhood are subject to order vetting by Robinhood. Orders created and submitted through
any API Products are not vetted until they are received by Robinhood. It is possible that Robinhood may
reject an order placed through any API Products. Robinhood cannot guarantee that any order will be
accepted when such order is routed to the market for execution, and Robinhood cannot guarantee that
notifications and Personal Information provided to Me by Robinhood will be successfully delivered to or
displayed by any API Products.
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Without limiting the generality of any other terms in this Agreement, I agree that:
Robinhood or its Affiliates shall not be liable for any Losses as a result of any issues addressed
in this Section 33 of this Agreement, nor shall Robinhood or its Affiliates be liable for any Losses
realized for technical issues involving any API Products or API Licensee technology or product
offerings (including system outages or downtime).
Robinhood or its Affiliates shall not be responsible for any investment research provided by any
API Licensee or any Licensee Products.
Robinhood or its Affiliates makes no representations, warranties or other guarantees as to the
accuracy, timeliness or efficacy of any market data, information, or other functionality made
available by any API Licensee or any API Products.
F. Intellectual Property.
My use of any API Products will not confer to Me any title, ownership interest or intellectual property
rights that otherwise belongs to Robinhood or any of its affiliates. The API Package, including content, is
protected under U.S. patent, copyright laws, international treaties or conventions, and other laws and will
remain Robinhood's exclusive property, as applicable. Names, logos, and all related product and service
names, design marks, and slogans displayed by or relating to Robinhood or any of its Affiliates or API
Licensees in the context of the API Products shall remain the property of the respective owner, and use
of such property by Robinhood or any API Licensee in marketing or provision of any API Products does
not grant ownership of or entitle Me to use any such name or mark in any manner.
G. User's Representations and Warranties.
I represent and warrant that:
By virtue of utilizing any API Products, I consent to and accept any risk associated with
Robinhood's sharing of Personal Information with any API Licensee and shall not hold Robinhood,
its Affiliates, or their respective officers, directors, or employees responsible for any Losses
resulting from the sharing of such Personal Information.
I agree that My use of any API Products or API Licensee's content, information, technology, or
functionality is at My own risk.
I agree that Robinhood may revoke any API Licensee or API Products' authorization at any time,
for any reason, with or without cause and without prior notice to Me.
34. Electronic Signatures; Modifications to the Agreement.
I agree to transact business with Robinhood electronically. By electronically signing an application for an
Account, I acknowledge and agree that such electronic signature is valid evidence of My consent to be
legally bound by this Agreement and such subsequent terms as may govern the use of Robinhood's
services. The use of an electronic version of any document fully satisfies any requirement that the
document be provided to Me in writing. I accept notice by electronic means as reasonable and proper
notice, for the purpose of any and all laws, rules and regulations. I acknowledge and agree that
Robinhood Financial may modify this Agreement from time to time and I agree to consult the Website
from time to time for the most up-to-date Agreement. The electronically stored copy of this Agreement is
considered to be the true, complete, valid, authentic and enforceable record of the Agreement,
admissible in judicial or administrative proceedings to the same extent as if the documents and records
were originally generated and maintained in printed form. I agree to not contest the admissibility or
enforceability of Robinhood Financial's electronically stored copy of the Agreement.
1.
2.
3.
1.
2.
3.
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35. Margin Accounts.
A. Election.
This numbered section applies to my account to the extent I elect and am approved for a Robinhood
Gold margin account.
B. Margin Trading.
I understand that margin trading involves interest charges and risks, including the potential to lose more
than deposited or the need to deposit additional collateral in a falling market. Before using margin,
customers must determine whether this type of trading strategy is right for them given their specific
investment objectives, experience, risk tolerance, and financial situation. If I have elected to have a
margin Account, I represent that I have read the Margin Disclosure Statement, Day Trading Risk
Disclosure, and FINRA Investor Information. These disclosures contain information on Robinhood's
lending policies, interest charges, and the risks associated with margin accounts.
C. Hypothecation.
Within the limitations imposed by applicable laws, rules and regulations, all securities now or hereafter
held by Robinhood, or carried by Robinhood in any account for Me (either individually or jointly with
others), or deposited to secure same, may from time to time, without any notice, be carried in your
general loans and may be pledged, repledged, hypothecated or re-hypothecated, separately or in
common with other securities for the sum due to you thereon or for a greater sum and without retaining
in your possession or control for delivery a like amount of similar securities. The IRS requires Broker
Dealers to treat dividend payments on loaned securities positions as payments received in lieu of
dividends for 1099 tax reporting purposes. Taxation of substitute dividend payments may be greater than
ordinary on qualified dividends. It is understood, however, that you agree to deliver to Me upon My
demand and upon payment of the full amount due thereon, all securities in such accounts, but without
obligation to deliver the same certificates or securities deposited by Me originally. Any securities in My
margin or short account may be borrowed by you, or lent to others.
D. Interest.
Debit balances in My Accounts shall be charged with interest in accordance with your established
custom, as disclosed to Me in the Customer Information Brochure pursuant to the provisions of the
Securities Exchange Act.
E. Margin.
I agree to maintain in all accounts with Robinhood such positions and margins as required by all
applicable statutes, rules, regulations, procedures and custom, or as you deem necessary or advisable. I
agree to promptly satisfy all margin and maintenance calls.
F. Sales.
I agree to specifically designate any order to sell a security, which I do not own as a short sale, and
understands that Robinhood will mark such order as a short sale. I agree that any order which is not
specifically designated as a short sale is a sale of securities owned by me, and that I will deliver the
securities on or before settlement date, if not already in the account. If I should fail to make such
delivery in the time required, Robinhood is authorized to borrow such securities as necessary to make
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delivery for the sale, and I agree to be responsible for any loss you may thereby sustain, or which you
may sustain as a result of your inability to borrow such securities.
36. Consent to Electronic Delivery of Documents.
A. Consent.
By agreeing to electronic delivery, I am giving My informed consent to electronic delivery of all
Account Documents, as defined below, other than those I have specifically requested to be
delivered in paper form. "Account Documents" include notices, disclosures, current and future account
statements, regulatory communications (such as prospectuses, proxy solicitations, and privacy notices),
trade confirmations, tax-related documents, and any other information, documents, data, and records
regarding My Account, this Agreement (including amendments to this Agreement), and the agreements
and disclosures governing the services delivered or provided to Me by Robinhood Financial, the issuers
of the securities or other property in which I invest, and any other parties. I agree that I can access,
view, download, save, and print any Account Documents I receive via electronic delivery for My records.
B. Electronic Delivery System.
I acknowledge that Robinhood's primary methods of communication with Me include (A) posting
information on the Website, (B) providing information via the App, (C) sending email(s) to My email
address of record, and, to the extent required by law, (D) providing Me with notice(s) that will direct Me
to the App or the Website where I can read and print such information. Unless otherwise required by law,
Robinhood reserves the right to post Account Documents on the Website without providing notice to Me.
Further, Robinhood reserves the right to send Account Documents to My postal or email address of
record, or via the App or Website. I agree that all Account Documents provided to Me in any of the
foregoing manner is considered delivered to Me personally when sent or posted by Robinhood, whether I
receive it or not.
All e-mail notifications regarding Account Documents will be sent to My e-mail address of record. I agree
to maintain the e-mail address that I have provided Robinhood until I provide Robinhood with a new one.
I understand that e-mail messages may fail to transmit promptly or properly, including being delivered to
SPAM folders. I further understand that it is My sole responsibility to ensure that any emails from
Robinhood or its Affiliates are not marked as SPAM. Regardless of whether or not I receive an e-mail
notification, I agree to check the Website regularly to avoid missing any information, including time-
sensitive or otherwise important communication. If I authorize someone else to access the e-mail
account I have provided Robinhood, I agree to tell them to share the Account Documents with Me
promptly, and I accept the risk that they will see My sensitive information. I understand that if I use a
work e-mail address or computing or communications device, My employer or other employees may
have access to the Account Documents.
Additionally, I acknowledge that the Internet is not a secure network and agree that I will not send any
confidential information, including Account numbers or passwords, in any unencrypted e-mails. I also
understand that communications transmitted over the Internet may be accessed by unauthorized or
unintended third parties and agree to hold Robinhood, its Affiliates, and Robinhood and its Affiliates'
respective officers and employees harmless for any such access regardless of the cause.
I agree to promptly and carefully review all Account Documents when they are delivered and notify
Robinhood Financial in writing within five (5) calendar days of delivery if I object to the information
provided (or other such time specified herein). If I fail to object in writing within such time, Robinhood
Financial is entitled to treat such information as accurate and conclusive. I will contact Robinhood to
report any problems with accessing the Account Documents.
C. Costs.
Potential costs associated with electronic delivery of Account Documents may include charges from
Internet access providers and telephone companies, and I agree to bear these costs. Robinhood
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Financial will not charge Me additional online access fees for receiving electronic delivery of Account
Documents.
D. Archival.
Upon My request, I may obtain copies of up to six (6) prior years of account statements, and three (3)
prior years of trade confirmations.
E. Revocation of Consent.
Subject to the terms of this Agreement, I may revoke or restrict My consent to electronic delivery of
Account Documents at any time by notifying Robinhood Financial in writing of My intention to do so. I
also understand that I have the right to request paper delivery of any Account Document that the law
requires Robinhood Financial to provide Me in paper form. Robinhood Financial will not treat My request
for paper copies as a withdrawal of My consent to electronic delivery of Account Documents. I
understand that if I revoke or restrict My consent to electronic delivery of Account Documents or request
paper delivery of same, Robinhood Financial, in its sole discretion, may charge Me a reasonable service
fee for the delivery of any Account Document that would otherwise be delivered to Me electronically,
restrict or close My account, or terminate My access to Robinhood Financial's services. I understand
that neither My revocation or restriction of consent, My request for paper delivery, nor Robinhood
Financial's delivery of paper copies of Account Documents will affect the legal effectiveness or validity
of any electronic communication provided while My consent was in effect.
F. Duration of Consent.
My consent to receive electronic delivery of Account Documents will be effective immediately and will
remain in effect unless and until either I or Robinhood Financial revokes it. I understand that it may take
up to three (3) Business Days to process a revocation of consent to electronic delivery, and that I may
receive electronic notifications until such consent is processed.
G. Hardware and Software Requirements.
I understand that in order to receive electronic deliveries, I must have access to a computer or Mobile
Device with Internet access, a valid e-mail address, and the ability to download such applications as
Robinhood Financial may specify and to which I have access. I also understand that if I wish to
download, print, or save any information I wish to retain, I must have access to a printer or other device
in order to do so.
H. Consent and Representations.
I hereby agree that I have carefully read the above information regarding informed consent to electronic
delivery and fully understand the implications thereof. Additionally, I hereby agree to all conditions
outlined above with respect to electronic delivery of any Account Document. I will maintain a valid e-mail
address and continue to have access to the Internet. If My e-mail address changes, I agree to
immediately notify Robinhood Financial of My new e-mail address in writing.
37. Miscellaneous Provisions.
The following provisions shall also govern this Agreement:
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A. Contact Information.
Robinhood Customer Service may be contacted by visiting support.robinhood.com or by email at
help@robinhood.com.
B. Interpretation.
The heading of each provision hereof is for descriptive purposes only and shall not be (1) deemed to
modify or qualify any of the rights or obligations set forth herein or (2) used to construe or interpret any of
the provisions hereunder. When a reference is made in this Agreement to a Section, such reference shall
be to a Section of this Agreement unless otherwise indicated. Whenever the words "include," "includes"
or "including" are used in this Agreement, they shall be deemed to be followed by the words "without
limitation." The word "or," when used in this Agreement, has the inclusive meaning represented by the
phrase "and/or." Unless the context of this Agreement otherwise requires: (i) words using the singular or
plural number also include the plural or singular number, respectively; and (ii) the terms "hereof,"
"herein," "hereunder" and derivative or similar words refer to this entire Agreement. References to any
law shall be deemed to refer to such law as amended from time to time and to any rules or regulations
promulgated thereunder.
C. Binding Effect; Assignment.
This Agreement shall bind My heirs, assigns, executors, successors, conservators and administrators. I
may not assign this Agreement or any rights or obligations under this Agreement without first obtaining
Robinhood's prior written consent. Robinhood may assign, sell, or transfer My Account and this
Agreement, or any portion thereof, at any time, without My prior consent.
D. Severability.
If any provisions or conditions of this Agreement are or become inconsistent with any present or future
law, rule, or regulation of any applicable government, regulatory or self-regulatory agency or body, or are
deemed invalid or unenforceable by any court of competent jurisdiction, such provisions shall be deemed
rescinded or modified, to the extent permitted by applicable law, to make this Agreement in compliance
with such law, rule or regulation, or to be valid and enforceable, but in all other respects, this Agreement
shall continue in full force and effect.
E. Website Postings.
I agree and understand that Robinhood Financial may post other specific agreements, disclosures,
policies, procedures, terms, and conditions that apply to My use of the App, the Website, or My Account
on the Website ("Website Postings"). I understand that it is My continuing obligation to understand the
terms of the Website Postings, and I agree to be bound by the Web Postings as are in effect at the time
of My use.
F. Entirety of Agreement.
This Agreement, any attachments hereto, other agreements and policies referred to in this Agreement
(including the Website Postings), and the terms and conditions contained in My Account statements and
confirmations, contain the entire agreement between Robinhood and Me and supersede all prior or
contemporaneous communications and proposals, whether electronic, oral, or written, between
Robinhood and Me, provided, however, that any and all other agreements between Robinhood and Me,
not inconsistent with this Agreement, will remain in full force and effect.
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G. Amendment.
Robinhood may at any time amend this Agreement without prior notice to Me. The current version of the
Agreement will be posted on the Website and My continued Account activity after such amendment
constitutes My agreement to be bound by all then-in-effect amendments to the Agreement, regardless of
whether I have actually reviewed them. Continued use of the App, the Website or any other Robinhood
Financial services after such posting will constitute My acknowledgment and acceptance of such
amendment. I agree to regularly consult the Website for up-to-date information about Robinhood
Financial services and any modifications to this Agreement. Robinhood is not bound by any verbal
statements that seek to amend the Agreement.
H. Termination.
Robinhood may terminate this Agreement, or close, deactivate, or block access to My Account at any
time in its sole discretion. I will remain liable to Robinhood for all obligations incurred in My Account,
pursuant to this Agreement, or otherwise, whether arising before or after termination. I may terminate this
Agreement after paying any obligations owed upon written notice. This Agreement survives termination
of My Account.
I. No Waiver; Cumulative Nature of Rights and Remedies.
I understand that Robinhood's failure to insist at any time upon strict compliance with any term
contained in this Agreement, or any delay or failure on Robinhood's part to exercise any power or right
given to Robinhood in this Agreement, or a continued course of such conduct on Robinhood's part, shall
at no time operate as a waiver of such power or right, nor shall any single or partial exercise preclude
any other further exercise. All rights and remedies given to Robinhood in this Agreement are cumulative
and not exclusive of any other rights or remedies to which Robinhood is entitled.
J. International Customers.
The products and services described on the Website are offered only in jurisdictions where they may be
legally offered. Neither the Website nor the App shall be considered a solicitation for or offering of any
investment product or service to any person in any jurisdiction where such solicitation or offering would
be illegal. I understand that Robinhood, in its sole discretion, may accept unsolicited accounts from non-
U.S. residents, depending on the country of residence and other factors. I understand that Robinhood is
based in the United States and that Robinhood accepts only U.S. currency in Robinhood's customer
accounts.
K. Governing Law.
This Agreement and all transactions made in My Account shall be governed by the laws of the State of
California (regardless of the choice of law rules thereof), except to the extent governed by the federal
securities laws, FINRA Rules, and the regulations, customs and usage of the exchanges or market (and
its clearing house) on which transactions are executed.
38. Arbitration.
A. This Agreement contains a pre-dispute arbitration clause. By signing an arbitration agreement,
the parties agree as follows: (1) All parties to this Agreement are giving up the right to sue each
other in court, including the right to a trial by jury, except as provided by the rules of the
arbitration forum in which a claim is filed. (2) Arbitration awards are generally final and binding; a
party's ability to have a court reverse or modify an arbitration award is very limited. (3) The ability
of the parties to obtain documents, witness statements and other discovery is generally more
limited in arbitration than in court proceedings. (4) The arbitrators do not have to explain the
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reason(s) for their award unless, in an eligible case, a joint request for an explained decision has
been submitted by all parties to the panel at least 20 days prior to the first scheduled hearing
date. (5) The panel of arbitrators will typically include a minority of arbitrators who were or are
affiliated with the securities industry. (6) The rules of some arbitration forums may impose time
limits for bringing a claim in arbitration. In some cases, a claim that is ineligible for arbitration
may be brought in court. (7) The rules of the arbitration forum in which the claim is filed, and any
amendments thereto, shall be incorporated into this Agreement. B. Any controversy or claim
arising out of or relating to this Agreement, any other agreement between Me and Robinhood, any
Account(s) established hereunder, any transaction therein, shall be settled by arbitration in
accordance with the rules of FINRA Dispute Resolution, Inc. ("FINRA DR"). I agree to arbitrate
any controversy or claim before FINRA DR in the State of California. C. This agreement to
arbitrate constitutes a waiver of the right to seek a judicial forum unless such a waiver would be
void under the federal securities laws. If I am a foreign national, non-resident alien, or if I do not
reside in the United States, I agree to waive My right to file an action against Robinhood in any
foreign venue. D. No person shall bring a putative or certified class action to arbitration, nor seek
to enforce any pre-dispute arbitration agreement against any person who has initiated in court a
putative class action; or who is a member of a putative class who has not opted out of the class
with respect to any claims encompassed by the putative class action until: (1) the class
certification is denied; or (2) the class is decertified; or (3) the customer is excluded from the
class by the court. Such forbearance to enforce an agreement to arbitrate shall not constitute a
waiver of any rights under this Agreement except to the extent stated herein.
ACCEPTED AND AGREED: I acknowledge that I have read the preceding terms and conditions of this
Agreement, that I understand them and that I hereby manifest my assent to, and my agreement to
comply with, those terms and conditions by accepting this agreement. I ALSO UNDERSTAND THAT
BY ACCEPTING THIS AGREEMENT I HAVE ACKNOWLEDGED THAT THIS AGREEMENT
CONTAINS A PREDISPUTE ARBITRATION CLAUSE IN SECTION 38 HEREIN. I ALSO AGREE (1)
THAT ANY OF MY MARGIN ACCOUNT SECURITIES MAY BE BORROWED BY ROBINHOOD OR
LOANED TO OTHERS; (2) I HAVE RECEIVED OF A COPY OF THIS AGREEMENT AND (3) I HAVE
REVIEWED A COPY OF THE MARGIN DISCLOSURE STATEMENT.
Appendix A
Electronic Fund Transfer Services Disclosures
The following disclosures apply to the use of any EFT services offered by Robinhood, including the
Card, ACH transactions and the Move Money functionality of the App.
Solely for purposes of these disclosures: (i) references to the Bank shall include any financial institution
that issues the Card or provides services in connection with ACH, Move Money or other EFT
transactions; (ii) "you" and "your" mean the owner of the Account; and (iii) "we" and "us" means
Robinhood and the Bank collectively.
1. Your Liability.
Contact Robinhood Customer Service AT ONCE if you believe your Card or PIN has been lost or stolen
or if you believe that an electronic fund transfer has been made without your permission. Telephoning is
the best way of keeping your losses down. You could lose all the Available Funds in your Account (plus
your maximum overdraft line of credit). If you tell Robinhood within 2 business days after you learn of
the loss or theft of your Card or PIN, you can lose no more than $50 if someone used your Card or PIN
without your permission.
If you do NOT tell Robinhood within 2 business days after you learn of the loss or theft of your Card or
PIN, and Robinhood can prove that it could have stopped someone from using your Card or PIN without
your permission if you had told Robinhood, you could lose as much as $500.
Also, if your statement shows transfers that you did not make, including those made by Card or using
your PIN, tell Robinhood at once. If you do not tell Robinhood within sixty (60) days after the statement
was mailed to you, or otherwise made available to you, you may not get back any money you lost after
the sixty (60) days if Robinhood can prove that Robinhood could have stopped someone from taking the
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money if you had told Robinhood in time. If a good reason (such as a long trip or a hospital stay) kept
you from telling Robinhood, Robinhood will extend the time periods.
2. Contact in event of unauthorized transfer.
If you believe your Card or PIN has been lost or stolen, contact Robinhood by emailing
help@robinhood.com.
3. Business Days.
Business Days are Monday through Friday, excluding federal holidays.
4. Transfer Types and Limitations.
You may use your Card to make purchases at any merchant that accepts Mastercard debit cards or
debit cards of other networks in which the Bank participates, and to make ATM withdrawals, in each
case subject to the Available Funds in your Account, the transaction limits described below, and the
other terms and conditions of this Agreement. You acknowledge and agree that the value available to
you for use with the Card is limited to the Available Funds in your Account. So long as you do not
exceed the Available Funds in your Account, you may use the Card to purchase goods or services
wherever the Card is honored, and to obtain cash by initiating cash withdrawal transactions through the
Card from any financial institution or ATM that accepts the Card. Each time you use the Card, you
authorize Robinhood to reduce the Available Funds in your Account by the amount of the purchase or
withdrawal and any applicable fees, costs, or holdings. Nevertheless, if you exceed the Available Funds
in your Account you shall remain fully liable to Robinhood for the amount of the transactions and any
applicable fees and charges.
You may also make ACH withdrawals from your Account, either originated through Robinhood or
originated by a third party (a "non-originated" withdrawal), subject to the Available Funds in your Account,
the transaction limits described below, and the other terms and conditions of this Agreement. You also
may make ACH deposits to your Account, either originated through Robinhood or originated by a third
party (a "non-originated" deposit), subject to the transaction limits described below.
There are limits on the dollar amount of transactions you can make with your Card each day and each
month, and limits on the amount of ACH withdrawals and deposits you can make each day. The
following lists the limits for each type of transaction:
Originated ACH Withdrawals* Daily Limit: $50,000.00
Weekly Limit: N/A Monthly Limit: N/A
Originated ACH Deposits* Daily Limit: $50,000.00
Weekly Limit: N/A Monthly Limit: N/A
Non-Originated ACH Withdrawals* Daily Limit: $250,000.00
Weekly Limit: N/A Monthly Limit: N/A
Non-Originated ACH Deposits* Daily Limit: $250,000.00
Weekly Limit: N/A Monthly Limit: N/A
Point of Sale Purchases with the Card* Daily Limit: $5,000.00 Weekly Limit: N/A Monthly Limit:
$15,000.00
ATM Withdrawals* Daily Limit: $510.00 Weekly Limit: N/A Monthly Limit: $5,000.00
Originated ACH* Daily Limit: N/A, subject to the Weekly Limit Weekly Limit: $2,999 Monthly Limit: N/A
30
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5. Fees.
We will not charge you any fees for use of ATMs that are part of the AllPoint or MoneyPass ATM
networks, or for point of sale transactions using the Card, or for initiating other EFTs on your behalf. If
you withdraw funds from ATMs outside of the AllPoint or MoneyPass ATM networks, you may be
separately assessed fees by those ATM owners or operators.
6. Confidentiality.
We may disclose information to third parties about you, your Card, or the transactions you make using
any of the EFT services we provide:
Where it is necessary or helpful for completing or correcting transactions and resolving claims
regarding transactions;
In order to verify the existence and condition of your Card or your Account for a third party, such
as a merchant;
In order to comply with a valid request by a government agency, a court order, or other legal or
administrative reporting requirements;
If you consent by giving us your written permission;
To our employees, auditors, affiliates, service providers, or attorneys as needed;
In order to prevent, investigate or report possible illegal activity;
In order to issue authorizations for transactions on the Card;
As permitted by applicable law; or
Otherwise as necessary to fulfill our obligations under this Agreement and the terms applicable to
the EFT service you are using.
Please see Robinhood's privacy policy, available at about.robinhood.com/legal, and the applicable
Bank's privacy policy, available at https://www.suttonbank.com/_/kcms-doc/85/49033/WK-Privacy-
Disclosure-1218.pdf, for further details. (The Robinhood privacy policy and the applicable Bank's privacy
policy are referred to collectively as the "Privacy Policies"). You hereby agree to Robinhood's and the
Bank's collection, use and sharing of information about you and the Card as provided in the Privacy
Policies, which are made a part of this Agreement. The Privacy Policies also tell you how you can (i)
limit the ways in which Bank and Robinhood share information about you, or (ii) request corrections to
the information that Bank or Robinhood maintain about you. You agree that information you provide in
connection with your Card or other EFT services you use is being provided directly to both Robinhood as
the holder of the Account associated with the service and the Bank as the Card issuer or provider of the
EFT service, as applicable.
7. Documentation.
Terminal Transfers. You can get a receipt at the time you make any transfer to or from your Account
using an ATM from the AllPoint or MoneyPass ATM networks or at the point of sale.
Preauthorized Credits. If you have arranged to have direct deposits made to your Account at least once
every 60 days from the same person or company, the person or company making the deposit will tell you
every time they send us the money. You can also check your Account online to see if a deposit has been
received.
Periodic Statements. You will get a monthly Account statement, unless there are no transfers in a
particular month. In any case you will get the statement at least quarterly. You may obtain information
about the Available Funds in your Account and a history of your Cash Management transactions on the
App.
1.
2.
3.
4.
5.
6.
7.
8.
9.
31
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8. Preauthorized Payments/Stop Payment Procedure and Notice of Varying
Amounts.
You do not have the right to request that Robinhood in advance make regular payments out of your
Account, although you may ask third parties to initiate regular payments out of your Account.
Right to stop payment: If you have automatic recurring payments taken out of your Account, you can
stop any of these payments by contacting us at help@robinhood.com. You must contact us in time for
us to receive your request at least three business days before the payment is scheduled to be made.
Notice of varying amounts: If these regular payments vary in amount, the party you are going to pay will
tell you, 10 days before each payment, when the payment will be made and how much it will be. (The
party you are going to pay may allow you to choose to get this notice only when the payment would
differ by more than a certain amount from the previous payment, or when the amount would fall outside
certain limits that you set.)
Liability for failure to stop payment of a preauthorized transfer: If you order us to stop a payment at least
three business days before the transfer is scheduled and we do not do so, we will be liable for your
losses or damages.
9. Our Liability.
If we do not complete a transaction to or from your Account on time or in the correct amount according
to our Agreement with you, we will be liable for your losses or damages. However, there are some
exceptions. We will not be liable, for instance:
If through no fault of Robinhood or the Bank, you do not have enough Available Funds in your
Account to complete the transaction;
If a merchant refuses to accept your Card;
If an electronic terminal where you are making a transaction does not operate properly, and you
knew about the problem when you initiated the transaction;
If access to your Card has been blocked after you reported your Card lost or stolen;
If there is a hold or your funds are subject to legal or administrative process or other encumbrance
restricting their use;
If Robinhood or the Bank have reason to believe the requested transaction is unauthorized;
If circumstances beyond the control of Robinhood or the Bank (such as fire, flood, or computer or
communication failure) prevent the completion of the transaction, despite reasonable precautions
that Robinhood or the Bank have taken; or
For any other exception stated in this Agreement with you or by applicable law.
10. Errors or Questions About Electronic Transfers.
In case of errors or questions about your electronic transfers, including your Card transactions, or if you
think your statement or receipt is wrong or if you need more information about a transaction listed on the
statement or receipt, telephone Robinhood at the Robinhood customer service number listed in Section 2
of this Appendix A. Robinhood must hear from you no later than sixty (60) days after you were sent the
FIRST statement on which the problem or error appeared.
Tell Robinhood your name and account number.
1.
2.
3.
4.
5.
6.
7.
8.
1.
32
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Describe the error or the transfer you are unsure about, and explain as clearly as you can why
you believe it is an error or why you need more information.
Tell Robinhood the dollar amount of the suspected error.
Robinhood will determine whether an error occurred within ten (10) business days after Robinhood hears
from you and will correct any error promptly. If Robinhood needs more time, however, it may take up to
forty-five (45) days to investigate your complaint or question. If Robinhood decides to do this, Robinhood
will credit your Account within ten (10) business days for the amount you think is in error, so that you will
have the use of the money during the time it takes Robinhood to complete our investigation.
For errors involving new accounts, point of sale, or foreign initiated transactions, Robinhood may take up
to ninety (90) days to investigate your complaint or question. For new accounts, Robinhood may take up
to twenty (20) business days to credit your Account for the amount you think is in error.
Robinhood will tell you the results of our investigation within three (3) business days after completing the
investigation. If Robinhood decides that there was no error, Robinhood will send you a written
explanation. You may ask for copies of the documents that Robinhood used in our investigation.
2.
3.
33
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Exhibit 6

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Revised February 5, 2020
Robinhood Financial LLC & Robinhood Securities, LLC
Customer Agreement
In consideration of Robinhood Financial LLC, Robinhood Securities, LLC, and their agents and
assigns (collectively, “Robinhood”) opening one or more accounts on my behalf (“My Account(s)”
or the “Account(s)”) for the purchase, sale or carrying of securities or contracts relating thereto
and/or the borrowing of funds, which transactions are cleared through Robinhood Securities, I
represent and agree with respect to all Accounts, whether margin or cash, to the terms set forth
below (the “Agreement”). When used in this Agreement, the words “I”, “Me”, “My”, “We”, or
“Us” mean the owner(s) of the Account. For purposes of this Agreement, Business Days are
Monday through Friday, excluding federal holidays. Any references to “days” found in this
Agreement are calendar days unless indicated otherwise.
I UNDERSTAND THAT THE TERMS AND CONDITIONS OF THIS AGREEMENT
GOVERN ALL ASPECTS OF MY RELATIONSHIP WITH ROBINHOOD REGARDING
MY ACCOUNTS. I WILL CAREFULLY READ, UNDERSTAND AND ACCEPT THE
TERMS AND CONDITIONS OF THIS AGREEMENT BEFORE I CLICK “SUBMIT
APPLICATION” OR OTHER SIMILARLY WORDED BUTTON. IF I HAVE ANY
QUESTIONS ABOUT ANY OF THE PROVISIONS IN THIS AGREEMENT, I WILL
EMAIL HELP@ROBINHOOD.COM. I UNDERSTAND THAT CLICKING “SUBMIT
APPLICATION” IS THE LEGAL EQUIVALENT OF MY MANUALLY SIGNING THIS
AGREEMENT AND I WILL BE LEGALLY BOUND BY ITS TERMS AND
CONDITIONS. BY ENTERING INTO THIS AGREEMENT, I ACKNOWLEDGE
RECEIPT OF THE ROBINHOOD PRIVACY POLICY AND PRIVACY AND SECURITY
STATEMENT. I UNDERSTAND THAT THIS AGREEMENT MAY BE AMENDED
FROM TIME TO TIME BY ROBINHOOD, WITH REVISED TERMS POSTED ON THE
ROBINHOOD WEBSITE. I AGREE TO CHECK FOR UPDATES TO THIS
AGREEMENT. I UNDERSTAND THAT BY CONTINUING TO MAINTAIN MY
SECURITIES BROKERAGE ACCOUNT WITHOUT OBJECTING TO ANY REVISED
TERMS OF THIS AGREEMENT, I AM ACCEPTING THE TERMS OF THE REVISED
AGREEMENT AND I WILL BE LEGALLY BOUND BY ITS TERMS AND
CONDITIONS. IF I REQUEST OTHER SERVICES PROVIDED BY ROBINHOOD
THAT REQUIRE ME TO AGREE TO SPECIFIC TERMS AND CONDITIONS
ELECTRONICALLY (THROUGH CLICKS OR OTHER ACTIONS) OR OTHERWISE,
SUCH TERMS AND CONDITIONS WILL BE DEEMED AN AMENDMENT AND WILL
BE INCORPORATED INTO AND MADE PART OF THIS AGREEMENT. I ALSO
UNDERSTAND
THAT
BY
CLICKING
“SUBMIT
APPLICATION”
I
HAVE
ACKNOWLEDGED THAT THIS AGREEMENT CONTAINS A PREDISPUTE
ARBITRATION CLAUSE IN SECTION 37 HEREIN.
1.
Capacity and Status. If an individual, I am of legal age under the laws of the state where
I reside and authorized to enter into this Agreement. If an entity, I am duly formed, validly
existing and in good standing in My state of organization, have full power and authority to
enter and perform this Agreement, and the persons signing the account application are fully
authorized to act on My behalf. No person, except Myself, has any interest in the Account
1
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opened pursuant to this Agreement. I acknowledge that unless Robinhood receives written
objection from Me, Robinhood may provide My name, address, and securities positions to
requesting companies in which I hold securities. Except as otherwise disclosed to
Robinhood in writing, neither I nor any member of My immediate family is an employee
of any exchange, any corporation of which any exchange owns a majority of the capital
stock, a member of any exchange or self-regulatory organization, a member of any firm or
member corporation registered on any exchange, a bank, trust company, insurance
company or any corporation, firm or individual engaged in the business of dealing either
as a broker-dealer or as principal in securities. I understand and agree that I am obligated
to promptly notify Robinhood in writing if I or a member of My immediate family becomes
registered or employed in any of the above-described capacities. Except as otherwise
disclosed to Robinhood in writing, I am not a Professional (as defined below). I further
agree to promptly notify Robinhood in writing if I am now or if I become a Professional or
an officer, director or 10% stockholder of any publicly traded company.
2.
Market Data. Robinhood may choose to make certain market data available to Me
pursuant to the terms and conditions set forth in this Agreement. By executing this
Agreement, I agree to comply with those terms and conditions.
A.
Definitions.
1)
“Market Data” means (a) last sale information and quotation information
relating to securities that are admitted to dealings on the New York Stock
Exchange (“NYSE”), (b) such bond and other equity last sale and quotation
information, and such index and other market information, as United States-
registered national securities exchanges and national securities associations
(each, an “Authorizing SRO”) may make available and as the NYSE may
from time to time designate as “Market Data”; and (c) all information that
derives from any such information.
2)
“Nonprofessional” means any natural person who receives market data
solely for his/her personal, non- business use and who is not a
“Professional.” A “Professional” includes an individual who, if working in
the United States, is: (i) registered or qualified with the Securities and
Exchange Commission (the “SEC”), the Commodity Futures Trading
Commission (the “CFTC”), any state securities agency, any securities
exchange or association, or any commodities or futures contract market or
association; (ii) engaged as an “investment advisor” as that term is defined
in Section 202 (a) (11) of the Investment Advisers Act of 1940 (whether or
not registered or qualified under that Act), or (iii) employed by a bank or
other organization exempt from registration under federal and/or state
securities laws to perform functions that would require him or her to be so
registered or qualified if he or she were to perform such functions for an
organization not so exempt. A person who works outside of the United
States will be considered a “Professional” if he or she performs the same
functions as someone who would be considered a “Professional” in the
United States.
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B.
Provisions Applicable to All Users.
1)
Proprietary Nature of Data. I understand and acknowledge that each
Authorizing SRO and Other Data Disseminator (as defined below) has a
proprietary interest in the Market Data that originates on or derives from it
or its market(s). I agree not to reproduce, distribute, sell or commercially
exploit the Market Data in any manner.
2)
Enforcement. I understand and acknowledge that (a) the Authorizing SROs
are third-party beneficiaries under this Agreement and (b) the Authorizing
SROs or their authorized representative(s) may enforce this Agreement, by
legal proceedings or otherwise, against Me or any person that obtains
Market Data that is made available pursuant to this Agreement other than
as this Agreement contemplates.
3)
Data Not Guaranteed. I understand that neither Robinhood nor any
Authorizing SRO, other entity whose information is made available over
the Authorizing SROs’ facilities (an “Other Data Disseminator”), or
information processor that assists any Authorizing SRO or Other Data
Disseminator in making Market Data available (collectively, the
“Disseminating Parties”) guarantees the timeliness, sequence, accuracy,
completeness, reliability, or content of Market Data or of other market
information or messages disseminated to or by any Disseminating Party. I
understand that neither Robinhood Financial nor any Disseminating Party
guarantees the timeliness, sequence, accuracy, completeness, reliability or
content of market information, or messages disseminated to or by any party.
I understand that neither Robinhood Financial nor any Disseminating Party
warrants that the service provided by any such entity will be uninterrupted
or error-free. I further understand that Market Data by Xignite provides
market data to Robinhood Financial customers. NEITHER ROBINHOOD
FINANCIAL, ANY OF ITS AFFILIATES, THEIR RESPECTIVE
OFFICERS OR EMPLOYEES, NOR ANY DISSEMINATING PARTY
SHALL BE LIABLE IN ANY WAY FOR (A) ANY INACCURACY,
ERROR OR DELAY IN, OR OMISSION OF, (I) ANY MARKET DATA,
INFORMATION OR MESSAGE, OR (II) THE TRANSMISSION OR
DELIVERY OF ANY SUCH DATA, INFORMATION OR MESSAGE;
OR (B) ANY LOSS (AS DEFINED IN THIS AGREEMENT) OR
DAMAGE ARISING FROM OR OCCASIONED BY (I) ANY SUCH
INACCURACY, ERROR, DELAY OR OMISSION, (II) NON-
PERFORMANCE OR III) INTERRUPTION IN ANY SUCH MARKET
DATA, INFORMATION, OR MESSAGE, WHETHER DUE TO ANY
ACT OR OMISSION BY ROBINHOOD FINANCIAL, ANY OF ITS
AFFILIATES, THEIR RESPECTIVE OFFICERS OR EMPLOYEES, OR
ANY DISSEMINATING PARTY, OR TO ANY “FORCE MAJEURE”
(E.G., FLOOD, EXTRAORDINARY WEATHER CONDITIONS,
EARTHQUAKE
OR
OTHER
ACT
OF
GOD,
FIRE,
WAR,
INSURRECTION, RIOT, LABOR DISPUTE, ACCIDENT, ACTION OF
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GOVERNMENT, OR COMMUNICATIONS OR POWER FAILURE,
EQUIPMENT OR SOFTWARE MALFUNCTION) OR ANY OTHER
CAUSE BEYOND THE REASONABLE CONTROL OF ROBINHOOD
FINANCIAL, ITS AFFILIATES, THEIR RESPECTIVE OFFICERS AND
EMPLOYEES, OR ANY DISSEMINATING PARTY.
4)
Permitted Use. I shall not furnish Market Data to any other person or entity.
If I receive Market Data other than as a Nonprofessional, I shall use Market
Data only for My individual use.
5)
Dissemination, Discontinuance, or Modification. I understand and
acknowledge that, at any time, the Authorizing SROs may discontinue
disseminating any category of Market Data, may change or eliminate any
transmission method and may change transmission speeds or other signal
characteristics. The Authorizing SROs shall not be liable for any resulting
liability, loss or damages that may arise therefrom.
6)
Duration; Survival. This Section 2 of this Agreement remains in effect for
so long as I have the ability to receive Market Data as contemplated by this
Section 2. In addition, Sections 2(B)(1)-(3) and the first two sentences of
Section 2(B)(7), survive any termination of this Agreement.
7)
Miscellaneous. The laws of the State of New York shall govern this Section
2 and it shall be interpreted in accordance with those laws. This Subsection
is subject to the Securities Exchange Act of 1934, the rules promulgated
under that act, and the joint-industry plans entered into pursuant to that act.
C.
Provisions Applicable to Nonprofessionals.
1)
Permitted Receipt. I understand that I may not receive Market Data from
Robinhood as a Nonprofessional, and Robinhood may not provide Market
Data to Me as a Nonprofessional, unless Robinhood first properly
determines that I qualify as a Nonprofessional as defined above and I in fact
qualify as a Nonprofessional. I agree that, as a prerequisite to Robinhood
Financial qualifying Me as a Nonprofessional, I will provide to Robinhood
truthful and accurate information about Me, such as: my occupation,
employer, employment position and functions; my use of Market Data; my
registration status with any securities agency, exchange, association, or
regulatory body, or any commodities or future contract market, association,
or regulatory body, whether in the United States or elsewhere; and any
compensation of any kind I may receive from any individual or entity for
my trading activities, asset management, or investment advice. Except as
otherwise declared to Robinhood in writing, by executing this Agreement,
I certify that I meet the definition of Nonprofessional as set forth in this
Agreement.
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2)
Permitted Use. If I am a Nonprofessional, I agree to receive Market Data
solely for my personal, non-business use.
3)
Notification. I shall notify Robinhood promptly in writing of any change in
my circumstances that may cause Me to cease to qualify as a
Nonprofessional.
3.
NASDAQ OMX Information.
A.
Definitions.
1)
“Information” means certain market data and other data disseminated that
has been collected, validated, processed, and recorded by any system
NASDAQ OMX has developed for the creation or dissemination of
Information or other sources made available for transmission to and receipt
from either a distributor such as RHF or from NASDAQ OMX relating to:
a) eligible securities or other financial instruments, markets, products,
vehicles, indicators, or devices; b) activities of a NASDAQ OMX company;
c) other information and data from a NASDAQ OMX company.
“Information” also includes any element of Information as used or
processed in such a way that the Information can be identified, recalculated
or re-engineered from the processed Information or that the processed
Information can be used as a substitute for Information.
2)
“NASDAQ OMX” means The NASDAQ OMX Group, Inc., a Delaware
limited liability company and its subsidiaries and Affiliates (collectively,
“NASDAQ OMX”).
B.
Use of Data. I understand that I may use the Information only for personal use and
not for any business purpose. I may not sell, lease, furnish or otherwise permit or
provide access to the Information to any other natural person or entity (“Person”)
or to any other office or place. I will not engage in the operation of any illegal
business use or permit anyone else to use the Information, or any part thereof, for
any illegal purpose or violate any NASDAQ OMX or SEC Rule or any FSA rule
or other applicable law, rule or regulation. I may not present the Information
rendered in any unfair, misleading or discriminatory format. I shall take reasonable
security precautions to prevent any Person other than Myself from gaining access
to the Information.
C.
Proprietary Data. I acknowledge and agree that NASDAQ OMX has proprietary
rights to the Information that originates on or derives from markets regulated or
operated by NASDAQ OMX, and compilation or other rights to Information
gathered from other sources. I further acknowledge and agree that NASDAQ
OMX’s third-party information providers have exclusive proprietary rights to their
respective Information. In the event of any misappropriation or misuse by Me or
anyone who accesses the Information through Me, NASDAQ OMX or its third-
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party information providers shall have the right to obtain injunctive relief for its
respective materials.
D.
System. I acknowledge that NASDAQ OMX, in its sole discretion, may from time-
to-time make modifications to its system or the Information. Such modifications
may require corresponding changes to be made in Robinhood Financial’s service.
Changes or the failure to make timely changes by Me may sever or affect My access
to or use of the Information. I understand that neither NASDAQ OMX nor
Robinhood shall be responsible for such effects.
E.
NASDAQ OMX Limitation of Liability. Except as may otherwise be set forth
herein, NASDAQ OMX shall not be liable to Me for indirect, special, punitive,
consequential or incidental loss or damage (including, but not limited to, trading
losses, lost profits, or other indirect loss or damage) of any nature arising from any
cause whatsoever, even if NASDAQ OMX has been advised of the possibility of
such damages. NASDAQ OMX shall not be liable to Me for any unavailability,
interruption, delay, incompleteness or inaccuracy of the Information. This Section
shall not relieve NASDAQ OMX or Me from liability for damages that result from
their own gross negligence or willful tortious misconduct or from personal injury
or wrongful death claims. I agree that the terms of this Section reflect a reasonable
allocation of risk and limitation of liability.
F.
Disclaimers of Warranties. NASDAQ OMX and its third-party information
providers make no warranties of any kind with respect to the Information—express,
implied or statutory (including without limitation, timeliness, truthfulness,
sequence, completeness, accuracy, freedom from interruption), any implied
warranties arising from trade usage, course of dealing, course of performance or
the implied warranties of merchantability or fitness for a particular use or purpose
or noninfringement.
G.
Termination by NASDAQ OMX. I acknowledge that NASDAQ OMX, when
required to do so in fulfillment of statutory obligations, may by notice to Robinhood
unilaterally limit or terminate the right of any or all Persons to receive or use the
Information and that Robinhood will comply with any such notice and will
terminate or limit the furnishing of the Information.
4.
Authorization. I understand that My Account is self-directed. Accordingly, I appoint
Robinhood Financial as My agent for the purpose of carrying out My directions to
Robinhood Financial in accordance with the terms and conditions of this Agreement and
any attendant risks with respect to the purchase or sale of securities. Robinhood Financial
is authorized to open or close My Account(s), place and withdraw orders and take such
other steps as are reasonable to carry out My directions. All transactions will be effected
only on My order or the order of My authorized delegate, except as described in Section
10. I understand Robinhood Financial provides trading and brokerage services through the
Robinhood website (the “Website”) and the Robinhood mobile application (the “App”). I
agree to receive and transmit financial information through such electronic means. My use
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or My grant of access to My Account to any third party to access information or place
transactions in My Account is solely at My risk.
5.
Customer Representations and Responsibilities.
(A)
Self-directed Account. I understand that My Account is self-directed, and so that I
am solely responsible for any and all orders placed in My Account and that all
orders entered by Me or on My behalf are unsolicited and based on My own
investment decisions or the investment decision of My duly authorized
representative or agent. Accordingly, I agree that neither Robinhood nor any of its
employees, agents, principals, or representatives:
1)
provide investment advice in connection with this Account;
2)
recommend any security, transaction or order;
3)
solicit orders;
4)
act as a market maker in any security;
5)
make discretionary trades; and
6)
produce or provide first-party research providing a specific investment
strategies such as buy, sell or hold recommendations, first-party ratings
and/or price targets. To the extent research materials or similar information
are available through the App or the Website or the websites of any entity
controlled by, controlling, or under common control with Robinhood (such
entity, an “Affiliate”), I understand that these materials are intended for
informational and educational purposes only and they do not constitute a
recommendation to enter into any securities transactions or to engage in any
investment strategies.
(B)
Information Accuracy. I: (i) certify that the information contained in this
Agreement, the account application, and any other document that I furnish to
Robinhood Financial in connection with My Account(s) is complete, true and
correct, and acknowledge that knowingly giving false information for the purpose
of inducing Robinhood Financial to extend credit is a federal crime; (ii) authorize
Robinhood Financial to contact any individual or firm noted herein or on the
documents referred to in subsection (i) of this Section and any other normal sources
of debit or credit information; (iii) authorize anyone so contacted to furnish such
information to Robinhood Financial as Robinhood may request; and (iv) agree that
this Agreement, the account application and any other document I furnish in
connection with My Account is Robinhood’s property, as the case may be. I shall
promptly advise Robinhood Financial of any changes to the information in such
agreements and documents in writing within ten (10) calendar days. I authorize
Robinhood Financial to obtain reports and provide information to others concerning
My creditworthiness and business conduct. Upon My request, Robinhood agrees
to provide Me a copy of any report so obtained. Robinhood may retain this
Agreement, the Account application, and all other such documents and their
respective records at Its sole discretion, whether or not credit is extended.
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(C)
Risks. I understand that all investments involve risk, that losses may exceed the
principal invested, and that the past performance of a security, industry, sector,
market, or financial product does not guarantee future results or returns.
(D)
Account Defaults. I understand that My Account comes with many defaulted
service instruction features and preferences. I further understand that I am not
required to use these defaulted options or preferences and that once My Account is
approved and opened I have the sole discretion to control and adjust such defaulted
service preferences that relate to My account.
(E)
Knowledge of Account. I understand that I am solely responsible for knowing the
rights and terms for all securities purchased, sold and maintained in My Account
including mergers, reorganizations, stock splits, name changes or symbol changes,
dividends, option symbols, and option deliverables. I further understand that
certain securities may grant Me valuable rights that may expire unless I take
specific action. These securities include bonds, convertible securities, warrants,
stock rights and securities subject to exchange offers or tenders. I am responsible
for knowing all expiration dates, redemption dates, and the circumstances under
which rights associated with My securities may be called, cancelled, or modified.
Robinhood may, but are not obligated to, notify Me of any upcoming expiration or
redemption dates, or take any action on My behalf without My specific instructions
except as required by law and the rules of regulatory authorities. I acknowledge
that Robinhood may adjust My Account to correct any error. If My Account has
an option position on the last trading day prior to expiration, which is one cent or
more in the money, Robinhood Financial will generally exercise the option, on My
behalf. However, Robinhood Financial reserves the right at Its discretion to close
any option position prior to expiration date or any position resulting from the
exercising/assignment after option expiration. I will be charged a commission for
any such transaction. Robinhood Financial is not obligated to take any of these
actions and Robinhood Financial is not liable for Losses should it not take them.
(F)
Purchases. All orders for the purchase of securities given for My Account will be
authorized by Me and executed in reliance on My promise that an actual purchase
is intended. It is My obligation to pay for purchases immediately or on
Robinhood’s demand. I understand Robinhood may at any time, in its sole
discretion and without prior notice to Me, prohibit or restrict My ability to trade
securities. I further agree not to allow any person to trade for My Account unless
a trading authorization for that person has been received and approved by
Robinhood. Robinhood reserve the right to require full payment in cleared funds
prior to the acceptance of any order. In the event that I fail to provide sufficient
funds, Robinhood may, at its option and without notice to Me, i) charge a
reasonable rate of interest, ii) liquidate the Property subject of the buy order, or iii)
sell other Property owned by Me and held in any of My Accounts. Robinhood may
also charge any consequential Loss to My Account. For purposes of this
Agreement, “Property” shall mean all monies, contracts, investments and options,
whether for present or future delivery, and all related distributions, proceeds,
products and accessions.
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(G)
Sales/Short Sales. I promise to deliver all securities sold in My Account and to
provide collateral of a type and amount acceptable to Robinhood Financial for all
short sales in My Account. Robinhood Financial requires that a security be held in
My Account prior to the acceptance of a sell order with respect to such security
unless the order is specifically designated as a “short sale.” If a security is not held
in My Account and a sell order is processed, I must promptly deliver such security
to Robinhood Financial for receipt in good deliverable form on or before the
settlement date. Any order accepted without negotiable certificates or positions in
My Account will be subject, at Robinhood Financial’s sole discretion, to
cancellation or buy-in. To ensure this will not occur, I agree to only place sell
orders for securities owned by Me and held in My Account at the time My order is
placed.
Proceeds of a sale will not be paid to Me or released into My Account until
Robinhood Financial has received the security in good deliverable form, whether
from a transfer agent or from Me and the settlement of the security is complete. If
the security is not received on or before settlement date, or as market conditions
warrant, Robinhood Financial may in its sole discretion purchase the security on
the open market for My Account and may liquidate and close out any and all
securities in My Account in order to pay for such purchase. In the event a security
is bought in, I will be responsible for all resulting Losses incurred by Robinhood
Financial.
I understand that I may execute short sales only in a margin Account and that such
execution must comply with applicable short sales rules.
(H)
Assistance by Robinhood. I understand that when I request assistance from
Robinhood or its employees in using the investment tools available on the Website
or the App, it will be limited to an explanation of the tool’s functionality and, if
requested by Me, to the entry by Robinhood or its employees of variables provided
by Me, and that such assistance does not constitute investment advice, an opinion
with respect to the suitability of any transaction, or solicitation of any orders.
(I)
No Tax or Legal Advice. I understand that Robinhood does not provide tax or legal
advice.
(J)
Discontinuation of Services. I understand that Robinhood may discontinue My
Account and any services related to My Account immediately by providing written
notice to Me
(K)
Electronic Access.
1)
I am solely responsible for keeping My Account numbers and PINs
confidential and will not share them with third parties. “PINs” shall mean
My username and password.
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2)
I agree and accept full responsibility for monitoring and safeguarding My
Accounts and access to My Accounts.
3)
I agree to immediately notify Robinhood in writing, delivered via e-mail
and a recognized international delivery service, if I become aware of: (i) any
loss, theft, or unauthorized use of My PINs or Account numbers; (ii) any
failure by Me to receive any communication from Robinhood indicating
that an order was received, executed or cancelled, as applicable; (iii) any
failure by Me to receive an accurate written confirmation of an order,
execution, or cancellation; (iv) any receipt by Me of confirmation of an
order, execution or cancellation, which I did not place; (v) any inaccurate
information in or relating to My orders, trades, margin status, Account
balances, deposits, withdrawals, securities positions or transaction history;
or (vi) any other unauthorized use or access of My Account.
4)
Each of the events described in subsections (K)(3)(i)-(vi) shall be deemed a
“Potential Fraudulent Event”. The use and storage of any information
including My Account numbers, PINs, portfolio information, transaction
activity, account balances and any other information or orders available on
My wireless, web-enabled cellular telephone or similar wireless
communications device (collectively, “Mobile Device”) or My personal
computer is at My own risk and is My sole responsibility. I represent that I
am solely responsible for and have authorized any orders or instructions
appearing in, originating from, or associated with My Account, My Account
number, My username and password, or PINs. I agree to notify Robinhood
immediately after I discover any Potential Fraudulent Event, but in no event
more than twenty-four (24) hours following discovery. Upon request by
Robinhood, I agree to report any Potential Fraudulent Event promptly to
legal authorities and provide Robinhood a copy of any report prepared by
such legal authorities. I agree to cooperate fully with the legal authorities
and Robinhood in any investigation of any Potential Fraudulent Event and
I will complete any required affidavits promptly, accurately and thoroughly.
I also agree to allow Robinhood access to My Mobile Device, My computer,
and My network in connection with Robinhood’s investigation of any
Potential Fraudulent Event. I understand that if I fail to do any of these
things I may encounter delays in regaining access to the funds in My
Account. I agree to indemnify and hold Robinhood, its Affiliates, and
Robinhood and its Affiliates’ respective officers, directors, and employees
harmless from and against any Losses arising out of or relating to any
Potential Fraudulent Event. I acknowledge that Robinhood does not know
when a person entering orders with My username and password is Me.
5)
Trusted Contact Person. I understand that, pursuant to FINRA regulations,
Robinhood is authorized to contact the Trusted Contact Person (as defined
by FINRA Rule 4512) designated for My Account and to disclose
information about My account to address possible financial exploitation, to
confirm the specifics of My current contact information, health status, or
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the identity of any legal guardian, executor, trustee or holder of a power of
attorney, or as otherwise permitted by Rule 2165.
6.
Clearance of Trades. I understand that Robinhood Financial has entered into a clearing
agreement with Robinhood Securities whereby Robinhood Financial will introduce My
Account to Robinhood Securities, and Robinhood Securities will clear all transactions, on
a fully-disclosed basis. I understand that Robinhood Securities carries My Account(s) and
is responsible for the clearing and bookkeeping of transactions, but is not otherwise
responsible for the conduct of Robinhood Financial.
Until receipt from Me of written notice to the contrary, Robinhood Securities may accept
from Robinhood Financial, without inquiry or investigation, (i) orders for the purchase or
sale of securities and other property on margin, if I have elected to have a margin account,
or otherwise, and (ii) any other instructions concerning my Accounts. Robinhood
Securities shall look solely to Robinhood Financial unless otherwise directed by
Robinhood Financial, and not to Me, with respect to any such orders or instructions; except
that I understand that Robinhood Securities will deliver confirmations, statements, and all
written or other notices with respect to My Account directly to Me with copies to
Robinhood Financial, and that Robinhood Securities will look directly to Me or Robinhood
Financial for delivery of margin, payment, or securities. I agree to hold Robinhood
Securities harmless from and against any Losses arising in connection with the delivery or
receipt of any such communication(s), provided Robinhood Securities has acted in
accordance with the above. The foregoing shall be effective as to My Account(s) until
written notice to the contrary is received from Me by Robinhood Securities or Robinhood
Financial.
7.
Review of Confirmations and Statements. I agree that it is My responsibility to review
order execution confirmations and statements of My Account(s) promptly upon receipt. I
agree to receive all confirmations and account statements, as well as all tax related
documents, in electronic format. I understand that account statements will evidence all
activity in My Account for the stated period, including securities transactions, cash
balances, credits to My Account and all fees paid from My Account. Notwithstanding
Section 35.B, confirmations will be considered binding on Me unless I notify Robinhood
of any objections within two (2) calendar days from the date confirmations are sent.
Account statements will be considered binding on Me unless I notify you of any objections
within ten (10) calendar days after My Account statements are posted online. Such
objection may be oral or in writing, but any oral objection must be immediately confirmed
in writing. In all cases, Robinhood reserves the right to determine the validity of My
objection. If I object to a transaction for any reason, I understand and agree that I am
obligated to take action to limit any losses that may result from such transaction or I will
bear sole responsibility for any losses relating to the transaction, even if My objection to
the transaction is ultimately determined to be valid. Nothing in this Section 7 shall limit
My responsibilities as described in Section 5 of this Agreement.
8.
Important Information Needed to Open a New Account. To help the government better
detect the funding of terrorism and money laundering activities, federal law requires all
financial institutions to obtain, verify, and record information that identifies each person
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who opens an account. Therefore, I understand that when I open My Account Robinhood
will ask for My name, address, date of birth and other identifying information. Robinhood
may also ask copies of My driver’s license, passport or other identifying documents. I
understand that Robinhood may take steps to verify the accuracy of the information I
provide to Robinhood in My Account application or otherwise, and that Robinhood may
restrict My access to My Account pending such verification. I will provide prompt
notification to Robinhood of any changes in the information including My name, address,
e-mail address and telephone number.
I further understand that if I attempt to access My Account from a jurisdiction subject to
certain U.S. sanctions or I am ordinarily resident in such a jurisdiction, or if you reasonably
believe that I am attempting such access or have become a resident in such a jurisdiction,
you may restrict My Account, and any pending orders may be cancelled. If this happens, I
understand that I should contact help@robinhood.com, and that I may be asked to provide
supplemental information as part of this process. I further understand that I must close My
Account before establishing residency in any jurisdiction subject to U.S. sanctions.
9.
Telephone Conversations and Electronic Communications. I understand and agree that
Robinhood may record and monitor any telephone or electronic communications with Me.
Unless otherwise agreed in writing in advance, Robinhood does not consent to the
recording of telephone conversations by any third party or Me. I acknowledge and
understand that not all telephone or electronic communications are recorded by Robinhood,
and Robinhood does not guarantee that recordings of any particular telephone or electronic
communications will be retained or capable of being retrieved.
10.
Oral Authorization. I agree that Robinhood shall be entitled to act upon any oral
instructions given by Me so long as Robinhood reasonably believes such instruction was
actually given by Me or My authorized agent.
11.
Applicable Laws and Regulations. All transactions in My Account will be subject to
federal securities laws and regulations, the applicable laws and regulations of any state or
jurisdiction in which Robinhood Financial is registered, the rules of any applicable self-
regulatory organization of which Robinhood Financial is a member and the rules,
regulations, customs and usages of the exchange or market, and its clearing house, if any,
where the transactions are executed. In no event will Robinhood Financial be obligated to
effect any transaction it believes would violate any federal or state law, rule or regulation
or the rules or regulations of any regulatory or self-regulatory organization.
12.
Erroneous Distributions. I agree to promptly return to Robinhood any assets erroneously
distributed to Me. In the event that I sell a security prior to its ex-dividend/distribution
date, and I receive the related cash/stock dividend or distribution in error, I direct
Robinhood on My behalf to pay such dividend/distribution to the entitled purchaser of the
securities I sold, and I guarantee to promptly reimburse Robinhood for, or deliver to
Robinhood, said dividend or distribution.
13.
Market Volatility; Market Orders; Limit Orders; and Queued Orders. I understand
that, whether I place a market or limit order, I will receive the price at which My order is
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executed in the marketplace, subject to any clarification stated below. Particularly during
periods of high volume, illiquidity, fast movement or volatility in the marketplace, the
execution price received may differ from the quote provided on entry of an order, and I
may receive partial executions of an order at different prices. I understand that Robinhood
Financial is not liable for any price fluctuations. I also understand that price quotes
generally are for only a small number of shares as specified by the marketplace, and larger
orders are relatively more likely to receive executions at prices that vary from the quotes
or in multiple lots at different prices.
I understand that Robinhood Financial does not currently support sending traditional
market buy orders and that Robinhood Financial collars all market buy orders by using
limit orders priced up to 5% above the last trade price. This is not the case for market sell
orders. I further understand that when I send a market buy order through Robinhood
Financial’s trading system, the trading system generates a limit order up to 5% above the
last trade price, and then Robinhood Financial sends the order to an executing broker. I
understand that Robinhood Financial’s implementation of market buy orders may vary
depending on prices of instruments, market conditions, and other factors. I further
understand that Robinhood Financial uses the following rounding mechanics with respect
to buy orders: the last trade price is (i) multiplied by 1.05; (ii) rounded down to two decimal
places if the last trade price is over $1.00; otherwise, rounded down to four decimal places;
and (iii) for securities included in the SEC’s Tick Size Pilot Program, rounded down to the
nearest $.05 increment. I understand that securities may open for trading at prices
substantially higher or lower than the previous closing price or the anticipated price. If I
place a market order (whether during normal market hours or when the market is closed),
I agree to pay or receive the prevailing market price at the time My market order is
executed, subject to the specific clarification above relating to buy orders. I understand
that the price I pay may be significantly higher or lower than anticipated at the time I placed
the order. To avoid buying a security at a higher price and possibly exceeding My
purchasing power, I understand My option to enter a limit order. I also understand that
limit orders may not be executed at any particular time, or at all, if there is not sufficient
trading at or better than the limit price I specify, and are only good until the end of the
trading day in which they are entered. The Website contains further information regarding
order types and limitations, which I agree to read and understand before placing such
orders.
As a customer of Robinhood Financial, I understand that after the market has closed for
the day, I have the ability to place in a queue order requests to be executed the following
day upon the opening of the market (“Queued Order”). I understand that My Queued Order
request is prioritized based on the order in which it is received by Robinhood Financial,
and that the Queued Order requests are sent out for execution shortly after the market opens
on the next day of trading. I further understand that each Queued Order request is sent out
per customer and per security as Robinhood Financial market orders (described above),
and that they are not aggregated.
A limit order may be “good till cancelled” which means the order remains valid until (A)
it is executed; (B) I cancel the order; (C) approximately 90 days from when the order is
placed; or (D) the contract to which it relates is closed. I understand that Robinhood will
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cancel a “good till cancelled” order at the end of every trading day (on the exchange on
which the instrument to which the contract relates is traded) and place such order again at
the start of the following trading day. This process will be repeated every day for as long
as the “good till cancelled” order remains valid. I further agree that any “good till
cancelled” orders I place should be treated as “do not reduce” orders.
14.
Bulletin Board/Pink Sheet Stocks. Bulletin board, pink sheet and other thinly-traded
securities (collectively “bulletin board stocks”) present particular trading risks, in part
because they are relatively less liquid and more volatile than actively traded securities listed
on a major exchange. I understand that bulletin board stocks may be subject to different
trading rules and systems than other securities and that I may encounter significant delays
in executions, reports of executions, and updating of quotations in trading bulletin board
stocks. Robinhood Financial in its sole discretion may require limit orders on certain
bulletin board stock transactions.
15.
Research and Internet Links. News, research, links to outside websites, and other
information accessible through the App or Website (“Content”) may be prepared by
independent external providers not affiliated with Robinhood Financial, including
Morningstar, Inc. (all such providers, the “Providers”). I agree not to distribute, reproduce,
sell, or otherwise commercially use the Content in any manner. I understand that
Robinhood may terminate My access to the Content. I understand that none of the Content
is a recommendation by Robinhood to buy or sell any securities or to engage in any
investment strategy.
16.
Restrictions on Trading. I understand that Robinhood may, in its discretion, prohibit or
restrict the trading of securities, or the substitution of securities, in any of My Accounts. I
understand that Robinhood may execute all orders by Me on any exchange or market,
unless I specifically instruct Robinhood to the contrary. In the event of a breach or default
by Me under this Agreement, Robinhood shall have all rights and remedies available to a
secured creditor under all applicable laws and in addition to the rights and remedies
provided herein. I understand that Robinhood may at any time, at its sole discretion and
without prior notice to Me: (i) prohibit or restrict My access to the use of the App or the
Website or related services and My ability to trade, (ii) refuse to accept any of My
transactions, (iii) refuse to execute any of My transactions, or (iv) terminate My Account.
The closing of My Account will not affect the rights or obligations of either party incurred
prior to the date My Account is closed.
Further, Robinhood will not tolerate any foul or abusive language, physical violence,
threatening behavior, or other inappropriate conduct directed toward Robinhood, its
Affiliates’ officers, employees, contractors or customers. If I engage in any such behavior,
as determined by Robinhood in its sole discretion, I agree that Robinhood is authorized to:
(i) liquidate any securities, instruments or other property in My Account, (ii) send Me the
proceeds, and (iii) close My account. Robinhood will not be responsible for any Losses
caused by the liquidation of securities, instruments or other property pursuant to this
paragraph, including any tax liabilities.
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17.
Waiver; Limitation of Liability; Indemnification. I agree that My use of the App or the
Website or any other service provided by Robinhood Financial or its Affiliates is at My
sole risk. The Robinhood Financial service (including the App, the Website, the provision
of Market Data, Information, Content, or any other information provided by Robinhood
Financial, any of its Affiliates, or any third-party content provider or market data provider)
is provided on an “as is,” “as available” basis without warranties of any kind, either express
or implied, statutory (including without limitation, timeliness, truthfulness, sequence,
completeness, accuracy, freedom from interruption), implied warranties arising from trade
usage, course of dealing, course of performance, or the implied warranties of
merchantability or fitness for a particular purpose or application, other than those
warranties which are implied by and incapable of exclusion, restriction or modification
under the laws applicable to this Agreement.
Although considerable effort is expended to make the Website, App and other operational
and communications channels available around the clock, Robinhood does not warrant that
these channels will be available and error free every minute of the day. I agree that
Robinhood will not be responsible for temporary interruptions in service due to
maintenance, Website or App changes, or failures, nor shall Robinhood be liable for
extended interruptions due to failures beyond our control, including but not limited to the
failure of interconnecting and operating systems, computer viruses, forces of nature, labor
disputes and armed conflicts.
EXCEPT AS OTHERWISE EXPRESSLY PROVIDED IN THIS AGREEMENT, I
UNDERSTAND AND AGREE THAT ROBINHOOD, ITS AFFILIATES, THEIR
RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES AND AGENTS, AND THE
PROVIDERS (COLLECTIVELY THE “ROBINHOOD PARTIES”) WILL NOT BE
LIABLE TO ME OR TO THIRD PARTIES UNDER ANY CIRCUMSTANCES, OR
HAVE ANY RESPONSIBILITY WHATSOEVER, FOR ANY SPECIAL, INDIRECT,
INCIDENTAL, PUNITIVE OR CONSEQUENTIAL DAMAGES (INCLUDING
TRADING LOSSES, DAMAGES, LOSS OF PROFITS, REVENUE, OR GOODWILL)
THAT I MAY INCUR IN CONNECTION WITH MY USE OF THE SERVICE
PROVIDED BY ROBINHOOD OR ANY OF ITS AFFILIATES UNDER THIS
AGREEMENT (INCLUDING MY USE OF THE APP, THE WEBSITE, THE MARKET
DATA, THE INFORMATION, OR THE CONTENT), BREACH OF THIS
AGREEMENT, OR ANY TERMINATION OF THIS AGREEMENT, WHETHER SUCH
LIABILITY IS ASSERTED ON THE BASIS OF CONTRACT, TORT (INCLUDING
NEGLIGENCE), OR OTHERWISE, AND WHETHER OR NOT FORESEEABLE,
EVEN IF ANY ROBINHOOD PARTY HAS BEEN ADVISED OR WAS AWARE OF
THE POSSIBILITY OF SUCH LOSS OR DAMAGES. THE ROBINHOOD PARTIES
SHALL NOT BE LIABLE BY REASON OF DELAYS OR INTERRUPTIONS OF THE
SERVICE OR TRANSMISSIONS, OR FAILURES OF PERFORMANCE OF THEIR
RESPECTIVE SYSTEMS, REGARDLESS OF CAUSE, INCLUDING THOSE
CAUSED BY GOVERNMENTAL OR REGULATORY ACTION, THE ACTION OF
ANY EXCHANGE OR OTHER SELF REGULATORY ORGANIZATION, OR THOSE
CAUSED BY SOFTWARE OR HARDWARE MALFUNCTIONS.
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Except as otherwise provided by law, Robinhood or any of its affiliates or respective
partners, officers, directors, employees or agents (collectively, “Indemnified Parties”) shall
not be liable for any expenses, losses, costs, damages, liabilities, demands, debts,
obligations, penalties, charges, claims, causes of action, penalties, fines and taxes of any
kind or nature (including legal expenses and attorneys’ fees) (whether known or unknown,
absolute or contingent, liquidated or unliquidated, direct or indirect, due or to become due,
accrued or not accrued, asserted or unasserted, related or not related to a third party claim,
or otherwise) (collectively, “Losses”) by or with respect to any matters pertaining to My
Account, except to the extent that such Losses are actual Losses and are determined by a
court of competent jurisdiction or an arbitration panel in a final non-appealable judgment
or order to have resulted solely from Robinhood’s or any of its affiliates’ gross negligence
or intentional misconduct. In addition, I agree that the Indemnified Parties shall have no
liability for, and I agree to indemnify, defend and hold harmless the Indemnified Parties
from all Losses that result from: (i) any noncompliance by Me with any of the terms and
conditions of this Agreement; (ii) any third-party actions related to My receipt and use of
any Information, Market Data, Content, market analysis, other third-party content, or other
such information obtained on the App or Website, whether authorized or unauthorized
under this Agreement; (iii) any third-party actions related to My use of the App or the
Website; (iv) My or My agent’s misrepresentation or alleged misrepresentation, or act or
omission; (v) Indemnified Parties following My or My agent’s directions or instructions,
or failing to follow My or My agent’s unlawful or unreasonable directions or instructions;
(vi) any activities or services of the Indemnified Parties in connection with My Account
(including any technology services, reporting, trading, research or capital introduction
services); or (vii) the failure by any person not controlled by the Indemnified Parties and
their affiliates to perform any obligations to Me. Further, if I authorize or allow third
parties to gain access to Robinhood’s services, including My Accounts, I will indemnify,
defend and hold harmless the Indemnified Parties against any Losses arising out of claims
or suits by such third parties based upon or relating to such access and use. Robinhood
does not warrant against loss of use or any direct, indirect or consequential damages or
Losses to Me caused by My assent, expressed or implied, to a third party accessing My
Account or information, including access provided through any other third party systems
or sites.
I consent to the use of automated systems or service bureaus by Robinhood and its
respective affiliates in conjunction with My Account, including automated order entry and
execution, record keeping, reporting and account reconciliation and risk management
systems (collectively “Automated Systems”). I understand that the use of Automated
Systems entails risks, such as interruption or delays of service, errors or omissions in the
information provided, system failure and errors in the design or functioning of such
Automated Systems (collectively, a “System Failure”) that could cause substantial damage,
expense, or liability to Me. I understand and agree that Indemnified Parties will have no
liability whatsoever for any of my Losses arising out of or relating to a System Failure.
I also agree that Indemnified Parties will have no responsibility or liability to Me in
connection with the performance or non-performance by any exchange, clearing
organization, market data provider, or other third party (including other broker-dealers and
clearing firms, and banks) or any of their respective agents or affiliates, of its or their
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obligations relative to any securities. I agree that Indemnified Parties will have no liability,
to Me or to third parties, or responsibility whatsoever for: (i) any Losses resulting from a
cause over which Indemnified Parties do not have direct control, including the failure of
mechanical equipment, unauthorized access, theft, operator errors, government
restrictions, force majeure (as defined in this Agreement), market data availability or
quality, exchange rulings or suspension of trading; and (ii) any special, indirect, incidental,
consequential, punitive or exemplary damages (including lost profits, trading losses and
damages) that I may incur in connection with My use of the App, the Website, Robinhood’s
brokerage, and other services provided by Indemnified Parties under this Agreement.
18.
Mutual Fund Transactions. In the event that I purchase or hold a mutual fund, I agree to
read and understand the terms of its prospectus. I understand that certain mutual funds
reserve the right to change their purchasing, switching or redemption procedures or
suspend or postpone redemptions under certain market conditions. I further understand
that any mutual fund order entered with Robinhood is placed by Robinhood on a best
efforts basis as prescribed and recognized by the individual fund, and that Robinhood is
not responsible for unexecuted orders due to the failure of any communication system. I
agree to be fully responsible for the information contained within the mutual fund
prospectus and to hold Robinhood, its Affiliates, and Robinhood and its Affiliates’
respective officers and employees harmless for any deficiencies contained therein. I
authorize Robinhood to act as My agent in the purchase and redemption of fund shares.
19.
Exchange Traded Funds. I understand that I should consider the investment objectives
and unique risk profile of Exchange Traded Funds (“ETFs”) carefully before investing, and
that ETFs are subject to risks similar to those of other diversified portfolios. I further
understand that leveraged and inverse ETFs may not be suitable for all investors and may
increase exposure to volatility through the use of leverage, short sales of securities,
derivatives, and other complex investment strategies, and that although ETFs are designed
to provide investment results that generally correspond to the performance of their
respective underlying indices, they may not be able to exactly replicate the performance of
the indices because of expenses and other factors. I further understand that ETFs are
required to distribute portfolio gains to shareholders at year end, which may be generated
by portfolio rebalancing or the need to meet diversification requirements, and that ETF
trading will also generate tax consequences. I understand that I can obtain prospectuses
from issuers or their third party agents who distribute and make prospectuses available for
review. Additional regulatory guidance on ETFs can be found here.
20.
Effect of Attachment or Sequestration of Accounts. Robinhood shall not be liable for
refusing to obey any orders given by or for Me with respect to any of My Accounts that
has or have been subject to an attachment or sequestration in any legal proceeding against
Me, and Robinhood shall be under no obligation to contest the validity of any such
attachment or sequestration.
21.
Event of Death. It is agreed that in the event of My death, the representative of My estate
or the survivor or survivors shall immediately give Robinhood written notice thereof, and
Robinhood may, before or after receiving such notice, take such proceedings, require such
papers and inheritance or estate tax waivers, retain such portion of, or restrict transactions
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in the Account as Robinhood may deem advisable to protect Robinhood against any tax,
liability, penalty or loss under any present or future laws or otherwise. Notwithstanding
the above, in the event of My death, all open orders shall be canceled, but Robinhood shall
not be responsible for any action taken on such orders prior to the actual receipt of notice
of death. Further, Robinhood may in Its discretion close out any or all of the Accounts
without awaiting the appointment of a personal representative for My estate and without
demand upon or notice to any such personal representative. The estate of any of the
Account holders who have died shall be liable and each survivor shall continue to be liable,
jointly and severally, to Robinhood for any net debit balance or loss in said account in any
way resulting from the completion of transactions initiated prior to the receipt by
Robinhood of the written notice of the death of the decedent or incurred in the liquidation
of the Account or the adjustment of the interests of the respective parties, and for all other
obligations pursuant to this Agreement. Such notice shall not affect Robinhood’s rights
under this Agreement to take any action that Robinhood could have taken if I had not died.
22.
Tax Reporting; Tax Withholding. The proceeds of sale transactions and dividends paid
will be reported to the Internal Revenue Service (“IRS”) in accordance with applicable law.
A.
U.S. Persons. This subsection is applicable if I am a U.S. person. Under penalties
of perjury, I certify that the taxpayer identification number that I have provided or
will provide to Robinhood (including any taxpayer identification number on any
Form W-9 that I have provided or will provide to Robinhood) is My correct
taxpayer identification number. I certify that I am not subject to backup
withholding and I am a United States Person (including a U.S. resident alien) as
such term is defined in section 7701(a)(30) of the Internal Revenue Code of 1986,
as amended (“U.S. Person”). If a correct Taxpayer Identification Number is not
provided Robinhood Financial, I understand I may be subject to backup
withholding tax at the appropriate rate on all dividends, interest and gross proceeds
paid to me. Backup withholding taxes are sent to the IRS and cannot be refunded
by Robinhood Financial. I further understand that if I waive tax withholding and
fail to pay sufficient estimated taxes to the IRS, I may be subject to tax penalties.
B.
Non-U.S. Persons. This subsection is applicable if I am not a U.S. Person. I certify
that I fully understand all the information on any Form W-8BEN that I have
submitted or will submit to Robinhood. Under penalties of perjury, I declare that
(i) I have examined all the information (including all the information in the English
language) on any Form W-8BEN that I have submitted or will submit to Robinhood
and (ii) to the best of My knowledge and belief all such information is true, correct,
and complete. I authorize Robinhood to provide any such Form W-8BEN to
Robinhood Securities or any withholding agent that has control, receipt, or custody
of the income of which I am the beneficial owner or any withholding agent that can
disburse or make payments of the income of which I am the beneficial owner. I
agree that I will submit a new Form W-8BEN to Robinhood within 30 calendar
days if any certification made on any previously submitted Form W-8BEN becomes
incorrect. I understand that the IRS does not require My consent to any provisions
of such Form W-8BEN other than the certifications required to establish My status
as a non-U.S. Person and, if applicable, obtain a reduced rate of withholding.
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23.
Equity Orders and Payment For Order Flow. SEC rules require all registered broker-
dealers to disclose their policies regarding any “payment for order flow” arrangement in
connection with the routing of customer orders. “Payment for order flow” includes, among
other things, any monetary payment, service, property, or other benefit that results in
remuneration, compensation, or consideration to a broker-dealer from any broker-dealer in
return for directing orders. I understand that Robinhood transmits customer orders for
execution to various exchanges or market centers based on a number of factors. These
include: size of order, trading characteristics of the security, favorable execution prices
(including the opportunity for price improvement), access to reliable market data,
availability of efficient automated transaction processing and reduced execution costs
through price concessions from the market centers. I further understand that certain of the
exchanges or market centers may execute orders at prices superior to the publicly quoted
market in accordance with their rules or practices and that while a customer may specify
that an order be directed to a particular market center for execution, the order-routing
policies, taking into consideration all of the factors listed above, are designed to result in
favorable transaction processing for customers. The nature and source of any payments or
credits received by Robinhood in connection with any specific transactions will be
furnished upon written request.
24.
Free Credit Balances and Sweep Service. If I enroll in Robinhood Financial Cash
Management (“Cash Management”), I understand that I am electing to participate in the
Insured Network Deposit (“IND”) sweep service (the “Sweep Service”). Under the Sweep
Service, free credit balances in My Account will be deposited into interest-bearing accounts
at one or more banks (“Participating Depository Institutions”), in accordance with the
Insured Network Deposit Sweep Program Disclosures (“IND Disclosures”) available on
the Website and in the App. By enrolling in Cash Management, I represent and warrant
that I have reviewed the IND Disclosures and agree to the terms set forth in the IND
Disclosures. If I am not enrolled in Cash Management, free credit balances in My Account
will remain in My Account, will not earn interest and will not be eligible for FDIC
insurance, but will be eligible for SIPC protection as described in the IND Disclosures.
25.
Fees and Charges. I understand that Robinhood does not charge fees or commissions for
executing buy and sell orders. However, I understand that other fees may apply. The
current fees are included in the fee schedule available in the App and on the Website. I
agree to pay any such fees at the then-prevailing rate. I acknowledge that the prevailing
fees may change and that change may occur without notice. I agree to be bound by such
changes once they are posted in the fee schedule available in the App and on the Website.
I also agree to pay all applicable federal, state, local, and foreign taxes. I authorize
Robinhood Financial to automatically debit My Account for any such fees and taxes. I
also agree to pay such expenses incurred by Robinhood in connection with collection of
any unpaid balance due on My Accounts including attorney’s fees allowed by law.
26.
ACH Transactions.
A.
Debit Transactions.
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Robinhood will initiate an ACH debit at My request to debit funds from an account
that I own at another financial institution (“External Account”) for deposit into My
Account. I understand that in order for Robinhood to initiate an ACH debit, the
financial institution holding my External Account must participate in the ACH
system. I understand that for the ACH transfers to be established, at least one
common name must match exactly between My Account and My External Account.
I authorize Robinhood to take such steps as it deems appropriate to verify my
ownership of External Account, including by telling the bank at which such
External Account is held that I have authorized and consented to such bank
disclosing to Robinhood any information that Robinhood may request about Me or
My External Account. I also agree to cooperate with Robinhood’s verification of
my ownership of such External Account by promptly providing any identification
and/or other documentation that Robinhood may request regarding such External
Account. I represent and warrant that there are sufficient funds in My External
Account to cover the amount of the deposit to My Account. Robinhood will initiate
the ACH debit to My External Account on the Business Day or next Business Day
after I request the transfer. A transfer request will be deemed to have been made
on a Business Day if it is received by Robinhood by 7:00 p.m. (Eastern Time) on
such Business Day; if received after that time, the transfer request will be deemed
to have been made on the next Business Day.
Within 60 days of the date of My ACH deposit, My funds may only be withdrawn
to the External Account from which such funds were deposited.
I understand that an ACH debit transfer may be reversed or rejected if: (A) there
are insufficient funds in My External Account; (B) there is a duplicate transaction;
(C) the transaction is denied by the bank holding My External Account; or (D) My
External Account does not support ACH transfers. I acknowledge that in the event
of an ACH reversal, I will incur a fee. Before initiating making an ACH debit
transfer, I agree to check Robinhood Financial’s most recent Commissions and Fees
Schedule,
available
at
https://brokerage-
static.s3.amazonaws.com/assets/robinhood/legal/RHF%20Retail%20Commisions
%2 0and%20Fees%20Schedule.pdf. I agree that I am solely liable and responsible
for any ACH reversal fees that I incur.
B.
Credit Transactions.
Robinhood will initiate an ACH credit at My request to transfer funds from My
Account to a recipient that I designate. I agree that I will have sufficient funds
(“Available Funds”) in My Account to cover the amount of any ACH credit that I
ask Robinhood to initiate. Robinhood will debit the amount of such request from
My Account on the Business Day or next Business Day after I request the transfer.
A transfer request will be deemed to have been made on a Business Day if it is
received by Robinhood by our cut-off time on such Business Day; if received after
that time, the transfer request will be deemed to have been made on the next
Business Day.
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I agree that Robinhood may use any means which Robinhood, in its sole discretion,
considers suitable to execute my ACH credit transfers.
27.
Fractional Shares
I acknowledge and understand that Robinhood rounds all holdings of fractional shares
to the sixth decimal place, the value of fractional shares to the nearest cent, and any
dividends paid on fractional shares to the nearest cent. I further understand that
Robinhood will not accept dollar-based purchases or sales of less than $1.00 and that I
will receive proceeds from the sale of any whole or fractional shares rounded to the
nearest cent.

I understand that a vendor employed by Robinhood will aggregate any proxy votes for
fractional shares of Robinhood’s customers with all votes reported to the issuer or
issuer’s designated vote tabulator and that, while Robinhood’s vendor will report such
proxy votes on fractional shares, the issuer or tabulator may not fully count such votes.

I understand that Robinhood will execute all orders that include fractional shares on a
principal basis. To the extent that Robinhood fulfills my order entirely out of its
inventory and without purchasing or selling shares in the market, Robinhood will
endeavor to price such shares or fractional shares at a price between the National Best
Bid and Offer (“NBBO”) at the time of the order for orders made during market hours,
or, for such orders made during extended hours trading (9:00-9:30 a.m. and 4:00-6:00
p.m. Eastern), Robinhood will endeavor to price such orders between the best bid and
offer at the time of the order, as reported by an external vendor. Orders made outside
market hours and extended hours trading are queued and fulfilled either at or near the
beginning of extended hours trading (9:00 a.m. Eastern) or at or near market open (9:30
a.m. Eastern), according to my instructions. To the extent that I trade fractional shares
outside of market hours, these trades are subject to Robinhood’s Extended Hours
Trading
Disclosure,
available
at:
https://cdn.robinhood.com/assets/robinhood/legal/ExtendedHoursTradingDisclosure.p
df

I understand Robinhood only accepts market orders for fractional shares at this time and
does not permit limit orders for fractional shares. I understand that fractional shares
within My Account (i) are unrecognized, unmarketable, and illiquid outside the
Robinhood platform, (ii) are not transferrable in-kind, and (iii) may only be liquidated
and the proceeds transferred out via a wire transfer. I acknowledge that, subject to
applicable requirements, Robinhood may report holdings and transactions in My
Account in terms of either U.S. Dollars, shares, or both.
28.
Dividend Reinvestment Program
Except as expressly stated otherwise, the provisions of this Section 28 will only apply if I
am enrolled in Robinhood’s Dividend Reinvestment Program (“DRIP”).
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My enrollment in the DRIP will be activated within three business days after I notify
Robinhood of my intention to enroll an eligible security through the App. “Eligible
security” means all shares available for fractional investing through Robinhood. I
understand that in order to be eligible for dividend reinvestment, the securities must be
held in My Account.
I may specify individual securities or have all Eligible securities in My Account enrolled
for dividend reinvestment. If I choose to reinvest dividends from all Eligible securities,
I understand that individual securities could subsequently no longer be Eligible
securities at Robinhood’s discretion or under applicable law. In those cases, only those
securities will be discontinued from the DRIP. If I specify individual securities, I may
add additional Eligible securities to the DRIP at any time if I hold a position in those
securities. Enrollment with respect to these additional Eligible securities will be
effective within three business days after Robinhood receives notification from me
through the App. If I maintain open orders for securities I do not already hold, I may not
enroll those securities for dividend reinvestment until my open orders are executed. If
my entire Account is set up for dividend reinvestment, any eligible securities I purchase
in the future will automatically participate in the DRIP.
All eligible cash distributions will be reinvested on all securities I have selected in the
DRIP, provided that I owned the securities on the record date for determining
shareholders eligible to receive dividends, and continue to hold the securities through
payable date. “Eligible cash distributions” means most cash distributions, including
regular and optional dividends, cash-in-lieu payments, and capital gains distributions.
Special dividends, late ex-date, liquidation, and miscellaneous payments may not be
eligible distributions. Optional dividends will be processed in accordance with dividend
reinvestment instructions. If I have a margin account, Robinhood is permitted to borrow
a dividend paying stock in the normal course of business and, as a result, in such
situations instead of a dividend payment I may receive a cash in lieu payment. If I receive
a cash in lieu payment, I authorize Robinhood to treat such payment as if it was not “in
lieu” and reinvest it accordingly.
Robinhood will credit My Account upon completion of the dividend reinvestment.
Robinhood will reinvest dividends on the business day following receipt of funds. In the
rare instance in which Robinhood is unable to reinvest all dividends on the business day
following receipt, it will reinvest the remaining funds as soon as reasonably possible
thereafter, which may take up to five business days. I will not have use of the funds prior
to reinvestment.
I understand that my participation in the DRIP is voluntary and that Robinhood has not
made any recommendation that I should participate. I further understand that
Robinhood is not recommending or offering any advice regarding the purchase of any
security included as an Eligible security in the DRIP. I further understand that dividend
reinvestment does not assure profits on my investments, nor does it protect against losses
in declining markets.
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I may terminate my participation in the DRIP, or the enrollment of individual securities
in the DRIP, at any time by giving notice through the App. Termination will take effect
prior to the next Eligible cash distribution provided my notice to terminate was received
at least three business days prior to the record date of that distribution. I understand that
my notice to terminate my participation in the DRIP will not affect any obligations that
may result from transactions initiated prior to Robinhood’s receipt and processing of my
notice.
If I participate in the DRIP, I understand Robinhood will reinvest the dividends of a
particular stock at or near the opening price on the trading day following receipt of the
dividend. Robinhood will combine Eligible cash distributions from My Account with
those from other Robinhood clients requesting dividend reinvestment in the same
security and use these combined funds to purchase securities on my behalf and on behalf
of these other clients. If the combined reinvested funds do not total the purchase price
of at least one share, the distribution will be invested in fractional shares. On that same
day, Robinhood will credit My Account with that number of shares, including fractional
shares, equal to my Eligible cash distribution divided by the purchase price per
share. Robinhood does not intend to charge a fee for transactions executed pursuant to
the DRIP.
Dividend reinvestment may result in my owning interests in fractional shares of a
security. I will be entitled to receive future dividend payments on my fractional shares,
although other corporate actions may result in allocation of only whole shares and cash
in lieu of fractions as determined by the issuer. In mandatory corporate reorganizations,
my partial interest will be handled according to the specific terms of the reorganization.
In voluntary corporate reorganizations, Robinhood will act on my instructions with
respect only to my whole shares.
Because fractional share positions cannot be transferred, reorganized, or issued in
certificate form, my partial interest will be liquidated, without commission charges to
me, at prevailing market prices in the event My Account is transferred or closed, the
stock is reorganized, or stock certificates are ordered out of My Account. The timing of
such liquidations will be at the discretion of Robinhood.
Reinvestment of dividends may result in my owning a fractional share position in
securities that are callable in part. In the event of a call, fractional shares to be called
will be determined through a random selection process. The probability of my fractional
share holdings being called will be proportional to the holdings of all Robinhood clients
who own a fractional share position in that security. Prior to the publication date of such
a call, I have the right to withdraw from My Account cash in lieu of my uncalled, fully
paid partial holdings. Once a call is announced, however, all shares, whether registered
or held in street name, participate in the random selection process. If my fractional shares
are selected and I no longer hold the shares that I held on the publication date of the call,
I will be responsible for covering those shares.
29.
Cash Management Services.
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Except as expressly stated otherwise, the provisions of this Section 29 will only apply if I
am enrolled in Cash Management.
A.
General.
I understand and agree that by enrolling in Cash Management, I am applying for a
Robinhood-branded debit card issued by the bank identified in My Robinhood
Debit Card Agreement (“Card”). I further understand and agree that by using My
Card or exercising My electronic fund transfer ("EFT") privileges offered in
connection with My Account, I authorize Robinhood to debit My Account
immediately whenever an electronic draft or Card transaction is presented for
payment on My behalf, when an EFT transaction is effected, or when any fee or
charge is due (collectively "Payments"). I further understand and agree that when
I request a Payment or withdrawal or instruct Robinhood to make a purchase of
securities from My Account, Robinhood is authorized to place a block on the
amount of the transaction (“Blocked Amounts”) prior to the settlement date of the
Payment, withdrawal or trade, and that the Blocked Amounts will not be available
for use for additional Payments or the purchase of securities. I agree to maintain
Available Funds sufficient to pay for EFT transactions, Card transactions and
withdrawals made by Me or any Authorized Card User (as defined below) and to
pay for any securities trades and for interest on any margin loans and other
transaction fees. For this purpose, "Available Funds" in My Account will fluctuate
daily and means the sum of (i) free credit balances, (ii) deposits to Participating
Depository Institutions through the Sweep Service, and (iii) available margin loan
value if My Account has margin privileges, minus (x) uncleared funds, (y) Blocked
Amounts, and (z) deposits subject to a hold. The loan value of eligible securities
for the purpose of margin is subject to regulatory requirements and Robinhood
credit policies then in effect.
B.
Payments and Withdrawals.
I agree that any Payments that I make from My Account will be lawful. I agree that
Payments will be deducted from the Available Funds in My Account in the
following order: first, from free credit balances; second, by withdrawal of funds
deposited to Participating Depository Institutions as part of the Sweep Service; and
third, if My Account has margin privileges, from margin loans on the eligible
securities in My margin Account. Robinhood will debit My Account only up to an
amount equal to the Available Funds. I understand and agree that (i) if there are
insufficient Available Funds in My Account to cover Payments when they become
due, Robinhood has no obligation to make such Payments, and (ii) Robinhood has
no obligation to make partial Payments. Robinhood will not charge a fee with
respect to any declined Payment for which there were insufficient Available Funds.
I acknowledge and agree, however, that Robinhood will not be responsible for any
costs or losses that I may incur (including fees, costs, charges, attorneys’ fees,
investment losses, claims, demands, or liability resulting from any litigation or
other actions) as a result of Robinhood’s decision to decline any Payment or
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withdrawal or other transaction because My Account has insufficient Available
Funds.
I understand that if a Payment is funded by a margin loan, I will incur interest until
the margin loan is repaid.
I agree that if my Available Funds at any time falls below zero, Robinhood may
suspend Card and EFT privileges and terminate My Card. If this occurs, I agree to
immediately pay all amounts owed to Robinhood, including any purchases on My
Card which will be immediately charged to My Account.
I acknowledge and agree that Robinhood reserves the right to decline any purchase
or cancel My Card, and EFT privileges at any time for any reason with or without
notice to Me. If Robinhood decides to take such action, I understand and agree that
I am responsible for any pending debits, which will be processed and deducted from
My Account.
I understand that transactions will post to My Account in any order determined by
Robinhood and that Robinhood may change that order without prior notice to Me.
Robinhood will comply with requirements of applicable law regarding the order of
posting transactions.
C.
Limitation of Liability.
I agree that, subject to any limitations imposed by applicable law, and except as
otherwise set forth in this Agreement or in the disclosures contained in the
Robinhood Debit Card Agreement, which has been provided to Me or made
available to me in connection with the opening of My Account, neither Robinhood,
any processing bank, nor the Card issuer will be liable for any loss I incur in
connection with My Account, Card transactions, EFT transactions, or other features
of My Account unless Robinhood is grossly negligent in fulfilling this Agreement.
In no event will Robinhood, any processing bank, or the Card issuer be liable for
consequential, special or indirect damages or losses unless applicable law requires
otherwise. I also agree that liability regarding online services or use of the App is
further limited by the Robinhood Terms and Conditions, available at
https://about.robinhood.com/legal/. To the extent I utilize online services or the
App I acknowledge that I am bound by such Robinhood Terms and Conditions.
D.
Debit Cards.
I understand and agree that My use of the Card is subject to the terms, conditions
and disclosures set forth in the Robinhood Debit Card Agreement, which has been
provided to Me in connection with the opening of My Account and which I may
access on the Website.
I understand and agree that I cannot request a Card for another person to use. I
agree, however, that if I permit another person to have access to use My Card or
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Card number (an “Authorized Card User”), I am authorizing all Card transactions
by such person and I agree that there are no limits to my authorization. I accept all
liability with respect to the Card transactions effected by Me and any Authorized
Card Users. I further agree that I may I may terminate the authority of an
Authorized Card User only by contacting help@robinhood.com to cancel my Card.
I agree that the cancellation of My Card is effective only after Robinhood has a
reasonable period to act on My notice.
If My Card is cancelled, I agree to destroy, or if requested by Robinhood, return the
Card to Robinhood. I acknowledge that I will be responsible for any Card
transactions that are processed because of My failure to destroy or return the Card
following cancellation.
If My Account includes margin privileges, I agree that transactions that exceed My
free credit balances and deposits in the Sweep Service may result in margin credit
being extended to My Account, for which I will be charged interest. I agree to
review
the
Margin
Disclosure
Statement,
which
is
available
at
https://about.robinhood.com/legal/.
E.
Deposits.
The provisions in this Section 29.E shall apply to My Account whether or not I am
enrolled in Cash Management.
General; Holds. I understand that I may deposit funds to My Account by ACH,
direct deposit or EFT (including deposits using the MoneySend service offered by
Mastercard). I acknowledge and agree that funds that I deposit may be subject to
one or more hold periods, which are described in the RHF Funds Availability
schedule available at https://about.robinhood.com/legal/. I understand and agree
that Robinhood reserves the right to modify the RHF Funds Availability schedule
at any time by posting an updated schedule at https://about.robinhood.com/legal/,
or otherwise providing notice to me. During the applicable hold period, My funds
will not be available for ACH transfers, Card transactions, withdrawal, or the
settling of securities transactions, in each case as described in the RHF Funds
Availability schedule. I further understand and agree that Robinhood reserves the
right to further delay making deposited funds available for periods longer than the
hold periods specified in the RHF Funds Availability schedule to the extent
Robinhood determines that additional time is needed to verify information about
the item deposited or the sender or if Robinhood otherwise believes there is a risk
of fraud or other unlawful activity with respect to My Account.
Mistaken Deposits. If funds are deposited or transferred into My Account by
mistake or otherwise, I agree that Robinhood may correct the situation and deduct
any interest paid by Participating Depository Institutions, if applicable, without
prior notice to Me.
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Returned Items. I acknowledge and agree that I am responsible for returned
transactions. If I have funds transferred into My Account and that transfer is
returned for any reason, Robinhood may charge the transfer and interest paid by
Participating Depository Institutions, if applicable, against My Account, without
prior notice to Me. Robinhood may send the returned transfer back for collection
a second time without notifying Me, and I waive notice of dishonor and protest.
F.
Electronic Fund Transfers.
The provisions in this Section 29.F relating to EFTs other than Card transactions
shall apply to My Account whether or not I am enrolled in Cash Management.
I understand that My Account may be eligible for a variety of EFTs, which may be
subject to separate agreements, terms and conditions. These services may include
use of the Card, and the “Move Money” functionality of the App. I understand that
I may be required to agree to separate terms and conditions governing the particular
service I use to initiate EFTs. In addition, I understand and agree that my use of
EFT services are subject to the disclosures set forth in Appendix A (Electronic Fund
Transfer Disclosures), and acknowledge that I have received and reviewed such
disclosures.
G.
Security.
I agree to protect My Card, and My PINs, from access by anyone not authorized by
Me to use them. I acknowledge that I will be liable for all Card and online
transactions conducted by anyone to whom I have given access or who has obtained
access even if not authorized by Me, up to applicable legal limits. I understand that
I am responsible for reviewing My Account statement promptly to discover and
report unauthorized activity, including use of My Card, Card number or PIN. I
agree to notify Robinhood as provided in Appendix A (Electronic Fund Transfer
Disclosures) if I believe or have reason to believe that there has been unauthorized
activity in My Account or that My Card, Card number or PIN has been lost, stolen
or may be used by an unauthorized person. Unless limited by law or as otherwise
set forth in this Agreement or in the disclosures contained in Robinhood Debit Card
Agreement, which is provided to Me as part of the Account opening process and is
available on the Website, I agree that I will be responsible for losses that arise from
My failure to (i) safeguard My Card and PINs, (ii) review My monthly statement
for possible unauthorized activity and (iii) report any unauthorized activity to
Robinhood as provided herein or in the Robinhood Debit Card Agreement.
H.
Disclosure of Information.
I agree and understand that all disclosures of My non-public personal information
shall be made in accordance with the terms of this Agreement or the Robinhood
Privacy Policy (available on the Website at https://about.robinhood.com/legal/), as
applicable. I agree that My consent to sharing non-public personal information will
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remain in effect until I revoke such consent by updating My settings and visibility,
which I may do at any time through the App.
In addition, I understand and agree that Robinhood may disclose information about
My Account and My related activities to third parties under the following
circumstances:
● As necessary to complete My Payment transactions;
● To investigate any complaint, disputed transaction, transaction inquiry or
request I make or as necessary to investigate potential fraud or misuse
related to My Account;
● To respond to requests from credit bureaus, creditors or other third parties
for account-related information, to the extent such inquiries are necessary
for processing My transactions or are usual and customary in the course of
servicing similar products or accounts;
● As necessary to comply with any applicable law, government or court order
or subpoena; or
● In accordance with My written permission or as otherwise permitted under
the Robinhood Privacy Policy.
I.
Termination.
I understand that Robinhood may terminate my participation in Cash Management
or in specific features of Cash Management for any reason, upon notice to me.

30.
Consent to Redeem Shares.
I understand and agree that whenever it is necessary for Robinhood’s protection or
to satisfy a margin call, deficiency, debit or other obligation owed to Robinhood,
Robinhood may (but is not required to) sell, assign and deliver all or any part of the
securities in My Account, or close any or all transactions in My Account. I
understand that Robinhood may, but is not obligated to, attempt to contact Me
before taking any such action. I understand and agree that Robinhood reserves the
right to take any such action without prior notice or demand for additional
collateral, and free of any right of redemption, and that any prior demand, call or
notice will not be considered a waiver of our right to sell or buy without demand,
call or notice.
I further understand that Robinhood may choose which securities to buy or sell,
which transactions to close, and the sequence and timing of liquidation, and may
take such actions on whatever exchange or market and in whatever manner
(including public auction or private sale) that Robinhood chooses in the exercise of
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its business judgment. I agree not to hold Robinhood liable for the choice of which
securities to buy or sell or of which transactions to close or for the timing or manner
of the liquidation. I also agree not to hold Robinhood liable for taking such action.
I understand and agree that Robinhood is entitled to exercise the rights described in
this section in its sole discretion, including, but not limited to, whenever any of the
following occurs:
● The equity level in My Account falls below required minimums;
● Sufficient funds or securities are not deposited to pay for transactions in My
Account;
● I reverse any ACH debit transfer to My Account;
● A petition of bankruptcy or for the appointment of a receiver is filed by or
against Me;
● An attachment is levied against My Account;
● I die or become incapacitated or incompetent; or
● My Account is closed.

31.
Electronic Delivery of Trade and Account Information; Notice. All communications,
notices, legal disclosures, and other materials related to My Account or this Agreement,
including account statements, trade confirmations, margin calls, notices, disclosures,
regulatory communications and other information, documents, data and records regarding
My Account (the “Communications”), or an alert that any such Communication has been
posted to the secure section of the Website or the App, and is available for viewing, may
be sent to Me at the mailing address for My Account or the e-mail address that I have given
to Robinhood in My account application or at such other address as I may hereafter give
Robinhood in writing or by e-mail at least ten (10) calendar days prior to delivery, and all
communications so sent, whether in writing or otherwise, shall be deemed given to Me
personally, whether actually received or not.
32.
API.
A.
Overview; Definitions. Robinhood may, in Robinhood’s sole discretion, provide
third parties with an application programming interface and other materials in
accordance with any accompanying documentation (collectively, the “API
Package”) (such third parties, “API Licensees”), to make available certain features
and functionality of Robinhood’s mobile applications, websites, or technology
platform via the API Licensees’ products (such products, the “Licensee Products”).
The API Package and the Licensee Products are collectively referred to as the “API
Products”. “Personal Information” means My personally identifiable information
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(including username, logon password, financial information, trade data, and other
financial information) and all data exchanged between Robinhood and the API
Products.
B.
Access to My Personal Information. Through My use of any API Products, I may
be providing API Licensees with access to My Account and Personal Information.
By using any API Products, I acknowledge that such API Products may employ
security, policies, procedures and systems of API Licensees which may or may not
be less stringent and secure than Robinhood’s policies, procedures and systems. I
agree that My use of any API Products shall be subject to the terms and conditions
of this Agreement, in addition to any other agreements which I executed with
respect to any such API Products. I understand and agree that any end user
agreement that I executed with any API Licensee is concluded between Me and
such API Licensee only, and not with Robinhood; and such API Licensee, not
Robinhood, is solely responsible for such Licensee Product and the content thereof.
I understand and agree that the API Products may deliver Personal Information to
Robinhood, and that Robinhood is authorized to receive and store such Personal
Information consistent with Robinhood’s then-in-effect policies and procedures.
Further, I agree that the API Products may request Personal Information stored by
Robinhood, and I consent to Robinhood’s disclosure of such Personal Information
to the API Products.
C.
No Recommendations. To the extent the Licensee Products or API Licensees
express opinions or make recommendations, I understand that such opinions and
recommendations are expressed solely by API Licensees and are not the opinions
or recommendations of Robinhood. The existence of the API Products and
Robinhood’s consent to any connectivity between any Licensee Products and
Robinhood’s technology, the App, the Website, or trading platform(s) does not
constitute (i) any recommendation by Robinhood to invest in any security or utilize
any investment strategy; or (ii) any representation, warranty, or other guarantee by
Robinhood as to the present or future value or suitability of any sale, trade, or other
transaction involving any particular security or any other investments. The
existence of any and all information, tools and services provided by API Licensees
or by the Licensee Products shall not constitute Robinhood’s endorsement of API
Licensees or the Licensee Products.
D.
Data Provided by Robinhood to API. From time to time, and subject to then-in-
effect agreements between Robinhood and API Licensees, Robinhood may, in its
own discretion, make market data feeds received from third parties available via
the API Products. Robinhood does not make any guarantees in regard to such
market data feeds. Furthermore, API Licensees or Licensee Products may make
available to Me market data feeds independent of Robinhood. I am aware that from
time to time that there may be discrepancy between the market data presented on
the App or Website and information provided by any API Products due to a variety
of reasons, including the time to update and transmit such data to a mobile
application or website and latency caused by such API Product’s or My local
environment (such as computer set up, connection speed, etc.). Robinhood is not
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responsible for the accuracy of any market data displayed on any API Products or
otherwise made available by API Licensees.
E.
Risks; No Liability. I acknowledge that there may be latency between the time an
order (or other Personal Information) is submitted from the API Products and the
time such order or Personal Information is received by Robinhood. Latency may
also affect order modification and order cancellation requests. The time an order
or a request is actually received by Robinhood (including for execution) will be the
official time, including for the purposes of routing the order to the market for
execution. In addition, all orders submitted to Robinhood are subject to order
vetting by Robinhood. Orders created and submitted through any API Products are
not vetted until they are received by Robinhood. It is possible that Robinhood may
reject an order placed through any API Products. Robinhood cannot guarantee that
any order will be accepted when such order is routed to the market for execution,
and Robinhood cannot guarantee that notifications and Personal Information
provided to Me by Robinhood will be successfully delivered to or displayed by any
API Products.
Without limiting the generality of any other terms in this Agreement, I agree that:
(i)
Robinhood or its Affiliates shall not be liable for any Losses as a result of
any issues addressed in this Section 32 of this Agreement, nor shall Robinhood or
its Affiliates be liable for any Losses realized for technical issues involving any
API Products or API Licensee technology or product offerings (including system
outages or downtime).
(ii)
Robinhood or its Affiliates shall not be responsible for any investment
research provided by any API Licensee or any Licensee Products.
(iii)
Robinhood or its Affiliates makes no representations, warranties or other
guarantees as to the accuracy, timeliness or efficacy of any market data,
information, or other functionality made available by any API Licensee or any API
Products.
F.
Intellectual Property. My use of any API Products will not confer to Me any title,
ownership interest or intellectual property rights that otherwise belongs to
Robinhood or any of its affiliates. The API Package, including content, is protected
under U.S. patent, copyright laws, international treaties or conventions, and other
laws and will remain Robinhood’s exclusive property, as applicable. Names, logos,
and all related product and service names, design marks, and slogans displayed by
or relating to Robinhood or any of its Affiliates or API Licensees in the context of
the API Products shall remain the property of the respective owner, and use of such
property by Robinhood or any API Licensee in marketing or provision of any API
Products does not grant ownership of or entitle Me to use any such name or mark
in any manner.
G.
User’s Representations and Warranties. I represent and warrant that:
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(i)
By virtue of utilizing any API Products, I consent to and accept any risk
associated with Robinhood’s sharing of Personal Information with any API
Licensee and shall not hold Robinhood, its Affiliates, or their respective officers,
directors, or employees responsible for any Losses resulting from the sharing of
such Personal Information.
(ii)
I agree that My use of any API Products or API Licensee’s content,
information, technology, or functionality is at My own risk.
(iii)
I agree that Robinhood may revoke any API Licensee or API Products’
authorization at any time, for any reason, with or without cause and without prior
notice to Me.
33.
Electronic Signatures; Modifications to the Agreement. I agree to transact business
with Robinhood electronically. By electronically signing an application for an Account, I
acknowledge and agree that such electronic signature is valid evidence of My consent to
be legally bound by this Agreement and such subsequent terms as may govern the use of
Robinhood’s services. The use of an electronic version of any document fully satisfies any
requirement that the document be provided to Me in writing. I accept notice by electronic
means as reasonable and proper notice, for the purpose of any and all laws, rules and
regulations. I acknowledge and agree that Robinhood Financial may modify this
Agreement from time to time and I agree to consult the Website from time to time for the
most up-to-date Agreement. The electronically stored copy of this Agreement is
considered to be the true, complete, valid, authentic and enforceable record of the
Agreement, admissible in judicial or administrative proceedings to the same extent as if
the documents and records were originally generated and maintained in printed form. I
agree to not contest the admissibility or enforceability of Robinhood Financial’s
electronically stored copy of the Agreement.
34.
Margin Accounts.
A.
Election. This numbered section applies to my account to the extent I elect and am
approved for a Robinhood Gold margin account.
B.
Margin Trading. I understand that margin trading involves interest charges and
risks, including the potential to lose more than deposited or the need to deposit
additional collateral in a falling market. Before using margin, customers must
determine whether this type of trading strategy is right for them given their specific
investment objectives, experience, risk tolerance, and financial situation. If I have
elected to have a margin Account, I represent that I have read the Margin Disclosure
Statement, Day Trading Risk Disclosure, and FINRA Investor Information. These
disclosures contain information on Robinhood’s lending policies, interest charges,
and the risks associated with margin accounts.
C.
Hypothecation. Within the limitations imposed by applicable laws, rules and
regulations, all securities now or hereafter held by Robinhood, or carried by
Robinhood in any account for Me (either individually or jointly with others), or
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deposited to secure same, may from time to time, without any notice, be carried in
your general loans and may be pledged, repledged, hypothecated or re-
hypothecated, separately or in common with other securities for the sum due to you
thereon or for a greater sum and without retaining in your possession or control for
delivery a like amount of similar securities. The IRS requires Broker Dealers to
treat dividend payments on loaned securities positions as payments received in lieu
of dividends for 1099 tax reporting purposes. Taxation of substitute dividend
payments may be greater than ordinary on qualified dividends. It is understood,
however, that you agree to deliver to Me upon My demand and upon payment of
the full amount due thereon, all securities in such accounts, but without obligation
to deliver the same certificates or securities deposited by Me originally. Any
securities in My margin or short account may be borrowed by you, or lent to others.
D.
Interest. Debit balances in My Accounts shall be charged with interest in
accordance with your established custom, as disclosed to Me in the Customer
Information Brochure pursuant to the provisions of the Securities Exchange Act.
E.
Margin. I agree to maintain in all accounts with Robinhood such positions and
margins as required by all applicable statutes, rules, regulations, procedures and
custom, or as you deem necessary or advisable. I agree to promptly satisfy all
margin and maintenance calls.
F.
Sales. I agree to specifically designate any order to sell a security, which I do not
own as a short sale, and understands that Robinhood will mark such order as a short
sale. I agree that any order which is not specifically designated as a short sale is a
sale of securities owned by me, and that I will deliver the securities on or before
settlement date, if not already in the account. If I should fail to make such delivery
in the time required, Robinhood is authorized to borrow such securities as necessary
to make delivery for the sale, and I agree to be responsible for any loss you may
thereby sustain, or which you may sustain as a result of your inability to borrow
such securities.
35.
Consent to Electronic Delivery of Documents.
A.
Consent. By agreeing to electronic delivery, I am giving My informed consent
to electronic delivery of all Account Documents, as defined below, other than
those I have specifically requested to be delivered in paper form. “Account
Documents” include notices, disclosures, current and future account statements,
regulatory communications (such as prospectuses, proxy solicitations, and privacy
notices), trade confirmations, tax-related documents, and any other information,
documents, data, and records regarding My Account, this Agreement (including
amendments to this Agreement), and the agreements and disclosures governing the
services delivered or provided to Me by Robinhood Financial, the issuers of the
securities or other property in which I invest, and any other parties. I agree that I
can access, view, download, save, and print any Account Documents I receive via
electronic delivery for My records.
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B.
Electronic Delivery System. I acknowledge that Robinhood’s primary methods of
communication with Me include (A) posting information on the Website, (B)
providing information via the App, (C) sending email(s) to My email address of
record, and, to the extent required by law, (D) providing Me with notice(s) that will
direct Me to the App or the Website where I can read and print such information.
Unless otherwise required by law, Robinhood reserves the right to post Account
Documents on the Website without providing notice to Me. Further, Robinhood
reserves the right to send Account Documents to My postal or email address of
record, or via the App or Website. I agree that all Account Documents provided to
Me in any of the foregoing manner is considered delivered to Me personally when
sent or posted by Robinhood, whether I receive it or not.
All e-mail notifications regarding Account Documents will be sent to My e-mail
address of record. I agree to maintain the e-mail address that I have provided
Robinhood until I provide Robinhood with a new one. I understand that e-mail
messages may fail to transmit promptly or properly, including being delivered to
SPAM folders. I further understand that it is My sole responsibility to ensure that
any emails from Robinhood or its Affiliates are not marked as SPAM. Regardless
of whether or not I receive an e-mail notification, I agree to check the Website
regularly to avoid missing any information, including time-sensitive or otherwise
important communication. If I authorize someone else to access the e-mail account
I have provided Robinhood, I agree to tell them to share the Account Documents
with Me promptly, and I accept the risk that they will see My sensitive information.
I understand that if I use a work e-mail address or computing or communications
device, My employer or other employees may have access to the Account
Documents.
Additionally, I acknowledge that the Internet is not a secure network and agree that
I will not send any confidential information, including Account numbers or
passwords, in any unencrypted e-mails. I also understand that communications
transmitted over the Internet may be accessed by unauthorized or unintended third
parties and agree to hold Robinhood, its Affiliates, and Robinhood and its
Affiliates’ respective officers and employees harmless for any such access
regardless of the cause.
I agree to promptly and carefully review all Account Documents when they are
delivered and notify Robinhood Financial in writing within five (5) calendar days
of delivery if I object to the information provided (or other such time specified
herein). If I fail to object in writing within such time, Robinhood Financial is
entitled to treat such information as accurate and conclusive. I will contact
Robinhood to report any problems with accessing the Account Documents.
C.
Costs. Potential costs associated with electronic delivery of Account Documents
may include charges from Internet access providers and telephone companies, and
I agree to bear these costs. Robinhood Financial will not charge Me additional
online access fees for receiving electronic delivery of Account Documents.
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D.
Archival. Upon My request, I may obtain copies of up to six (6) prior years of
account statements, and three (3) prior years of trade confirmations.
E.
Revocation of Consent. Subject to the terms of this Agreement, I may revoke or
restrict My consent to electronic delivery of Account Documents at any time by
notifying Robinhood Financial in writing of My intention to do so. I also
understand that I have the right to request paper delivery of any Account Document
that the law requires Robinhood Financial to provide Me in paper form. Robinhood
Financial will not treat My request for paper copies as a withdrawal of My consent
to electronic delivery of Account Documents. I understand that if I revoke or
restrict My consent to electronic delivery of Account Documents or request paper
delivery of same, Robinhood Financial, in its sole discretion, may charge Me a
reasonable service fee for the delivery of any Account Document that would
otherwise be delivered to Me electronically, restrict or close My account, or
terminate My access to Robinhood Financial’s services. I understand that neither
My revocation or restriction of consent, My request for paper delivery, nor
Robinhood Financial’s delivery of paper copies of Account Documents will affect
the legal effectiveness or validity of any electronic communication provided while
My consent was in effect.
F.
Duration of Consent. My consent to receive electronic delivery of Account
Documents will be effective immediately and will remain in effect unless and until
either I or Robinhood Financial revokes it. I understand that it may take up to three
(3) Business Days to process a revocation of consent to electronic delivery, and that
I may receive electronic notifications until such consent is processed.
G.
Hardware and Software Requirements. I understand that in order to receive
electronic deliveries, I must have access to a computer or Mobile Device with
Internet access, a valid e-mail address, and the ability to download such
applications as Robinhood Financial may specify and to which I have access. I also
understand that if I wish to download, print, or save any information I wish to retain,
I must have access to a printer or other device in order to do so.
H.
Consent and Representations. I hereby agree that I have carefully read the above
information regarding informed consent to electronic delivery and fully understand
the implications thereof. Additionally, I hereby agree to all conditions outlined
above with respect to electronic delivery of any Account Document. I will maintain
a valid e-mail address and continue to have access to the Internet. If My e-mail
address changes, I agree to immediately notify Robinhood Financial of My new e-
mail address in writing.
36.
Miscellaneous Provisions. The following provisions shall also govern this Agreement:
A.
Contact Information. Robinhood Customer Service may be contacted by visiting
support.robinhood.com or by email at help@robinhood.com.
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B.
Interpretation. The heading of each provision hereof is for descriptive purposes
only and shall not be (1) deemed to modify or qualify any of the rights or obligations
set forth herein or (2) used to construe or interpret any of the provisions hereunder.
When a reference is made in this Agreement to a Section, such reference shall be
to a Section of this Agreement unless otherwise indicated. Whenever the words
“include,” “includes” or “including” are used in this Agreement, they shall be
deemed to be followed by the words “without limitation.” The word “or,” when
used in this Agreement, has the inclusive meaning represented by the phrase
“and/or.” Unless the context of this Agreement otherwise requires: (i) words using
the singular or plural number also include the plural or singular number,
respectively; and (ii) the terms “hereof,” “herein,” “hereunder” and derivative or
similar words refer to this entire Agreement. References to any law shall be deemed
to refer to such law as amended from time to time and to any rules or regulations
promulgated thereunder.
C.
Binding Effect; Assignment. This Agreement shall bind My heirs, assigns,
executors, successors, conservators and administrators. I may not assign this
Agreement or any rights or obligations under this Agreement without first obtaining
Robinhood’s prior written consent. Robinhood may assign, sell, or transfer My
Account and this Agreement, or any portion thereof, at any time, without My prior
consent.
D.
Severability. If any provisions or conditions of this Agreement are or become
inconsistent with any present or future law, rule, or regulation of any applicable
government, regulatory or self-regulatory agency or body, or are deemed invalid or
unenforceable by any court of competent jurisdiction, such provisions shall be
deemed rescinded or modified, to the extent permitted by applicable law, to make
this Agreement in compliance with such law, rule or regulation, or to be valid and
enforceable, but in all other respects, this Agreement shall continue in full force
and effect.
E.
Website Postings. I agree and understand that Robinhood Financial may post other
specific agreements, disclosures, policies, procedures, terms, and conditions that
apply to My use of the App, the Website, or My Account on the Website (“Website
Postings”). I understand that it is My continuing obligation to understand the terms
of the Website Postings, and I agree to be bound by the Web Postings as are in
effect at the time of My use.
F.
Entirety of Agreement. This Agreement, any attachments hereto, other agreements
and policies referred to in this Agreement (including the Website Postings), and the
terms and conditions contained in My Account statements and confirmations,
contain the entire agreement between Robinhood and Me and supersede all prior or
contemporaneous communications and proposals, whether electronic, oral, or
written, between Robinhood and Me, provided, however, that any and all other
agreements between Robinhood and Me, not inconsistent with this Agreement, will
remain in full force and effect.
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G.
Amendment. Robinhood may at any time amend this Agreement without prior
notice to Me. The current version of the Agreement will be posted on the Website
and My continued Account activity after such amendment constitutes My
agreement to be bound by all then-in-effect amendments to the Agreement,
regardless of whether I have actually reviewed them. Continued use of the App,
the Website or any other Robinhood Financial services after such posting will
constitute My acknowledgment and acceptance of such amendment. I agree to
regularly consult the Website for up-to-date information about Robinhood
Financial services and any modifications to this Agreement. Robinhood is not
bound by any verbal statements that seek to amend the Agreement.
H.
Termination. Robinhood may terminate this Agreement, or close, deactivate, or
block access to My Account at any time in its sole discretion. I will remain liable
to Robinhood for all obligations incurred in My Account, pursuant to this
Agreement, or otherwise, whether arising before or after termination. I may
terminate this Agreement after paying any obligations owed upon written notice.
This Agreement survives termination of My Account.
I.
No Waiver; Cumulative Nature of Rights and Remedies. I understand that
Robinhood’s failure to insist at any time upon strict compliance with any term
contained in this Agreement, or any delay or failure on Robinhood’s part to exercise
any power or right given to Robinhood in this Agreement, or a continued course of
such conduct on Robinhood’s part, shall at no time operate as a waiver of such
power or right, nor shall any single or partial exercise preclude any other further
exercise. All rights and remedies given to Robinhood in this Agreement are
cumulative and not exclusive of any other rights or remedies to which Robinhood
is entitled.
J.
International Customers. The products and services described on the Website are
offered only in jurisdictions where they may be legally offered. Neither the
Website nor the App shall be considered a solicitation for or offering of any
investment product or service to any person in any jurisdiction where such
solicitation or offering would be illegal. I understand that Robinhood, in its sole
discretion, may accept unsolicited accounts from non-U.S. residents, depending on
the country of residence and other factors. I understand that Robinhood is based in
the United States and that Robinhood accepts only U.S. currency in Robinhood’s
customer accounts.
K.
Governing Law. This Agreement and all transactions made in My Account shall
be governed by the laws of the State of California (regardless of the choice of law
rules thereof), except to the extent governed by the federal securities laws, FINRA
Rules, and the regulations, customs and usage of the exchanges or market (and its
clearing house) on which transactions are executed.
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37.
Arbitration.
A.
This Agreement contains a pre-dispute arbitration clause. By signing an
arbitration agreement, the parties agree as follows:
(1)
All parties to this Agreement are giving up the right to sue each other in
court, including the right to a trial by jury, except as provided by the rules of the
arbitration forum in which a claim is filed.
(2)
Arbitration awards are generally final and binding; a party’s ability to have
a court reverse or modify an arbitration award is very limited.
(3)
The ability of the parties to obtain documents, witness statements and other
discovery is generally more limited in arbitration than in court proceedings.
(4)
The arbitrators do not have to explain the reason(s) for their award unless,
in an eligible case, a joint request for an explained decision has been submitted by
all parties to the panel at least 20 days prior to the first scheduled hearing date.
(5)
The panel of arbitrators will typically include a minority of arbitrators who
were or are affiliated with the securities industry.
(6)
The rules of some arbitration forums may impose time limits for bringing a
claim in arbitration. In some cases, a claim that is ineligible for arbitration may be
brought in court.
(7)
The rules of the arbitration forum in which the claim is filed, and any
amendments thereto, shall be incorporated into this Agreement.
B.
Any controversy or claim arising out of or relating to this Agreement, any
other agreement between Me and Robinhood, any Account(s) established
hereunder, any transaction therein, shall be settled by arbitration in accordance
with the rules of FINRA Dispute Resolution, Inc. (“FINRA DR”). I agree to
arbitrate any controversy or claim before FINRA DR in the State of California.
C.
This agreement to arbitrate constitutes a waiver of the right to seek a
judicial forum unless such a waiver would be void under the federal securities laws.
If I am a foreign national, non-resident alien, or if I do not reside in the United
States, I agree to waive My right to file an action against Robinhood in any foreign
venue.
D.
No person shall bring a putative or certified class action to arbitration, nor
seek to enforce any pre-dispute arbitration agreement against any person who has
initiated in court a putative class action; or who is a member of a putative class who
has not opted out of the class with respect to any claims encompassed by the
putative class action until:
(1)
the class certification is denied; or (2) the class is decertified; or (3) the
customer is excluded from the class by the court. Such forbearance to enforce an
agreement to arbitrate shall not constitute a waiver of any rights under this
Agreement except to the extent stated herein.

ACCEPTED AND AGREED: I acknowledge that I have read the preceding terms and conditions
of this Agreement, that I understand them and that I hereby manifest my assent to, and my
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agreement to comply with, those terms and conditions by accepting this agreement. I ALSO
UNDERSTAND
THAT
BY
ACCEPTING
THIS
AGREEMENT
I
HAVE
ACKNOWLEDGED THAT THIS AGREEMENT CONTAINS A PREDISPUTE
ARBITRATION CLAUSE IN SECTION 37 HEREIN. I ALSO AGREE (1) THAT ANY OF
MY MARGIN ACCOUNT SECURITIES MAY BE BORROWED BY ROBINHOOD OR
LOANED TO OTHERS; (2) I HAVE RECEIVED OF A COPY OF THIS AGREEMENT
AND (3) I HAVE REVIEWED A COPY OF THE MARGIN DISCLOSURE STATEMENT.

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Appendix A
Electronic Fund Transfer Services Disclosures
The following disclosures apply to the use of any EFT services offered by Robinhood, including
the Card, ACH transactions and the Move Money functionality of the App.
Solely for purposes of these disclosures: (i) references to the Bank shall include any financial
institution that issues the Card or provides services in connection with ACH, Move Money or other
EFT transactions; (ii) “you” and “your” mean the owner of the Account; and (iii) “we” and “us”
means Robinhood and the Bank collectively.
1.
Your Liability.
Contact Robinhood Customer Service AT ONCE if you believe your Card or PIN has been lost or
stolen or if you believe that an electronic fund transfer has been made without your permission.
Telephoning is the best way of keeping your losses down. You could lose all the Available Funds
in your Account (plus your maximum overdraft line of credit). If you tell Robinhood within 2
business days after you learn of the loss or theft of your Card or PIN, you can lose no more than
$50 if someone used your Card or PIN without your permission.
If you do NOT tell Robinhood within 2 business days after you learn of the loss or theft of your
Card or PIN, and Robinhood can prove that it could have stopped someone from using your Card
or PIN without your permission if you had told Robinhood, you could lose as much as $500.
Also, if your statement shows transfers that you did not make, including those made by Card or
using your PIN, tell Robinhood at once. If you do not tell Robinhood within sixty (60) days after
the statement was mailed to you, or otherwise made available to you, you may not get back any
money you lost after the sixty (60) days if Robinhood can prove that Robinhood could have
stopped someone from taking the money if you had told Robinhood in time. If a good reason (such
as a long trip or a hospital stay) kept you from telling Robinhood, Robinhood will extend the time
periods.
2.
Contact in event of unauthorized transfer.
If you believe your Card or PIN has been lost or stolen, contact Robinhood by emailing
help@robinhood.com.
3.
Business Days.
Business Days are Monday through Friday, excluding federal holidays.
4.
Transfer Types and Limitations.
You may use your Card to make purchases at any merchant that accepts Mastercard debit cards or
debit cards of other networks in which the Bank participates, and to make ATM withdrawals, in
each case subject to the Available Funds in your Account, the transaction limits described below,
and the other terms and conditions of this Agreement. You acknowledge and agree that the value
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available to you for use with the Card is limited to the Available Funds in your Account. So long
as you do not exceed the Available Funds in your Account, you may use the Card to purchase
goods or services wherever the Card is honored, and to obtain cash by initiating cash withdrawal
transactions through the Card from any financial institution or ATM that accepts the Card. Each
time you use the Card, you authorize Robinhood to reduce the Available Funds in your Account
by the amount of the purchase or withdrawal and any applicable fees, costs, or holdings.
Nevertheless, if you exceed the Available Funds in your Account you shall remain fully liable to
Robinhood for the amount of the transactions and any applicable fees and charges.
You may also make ACH withdrawals from your Account, either originated through Robinhood
or originated by a third party (a “non-originated” withdrawal), subject to the Available Funds in
your Account, the transaction limits described below, and the other terms and conditions of this
Agreement. You also may make ACH deposits to your Account, either originated through
Robinhood or originated by a third party (a “non-originated” deposit), subject to the transaction
limits described below.
There are limits on the dollar amount of transactions you can make with your Card each day and
each month, and limits on the amount of ACH withdrawals and deposits you can make each day.
The following lists the limits for each type of transaction:

Transaction Type
Daily Limit
Weekly Limit
Monthly Limit
Originated
ACH
Withdrawals
$50,000.00
N/A
N/A
Originated
ACH
Deposits
$50,000.00
N/A
N/A
Non-Originated
ACH
Withdrawals
$250,000.00
N/A
N/A
Non-Originated
ACH
Deposits
$250,000.00
N/A
N/A
Point of Sale Purchases
with the Card
$5,000.00
N/A
$15,000.00
ATM Withdrawals
$510.00

$5,000.00
MoneySend Deposits
N/A, subject to
the Weekly Limit
$2,999
N/A

5.
Fees.
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We will not charge you any fees for use of ATMs that are part of the AllPoint or MoneyPass ATM
networks, or for point of sale transactions using the Card, or for initiating other EFTs on your
behalf. If you withdraw funds from ATMs outside of the AllPoint or MoneyPass ATM networks,
you may be separately assessed fees by those ATM owners or operators.
6.
Confidentiality.
We may disclose information to third parties about you, your Card, or the transactions you make
using any of the EFT services we provide:
(1)
Where it is necessary or helpful for completing or correcting transactions and
resolving claims regarding transactions;
(2)
In order to verify the existence and condition of your Card or your Account for a
third party, such as a merchant;
(3)
In order to comply with a valid request by a government agency, a court order, or
other legal or administrative reporting requirements;
(4)
If you consent by giving us your written permission;
(5)
To our employees, auditors, affiliates, service providers, or attorneys as needed;
(6)
In order to prevent, investigate or report possible illegal activity;
(7)
In order to issue authorizations for transactions on the Card;
(8)
As permitted by applicable law; or
(9)
Otherwise as necessary to fulfill our obligations under this Agreement and the terms
applicable to the EFT service you are using.
Please see Robinhood’s privacy policy, available at about.robinhood.com/legal, and the applicable
Bank’s privacy policy, available at https://www.suttonbank.com/_/kcms-doc/85/49033/WK-
Privacy-Disclosure-1218.pdf, for further details. (The Robinhood privacy policy and the
applicable Bank’s privacy policy are referred to collectively as the “Privacy Policies”). You
hereby agree to Robinhood’s and the Bank’s collection, use and sharing of information about you
and the Card as provided in the Privacy Policies, which are made a part of this Agreement. The
Privacy Policies also tell you how you can (i) limit the ways in which Bank and Robinhood share
information about you, or (ii) request corrections to the information that Bank or Robinhood
maintain about you. You agree that information you provide in connection with your Card or other
EFT services you use is being provided directly to both Robinhood as the holder of the Account
associated with the service and the Bank as the Card issuer or provider of the EFT service, as
applicable.

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7.
Documentation.
Terminal Transfers. You can get a receipt at the time you make any transfer to or from your
Account using an ATM from the AllPoint or MoneyPass ATM networks or at the point of sale.
Preauthorized Credits. If you have arranged to have direct deposits made to your Account at least
once every 60 days from the same person or company, the person or company making the deposit
will tell you every time they send us the money. You can also check your Account online to see
if a deposit has been received.
Periodic Statements. You will get a monthly Account statement, unless there are no transfers in a
particular month. In any case you will get the statement at least quarterly. You may obtain
information about the Available Funds in your Account and a history of your Cash Management
transactions on the App.
8.
Preauthorized Payments/Stop Payment Procedure and Notice of Varying Amounts.
You do not have the right to request that Robinhood in advance make regular payments out of
your Account, although you may ask third parties to initiate regular payments out of your Account.
a. Right to stop payment: If you have automatic recurring payments taken out of your Account,
you can stop any of these payments by contacting us at help@robinhood.com. You must contact
us in time for us to receive your request at least three business days before the payment is scheduled
to be made.
b. Notice of varying amounts: If these regular payments vary in amount, the party you are going
to pay will tell you, 10 days before each payment, when the payment will be made and how much
it will be. (The party you are going to pay may allow you to choose to get this notice only when
the payment would differ by more than a certain amount from the previous payment, or when the
amount would fall outside certain limits that you set.)
c. Liability for failure to stop payment of preauthorized transfer: If you order us to stop a
payment at least three business days before the transfer is scheduled and we do not do so, we will
be liable for your losses or damages.
9.
Our Liability.
If we do not complete a transaction to or from your Account on time or in the correct amount
according to our Agreement with you, we will be liable for your losses or damages. However,
there are some exceptions. We will not be liable, for instance:
(1)
If through no fault of Robinhood or the Bank, you do not have enough Available
Funds in your Account to complete the transaction;
(2)
If a merchant refuses to accept your Card;
(3)
If an electronic terminal where you are making a transaction does not operate
properly, and you knew about the problem when you initiated the transaction;
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(4)
If access to your Card has been blocked after you reported your Card lost or stolen;
(5)
If there is a hold or your funds are subject to legal or administrative process or other
encumbrance restricting their use;
(6)
If Robinhood or the Bank have reason to believe the requested transaction is
unauthorized;
(7)
If circumstances beyond the control of Robinhood or the Bank (such as fire, flood,
or computer or communication failure) prevent the completion of the transaction,
despite reasonable precautions that Robinhood or the Bank have taken; or
(8)
For any other exception stated in this Agreement with you or by applicable law.
10.
Errors or Questions About Electronic Transfers.
In case of errors or questions about your electronic transfers, including your Card transactions, or
if you think your statement or receipt is wrong or if you need more information about a transaction
listed on the statement or receipt, contact Robinhood by emailing help@robinhood.com.
Robinhood must hear from you no later than sixty (60) days after you were sent the FIRST
statement on which the problem or error appeared.
(a) Tell Robinhood your name and account number.
(b) Describe the error or the transfer you are unsure about, and explain as clearly as you can
why you believe it is an error or why you need more information.
(c) Tell Robinhood the dollar amount of the suspected error.
Robinhood will determine whether an error occurred within ten (10) business days after Robinhood
hears from you and will correct any error promptly. If Robinhood needs more time, however, it
may take up to forty-five (45) days to investigate your complaint or question. If Robinhood
decides to do this, Robinhood will credit your Account within ten (10) business days for the
amount you think is in error, so that you will have the use of the money during the time it takes
Robinhood to complete our investigation.
For errors involving new accounts, point of sale, or foreign initiated transactions, Robinhood may
take up to ninety (90) days to investigate your complaint or question. For new accounts,
Robinhood may take up to twenty (20) business days to credit your Account for the amount you
think is in error.
Robinhood will tell you the results of our investigation within three (3) business days after
completing the investigation. If Robinhood decides that there was no error, Robinhood will send
you a written explanation. You may ask for copies of the documents that Robinhood used in our
investigation.
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Exhibit 7

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A. Definitions.
"Market Data" means (a) last sale information and quotation information relating to securities that
are admitted to dealings on the New York Stock Exchange ("NYSE"), (b) such bond and other
equity last sale and quotation information, and such index and other market information, as United
States-registered national securities exchanges and national securities associations (each, an
"Authorizing SRO") may make available and as the NYSE may from time to time designate as
"Market Data"; and (c) all information that derives from any such information.
"Nonprofessional" means any natural person who receives market data solely for his/her
personal, non- business use and who is not a "Professional." A "Professional" includes an
individual who, if working in the United States, is: (i) registered or qualified with the Securities and
Exchange Commission (the "SEC"), the Commodity Futures Trading Commission (the "CFTC"),
any state securities agency, any securities exchange or association, or any commodities or
futures contract market or association; (ii) engaged as an "investment advisor" as that term is
defined in Section 202 (a) (11) of the Investment Advisers Act of 1940 (whether or not registered
or qualified under that Act), or (iii) employed by a bank or other organization exempt from
registration under federal and/or state securities laws to perform functions that would require him
or her to be so registered or qualified if he or she were to perform such functions for an
organization not so exempt. A person who works outside of the United States will be considered a
"Professional" if he or she performs the same functions as someone who would be considered a
"Professional" in the United States.
B. Provisions Applicable to All Users.
Proprietary Nature of Data. I understand and acknowledge that each Authorizing SRO and Other
Data Disseminator (as defined below) has a proprietary interest in the Market Data that originates
on or derives from it or its market(s). I agree not to reproduce, distribute, sell or commercially
exploit the Market Data in any manner.
Enforcement. I understand and acknowledge that (a) the Authorizing SROs are third-party
beneficiaries under this Agreement and (b) the Authorizing SROs or their authorized
representative(s) may enforce this Agreement, by legal proceedings or otherwise, against Me or
any person that obtains Market Data that is made available pursuant to this Agreement other than
as this Agreement contemplates.
Data Not Guaranteed. I understand that neither Robinhood nor any Authorizing SRO, other entity
whose information is made available over the Authorizing SROs' facilities (an "Other Data
Disseminator"), or information processor that assists any Authorizing SRO or Other Data
Disseminator in making Market Data available (collectively, the "Disseminating Parties")
guarantees the timeliness, sequence, accuracy, completeness, reliability, or content of Market
Data or of other market information or messages disseminated to or by any Disseminating Party. I
understand that neither Robinhood Financial nor any Disseminating Party guarantees the
timeliness, sequence, accuracy, completeness, reliability or content of market information, or
messages disseminated to or by any party. I understand that neither Robinhood Financial nor any
Disseminating Party warrants that the service provided by any such entity will be uninterrupted or
error-free. I further understand that Market Data by Xignite provides market data to Robinhood
Financial customers. NEITHER ROBINHOOD FINANCIAL, ANY OF ITS AFFILIATES, THEIR
RESPECTIVE OFFICERS OR EMPLOYEES, NOR ANY DISSEMINATING PARTY SHALL BE
LIABLE IN ANY WAY FOR (A) ANY INACCURACY, ERROR OR DELAY IN, OR OMISSION
OF, (I) ANY MARKET DATA, INFORMATION OR MESSAGE, OR (II) THE TRANSMISSION
OR DELIVERY OF ANY SUCH DATA, INFORMATION OR MESSAGE; OR (B) ANY LOSS (AS
DEFINED IN THIS AGREEMENT) OR DAMAGE ARISING FROM OR OCCASIONED BY (I)
ANY SUCH INACCURACY, ERROR, DELAY OR OMISSION, (II) NON-PERFORMANCE OR
III) INTERRUPTION IN ANY SUCH MARKET DATA, INFORMATION, OR MESSAGE,
WHETHER DUE TO ANY ACT OR OMISSION BY ROBINHOOD FINANCIAL, ANY OF ITS
AFFILIATES, THEIR RESPECTIVE OFFICERS OR EMPLOYEES, OR ANY DISSEMINATING
PARTY, OR TO ANY "FORCE MAJEURE" (E.G., FLOOD, EXTRAORDINARY WEATHER
CONDITIONS, EARTHQUAKE OR OTHER ACT OF GOD, FIRE, WAR, INSURRECTION,
RIOT, LABOR DISPUTE, ACCIDENT, ACTION OF GOVERNMENT, OR COMMUNICATIONS
OR POWER FAILURE, EQUIPMENT OR SOFTWARE MALFUNCTION) OR ANY OTHER
1.
2.
1.
2.
3.
2
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CAUSE BEYOND THE REASONABLE CONTROL OF ROBINHOOD FINANCIAL, ITS
AFFILIATES, THEIR RESPECTIVE OFFICERS AND EMPLOYEES, OR ANY
DISSEMINATING PARTY.
Permitted Use. I shall not furnish Market Data to any other person or entity. If I receive Market
Data other than as a Nonprofessional, I shall use Market Data only for My individual use.
Dissemination, Discontinuance, or Modification. I understand and acknowledge that, at any time,
the Authorizing SROs may discontinue disseminating any category of Market Data, may change
or eliminate any transmission method and may change transmission speeds or other signal
characteristics. The Authorizing SROs shall not be liable for any resulting liability, loss or
damages that may arise therefrom.
Duration; Survival. This Section 2 of this Agreement remains in effect for so long as I have the
ability to receive Market Data as contemplated by this Section 2. In addition, Sections 2(B)(1)-(3)
and the first two sentences of Section 2(B)(7), survive any termination of this Agreement.
Miscellaneous. The laws of the State of New York shall govern this Section 2 and it shall be
interpreted in accordance with those laws. This Subsection is subject to the Securities Exchange
Act of 1934, the rules promulgated under that act, and the joint-industry plans entered into
pursuant to that act.
C. Provisions Applicable to Nonprofessionals.
Permitted Receipt. I understand that I may not receive Market Data from Robinhood as a
Nonprofessional, and Robinhood may not provide Market Data to Me as a Nonprofessional,
unless Robinhood first properly determines that I qualify as a Nonprofessional as defined above
and I in fact qualify as a Nonprofessional. I agree that, as a prerequisite to Robinhood Financial
qualifying Me as a Nonprofessional, I will provide to Robinhood truthful and accurate information
about Me, such as: my occupation, employer, employment position and functions; my use of
Market Data; my registration status with any securities agency, exchange, association, or
regulatory body, or any commodities or future contract market, association, or regulatory body,
whether in the United States or elsewhere; and any compensation of any kind I may receive from
any individual or entity for my trading activities, asset management, or investment advice. Except
as otherwise declared to Robinhood in writing, by executing this Agreement, I certify that I meet
the definition of Nonprofessional as set forth in this Agreement.
Permitted Use. If I am a Nonprofessional, I agree to receive Market Data solely for my personal,
non-business use.
Notification. I shall notify Robinhood promptly in writing of any change in my circumstances that
may cause Me to cease to qualify as a Nonprofessional.
3. NASDAQ OMX Information.
A. Definitions.
"Information" means certain market data and other data disseminated that has been collected,
validated, processed, and recorded by any system NASDAQ OMX has developed for the creation
or dissemination of Information or other sources made available for transmission to and receipt
from either a distributor such as RHF or from NASDAQ OMX relating to: a) eligible securities or
other financial instruments, markets, products, vehicles, indicators, or devices; b) activities of a
NASDAQ OMX company; c) other information and data from a NASDAQ OMX company.
"Information" also includes any element of Information as used or processed in such a way that
the Information can be identified, recalculated or re-engineered from the processed Information or
that the processed Information can be used as a substitute for Information.
"NASDAQ OMX" means The NASDAQ OMX Group, Inc., a Delaware limited liability company
and its subsidiaries and Affiliates (collectively, "NASDAQ OMX").
4.
5.
6.
7.
1.
2.
3.
1.
2.
3
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B. Use of Data.
I understand that I may use the Information only for personal use and not for any business purpose. I
may not sell, lease, furnish or otherwise permit or provide access to the Information to any other natural
person or entity ("Person") or to any other office or place. I will not engage in the operation of any illegal
business use or permit anyone else to use the Information, or any part thereof, for any illegal purpose or
violate any NASDAQ OMX or SEC Rule or any FSA rule or other applicable law, rule or regulation. I may
not present the Information rendered in any unfair, misleading or discriminatory format. I shall take
reasonable security precautions to prevent any Person other than Myself from gaining access to the
Information.
C. Proprietary Data.
I acknowledge and agree that NASDAQ OMX has proprietary rights to the Information that originates on
or derives from markets regulated or operated by NASDAQ OMX, and compilation or other rights to
Information gathered from other sources. I further acknowledge and agree that NASDAQ OMX's third-
party information providers have exclusive proprietary rights to their respective Information. In the event
of any misappropriation or misuse by Me or anyone who accesses the Information through Me,
NASDAQ OMX or its third-party information providers shall have the right to obtain injunctive relief for its
respective materials.
D. System.
I acknowledge that NASDAQ OMX, in its sole discretion, may from time-to-time make modifications to
its system or the Information. Such modifications may require corresponding changes to be made in
Robinhood Financial's service. Changes or the failure to make timely changes by Me may sever or
affect My access to or use of the Information. I understand that neither NASDAQ OMX nor Robinhood
shall be responsible for such effects.
E. NASDAQ OMX Limitation of Liability.
Except as may otherwise be set forth herein, NASDAQ OMX shall not be liable to Me for indirect,
special, punitive, consequential or incidental loss or damage (including, but not limited to, trading losses,
lost profits, or other indirect loss or damage) of any nature arising from any cause whatsoever, even if
NASDAQ OMX has been advised of the possibility of such damages. NASDAQ OMX shall not be liable
to Me for any unavailability, interruption, delay, incompleteness or inaccuracy of the Information. This
Section shall not relieve NASDAQ OMX or Me from liability for damages that result from their own gross
negligence or willful tortious misconduct or from personal injury or wrongful death claims. I agree that the
terms of this Section reflect a reasonable allocation of risk and limitation of liability.
F. Disclaimers of Warranties.
NASDAQ OMX and its third-party information providers make no warranties of any kind with respect to
the Information---express, implied or statutory (including without limitation, timeliness, truthfulness,
sequence, completeness, accuracy, freedom from interruption), any implied warranties arising from trade
usage, course of dealing, course of performance or the implied warranties of merchantability or fitness
for a particular use or purpose or noninfringement.
G. Termination by NASDAQ OMX.
I acknowledge that NASDAQ OMX, when required to do so in fulfillment of statutory obligations, may by
notice to Robinhood unilaterally limit or terminate the right of any or all Persons to receive or use the
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Information and that Robinhood will comply with any such notice and will terminate or limit the furnishing
of the Information.
4. Authorization.
I understand that My Account is self-directed. Accordingly, I appoint Robinhood Financial as My agent for
the purpose of carrying out My directions to Robinhood Financial in accordance with the terms and
conditions of this Agreement and any attendant risks with respect to the purchase or sale of securities.
Robinhood Financial is authorized to open or close My Account(s), place and withdraw orders and take
such other steps as are reasonable to carry out My directions. All transactions will be effected only on
My order or the order of My authorized delegate, except as described in Section 10. I understand
Robinhood Financial provides trading and brokerage services through the Robinhood website (the
"Website") and the Robinhood mobile application (the "App"). I agree to receive and transmit financial
information through such electronic means. My use or My grant of access to My Account to any third
party to access information or place transactions in My Account is solely at My risk.
5. Customer Representations and Responsibilities.
A. Self-directed Account.
I understand that My Account is self-directed, and so that I am solely responsible for any and all orders
placed in My Account and that all orders entered by Me or on My behalf are unsolicited and based on My
own investment decisions or the investment decision of My duly authorized representative or agent.
Accordingly, I agree that neither Robinhood nor any of its employees, agents, principals, or
representatives:
provide investment advice in connection with this Account;
recommend any security, transaction or order;
solicit orders;
act as a market maker in any security;
make discretionary trades; and
produce or provide first-party research providing a specific investment strategies such as buy, sell
or hold recommendations, first-party ratings and/or price targets. To the extent research materials
or similar information are available through the App or the Website or the websites of any entity
controlled by, controlling, or under common control with Robinhood (such entity, an "Affiliate"), I
understand that these materials are intended for informational and educational purposes only and
they do not constitute a recommendation to enter into any securities transactions or to engage in
any investment strategies.
B. Information Accuracy.
I: (i) certify that the information contained in this Agreement, the account application, and any other
document that I furnish to Robinhood Financial in connection with My Account(s) is complete, true and
correct, and acknowledge that knowingly giving false information for the purpose of inducing Robinhood
Financial to extend credit is a federal crime; (ii) authorize Robinhood Financial to contact any individual
or firm noted herein or on the documents referred to in subsection (i) of this Section and any other normal
sources of debit or credit information; (iii) authorize anyone so contacted to furnish such information to
Robinhood Financial as Robinhood may request; and (iv) agree that this Agreement, the account
application and any other document I furnish in connection with My Account is Robinhood's property, as
the case may be. I shall promptly advise Robinhood Financial of any changes to the information in such
agreements and documents in writing within ten (10) calendar days. I authorize Robinhood Financial to
obtain reports and provide information to others concerning My creditworthiness and business conduct.
Upon My request, Robinhood agrees to provide Me a copy of any report so obtained. Robinhood may
1.
2.
3.
4.
5.
6.
5
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retain this Agreement, the Account application, and all other such documents and their respective
records at Its sole discretion, whether or not credit is extended.
C. Risks.
I understand that all investments involve risk, that losses may exceed the principal invested, and that
the past performance of a security, industry, sector, market, or financial product does not guarantee
future results or returns.
D. Account Defaults.
I understand that My Account comes with many defaulted service instruction features and preferences. I
further understand that I am not required to use these defaulted options or preferences and that once My
Account is approved and opened I have the sole discretion to control and adjust such defaulted service
preferences that relate to My account.
E. Knowledge of Account.
I understand that I am solely responsible for knowing the rights and terms for all securities purchased,
sold and maintained in My Account including mergers, reorganizations, stock splits, name changes or
symbol changes, dividends, option symbols, and option deliverables. I further understand that certain
securities may grant Me valuable rights that may expire unless I take specific action. These securities
include bonds, convertible securities, warrants, stock rights and securities subject to exchange offers or
tenders. I am responsible for knowing all expiration dates, redemption dates, and the circumstances
under which rights associated with My securities may be called, cancelled, or modified. Robinhood may,
but are not obligated to, notify Me of any upcoming expiration or redemption dates, or take any action on
My behalf without My specific instructions except as required by law and the rules of regulatory
authorities. I acknowledge that Robinhood may adjust My Account to correct any error. If My Account
has an option position on the last trading day prior to expiration, which is one cent or more in the money,
Robinhood Financial will generally exercise the option, on My behalf. However, Robinhood Financial
reserves the right at Its discretion to close any option position prior to expiration date or any position
resulting from the exercising/assignment after option expiration. I will be charged a commission for any
such transaction. Robinhood Financial is not obligated to take any of these actions and Robinhood
Financial is not liable for Losses should it not take them.
F. Purchases.
All orders for the purchase of securities given for My Account will be authorized by Me and executed in
reliance on My promise that an actual purchase is intended. It is My obligation to pay for purchases
immediately or on Robinhood's demand. I understand Robinhood may at any time, in its sole discretion
and without prior notice to Me, prohibit or restrict My ability to trade securities. I further agree not to
allow any person to trade for My Account unless a trading authorization for that person has been
received and approved by Robinhood. Robinhood reserve the right to require full payment in cleared
funds prior to the acceptance of any order. In the event that I fail to provide sufficient funds, Robinhood
may, at its option and without notice to Me, i) charge a reasonable rate of interest, ii) liquidate the
Property subject of the buy order, or iii) sell other Property owned by Me and held in any of My Accounts.
Robinhood may also charge any consequential Loss to My Account. For purposes of this Agreement,
"Property" shall mean all monies, contracts, investments and options, whether for present or future
delivery, and all related distributions, proceeds, products and accessions.
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G. Sales/Short Sales.
I promise to deliver all securities sold in My Account and to provide collateral of a type and amount
acceptable to Robinhood Financial for all short sales in My Account. Robinhood Financial requires that a
security be held in My Account prior to the acceptance of a sell order with respect to such security
unless the order is specifically designated as a "short sale." If a security is not held in My Account and a
sell order is processed, I must promptly deliver such security to Robinhood Financial for receipt in good
deliverable form on or before the settlement date. Any order accepted without negotiable certificates or
positions in My Account will be subject, at Robinhood Financial's sole discretion, to cancellation or buy-
in. To ensure this will not occur, I agree to only place sell orders for securities owned by Me and held in
My Account at the time My order is placed.
Proceeds of a sale will not be paid to Me or released into My Account until Robinhood Financial has
received the security in good deliverable form, whether from a transfer agent or from Me and the
settlement of the security is complete. If the security is not received on or before settlement date, or as
market conditions warrant, Robinhood Financial may in its sole discretion purchase the security on the
open market for My Account and may liquidate and close out any and all securities in My Account in
order to pay for such purchase. In the event a security is bought in, I will be responsible for all resulting
Losses incurred by Robinhood Financial.
I understand that I may execute short sales only in a margin Account and that such execution must
comply with applicable short sales rules.
H. Assistance by Robinhood.
I understand that when I request assistance from Robinhood or its employees in using the investment
tools available on the Website or the App, it will be limited to an explanation of the tool's functionality
and, if requested by Me, to the entry by Robinhood or its employees of variables provided by Me, and
that such assistance does not constitute investment advice, an opinion with respect to the suitability of
any transaction, or solicitation of any orders.
I. No Tax or Legal Advice.
I understand that Robinhood does not provide tax or legal advice.
J. Discontinuation of Services.
I understand that Robinhood may discontinue My Account and any services related to My Account
immediately by providing written notice to Me
K. Electronic Access.
I am solely responsible for keeping My Account numbers and PINs confidential and will not share
them with third parties. "PINs" shall mean My username and password.
I agree and accept full responsibility for monitoring and safeguarding My Accounts and access to
My Accounts.
I agree to immediately notify Robinhood in writing, delivered via e-mail and a recognized
international delivery service, if I become aware of: (i) any loss, theft, or unauthorized use of My
PINs or Account numbers; (ii) any failure by Me to receive any communication from Robinhood
indicating that an order was received, executed or cancelled, as applicable; (iii) any failure by Me
to receive an accurate written confirmation of an order, execution, or cancellation; (iv) any receipt
by Me of confirmation of an order, execution or cancellation, which I did not place; (v) any
1.
2.
3.
7
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inaccurate information in or relating to My orders, trades, margin status, Account balances,
deposits, withdrawals, securities positions or transaction history; or (vi) any other unauthorized
use or access of My Account.
Each of the events described in subsections (K)(3)(i)-(vi) shall be deemed a "Potential Fraudulent
Event". The use and storage of any information including My Account numbers, PINs, portfolio
information, transaction activity, account balances and any other information or orders available
on My wireless, web-enabled cellular telephone or similar wireless communications device
(collectively, "Mobile Device") or My personal computer is at My own risk and is My sole
responsibility. I represent that I am solely responsible for and have authorized any orders or
instructions appearing in, originating from, or associated with My Account, My Account number,
My username and password, or PINs. I agree to notify Robinhood immediately after I discover
any Potential Fraudulent Event, but in no event more than twenty-four (24) hours following
discovery. Upon request by Robinhood, I agree to report any Potential Fraudulent Event promptly
to legal authorities and provide Robinhood a copy of any report prepared by such legal authorities.
I agree to cooperate fully with the legal authorities and Robinhood in any investigation of any
Potential Fraudulent Event and I will complete any required affidavits promptly, accurately and
thoroughly. I also agree to allow Robinhood access to My Mobile Device, My computer, and My
network in connection with Robinhood's investigation of any Potential Fraudulent Event. I
understand that if I fail to do any of these things I may encounter delays in regaining access to
the funds in My Account. I agree to indemnify and hold Robinhood, its Affiliates, and Robinhood
and its Affiliates' respective officers, directors, and employees harmless from and against any
Losses arising out of or relating to any Potential Fraudulent Event. I acknowledge that Robinhood
does not know when a person entering orders with My username and password is Me.
Trusted Contact Person. I understand that, pursuant to FINRA regulations, Robinhood is
authorized to contact the Trusted Contact Person (as defined by FINRA Rule 4512) designated
for My Account and to disclose information about My account to address possible financial
exploitation, to confirm the specifics of My current contact information, health status, or the
identity of any legal guardian, executor, trustee or holder of a power of attorney, or as otherwise
permitted by Rule 2165.
6. Clearance of Trades.
I understand that Robinhood Financial has entered into a clearing agreement with Robinhood Securities
whereby Robinhood Financial will introduce My Account to Robinhood Securities, and Robinhood
Securities will clear all transactions, on a fully-disclosed basis. I understand that Robinhood Securities
carries My Account(s) and is responsible for the clearing and bookkeeping of transactions, but is not
otherwise responsible for the conduct of Robinhood Financial.
Until receipt from Me of written notice to the contrary, Robinhood Securities may accept from Robinhood
Financial, without inquiry or investigation, (i) orders for the purchase or sale of securities and other
property on margin, if I have elected to have a margin account, or otherwise, and (ii) any other
instructions concerning my Accounts. Robinhood Securities shall look solely to Robinhood Financial
unless otherwise directed by Robinhood Financial, and not to Me, with respect to any such orders or
instructions; except that I understand that Robinhood Securities will deliver confirmations, statements,
and all written or other notices with respect to My Account directly to Me with copies to Robinhood
Financial, and that Robinhood Securities will look directly to Me or Robinhood Financial for delivery of
margin, payment, or securities. I agree to hold Robinhood Securities harmless from and against any
Losses arising in connection with the delivery or receipt of any such communication(s), provided
Robinhood Securities has acted in accordance with the above. The foregoing shall be effective as to My
Account(s) until written notice to the contrary is received from Me by Robinhood Securities or Robinhood
Financial.
7. Review of Confirmations and Statements.
I agree that it is My responsibility to review order execution confirmations and statements of My
Account(s) promptly upon receipt. I agree to receive all confirmations and account statements, as well
as all tax related documents, in electronic format. I understand that account statements will evidence all
activity in My Account for the stated period, including securities transactions, cash balances, credits to
My Account and all fees paid from My Account. Notwithstanding Section 36.B, confirmations will be
considered binding on Me unless I notify Robinhood of any objections within two (2) calendar days from
the date confirmations are sent. Account statements will be considered binding on Me unless I notify you
4.
5.
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of any objections within ten (10) calendar days after My Account statements are posted online. Such
objection may be oral or in writing, but any oral objection must be immediately confirmed in writing. In all
cases, Robinhood reserves the right to determine the validity of My objection. If I object to a transaction
for any reason, I understand and agree that I am obligated to take action to limit any losses that may
result from such transaction or I will bear sole responsibility for any losses relating to the transaction,
even if My objection to the transaction is ultimately determined to be valid. Nothing in this Section 7
shall limit My responsibilities as described in Section 5 of this Agreement.
8. Important Information Needed to Open a New Account.
To help the government better detect the funding of terrorism and money laundering activities, federal
law requires all financial institutions to obtain, verify, and record information that identifies each person
who opens an account. Therefore, I understand that when I open My Account Robinhood will ask for My
name, address, date of birth and other identifying information. Robinhood may also ask copies of My
driver's license, passport or other identifying documents. I understand that Robinhood may take steps to
verify the accuracy of the information I provide to Robinhood in My Account application or otherwise, and
that Robinhood may restrict My access to My Account pending such verification. I will provide prompt
notification to Robinhood of any changes in the information including My name, address, e-mail address
and telephone number.
I further understand that if I attempt to access My Account from a jurisdiction subject to certain U.S.
sanctions or I am ordinarily resident in such a jurisdiction, or if you reasonably believe that I am
attempting such access or have become a resident in such a jurisdiction, you may restrict My Account,
and any pending orders may be cancelled. If this happens, I understand that I should contact
help@robinhood.com, and that I may be asked to provide supplemental information as part of this
process. I further understand that I must close My Account before establishing residency in any
jurisdiction subject to U.S. sanctions.
9. Telephone Conversations and Electronic Communications.
I understand and agree that Robinhood may record and monitor any telephone or electronic
communications with Me. Unless otherwise agreed in writing in advance, Robinhood does not consent
to the recording of telephone conversations by any third party or Me. I acknowledge and understand that
not all telephone or electronic communications are recorded by Robinhood, and Robinhood does not
guarantee that recordings of any particular telephone or electronic communications will be retained or
capable of being retrieved.
10. Oral Authorization.
I agree that Robinhood shall be entitled to act upon any oral instructions given by Me so long as
Robinhood reasonably believes such instruction was actually given by Me or My authorized agent.
11. Applicable Laws and Regulations.
All transactions in My Account will be subject to federal securities laws and regulations, the applicable
laws and regulations of any state or jurisdiction in which Robinhood Financial is registered, the rules of
any applicable self-regulatory organization of which Robinhood Financial is a member and the rules,
regulations, customs and usages of the exchange or market, and its clearing house, if any, where the
transactions are executed. In no event will Robinhood Financial be obligated to effect any transaction it
believes would violate any federal or state law, rule or regulation or the rules or regulations of any
regulatory or self-regulatory organization.
12. Erroneous Distributions.
I agree to promptly return to Robinhood any assets erroneously distributed to Me. In the event that I sell
a security prior to its ex-dividend/distribution date, and I receive the related cash/stock dividend or
distribution in error, I direct Robinhood on My behalf to pay such dividend/distribution to the entitled
purchaser of the securities I sold, and I guarantee to promptly reimburse Robinhood for, or deliver to
Robinhood, said dividend or distribution.
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13. Market Volatility; Market Orders; Limit Orders; and Queued Orders.
I understand that, whether I place a market or limit order, I will receive the price at which My order is
executed in the marketplace, subject to any clarification stated below. Particularly during periods of high
volume, illiquidity, fast movement or volatility in the marketplace, the execution price received may differ
from the quote provided on entry of an order, and I may receive partial executions of an order at different
prices. I understand that Robinhood Financial is not liable for any price fluctuations. I also understand
that price quotes generally are for only a small number of shares as specified by the marketplace, and
larger orders are relatively more likely to receive executions at prices that vary from the quotes or in
multiple lots at different prices.
I understand that Robinhood Financial does not currently support sending traditional market buy orders
and that Robinhood Financial collars all market buy orders (other than dollar-based buy orders executed
during market hours) by using limit orders priced up to 5% above the last trade price. This is not the
case for market sell orders. I further understand that when I send a market buy order through Robinhood
Financial's trading system, the trading system generates a limit order up to 5% above the last trade
price, and then Robinhood Financial sends the order to an executing broker. I understand that Robinhood
Financial's implementation of market buy orders may vary depending on prices of instruments, market
conditions, and other factors. I further understand that Robinhood Financial uses the following rounding
mechanics with respect to buy orders: the last trade price is (i) multiplied by 1.05; (ii) rounded down to
two decimal places if the last trade price is over $1.00; otherwise, rounded down to four decimal places;
and (iii) for securities included in the SEC's Tick Size Pilot Program, rounded down to the nearest $.05
increment. I understand that securities may open for trading at prices substantially higher or lower than
the previous closing price or the anticipated price. If I place a market order (whether during normal
market hours or when the market is closed), I agree to pay or receive the prevailing market price at the
time My market order is executed, subject to the specific clarification above relating to buy orders. I
understand that the price I pay may be significantly higher or lower than anticipated at the time I placed
the order. To avoid buying a security at a higher price and possibly exceeding My purchasing power, I
understand My option to enter a limit order. I also understand that limit orders may not be executed at
any particular time, or at all, if there is not sufficient trading at or better than the limit price I specify, and
are only good until the end of the trading day in which they are entered. The Website contains further
information regarding order types and limitations, which I agree to read and understand before placing
such orders.
As a customer of Robinhood Financial, I understand that after the market has closed for the day, I have
the ability to place in a queue order requests to be executed the following day upon the opening of the
market ("Queued Order"). I understand that My Queued Order request is prioritized based on the order in
which it is received by Robinhood Financial, and that the Queued Order requests are sent out for
execution shortly after the market opens on the next day of trading. I further understand that each
Queued Order request is sent out per customer and per security as Robinhood Financial market orders
(described above), and that they are not aggregated.
A limit order may be "good till cancelled" which means the order remains valid until (A) it is executed; (B)
I cancel the order; (C) approximately 90 days from when the order is placed; or (D) the contract to which
it relates is closed. I understand that Robinhood will cancel a "good till cancelled" order at the end of
every trading day (on the exchange on which the instrument to which the contract relates is traded) and
place such order again at the start of the following trading day. This process will be repeated every day
for as long as the "good till cancelled" order remains valid. I further agree that any "good till cancelled"
orders I place should be treated as "do not reduce" orders.
14. Bulletin Board/Pink Sheet Stocks.
Bulletin board, pink sheet and other thinly-traded securities (collectively "bulletin board stocks") present
particular trading risks, in part because they are relatively less liquid and more volatile than actively
traded securities listed on a major exchange. I understand that bulletin board stocks may be subject to
different trading rules and systems than other securities and that I may encounter significant delays in
executions, reports of executions, and updating of quotations in trading bulletin board stocks. Robinhood
Financial in its sole discretion may require limit orders on certain bulletin board stock transactions.
15. Research and Internet Links.
News, research, links to outside websites, and other information accessible through the App or Website
("Content") may be prepared by independent external providers not affiliated with Robinhood Financial,
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including Morningstar, Inc. (all such providers, the "Providers"). I agree not to distribute, reproduce, sell,
or otherwise commercially use the Content in any manner. I understand that Robinhood may terminate
My access to the Content. I understand that none of the Content is a recommendation by Robinhood to
buy or sell any securities or to engage in any investment strategy.
16. Restrictions on Trading.
I understand that Robinhood may, in its discretion, prohibit or restrict the trading of securities, or the
substitution of securities, in any of My Accounts. I understand that Robinhood may execute all orders by
Me on any exchange or market, unless I specifically instruct Robinhood to the contrary. In the event of a
breach or default by Me under this Agreement, Robinhood shall have all rights and remedies available to
a secured creditor under all applicable laws and in addition to the rights and remedies provided herein. I
understand that Robinhood may at any time, at its sole discretion and without prior notice to Me: (i)
prohibit or restrict My access to the use of the App or the Website or related services and My ability to
trade, (ii) refuse to accept any of My transactions, (iii) refuse to execute any of My transactions, or (iv)
terminate My Account. The closing of My Account will not affect the rights or obligations of either party
incurred prior to the date My Account is closed.
Further, Robinhood will not tolerate any foul or abusive language, physical violence, threatening behavior,
or other inappropriate conduct directed toward Robinhood, its Affiliates' officers, employees, contractors
or customers. If I engage in any such behavior, as determined by Robinhood in its sole discretion, I
agree that Robinhood is authorized to: (i) liquidate any securities, instruments or other property in My
Account, (ii) send Me the proceeds, and (iii) close My account. Robinhood will not be responsible for any
Losses caused by the liquidation of securities, instruments or other property pursuant to this paragraph,
including any tax liabilities.
17. Waiver; Limitation of Liability; Indemnification.
I agree that My use of the App or the Website or any other service provided by Robinhood Financial or
its Affiliates is at My sole risk. The Robinhood Financial service (including the App, the Website, the
provision of Market Data, Information, Content, or any other information provided by Robinhood
Financial, any of its Affiliates, or any third-party content provider or market data provider) is provided on
an "as is," "as available" basis without warranties of any kind, either express or implied, statutory
(including without limitation, timeliness, truthfulness, sequence, completeness, accuracy, freedom from
interruption), implied warranties arising from trade usage, course of dealing, course of performance, or
the implied warranties of merchantability or fitness for a particular purpose or application, other than
those warranties which are implied by and incapable of exclusion, restriction or modification under the
laws applicable to this Agreement.
Although considerable effort is expended to make the Website, App and other operational and
communications channels available around the clock, Robinhood does not warrant that these channels
will be available and error free every minute of the day. I agree that Robinhood will not be responsible for
temporary interruptions in service due to maintenance, Website or App changes, or failures, nor shall
Robinhood be liable for extended interruptions due to failures beyond our control, including but not limited
to the failure of interconnecting and operating systems, computer viruses, forces of nature, labor
disputes and armed conflicts.
EXCEPT AS OTHERWISE EXPRESSLY PROVIDED IN THIS AGREEMENT, I UNDERSTAND AND
AGREE THAT ROBINHOOD, ITS AFFILIATES, THEIR RESPECTIVE OFFICERS, DIRECTORS,
EMPLOYEES AND AGENTS, AND THE PROVIDERS (COLLECTIVELY THE "ROBINHOOD
PARTIES") WILL NOT BE LIABLE TO ME OR TO THIRD PARTIES UNDER ANY
CIRCUMSTANCES, OR HAVE ANY RESPONSIBILITY WHATSOEVER, FOR ANY SPECIAL,
INDIRECT, INCIDENTAL, PUNITIVE OR CONSEQUENTIAL DAMAGES (INCLUDING TRADING
LOSSES, DAMAGES, LOSS OF PROFITS, REVENUE, OR GOODWILL) THAT I MAY INCUR IN
CONNECTION WITH MY USE OF THE SERVICE PROVIDED BY ROBINHOOD OR ANY OF ITS
AFFILIATES UNDER THIS AGREEMENT (INCLUDING MY USE OF THE APP, THE WEBSITE, THE
MARKET DATA, THE INFORMATION, OR THE CONTENT), BREACH OF THIS AGREEMENT, OR
ANY TERMINATION OF THIS AGREEMENT, WHETHER SUCH LIABILITY IS ASSERTED ON THE
BASIS OF CONTRACT, TORT (INCLUDING NEGLIGENCE), OR OTHERWISE, AND WHETHER OR
NOT FORESEEABLE, EVEN IF ANY ROBINHOOD PARTY HAS BEEN ADVISED OR WAS AWARE
OF THE POSSIBILITY OF SUCH LOSS OR DAMAGES. THE ROBINHOOD PARTIES SHALL NOT
BE LIABLE BY REASON OF DELAYS OR INTERRUPTIONS OF THE SERVICE OR
TRANSMISSIONS, OR FAILURES OF PERFORMANCE OF THEIR RESPECTIVE SYSTEMS,
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REGARDLESS OF CAUSE, INCLUDING THOSE CAUSED BY GOVERNMENTAL OR
REGULATORY ACTION, THE ACTION OF ANY EXCHANGE OR OTHER SELF REGULATORY
ORGANIZATION, OR THOSE CAUSED BY SOFTWARE OR HARDWARE MALFUNCTIONS.
Except as otherwise provided by law, Robinhood or any of its affiliates or respective partners, officers,
directors, employees or agents (collectively, "Indemnified Parties") shall not be liable for any expenses,
losses, costs, damages, liabilities, demands, debts, obligations, penalties, charges, claims, causes of
action, penalties, fines and taxes of any kind or nature (including legal expenses and attorneys' fees)
(whether known or unknown, absolute or contingent, liquidated or unliquidated, direct or indirect, due or
to become due, accrued or not accrued, asserted or unasserted, related or not related to a third party
claim, or otherwise) (collectively, "Losses") by or with respect to any matters pertaining to My Account,
except to the extent that such Losses are actual Losses and are determined by a court of competent
jurisdiction or an arbitration panel in a final non-appealable judgment or order to have resulted solely from
Robinhood's or any of its affiliates' gross negligence or intentional misconduct. In addition, I agree that
the Indemnified Parties shall have no liability for, and I agree to indemnify, defend and hold harmless the
Indemnified Parties from all Losses that result from: (i) any noncompliance by Me with any of the terms
and conditions of this Agreement; (ii) any third-party actions related to My receipt and use of any
Information, Market Data, Content, market analysis, other third-party content, or other such information
obtained on the App or Website, whether authorized or unauthorized under this Agreement; (iii) any third-
party actions related to My use of the App or the Website; (iv) My or My agent's misrepresentation or
alleged misrepresentation, or act or omission; (v) Indemnified Parties following My or My agent's
directions or instructions, or failing to follow My or My agent's unlawful or unreasonable directions or
instructions; (vi) any activities or services of the Indemnified Parties in connection with My Account
(including any technology services, reporting, trading, research or capital introduction services); or (vii)
the failure by any person not controlled by the Indemnified Parties and their affiliates to perform any
obligations to Me. Further, if I authorize or allow third parties to gain access to Robinhood's services,
including My Accounts, I will indemnify, defend and hold harmless the Indemnified Parties against any
Losses arising out of claims or suits by such third parties based upon or relating to such access and
use. Robinhood does not warrant against loss of use or any direct, indirect or consequential damages or
Losses to Me caused by My assent, expressed or implied, to a third party accessing My Account or
information, including access provided through any other third party systems or sites.
I consent to the use of automated systems or service bureaus by Robinhood and its respective affiliates
in conjunction with My Account, including automated order entry and execution, record keeping, reporting
and account reconciliation and risk management systems (collectively "Automated Systems"). I
understand that the use of Automated Systems entails risks, such as interruption or delays of service,
errors or omissions in the information provided, system failure and errors in the design or functioning of
such Automated Systems (collectively, a "System Failure") that could cause substantial damage,
expense, or liability to Me. I understand and agree that Indemnified Parties will have no liability
whatsoever for any of my Losses arising out of or relating to a System Failure.
I also agree that Indemnified Parties will have no responsibility or liability to Me in connection with the
performance or non-performance by any exchange, clearing organization, market data provider, or other
third party (including other broker-dealers and clearing firms, and banks) or any of their respective agents
or affiliates, of its or their obligations relative to any securities. I agree that Indemnified Parties will have
no liability, to Me or to third parties, or responsibility whatsoever for: (i) any Losses resulting from a
cause over which Indemnified Parties do not have direct control, including the failure of mechanical
equipment, unauthorized access, theft, operator errors, government restrictions, force majeure (as
defined in this Agreement), market data availability or quality, exchange rulings or suspension of trading;
and (ii) any special, indirect, incidental, consequential, punitive or exemplary damages (including lost
profits, trading losses and damages) that I may incur in connection with My use of the App, the Website,
Robinhood's brokerage, and other services provided by Indemnified Parties under this Agreement.
18. Mutual Fund Transactions.
In the event that I purchase or hold a mutual fund, I agree to read and understand the terms of its
prospectus. I understand that certain mutual funds reserve the right to change their purchasing,
switching or redemption procedures or suspend or postpone redemptions under certain market
conditions. I further understand that any mutual fund order entered with Robinhood is placed by
Robinhood on a best efforts basis as prescribed and recognized by the individual fund, and that
Robinhood is not responsible for unexecuted orders due to the failure of any communication system. I
agree to be fully responsible for the information contained within the mutual fund prospectus and to hold
Robinhood, its Affiliates, and Robinhood and its Affiliates' respective officers and employees harmless
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for any deficiencies contained therein. I authorize Robinhood to act as My agent in the purchase and
redemption of fund shares.
19. Exchange Traded Funds.
I understand that I should consider the investment objectives and unique risk profile of Exchange Traded
Funds ("ETFs") carefully before investing, and that ETFs are subject to risks similar to those of other
diversified portfolios. I further understand that leveraged and inverse ETFs may not be suitable for all
investors and may increase exposure to volatility through the use of leverage, short sales of securities,
derivatives, and other complex investment strategies, and that although ETFs are designed to provide
investment results that generally correspond to the performance of their respective underlying indices,
they may not be able to exactly replicate the performance of the indices because of expenses and other
factors. I further understand that ETFs are required to distribute portfolio gains to shareholders at year
end, which may be generated by portfolio rebalancing or the need to meet diversification requirements,
and that ETF trading will also generate tax consequences. I understand that I can obtain prospectuses
from issuers or their third party agents who distribute and make prospectuses available for review.
Additional regulatory guidance on ETFs can be found here.
20. Effect of Attachment or Sequestration of Accounts.
Robinhood shall not be liable for refusing to obey any orders given by or for Me with respect to any of
My Accounts that has or have been subject to an attachment or sequestration in any legal proceeding
against Me, and Robinhood shall be under no obligation to contest the validity of any such attachment or
sequestration.
21. Event of Death.
It is agreed that in the event of My death, the representative of My estate or the survivor or survivors
shall immediately give Robinhood written notice thereof, and Robinhood may, before or after receiving
such notice, take such proceedings, require such papers and inheritance or estate tax waivers, retain
such portion of, or restrict transactions in the Account as Robinhood may deem advisable to protect
Robinhood against any tax, liability, penalty or loss under any present or future laws or otherwise.
Notwithstanding the above, in the event of My death, all open orders shall be canceled, but Robinhood
shall not be responsible for any action taken on such orders prior to the actual receipt of notice of death.
Further, Robinhood may in Its discretion close out any or all of the Accounts without awaiting the
appointment of a personal representative for My estate and without demand upon or notice to any such
personal representative. The estate of any of the Account holders who have died shall be liable and each
survivor shall continue to be liable, jointly and severally, to Robinhood for any net debit balance or loss in
said account in any way resulting from the completion of transactions initiated prior to the receipt by
Robinhood of the written notice of the death of the decedent or incurred in the liquidation of the Account
or the adjustment of the interests of the respective parties, and for all other obligations pursuant to this
Agreement. Such notice shall not affect Robinhood's rights under this Agreement to take any action that
Robinhood could have taken if I had not died.
22. Tax Reporting; Tax Withholding.
The proceeds of sale transactions and dividends paid will be reported to the Internal Revenue Service
("IRS") in accordance with applicable law.
A. U.S. Persons.
This subsection is applicable if I am a U.S. person. Under penalties of perjury, I certify that the taxpayer
identification number that I have provided or will provide to Robinhood (including any taxpayer
identification number on any Form W-9 that I have provided or will provide to Robinhood) is My correct
taxpayer identification number. I certify that I am not subject to backup withholding and I am a United
States Person (including a U.S. resident alien) as such term is defined in section 7701(a)(30) of the
Internal Revenue Code of 1986, as amended ("U.S. Person"). If a correct Taxpayer Identification
Number is not provided Robinhood Financial, I understand I may be subject to backup withholding tax at
the appropriate rate on all dividends, interest and gross proceeds paid to me. Backup withholding taxes
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are sent to the IRS and cannot be refunded by Robinhood Financial. I further understand that if I waive
tax withholding and fail to pay sufficient estimated taxes to the IRS, I may be subject to tax penalties.
B. Non-U.S. Persons.
This subsection is applicable if I am not a U.S. Person. I certify that I fully understand all the information
on any Form W-8BEN that I have submitted or will submit to Robinhood. Under penalties of perjury, I
declare that (i) I have examined all the information (including all the information in the English language)
on any Form W-8BEN that I have submitted or will submit to Robinhood and (ii) to the best of My
knowledge and belief all such information is true, correct, and complete. I authorize Robinhood to
provide any such Form W-8BEN to Robinhood Securities or any withholding agent that has control,
receipt, or custody of the income of which I am the beneficial owner or any withholding agent that can
disburse or make payments of the income of which I am the beneficial owner. I agree that I will submit a
new Form W-8BEN to Robinhood within 30 calendar days if any certification made on any previously
submitted Form W-8BEN becomes incorrect. I understand that the IRS does not require My consent to
any provisions of such Form W-8BEN other than the certifications required to establish My status as a
non-U.S. Person and, if applicable, obtain a reduced rate of withholding.
23. Equity Orders and Payment For Order Flow.
SEC rules require all registered broker-dealers to disclose their policies regarding any "payment for order
flow" arrangement in connection with the routing of customer orders. "Payment for order flow" includes,
among other things, any monetary payment, service, property, or other benefit that results in
remuneration, compensation, or consideration to a broker-dealer from any broker-dealer in return for
directing orders. I understand that Robinhood transmits customer orders for execution to various
exchanges or market centers based on a number of factors. These include: size of order, trading
characteristics of the security, favorable execution prices (including the opportunity for price
improvement), access to reliable market data, availability of efficient automated transaction processing
and reduced execution costs through price concessions from the market centers. I further understand
that certain of the exchanges or market centers may execute orders at prices superior to the publicly
quoted market in accordance with their rules or practices and that while a customer may specify that an
order be directed to a particular market center for execution, the order-routing policies, taking into
consideration all of the factors listed above, are designed to result in favorable transaction processing for
customers. The nature and source of any payments or credits received by Robinhood in connection with
any specific transactions will be furnished upon written request.
24. Free Credit Balances and Sweep Service.
If I enroll in Robinhood Financial Cash Management ("Cash Management"), I understand that I am
electing to participate in the Insured Network Deposit ("IND") sweep service (the "Sweep Service").
Under the Sweep Service, free credit balances in My Account will be deposited into interest-bearing
accounts at one or more banks ("Participating Depository Institutions"), in accordance with the Insured
Network Deposit Sweep Program Disclosures ("IND Disclosures") available on the Website and in the
App. By enrolling in Cash Management, I represent and warrant that I have reviewed the IND
Disclosures and agree to the terms set forth in the IND Disclosures. If I am not enrolled in Cash
Management, free credit balances in My Account will remain in My Account, will not earn interest and
will not be eligible for FDIC insurance, but will be eligible for SIPC protection as described in the IND
Disclosures.
25. Fees and Charges.
I understand that Robinhood does not charge fees or commissions for executing buy and sell orders.
However, I understand that other fees may apply. The current fees are included in the fee schedule
available in the App and on the Website. I agree to pay any such fees at the then-prevailing rate. I
acknowledge that the prevailing fees may change and that change may occur without notice. I agree to
be bound by such changes once they are posted in the fee schedule available in the App and on the
Website. I also agree to pay all applicable federal, state, local, and foreign taxes. I authorize Robinhood
Financial to automatically debit My Account for any such fees and taxes. I also agree to pay such
expenses incurred by Robinhood in connection with collection of any unpaid balance due on My
Accounts including attorney's fees allowed by law.
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26. ACH Transactions.
A. Debit Transactions.
Robinhood will initiate an ACH debit at My request to debit funds from an account that I own at another
financial institution ("External Account") for deposit into My Account. I understand that in order for
Robinhood to initiate an ACH debit, the financial institution holding my External Account must participate
in the ACH system. I understand that for the ACH transfers to be established, at least one common
name must match exactly between My Account and My External Account. I authorize Robinhood to take
such steps as it deems appropriate to verify my ownership of External Account, including by telling the
bank at which such External Account is held that I have authorized and consented to such bank
disclosing to Robinhood any information that Robinhood may request about Me or My External Account.
I also agree to cooperate with Robinhood's verification of my ownership of such External Account by
promptly providing any identification and/or other documentation that Robinhood may request regarding
such External Account. I represent and warrant that there are sufficient funds in My External Account to
cover the amount of the deposit to My Account. Robinhood will initiate the ACH debit to My External
Account on the Business Day or next Business Day after I request the transfer. A transfer request will be
deemed to have been made on a Business Day if it is received by Robinhood by 7:00 p.m. (Eastern
Time) on such Business Day; if received after that time, the transfer request will be deemed to have
been made on the next Business Day.
Within 60 days of the date of My ACH deposit, My funds may only be withdrawn to the External Account
from which such funds were debited.
I understand that an ACH debit transfer may be reversed or rejected if: (A) there are insufficient funds in
My External Account; (B) there is a duplicate transaction; (C) the transaction is denied by the bank
holding My External Account; or (D) My External Account does not support ACH transfers. I
acknowledge that in the event of an ACH reversal, I will incur a fee. Before initiating making an ACH
debit transfer, I agree to check Robinhood Financial's most recent Commissions and Fees Schedule. I
agree that I am solely liable and responsible for any ACH reversal fees that I incur.
B. Credit Transactions.
Robinhood will initiate an ACH credit at My request to transfer funds from My Account to a recipient that
I designate. I agree that I will have sufficient Available Funds in My Account to cover the amount of any
ACH credit that I ask Robinhood to initiate. Robinhood will debit the amount of such request from My
Account on the Business Day or next Business Day after I request the transfer. A transfer request will be
deemed to have been made on a Business Day if it is received by Robinhood on such Business Day; if
received after that time, the transfer request will be deemed to have been made on the next Business
Day.
I agree that Robinhood may use any means which Robinhood, in its sole discretion, considers suitable
to execute my ACH credit transfers.
27. Fractional Shares.
I acknowledge and understand that Robinhood rounds all holdings of fractional shares to the sixth
decimal place, the value of fractional shares to the nearest cent, and any dividends paid on fractional
shares to the nearest cent. I further understand that Robinhood will not accept dollar-based purchases or
sales of less than $1.00 and that I will receive proceeds from the sale of any whole or fractional shares
rounded to the nearest cent.
I understand that if I enter repeated fractional orders with individual notional values of less than $0.01,
my account may be restricted.
I understand that a vendor employed by Robinhood will aggregate any proxy votes for fractional shares
of Robinhood’s customers with all votes reported to the issuer or issuer’s designated vote tabulator and
that, while Robinhood’s vendor will report such proxy votes on fractional shares, the issuer or tabulator
may not fully count such votes.
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I understand that Robinhood will execute all orders that include fractional shares ("Fractional Orders") on
a principal basis. To the extent that Robinhood must purchase or sell shares in the market to fulfill any
part of my Fractional Order, the fractional component of that order will be fulfilled at the execution price
Robinhood received for the corresponding whole shares. To the extent that Robinhood fulfills my
Fractional Order for national exchange-listed securities ("NMS Securities") entirely out of its inventory
and without purchasing or selling shares in the market ("Inventory Fulfillment"), Robinhood will endeavor
to price such shares or fractional shares at a price between the National Best Bid and Offer (“NBBO”) at
the time of the order for orders made during market hours, or, for such orders made during extended
hours trading (9:00-9:30 a.m. and 4:00-6:00 p.m. Eastern), Robinhood will endeavor to price such orders
between the best bid and offer at the time of the order, as reported by an external vendor ("Vendor
BBO"). For Inventory Fulfillment of Fractional Orders for securities not listed on a national exchange
("Non-NMS Securities") made during market hours as well as extended hours trading, Robinhood will
endeavor to price such orders between Vendor BBO.
All non-market orders placed outside market hours and extended hours trading are queued and fulfilled
either at or near the beginning of extended hours trading (9:00 a.m. Eastern) or at or near market open
(9:30 a.m. Eastern), according to my instructions. All market orders placed outside market hours and
extended hours trading are queued and fulfilled at or near market open. To the extent that I trade outside
of market hours, these trades are subject to Robinhood’s Extended Hours Trading Disclosure.
I understand Robinhood only accepts market orders for fractional shares at this time and does not permit
limit orders for fractional shares. I understand that fractional shares within My Account (i) are
unrecognized, unmarketable, and illiquid outside the Robinhood platform, (ii) are not transferrable in-kind,
and (iii) may only be liquidated and the proceeds transferred out via a wire transfer. I acknowledge that,
subject to applicable requirements, Robinhood may report holdings and transactions in My Account in
terms of either U.S. Dollars, shares, or both.
28. Phone Calls.
You agree that, by providing information Robinhood requests, Robinhood and its third party services
providers may contact you via mail, phone or email.
Specifically, if you provide us with a phone number: (a) you represent and warrant that the number you
provide is your phone number, and you will promptly notify us if that changes, and (b) you consent to
receive calls (including text messages) made to that phone number that may be prerecroded and/or
completed with an automatic telephone dialing system (automated calls) for purposes including but not
limited to providing account-related communications (including security alerts), investigating or
preventing fraud, and/or collecting amounts owed to Robinhood. We may share your number with third
parties that provide services to us in connection with any of the foregoing purposes, including but not
limited to debt collectors. You understand that message, telephone minute and data rates may apply for
calls made to a mobile phone number. You may opt out at any time from receiving these types of calls
orally or in writing to limitsharing@robinhood.com. Please note, even if you opt out, we may still make
other calls as permitted by law.
You consent to our recording of phone calls, including calls we make to you or that we receive from you.
29. Dividend Reinvestment Program.
Except as expressly stated otherwise, the provisions of this Section 29 will only apply if I am enrolled in
Robinhood’s Dividend Reinvestment Program (“DRIP”). My enrollment in the DRIP will be activated
within three business days after I notify Robinhood of my intention to enroll an eligible security through
the App. “Eligible security” means all shares available for fractional investing through Robinhood. I
understand that in order to be eligible for dividend reinvestment, the securities must be held in My
Account.
I may specify individual securities or have all Eligible securities in My Account enrolled for dividend
reinvestment. If I choose to reinvest dividends from all Eligible securities, I understand that individual
securities could subsequently no longer be Eligible securities at Robinhood’s discretion or under
applicable law. In those cases, only those securities will be discontinued from the DRIP. If I specify
individual securities, I may add additional Eligible securities to the DRIP at any time if I hold a position
in those securities. Enrollment with respect to these additional Eligible securities will be effective within
three business days after Robinhood receives notification from me through the App. If I maintain open
orders for securities I do not already hold, I may not enroll those securities for dividend reinvestment
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E. Margin.
I agree to maintain in all accounts with Robinhood such positions and margins as required by all
applicable statutes, rules, regulations, procedures and custom, or as you deem necessary or advisable. I
agree to promptly satisfy all margin and maintenance calls.
F. Sales.
I agree to specifically designate any order to sell a security, which I do not own as a short sale, and
understands that Robinhood will mark such order as a short sale. I agree that any order which is not
specifically designated as a short sale is a sale of securities owned by me, and that I will deliver the
securities on or before settlement date, if not already in the account. If I should fail to make such
delivery in the time required, Robinhood is authorized to borrow such securities as necessary to make
delivery for the sale, and I agree to be responsible for any loss you may thereby sustain, or which you
may sustain as a result of your inability to borrow such securities.
36. Consent to Electronic Delivery of Documents.
A. Consent.
By agreeing to electronic delivery, I am giving My informed consent to electronic delivery of all
Account Documents, as defined below, other than those I have specifically requested to be
delivered in paper form. "Account Documents" include notices, disclosures, current and future account
statements, regulatory communications (such as prospectuses, proxy solicitations, and privacy notices),
trade confirmations, tax-related documents, and any other information, documents, data, and records
regarding My Account, this Agreement (including amendments to this Agreement), and the agreements
and disclosures governing the services delivered or provided to Me by Robinhood Financial, the issuers
of the securities or other property in which I invest, and any other parties. I agree that I can access,
view, download, save, and print any Account Documents I receive via electronic delivery for My records.
B. Electronic Delivery System.
I acknowledge that Robinhood's primary methods of communication with Me include (A) posting
information on the Website, (B) providing information via the App, (C) sending email(s) to My email
address of record, and, to the extent required by law, (D) providing Me with notice(s) that will direct Me
to the App or the Website where I can read and print such information. Unless otherwise required by law,
Robinhood reserves the right to post Account Documents on the Website without providing notice to Me.
Further, Robinhood reserves the right to send Account Documents to My postal or email address of
record, or via the App or Website. I agree that all Account Documents provided to Me in any of the
foregoing manner is considered delivered to Me personally when sent or posted by Robinhood, whether I
receive it or not.
All e-mail notifications regarding Account Documents will be sent to My e-mail address of record. I agree
to maintain the e-mail address that I have provided Robinhood until I provide Robinhood with a new one.
I understand that e-mail messages may fail to transmit promptly or properly, including being delivered to
SPAM folders. I further understand that it is My sole responsibility to ensure that any emails from
Robinhood or its Affiliates are not marked as SPAM. Regardless of whether or not I receive an e-mail
notification, I agree to check the Website regularly to avoid missing any information, including time-
sensitive or otherwise important communication. If I authorize someone else to access the e-mail
account I have provided Robinhood, I agree to tell them to share the Account Documents with Me
promptly, and I accept the risk that they will see My sensitive information. I understand that if I use a
work e-mail address or computing or communications device, My employer or other employees may
have access to the Account Documents.
Additionally, I acknowledge that the Internet is not a secure network and agree that I will not send any
confidential information, including Account numbers or passwords, in any unencrypted e-mails. I also
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understand that communications transmitted over the Internet may be accessed by unauthorized or
unintended third parties and agree to hold Robinhood, its Affiliates, and Robinhood and its Affiliates'
respective officers and employees harmless for any such access regardless of the cause.
I agree to promptly and carefully review all Account Documents when they are delivered and notify
Robinhood Financial in writing within five (5) calendar days of delivery if I object to the information
provided (or other such time specified herein). If I fail to object in writing within such time, Robinhood
Financial is entitled to treat such information as accurate and conclusive. I will contact Robinhood to
report any problems with accessing the Account Documents.
C. Costs.
Potential costs associated with electronic delivery of Account Documents may include charges from
Internet access providers and telephone companies, and I agree to bear these costs. Robinhood
Financial will not charge Me additional online access fees for receiving electronic delivery of Account
Documents.
D. Archival.
Upon My request, I may obtain copies of up to six (6) prior years of account statements, and three (3)
prior years of trade confirmations.
E. Revocation of Consent.
Subject to the terms of this Agreement, I may revoke or restrict My consent to electronic delivery of
Account Documents at any time by notifying Robinhood Financial in writing of My intention to do so. I
also understand that I have the right to request paper delivery of any Account Document that the law
requires Robinhood Financial to provide Me in paper form. Robinhood Financial will not treat My request
for paper copies as a withdrawal of My consent to electronic delivery of Account Documents. I
understand that if I revoke or restrict My consent to electronic delivery of Account Documents or request
paper delivery of same, Robinhood Financial, in its sole discretion, may charge Me a reasonable service
fee for the delivery of any Account Document that would otherwise be delivered to Me electronically,
restrict or close My account, or terminate My access to Robinhood Financial's services. I understand
that neither My revocation or restriction of consent, My request for paper delivery, nor Robinhood
Financial's delivery of paper copies of Account Documents will affect the legal effectiveness or validity
of any electronic communication provided while My consent was in effect.
F. Duration of Consent.
My consent to receive electronic delivery of Account Documents will be effective immediately and will
remain in effect unless and until either I or Robinhood Financial revokes it. I understand that it may take
up to three (3) Business Days to process a revocation of consent to electronic delivery, and that I may
receive electronic notifications until such consent is processed.
G. Hardware and Software Requirements.
I understand that in order to receive electronic deliveries, I must have access to a computer or Mobile
Device with Internet access, a valid e-mail address, and the ability to download such applications as
Robinhood Financial may specify and to which I have access. I also understand that if I wish to
download, print, or save any information I wish to retain, I must have access to a printer or other device
in order to do so.
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H. Consent and Representations.
I hereby agree that I have carefully read the above information regarding informed consent to electronic
delivery and fully understand the implications thereof. Additionally, I hereby agree to all conditions
outlined above with respect to electronic delivery of any Account Document. I will maintain a valid e-mail
address and continue to have access to the Internet. If My e-mail address changes, I agree to
immediately notify Robinhood Financial of My new e-mail address in writing.
37. Miscellaneous Provisions.
The following provisions shall also govern this Agreement:
A. Contact Information.
Robinhood Customer Service may be contacted by visiting support.robinhood.com or by email at
help@robinhood.com.
B. Interpretation.
The heading of each provision hereof is for descriptive purposes only and shall not be (1) deemed to
modify or qualify any of the rights or obligations set forth herein or (2) used to construe or interpret any of
the provisions hereunder. When a reference is made in this Agreement to a Section, such reference shall
be to a Section of this Agreement unless otherwise indicated. Whenever the words "include," "includes"
or "including" are used in this Agreement, they shall be deemed to be followed by the words "without
limitation." The word "or," when used in this Agreement, has the inclusive meaning represented by the
phrase "and/or." Unless the context of this Agreement otherwise requires: (i) words using the singular or
plural number also include the plural or singular number, respectively; and (ii) the terms "hereof,"
"herein," "hereunder" and derivative or similar words refer to this entire Agreement. References to any
law shall be deemed to refer to such law as amended from time to time and to any rules or regulations
promulgated thereunder.
C. Binding Effect; Assignment.
This Agreement shall bind My heirs, assigns, executors, successors, conservators and administrators. I
may not assign this Agreement or any rights or obligations under this Agreement without first obtaining
Robinhood's prior written consent. Robinhood may assign, sell, or transfer My Account and this
Agreement, or any portion thereof, at any time, without My prior consent.
D. Severability.
If any provisions or conditions of this Agreement are or become inconsistent with any present or future
law, rule, or regulation of any applicable government, regulatory or self-regulatory agency or body, or are
deemed invalid or unenforceable by any court of competent jurisdiction, such provisions shall be deemed
rescinded or modified, to the extent permitted by applicable law, to make this Agreement in compliance
with such law, rule or regulation, or to be valid and enforceable, but in all other respects, this Agreement
shall continue in full force and effect.
E. Website Postings.
I agree and understand that Robinhood Financial may post other specific agreements, disclosures,
policies, procedures, terms, and conditions that apply to My use of the App, the Website, or My Account
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on the Website ("Website Postings"). I understand that it is My continuing obligation to understand the
terms of the Website Postings, and I agree to be bound by the Web Postings as are in effect at the time
of My use.
F. Entirety of Agreement.
This Agreement, any attachments hereto, other agreements and policies referred to in this Agreement
(including the Website Postings), and the terms and conditions contained in My Account statements and
confirmations, contain the entire agreement between Robinhood and Me and supersede all prior or
contemporaneous communications and proposals, whether electronic, oral, or written, between
Robinhood and Me, provided, however, that any and all other agreements between Robinhood and Me,
not inconsistent with this Agreement, will remain in full force and effect.
G. Amendment.
Robinhood may at any time amend this Agreement without prior notice to Me. The current version of the
Agreement will be posted on the Website and My continued Account activity after such amendment
constitutes My agreement to be bound by all then-in-effect amendments to the Agreement, regardless of
whether I have actually reviewed them. Continued use of the App, the Website or any other Robinhood
Financial services after such posting will constitute My acknowledgment and acceptance of such
amendment. I agree to regularly consult the Website for up-to-date information about Robinhood
Financial services and any modifications to this Agreement. Robinhood is not bound by any verbal
statements that seek to amend the Agreement.
H. Termination.
Robinhood may terminate this Agreement, or close, deactivate, or block access to My Account at any
time in its sole discretion. I will remain liable to Robinhood for all obligations incurred in My Account,
pursuant to this Agreement, or otherwise, whether arising before or after termination. I may terminate this
Agreement after paying any obligations owed upon written notice. This Agreement survives termination
of My Account.
I. No Waiver; Cumulative Nature of Rights and Remedies.
I understand that Robinhood's failure to insist at any time upon strict compliance with any term
contained in this Agreement, or any delay or failure on Robinhood's part to exercise any power or right
given to Robinhood in this Agreement, or a continued course of such conduct on Robinhood's part, shall
at no time operate as a waiver of such power or right, nor shall any single or partial exercise preclude
any other further exercise. All rights and remedies given to Robinhood in this Agreement are cumulative
and not exclusive of any other rights or remedies to which Robinhood is entitled.
J. International Customers.
The products and services described on the Website are offered only in jurisdictions where they may be
legally offered. Neither the Website nor the App shall be considered a solicitation for or offering of any
investment product or service to any person in any jurisdiction where such solicitation or offering would
be illegal. I understand that Robinhood, in its sole discretion, may accept unsolicited accounts from non-
U.S. residents, depending on the country of residence and other factors. I understand that Robinhood is
based in the United States and that Robinhood accepts only U.S. currency in Robinhood's customer
accounts.
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K. Governing Law.
This Agreement and all transactions made in My Account shall be governed by the laws of the State of
California (regardless of the choice of law rules thereof), except to the extent governed by the federal
securities laws, FINRA Rules, and the regulations, customs and usage of the exchanges or market (and
its clearing house) on which transactions are executed.
38. Arbitration.
A. This Agreement contains a pre-dispute arbitration clause. By signing an arbitration agreement,
the parties agree as follows: (1) All parties to this Agreement are giving up the right to sue each
other in court, including the right to a trial by jury, except as provided by the rules of the
arbitration forum in which a claim is filed. (2) Arbitration awards are generally final and binding; a
party's ability to have a court reverse or modify an arbitration award is very limited. (3) The ability
of the parties to obtain documents, witness statements and other discovery is generally more
limited in arbitration than in court proceedings. (4) The arbitrators do not have to explain the
reason(s) for their award unless, in an eligible case, a joint request for an explained decision has
been submitted by all parties to the panel at least 20 days prior to the first scheduled hearing
date. (5) The panel of arbitrators will typically include a minority of arbitrators who were or are
affiliated with the securities industry. (6) The rules of some arbitration forums may impose time
limits for bringing a claim in arbitration. In some cases, a claim that is ineligible for arbitration
may be brought in court. (7) The rules of the arbitration forum in which the claim is filed, and any
amendments thereto, shall be incorporated into this Agreement. B. Any controversy or claim
arising out of or relating to this Agreement, any other agreement between Me and Robinhood, any
Account(s) established hereunder, any transaction therein, shall be settled by arbitration in
accordance with the rules of FINRA Dispute Resolution, Inc. ("FINRA DR"). I agree to arbitrate
any controversy or claim before FINRA DR in the State of California. C. This agreement to
arbitrate constitutes a waiver of the right to seek a judicial forum unless such a waiver would be
void under the federal securities laws. If I am a foreign national, non-resident alien, or if I do not
reside in the United States, I agree to waive My right to file an action against Robinhood in any
foreign venue. D. No person shall bring a putative or certified class action to arbitration, nor seek
to enforce any pre-dispute arbitration agreement against any person who has initiated in court a
putative class action; or who is a member of a putative class who has not opted out of the class
with respect to any claims encompassed by the putative class action until: (1) the class
certification is denied; or (2) the class is decertified; or (3) the customer is excluded from the
class by the court. Such forbearance to enforce an agreement to arbitrate shall not constitute a
waiver of any rights under this Agreement except to the extent stated herein.
ACCEPTED AND AGREED: I acknowledge that I have read the preceding terms and conditions of this
Agreement, that I understand them and that I hereby manifest my assent to, and my agreement to
comply with, those terms and conditions by accepting this agreement. I ALSO UNDERSTAND THAT
BY ACCEPTING THIS AGREEMENT I HAVE ACKNOWLEDGED THAT THIS AGREEMENT
CONTAINS A PREDISPUTE ARBITRATION CLAUSE IN SECTION 38 HEREIN. I ALSO AGREE (1)
THAT ANY OF MY MARGIN ACCOUNT SECURITIES MAY BE BORROWED BY ROBINHOOD OR
LOANED TO OTHERS; (2) I HAVE RECEIVED OF A COPY OF THIS AGREEMENT AND (3) I HAVE
REVIEWED A COPY OF THE MARGIN DISCLOSURE STATEMENT.
Appendix A
Electronic Fund Transfer Services Disclosures
The following disclosures apply to the use of any EFT services offered by Robinhood, including the
Card, ACH transactions and the Move Money functionality of the App.
Solely for purposes of these disclosures: (i) references to the Bank shall include any financial institution
that issues the Card or provides services in connection with ACH, Move Money or other EFT
transactions; (ii) "you" and "your" mean the owner of the Account; and (iii) "we" and "us" means
Robinhood and the Bank collectively.
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1. Your Liability.
Contact Robinhood Customer Service AT ONCE if you believe your Card or PIN has been lost or stolen
or if you believe that an electronic fund transfer has been made without your permission. Telephoning is
the best way of keeping your losses down. You could lose all the Available Funds in your Account (plus
your maximum overdraft line of credit). If you tell Robinhood within 2 business days after you learn of
the loss or theft of your Card or PIN, you can lose no more than $50 if someone used your Card or PIN
without your permission.
If you do NOT tell Robinhood within 2 business days after you learn of the loss or theft of your Card or
PIN, and Robinhood can prove that it could have stopped someone from using your Card or PIN without
your permission if you had told Robinhood, you could lose as much as $500.
Also, if your statement shows transfers that you did not make, including those made by Card or using
your PIN, tell Robinhood at once. If you do not tell Robinhood within sixty (60) days after the statement
was mailed to you, or otherwise made available to you, you may not get back any money you lost after
the sixty (60) days if Robinhood can prove that Robinhood could have stopped someone from taking the
money if you had told Robinhood in time. If a good reason (such as a long trip or a hospital stay) kept
you from telling Robinhood, Robinhood will extend the time periods.
2. Contact in event of unauthorized transfer.
If you believe your Card or PIN has been lost or stolen, contact Robinhood by emailing
help@robinhood.com,.
3. Business Days.
Business Days are Monday through Friday, excluding federal holidays.
4. Transfer Types and Limitations.
You may use your Card to make purchases at any merchant that accepts Mastercard debit cards or
debit cards of other networks in which the Bank participates, and to make ATM withdrawals, in each
case subject to the Available Funds in your Account, the transaction limits described below, and the
other terms and conditions of this Agreement. You acknowledge and agree that the value available to
you for use with the Card is limited to the Available Funds in your Account. So long as you do not
exceed the Available Funds in your Account, you may use the Card to purchase goods or services
wherever the Card is honored, and to obtain cash by initiating cash withdrawal transactions through the
Card from any financial institution or ATM that accepts the Card. Each time you use the Card, you
authorize Robinhood to reduce the Available Funds in your Account by the amount of the purchase or
withdrawal and any applicable fees, costs, or holdings. Nevertheless, if you exceed the Available Funds
in your Account you shall remain fully liable to Robinhood for the amount of the transactions and any
applicable fees and charges.
You may also make ACH withdrawals from your Account, either originated through Robinhood or
originated by a third party (a "non-originated" withdrawal), subject to the Available Funds in your Account,
the transaction limits described below, and the other terms and conditions of this Agreement. You also
may make ACH deposits to your Account, either originated through Robinhood or originated by a third
party (a "non-originated" deposit), subject to the transaction limits described below.
There are limits on the dollar amount of transactions you can make with your Card each day and each
month, and limits on the amount of ACH withdrawals and deposits you can make each day. The
following lists the limits for each type of transaction:
Originated ACH Withdrawals* Daily Limit: $50,000.00
Weekly Limit: N/A Monthly Limit: N/A
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Declaration in Support of Motion to Compel Arbitration

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