CMC Markets - Broker Information Pack Reliance Money

 
CMC Markets – Broker Information Pack
           Reliance Money
GUIDE FOR INTRODUCING BROKERS.....................................................................3
1.0      OVERVIEW OF MAIN TOPICS.........................................................................3
2.0      CMC MARKETS’ PARTNERS SERVICE TEAM .............................................3
         2.1 Account Management at CMC Markets............................................................. 3
         2.2 Partners Services Team .................................................................................. 3
3.0      INTRODUCTION OF THE HELP WEBSITE....................................................4
4.0      OPENING ACCOUNTS.....................................................................................5
         4.1 The Reliance Money Account Opening Process: ............................................... 5
         4.2 Checking the Application Form......................................................................... 9
         4.3 Checking the Intermediate Customer Notice ..................................................... 9
         4.4 Documentation.............................................................................................. 10
         4.5 Avoiding Delays ............................................................................................ 11
5.0       PAYMENTS....................................................................................................14
         5.1 Segregated Funds ......................................................................................... 14
         5.2 Bank Transfers ............................................................................................. 14
         5.3 3rd Party Funds ............................................................................................ 14
         5.4 Payments Out from CMC Markets .................................................................. 14
6.0      IT SUPPORT....................................................................................................15
         6.1 IT Solution Wizard ......................................................................................... 15
         6.2 IT Support Details ......................................................................................... 16
         6.3 New Business Requirements ......................................................................... 16
7.0      ACCOUNT INFORMATION ............................................................................16
         7.1   Client Reports ............................................................................................... 16
         7.2   Margin Calls and Liquidations ........................................................................ 16
         7.3   Commission Accounts ................................................................................... 18
         7.4   Commission Payments .................................................................................. 18
8.0      MARKETING AND LOGO GUIDELINES.......................................................19
         8.1 Reference to your Relationship with CMC Markets: ......................................... 19
         8.2 Marketing Guidelines ..................................................................................... 20
         8.3 Use of the CMC Markets logo: ....................................................................... 20
9.0 Marketmaker®. SECURITY..................................................................................21
Appendix A - Key Contacts.......................................................................................25
Appendix B – Bank Account Details .......................................................................26
Appendix C – Client Transfer Request....................................................................27
Appendix D – Broker Transfer Request..................................................................28
Appendix E – Example Stage 2 Letter.....................................................................29
Appendix F – Example Stage 3 Letter.....................................................................31
Appendix G – Account Opening Letter...................................................................33
Appendix H – Example Margin Call Email ..............................................................34
Appendix I – Example Liquidation Email ................................................................35

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GUIDE FOR INTRODUCING BROKERS

1.0     OVERVIEW OF MAIN TOPICS

This guide is designed to provide information on the CMC Markets services to Reliance
Money and Syntel. The guide also covers what to do in the event of problems and how they
might be resolved quickly and efficiently.

Topics covered include:

                 •   Account Opening

                 •   IT Support

                 •   Payments

                 •   Account Information

2.0     CMC MARKETS’ PARTNERS SERVICE TEAM

2.1 Account Management at CMC Markets

Once your IB relationship with CMC Markets is established you will be allocated Account
Managers who will be responsible for providing assistance and dealing with any queries you
may have on a day-t o-day basis. Your Account Managers will be your main contact within
CMC Markets and will be able to deal with anything in relation to the topics above. This
ensures that you don’t waste time trying to resolve queries by dealing with different
departments and you will always have someone at CMC Markets who is conversant with your
account. CMC Markets Account Managers will deal with Reliance Money and Syntel directly
when required but will never interact with clients (with the exception of complaints handling
which are discussed in more details in section 7.5).

2.2 Partners Services Team

If your Account Manager is unavailable for any reason and you need urgent assistance, the
Partners Services Team will be able to help.           This team is responsible for providing
assistance to all CMC Markets Partners and is currently available from 8am to 9pm (GMT).

The Services Team will also work with your Account Manager, assisting them to ensure that
you are dealt with efficiently and promptly.

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3.0     INTRODUCTION OF THE HELP WEBSITE

The website http://www.cmcmarketsglobal.com/reliance/support provides easy access to
useful information and updates on CMC Markets’ service.           The site gives guidance on
everything from the products in which CMC Markets make prices, to understanding your
statement.

CMC Markets regularly review the website and update it with any developments or changes
to the service. This is to ensure that you have access to up-to-date information.

You can use the site to answer the majority of the initial questions that, you, or any potential
clients may have about CMC Markets service. The IT Wizard also gives easy to follow step-
by-step instructions on how to solve basic IT problems. The Wizard is explained further in
Section 6 of this guide.

This help-site has been developed especially for Reliance Money employees, Syntel support
staff and the Reliance Franchisee network. This site should not be distributed to clients.

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4.0         OPENING ACCOUNTS

A client account can only be set up once all account application documentation has been
received and approved by CMC Markets’ Account Management Team.

4.1 The Reliance Money Account Opening Process:

The Reliance Money account opening process will be rolled out in 3 main phases. The
objective of moving from phase to phase is to maximise the efficiency of the process,
therefore removing barriers to account opening.

Phase 1:

Phase 1 will be in place and utilised from the initial product launch

                                                                        Physical Documents
                                                                    (triggers account opening)

                                                                  Syntel
                    Franchisee          Reliance Centre
                                                                [review 3]            CMC Markets
                     [review 1]            [review 2]
                                                            [control document]
Potential
 Client

                                                                        Scanned Documents

      §     The application and certification documentation (“application pack”) is sent to the
            franchisee by the client.
      §     The franchisee reviews the application pack [review 1].
      §     When satisfied that all information is correct, the Franchisee forwards the entire pack
            to the appropriate Reliance Money Regional Centre.
      §     The Regional Centres will review the application pack again. [review 2]
      §     The application pack is then sent to Syntel, where all documents are reviewed
            [review 3], scanned and the application details entered into Syntel’s CRM system.
      §     An assigned signatory at Syntel approves the LAOA as well as the control document.
      §     Syntel adds a unique client identification number to the application pack.
      §     An additional control document is added to the application pack (appendix G). The
            control document outlines the account –broker links required by the Franchisee. This
            document now becomes part of the application pack.
      §     The scanned application pack is sent to CMC Markets and reviewed by account
            management.

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§       Following approval by CMC Markets’ account managers, Syntel will send the physical
            application pack to CMC Markets and the CMC Markets will begin the process of
            opening the account once the physical application pack is received.

Phase 2:

The objective is to have our Phase 2 process in place as soon as possible after the
successful trial of Phase 1:

                                                                       Physical Documents

                                                                  Syntel
                    Franchisee          Reliance Centre
                                                                [review 3]             CMC Markets
                     [review 1]            [review 2]
                                                            [control document]
Potential
 Client

                                                                          Scanned Documents
                                                                      (triggers account opening)

    §       The application and certification documentation (“application pack”) is sent to the
            franchisee by the client.
    §       The franchisee reviews the application pack [review 1].
    §       When satisfied that all information is correct, the Franchisee forwards the entire pack
            to the appropriate Reliance Money Regional Centre.
    §       The Regional Centres will review the application pack again. [review 2]
    §       The application pack is then sent to Syntel, where all documents are reviewed
            [review 3], scanned and the application details entered into Syntel’s CRM system.
    §       An assigned signatory at Syntel approves the LAOA as well as the control document.
    §       Syntel adds a unique client identification number to the application pack.
    §       An additional control document is added to the application pack (appendix G). The
            control document outlines the account –broker links required by the Franchisee. This
            document now becomes part of the application pack.
    §       The scanned application pack is sent to CMC Markets and reviewed by account
            management.
    §       On receipt and approval of the scanned application pack, CMC Markets’ account
            managers will begin the process of opening the account.
    §       Syntel must send the physical application pack to CMC Markets, to be received in
            London within 10 days of the account being approved.

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Phase 3:

Our Phase 3 process intends to maximise the efficiency of the account opening process by
reducing the number of steps that application pack must go through within the Reliance
Money network.

                                                                       Physical Documents

                                                                  Syntel
                    Franchisee
                                                                [review 2]             CMC Markets
                     [review 1]
                                                            [control document]
Potential
 Client

                                                                          Scanned Documents
                                                                      (triggers account opening)

    §       The application and certification documentation (“application pack”) is sent to the
            franchisee by the client.
    §       The franchisee reviews the application pack [review 1].
    §       The application pack is then sent to Syntel, where all documents are reviewed
            [review 2], scanned and the application details entered into Syntel’s CRM system.
    §       An assigned signatory at Syntel approves the LAOA as well as the control document.
    §       Syntel adds a unique client identification number to the application pack.
    §       An additional control document is added to the application pack (appendix G). The
            control document outlines the account –broker links required by the Franchisee. This
            document now becomes part of the application pack.
    §       The scanned application pack is sent to CMC Markets and reviewed by account
            management.
    §       On receipt and approval of the scanned application pack, CMC Markets’ account
            managers will begin the process of opening the account.
    §       Syntel must send the physical application pack to CMC Markets, to be received in
            London within 10 days of the account being approved.

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The Application Pack:

The application pack will contain the following documents:

            o    CFD/FX Application Form
            o    Intermediate Client Notice (ICN)
            o    Limited Appointment of Agent (LAOA)*

        Note*: Clients are only required to complete the LAOA if they wish to permit Syntel or
        a Reliance Money franchisee to trade on their requested instructions.

        Note: All application packs distributed to clients must include CMC Markets’ Terms of
        Business (TOB). The client, on completing the account open documentation, should
        retain the TOB for future reference.

    §   All application documentation must be accompanied by one (1) proof of address and
        one (1) proof of identification. These are referred to as the certification
        documentation. The certification documentation can be either the original document
        or a certified copy of the original.

            o    One proof of address:
                     §    Utility Bill (excluding mobile phone)
                     §    Local authority tax bill
                     §    Bank statement
                     §    Local council rent card or tenancy agreement
                     §    Most recent mortgage statement from recognised lender.
                     §    Passport
                     §    Driving License
                     §    National ID card
                     §    PAN card

        Note: Each of these documents must show the current address of the applicant must
        be the same address as on the account application form and be within 6 months old.
        Documents in languages other than English should be accompanied by a translation.

            o    One proof of ID:
                     §    Passport*
                     §    Driving License*
                     §    National ID card*
                     §    PAN card*

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Note*: Passport, driving license, national ID card and PAN card cannot be used as
        proof of ID if already used as proof of address.

4.2 Checking the Application Form

When reviewing the application form the following checks must be made:

    •   The address on the application form is the same as the address as on the “proof of
        address” document submitted by the client.
    •   The application form must have an email address, which is not in the name of the
        broker.
    •   The application must have a landline telephone number.
    •   The applicant’s date of birth must be filled out.
    •   Investment services: If the client requires a Franchisee or Syntel to trade on their
        expressed orders through a LAOA, the “yes” box must be ticked. When the client
        ticks “no”, only the client themselves will be able to trade on the account, even if a
        LAOA has been submitted.
    •   If the applicant works for an FSA Member you must confirm if their compliance
        department require to see copy contract notes.
    •   The client must have a net worth of more then $20,000 or equivalent.
    •   The application form must be signed and dated.
    •   If any part of the form is not completed it should be returned to the client to complete
        all missing sections and sign the form again.
    •   NOTE: no member of CMC Markets or the broker should complete any section
        of the form on behalf of the client.

4.3 Checking the Intermediate Customer Notice

When reviewing the ICN the following checks must be made before being passed to CMC
Markets. The account should be rejected immediately if any client does not demonstrate
sufficient understanding and experience:

    •   If the client has traded in a certain instrument then they must put in the amount of
        time traded also.
    •   If the client has traded in a certain instrument then they must put in their average
        number of trades and their average deal size.
    •   Also if the client has traded in a certain instrument then we need to know the
        company that they have traded with and if it was on an execution basis.
    •   The client must also let us know the date of their last trade.
    •   Clients must confirm understanding of any product they wish to trade

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•    The ICN must be signed and dated
     •    If any part of the ICN is not completed it should be returned to the client to complete
          all missing sections and sign the form again. NOTE, no member of CMC Markets or
          the broker should complete any section of the form on behalf of the client.

Note: If the client has not traded Financial Spread betting or CFDs before, this alone will not
prevent them from opening an account

4.4 Accompanying Documentation

Accompanying documents are needed to ensure that we take reasonable steps to find out
who the client is. We need to obtain sufficient evidence of the identity of clients.

The client will need to provide two documents, one from List A and one from List B.

We will accept originals or a photocopy of the identity documents if they are officially stamped
and signed together with the following statement “certified as a true copy of the original”
by a lawyer, embassy or consulate, public notary or by a recognised and authorised legal
representative of Reliance Group (This person must be identified by CMC Markets and hold a
BAR council license or equivalent).

List A (one from the list)

     •    Current signed passport

     •    Current Driving License

     •    National ID cards

     •    PAN Card
-----------------------------------------------------------------------------------------------------------------
Only documents issued within the last six months can be accepted:

List B (one from the list)

     •    Utility bill, statement or a certificate from a supplier of utilities confirming the
          arrangement to pay for the services.

     •    Local Authority tax bill (valid for the current year)

     •    Bank, Building Society or Credit Union statement

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•   Solicitors letter confirming recent house purchase or land registry confirmation. (The
         previous address should also be verified)

     •   Local council rent card or tenancy agreement.

     •   Most recent mortgage statement from recognised lender

(These must show a current address)

The following can be used if they have NOT all ready been used for List A

     •   Current signed passport

     •   Current Driving License

     •   National ID cards

     •   PAN Card

If you are likely to have any corporate account applications it is worth discussing the
documents required for these types of accounts with your Account Manager.

4.5 Avoiding Delays

Once CMC Markets receive all the correctly completed documentation, client’s accounts can
be opened and trading very quickly.         Incomplete or incorrect Applications Forms and
accompanying documents can cause delays in opening accounts.            Checking applications
before sending them to CMC Markets can avoid these delays for the client.

We suggest that you check all the details for each application. From experience the following
are some of the points that you may want to highlight to the client and check:

                 •    Intermediate Customer Notice needs to be signed and dated

                 •    Mobile Phone bills will not be accepted

                 •    A land line telephone number is required

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As a guideline CMC Markets will expect clients must demonstrate a minimum of 6 months
experience, trading at least 50 times within that period on an execution only basis for a
specific product category that they wish to trade with CMC Markets.

If the client has little relevant experience then CMC Markets Compliance will reject the
application. CMC Markets need to have confirmation of the client’s understanding as to the
nature of, and risks associated with, margin trading.

Application Issue Resolution Process:

                                             below-standard docs or                             below-standard docs or
                                                  client queries                                    client queries

                                      CHECK 1                    CHECK 2
                 documents                                                               CHECK 3
                                     Franchisee                  Reliance
                                                                                          Syntel                   CMC
                                                                  Centre
Potential
 Client

            below-standard docs or                                     below-standard docs or
                 client queries                                             client queries

     §      All client documentation will be checked by a) Franchisees b) Reliance Centres and
            c) Syntel before being scanned and sent to CMC by Syntel.
     §      Any Franchisee queries will be dealt with between the Franchisee and the client.
     §      Any Reliance Centre queries will be dealt with between the Franchisee and the
            Reliance Centre.
     §      Any Syntel issues will be dealt with between Syntel and the client. Subsequent
            queries can be handled between Syntel and any member of the application chain
            directly.
     §      CMC will only deal with Syntel on a client-service level.

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4.6 After CMC Account Management Acceptance

           Reliance / Syntel                      Application Pack                             CMC Markets

                                                                                    te r
                               (A

                                                                                le t
                                  )
                                 Ap

                                                                           e2
                                   p li

                                                                         t ag
                                      ca
                                         tio

                                                                       )S
                                            n

                                                                     (B
                                           Pa
                                             ck
                                                                      (C) Client Funds
                                                                        (D) Stage 3 letter

                                                     Potential                  (E) Password
                                                      Client

(B) Once CMC Markets account managers have signed off a client they will receive
notification by email and post that confirms that they have been accepted for an account. This
will include the clients account number and funding instructions.

(C) Following the funding instructions outlined in B, the client will proceed to fund their
account.

(D) Once the client has received the notification and funded their account they will be sent an
additional notification by email and post, which confirms their user ID, username and the
clients commission structure. It will also give the client the email address to email their
requested password to, which is pw@cmcmarketsglobal.com

An example of the primary and secondary notification are attached in appendix E and F.

Password Process:

Clients will be requested to submit their unique password directly to CMC Markets’ account
management team by sending an email to pw@cmcmarketsglobals.com

When CMC Markets receive the password request from the client we will check to make sure
that the email address that the request has come from is the same as the one that the client
filled out on their application form. If the email addresses are the same the password will be
set and the client informed that they can use their trading account.

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5.0        PAYMENTS

Once an account application is approved by CMC Markets’ compliance department the client
will be informed by letter and email of their account number and how to fund their account.
Below are some of the important points to note regarding payments:

5.1 Segregated Funds

All funds of Reliance Financial clients will be segregated in accordance with FSA money
rules. Therefore no client funds will be used in the daily course of CMC Markets business and
this will be confirmed to clients in their account opening documentation.

5.2 Bank Transfers

When transferring funds by electronic transfer, the client should ask their bank to quote their
full name and CMC Markets Account Number as reference so that funds are promptly
credited to their account.

CMC Markets has bank accounts throughout the world; this avoids delays that can be
experienced with International transfers. Bank account details for CMC Markets accounts
relevant for your clients can be found in Appendix B – Bank Account Details.

CMC Markets will not accept payments by cash into a CMC Markets account. Any monies
deposited in cash will be returned in cash, it is important that clients understand this as
returning cash deposits is dependant on the banks involved and can take considerable time to
arrange.

5.3 3rd Party Funds

When monies are sent to CMC Markets to fund an account and the remitter is not the CMC
                                                        rd
Markets account holder, the funds will be deemed as 3 Party Funds

To ensure that CMC Markets meets it’s money laundering prevention requirements we will not
                   rd
generally accept 3 Party Funds. These funds will be returned to the remitter.

5.4 Payments Out from CMC Markets

To request funds out of their trading account client’s can use the CMC Markets Payment
Withdrawal form – Appendix C. Once CM C Markets receives this form from Syntel, we will
check to make sure that the client’s bank account details on the withdrawal form are the same
as the clients bank details given on the application form. If the bank details differ, then CMC
Markets will contact Syntel to advise them that the funds can only be transferred back to the

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account it was received from. Syntel will communicate this information to the client and the
correct information should be submitted.

      •   Some other important points regarding payments out:

             o   The daily cut off time for a payment request out is 11 am (UK time).
             o   Any requests received after 11 am GMT will be sent the following working
                 day.
             o   It can take up to 5 working days for banks to process International transfers,
                 this varies depending the intermediary banks.

             o   Bank charges vary; this depends on how many intermediary banks are
                 in between.

6.0       IT SUPPORT

6.1 IT Solution Wizard

The vast majority of clients will be able to download and use Marketmaker® without any help.
Where a client experiences a problem or just needs guidance on using Marketmaker®, they
should contact their Franchisee or Syntel for support. CMC Markets has created the website
www.cmcmarketsglobal.com/reliance/support to educate Syntel and Franchisees on how to
resolve issues on the platform.

The Wizard gives easy to follow instructions for solving basic IT problems that clients might
encounter.

From past experience, following the Wizard’s instructions can solve 95% of all problems that
clients may experience.    It can determine the cause of problems by following the steps then
offer the most appropriate solution.

The IT Solution Wizard is very easy to use.

Follow the on-line instructions to get to the suggested solution. For example if you have
installed Marketmaker® successfully and can get to the log-on page, but receive and
message “Logon failed because cannot connect”. You can follow the links:

                     §    Log On Wizard
                          If you are experiencing difficulty progressing from the Logon page to
                          the trading platform please select this Wizard.

                     §    Logon failed because cannot connect

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You can then follow the on-line instructions to solve the problem.

6.2 IT Support Details

If you have tried the solution suggested by the Wizard, or there isn’t one for the problem your
client has then CMC Markets has IT support available 8am to 9pm (GMT).

If you want to contact CMC Markets about an IT issue, your first point of contact is as always
your Account Managers. They will be up-to-date with any developments with Marketmaker®
and, provided with the right information, will be able to suggest solutions to the mast majority
of problems.    If your Account Manager is unable to give you the answers you need
                                                                      nd
straightaway they will ask for the assistance from the CMC Markets 2       Line IT Support Team.
You don’t need to contact our Support Team yourself, as your Account Manager will do that
for you. However, if you need more complex IT Support your Account Manager can put you
in contact with someone that will be able to help.

6.3 New Business Requirements

CMC Markets has developed it’s own trading platform, Marketmaker®, so we have the
benefit of being able to develop the platform in-house to meet client’s preferences. As a
Partner of CMC Markets we appreciate your feedback on the trading platform and any
suggestions on how it can be improved.

We have trading and accounting functions that, on the whole, meet the needs of most CMC
Markets Partners. However, if you have new business requirements that you think CMC
Markets can help with at any time your Account Manager can review these with you and work
with our development team to get solutions implemented.

7.0     ACCOUNT INFORMATION

7.1 Client Reports

Wherever possible CMC Markets sends client communications via email. Account holders
will need to provide an email address on the Application Form, which will then be used for
communications.      CMC Markets provide Daily and Monthly Statements, which are all also
available on the Marketmaker® platform, www.cmcmarketsglobal.com/reliance/support
provides an explanation on how to understand statements.

7.2 Margin Calls and Liquidations

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When a client incurs losses on their open positions, which result in their account having a
position where their Total Equity is lower than their Total Margin, their account will be on
margin call, as they have a negative Free Equity (or deficit equity).

Then it is the client’s responsibility to fund the margin short fall. CMC Markets has an
automated email notification system that emails clients highlighting a margin call on their
account. However, margin calls are not guaranteed and the client is responsible for
monitoring and maintaining their account and margin at all times.

If the client takes no action and the Total Equity falls below a set percentage of their Total
Margin an order may automatically be produced on their account to reduce their positions.
The effect of this is to reduce the risk on their account, which may in turn decrease the margin
requirement.

The set percentage is known as the Liquidation Percentage or Liq % and can be found on the
CFD or FX Positions tab on the Client Positions window.

When any liquidation action is taken a Liquidation Notice email regarding that action may
be sent to the client. These procedures are in place due to the risks involved in margin
trading and are intended to help reduce the client’s risk of losing more money than they hold
in their account, although this cannot be guaranteed.

Note. Liquidation orders should never be used as stop loss orders.

For example where a client has a Total Margin of $10,000 and the Liq % is 40%. An order
may be generated to reduce the client’s positions when such client’s Total Equity falls below
$4,000. In addition, clients need to ensure that they keep a minimum Total Equity on their

17
account of $200 or currency equivalent at all times to keep open positions, if the account has
less then $200 on it then clients will not be able to place any further trades

An example of the margin call and liquidation emails is attached Appendix H and I.

In Summary:

T. Equity > T. Margin           Account fully margined

T. Equity < T. Margin            Funds are required or position(s) need to be reduced

T. Equity < T. Margin x Liq %    Liquidation order may be produced to reduce/close position

T. Equity < 200 USD              Liquidation order may be produced to close position

7.3 Commission Accounts

Your Commission account at CMC Markets updates in real time. When a client trades, the
commission is calculated instantly and credited to your account at CMC Markets.          The
amount of commissions generated throughout the day can be viewed in the “Cash & Payment
History” blotter in Marketmaker®.

Client Position Keeping is also available for your commission account, which will also update
in real time with any commissions earned and give a Total Equity balance.

Overnight a Broker Daily Statement is generated and sent to you via email. The statement
gives a full breakdown of trades and commissions earned. At the end of each month you will
receive a Broker Monthly Statement for your records. These statements are also available
through the Marketmaker®. Platform.

7.4 Commission Payments

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We are able to make commission payments to you in the same way as we do for your clients.
As you are likely to require more frequent transfers we can arrange for commissions to be
paid on a monthly or weekly basis or a specific set date within the month.

We suggest that you arrange monthly transfers as it allows you to reconcile payments and
commission earned easily against your Broker Monthly Statement. Appendix D – Broker
Transfer Request can be completed at any time to arrange your transfers.

7.5 Compliant Procedure

As Syntel act as our level-one client support function for Reliance clients, they will be the first
point of contact for complaints from Indian clients. When a complaint is received by Syntel,
the following process will be adhered to:

      •   Syntel will receive client complaints via email or telephone.
      •   A complaint by email must be sent to reliance@cmcmarketsglobal.com
      •   A copy of any complaints received by telephone must be sent to
          reliance@cmcmarketsglobal.com as an email attachment.
      •   CMC Markets will attempt to resolve all client complaints directly with the client as per
          our standard internal processes.
      •   CMC will inform Syntel when a client issue has been resolved, enabling Syntel to
          update their CRM system accordingly.

      Complaint Procedure:

                                                Reliance Money

                             complaint
                                                                   update
                    Client
                                                    Syntel                   CMC Markets
                                                                 compliant

                                                  Franchisee

                                    COMPLAINT RESOLUTION COMMUNICATION

8.0       MARKETING AND LOGO GUIDELINES

A detailed explanation of your requirements in this area is available in your Introducing Broker
Agreement.

8.1 Reference to your Relationship with CMC Markets:

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When referring to CMC Markets in any form of marketing material, attention must be paid to
the positioning of your relationship with our company. As a rule of thumb, brokers may refer to
it as a “relationship” or “introducing broker relationship” with CMC Markets, however brokers
should refrain from using any of the following terms:

     q   ………..is a partner of CMC Markets……….
     q   ………..is in partnership with CMC Markets…..
     q   ………..is an agent or / acting as an agent of CMC Markets…
     q   ………..is a representative of CMC Markets / is CMC Markets’ representative in……..
     q   ………. joint venture…

Any references made by an Introducing Broker about CMC Markets, our products or CMC
Markets must first approve the relationship with our company in any marketing material. This
can be organised through your CMC Markets account manager.

8.2 Marketing Guidelines

As stated in the Introducing Broker Agreement, IBs should not, without express consent form
CMC Markets:

     q   Circulate any written material in relation to CMC Markets or our products.
     q   Use our logo or letterhead or make reference to CMC Markets on your own
         letterheads and printed or electronic material.
     q   Make or purport to make a representation of CMC Markets.
     q   Provide information of any kind relating to CMC Markets or our products in interviews,
         press releases or otherwise.
     q   Respond on behalf of CMC Markets to enquiries or requests from the media or the
         press relating to CMC Markets. Additionally, these enquiries or requests should be
         referred to CMC Markets.

Prior to publication, the Introducing Broker must provide CMC Markets with drafts of all written
information, advertisements and other materials in any media or form which relate to or
mention CMC Markets, and/or the Products (the “Promotional Material”), and shall not release
the materials until express written approval is obtained from an authorised officer of CMC
Markets.

8.3 Use of the CMC Markets logo:

CMC Markets must first approve any use of CMC Markets corporate logo. This includes all
online and offline media usage. A signed CMC Markets “Logo Usage Agreement” will need to
be obtained by the Introducing Broker before any use of the logo can be undertaken. This can
be organised through your CMC Markets account manager.

20
Where usage of the logo has been permitted by CMC Markets, brokers must use the logo in
accordance with our latest Corporate Brand Guidelines document. Which will be issued on
request from your account manager.

9.0 Marketmaker®. SECURITY

9.1     Trading Platform – Overview

CMC Markets trading platform comprises a number of separate components that interact to
provide client -trading facilities. The core platform uses TCP based client server architecture
over distributed messaging layers, this provides client connections, encryption and
authentication and is used to stream prices to clients and to securely route orders and trades
to our Back Office systems.

A number of distributed applications provide the messaging infrastructure; there are a large
number of back-end services such as automatic trade execution, chart requests, news and
many other features.

Central to the process is the Oracle database that stores all client account details, orders and
trade information. There are also a number of MS SQL databases for ancillary data, i.e.
historic charts and non-sensitive data.

The distributed message layer comprises of a number of distributors linked together to a
central distributor. All client distributors are hosted in the De-Militarised Zone (DMZ), then
connected separately to a central distributor in our internal network which in turn is
segmented to ensure that all MarketMaker back office servers are hosted in their own subnet.

9.2. Network Security

Our DMZ is protected by a number of Internet firewalls clustered to ensure redundancy; these
are a primary defence against network-based attacks.

There is also an Intrusion Detection System (IDS), and a number of other utilities that provide
us information pertaining to any attacks against our systems.

Because the trading platform does not employ standard web servers common Internet related
attacks such as sql injection and other similar exploits do not affect this platform.

21
The Oracle database is in the same subnet as the MarketMaker servers but separated from
other internal networks operated by the company.

9.3. Client Authentication

The MarketMaker software provides for client authentication and the encryption of traffic
transmitted over the Internet.

Clients are required to enter three elements of identification credentials to authenticate
themselves to gain access to the MarketMaker application. These consist of a User ID, User
Name and Password. CMC Markets mandates the criteria for establishing these credentials;
the client cannot alter the User ID or User Name, but can select their own password provided
they adhere to our Password Policy.

9.4. Anti-Virus

CMC Markets employs a double layer anti- virus policy. Externally our systems are protected
by Barracuda devices, which scan all incoming email before forwarding the content to our
internal systems. All desktop PCs are maintained with the latest version of anti-virus software
and updates to ensure that in the unlikely event a virus traverses the email system it will be
detected at the desktop machine. Any web-based viruses are captured and deleted as soon
as they are detected. CMC Markets also employs Lotus Notes as its email application, which
is less susceptible to viruses therefore reducing the likelihood of infection to our systems.

9.5. Web-based Attacks

Like any organisation that relies heavily on the Internet to conduct its business CMC Markets
faces many indiscriminate scans and script attacks. In addition to the features outlined above,
we constantly monitor our exposure on the Internet and limit the number of systems and
services that are exposed; we harden and patch our Operating Systems to reduce their
signature, and remove all unnecessary products and services from our systems.

9.6. Denial-of-Service (DoS)

DoS is prevented at the Distributor level. Distributors can control the number of connections
accepted within a specific time frame, and automatically prevents any additional connections

22
from being made. This protects those clients currently logged on to the system from a higher
level of activity. Other factors that reduce the likelihood of a DoS attack are:

     •   Our servers are not http based
     •   The ratio of clients to distributors ensures there is at least two and a half times
         capacity on the Distributors than our peak load – preventing overloading of the
         system
     •   Large bandwidth Internet lines prevent overloading
     •   CMC Markets has access distributed across a number of locations making it harder to
         create and achieve a DoS against our systems.

9.7. Security Reviews

CMC Markets conducts regular reviews of its networks, systems and applications. Staff
Monitor the incident logs from the firewalls, IDS and Barracuda systems. Any anomalies are
investigated as appropriate.

We constantly maintain our vigilance for new security vulnerabilities and the creation of new
types of malicious code (Viruses, Trojans, Spyware, worms, etc) that could potentially cause
damage to our systems.

CMC Markets engages independent third parties to assist us to assess our networks, systems
and applications by conducting periodic vulnerability assessments to explore for any potential
weaknesses and avenues of unnecessary exposures. Our staff are given detailed evidence of
any vulnerability identified along with guidance on the Best Practice solution for not only
implementing any corrective action but the necessary measures to implement to prevent any
reoccurrence. All assessments culminate in a written report providing detailed confirmation of
the vulnerabilities identified; this forms the basis for our Action Plan to rectify these points. All
reports are securely maintained to provide an audit trail of activities, and the subsequent
actions we have taken. Both Internal and External Auditors who review the Companies
processes and procedures review these reports.

9.8. Business Continuity / Disaster Recovery (BC/DR)

CMC is constantly reviewing, revising and upgrading its BC/DR. There has recently been a
major investment of new hardware to increase the capability to support the core systems and

communications links. We are actively increasing our BC/DR preparations including various
scenarios and potential responses to them.

23
Investment has also included the provision of an off-site hosted location with independent
power and dedicated telecommunications systems, and excellent accessibility by various
transport methods. This site is a node on our recently upgraded wide area MPLS network that
interconnects our key sites around the world.

Data replication between the sites as near to real-time as is practical has been implemented
to minimise the disruption in the event that any significant event affects CMC Markets either
directly or within the surrounding infrastructure.

9.9. Security Education and Awareness

CMC Markets is undertaking to ensure that all its staff are appropriately made aware of their
roles and responsibilities with regards to Information Security. Various methods and media
are utilized to communicate Information Security (INFOSEC) Awareness to staff at all levels;
new members of staff are required to undertake this upon joining the Company.

CMC Markets is upgrading and enhancing its Policies and Procedures and has recently
brought an application to facilitate the availability of these to all staff ensuring that they have
the relevant information applicable to their role and responsibilities.

CMC Markets is aligning its security management to the ISO17799 standard, to ensure that it
aspires to the highest level of assurance that is recognised around the world.

We are extending this Security Education and Awareness to our Clients and Partners, to
ensure that they are advised of how they can help us by maintaining the security of their
Access codes, and prevent unauthorised access to their account information.

24
Appendix A - Key Contacts

Group Telephone.            +44 (0) 207 170 8430

Main e-mail                 services@cmcmarketsglobal.com

Fax                         + 44 (0) 207 170 8485

Mail Address:               CMC Markets UK Plc
                            66 Prescot St
                            London
                            E1 8HG

CFD Dealers:                +44 (0) 207 170 8203

FX Dealers:                 +44 (0) 207 170 8204
Appendix B – Bank Account Details

                   Natwest Bank Plc, City of London Office, 1 Princes Street, London EC3P
       Bank:
                                                   3AR.

 Account Name:                            CMC MARKETS UK PLC

     Sort Code:                                   60-00-01

     BIC / SWIFT
                                                NWBKGB2L
        code:

Currency                                            Account Number
US Dollars                                             42006783

You may wish to include the IBAN numbers shown below in your transfer instructions. The
IBAN number is a combination of our swift code, sort code and accounts number. This
number is not essential however it may help to speed up the transfer of funds

Currency                                            IBAN Number
US Dollars                                   GB24 NWBK 6073 0142 0067 83

26
Appendix C – Client Transfer Request

                        Transferring funds from your CMC Markets UK Plc Account

Please complete and return this form by fax to +91-(0)22-25862643, as a scanned email attachment to
customer.support@reliancemoney.co.in or send to the postal address below.

  Account Name

  Account Number

Bank Account Details

  Bank Name

  Account Name

  Bank Account Number

Compulsory Details

  Swift Code / BIC

  IBAN Number

Please select payment type

       Standard International                Express International

 Amount To Withdraw                                       Currency

  Signed                                                                                                Date

Our bank charges are subject to change without notice.
Please note that intermediary banks and your bank may also levy transfer charges.

If you have any questions regarding this form or your account please contact the Services Team on 022
39886000 or customer.support@reliancemoney.co.in

27
Reliance Money, 5th floor, Lexington, Hiranandani Estate, Ghodbunder Road, Thane (W), Mumbai,
India Tel: 022 39886000 International: + 91 022 39886000 FAX +91-(0)22-25862643

Appendix D – Broker Transfer Request

                            Transferring funds from your Broker Account

Please complete and return this form by fax to +44 (0) 207 170 8485, as a scanned email attachment to
services@cmcmarketsglobal.com, or send to the postal address below.

    CMC Commission Account

Bank Account Details
    Bank Name

    Account Name

    Bank Account Number

    Sort Code / BLZ

Further Details

    Swift Code / BIC

    IBAN Number

Payment Type

      Standard Domestic / International   Express International

•          Please transfer the balance of the commission account above on a monthly basis.

•          Please transfer the balance of the commission account above on ______ of every month or the nearest
           business day to this date

    Print Name                                                    Signed                                    Date

Transfers can be made the same day providing requests are made prior to 11.00am London time.

CMC Markets does not charge for international transfers. Our bank charges are subject to change without notice.
Please note that intermediary banks and your bank may also levy transfer charges.

28
.
    If you have any questions regarding this form or your account please contact the Services Team on +44 (0) 207
    170 8430 or services@cmcmarketsglobal.com

      CMC Markets UK Plc 66 Prescot Street London E1 8HG T EL: +44 (0) 20 7170 8430 FAX: +44 (0) 20 7170 8485

    Appendix E – Example Stage 2 Letter

    [Click here and type name of Client]
    [Click here and type Address]

    13 February 2007

    Dear [Click here and type name of Client ]

    CMC Markets Account Number: [Click here and type Account Number]

    Thank you for returning the account opening documents, which included your signed
    Intermediate Customer Notice. We are pleased to inform you that your account has now been
    approved by CMC Markets and that CMC Markets UK Plc intends to treat you as an
    Intermediate Customer in respect of all investment business that we carry out with you or for
    you.

    CMC Markets will hold any monies on your account on a segregated basis in accordance with
    FSA Client Money Rules. This therefore means that we will hold your money in a segregated
    account at a bank approved by us for this purpose. Once you have funded your trading
    account, the bank at which your money will be held is be Natwest Bank, City of London
    Office, 1 Princes Street, London, EC3P 3AR.

    To complete the opening of your account you are required to deposit funds. You can fund
    your account using the methods detailed below:

    Electronic Bank Transfer

    When transferring funds by electronic transfer, please ask your bank to quote your full name
    and CMC Markets Account Number as reference so that funds are promptly credited to your
    account.

    29
Bank:               Natwest Bank Plc, City of London Office, 1 Princes Street, London EC3P
                    3AR, UK
Account Name:       CMC Markets UK Plc
Sort Code:          60-00-01
Swift Code:         NWBK GB 2L

Currncy                     Account Number               IBAN Number
Sterling GBP                39060594                     GB13 NWBK 6000 0139 0605 94
US$                         42006783                     GB24 NWBK 6073 0142 0067 83
Euro                        42006821                     GB20 NWBK 6072 1442 0068 21

Important:

To avoid any delay in your application please ensure that any transfer that you effect is made
from a bank account in your name and not from that of another party. Any remittances from
third party accounts will be returned to the remitter.

Once we have received your funds, we will issue you with the necessary details to commence
trading, as well as your personal log in details.

Should you have any questions with regards to any of the points above then please do not
hesitate to contact the Helpdesk Team on customercare@reliancemoney.com or alternatively
you can call them on 022-39886000.

Yours Sincerely,

Nidhi Mehrotra
Account Manager
CMC Markets UK Plc

30
Appendix F – Example Stage 3 Letter

Dear

Thank you for depositing funds to activate your live trading account. Please find your Account
details below:

ACCOUNT NUMBER:
USER ID:
USER NAME:
PASSWORD:                        If not already selected. Please advise by emailing
                                 pw@cmcmarketsglobal.com

You will also find enclosed useful information relating to our products, how to access CMC
Markets’ award winning software, and a comprehensive list of contact details.

The trading platform can be installed from:

http://builds.marketmaker.co.uk/web_mmv5/partners/Reliance/Live/MM5_en_Installer.exe

Alternatively a CD can be provided, please email info@cmcmarketsglobal.com with your
request and Account Number.

When first accessing the platform you will be asked to read and agree to the End User
License Agreement. You will then proceed to the log on page where you will require the
following three pieces of information: user ID, user name and password. Your user ID and
user name are provided above.

Please     advise    CMC      Markets     of    your    chosen     password      by    emailing
pw@cmcmarketsglobal.com.        Your chosen password should have a minimum of four
characters and a maximum of ten, and please include your account number in the email. You
will received email confirmation when your password has been activated

We would also like to confirm that in accordance with the rules of the Financial Services
Authority, CMC Markets UK Plc intend to treat you as an Intermediate Customer in respect of
all investment business we carry out with you or for you.

It is CMC Markets’ policy to establish financial limits with clients dealing on the off-exchange
markets. The limits established on your account are set out in the attached Rate Schedule

31
and are referred to in our Terms of Business, which have been provided to you previously.
CMC Markets may remunerate Reliance Money Limited for introducing business and details
of such arrangements are available on request.

32
Appendix G – Account Opening Letter

  Date:

  To
  CMC Markets
  66, Prescot Street,
  London, E1, 8HG,
  UK

  Client Application of Mr./Ms./M/s: ______________________________ [Client ]

  q Direct Application

  q Through Franchisee

  If through franchisee, name and address of franchisee:

          Name:

          Address:

          Franchisee Code:

  Whether Log-on code to be given to above franchisee

  q Yes

  q No

  [Client Signature]

  For Office Use

We Confirm the above

Reliance Money Limited

  33
Appendix H – Example Margin Call Email
Dear Client,

YOUR ACCOUNT IS ON MARGIN CALL. YOU MUST SEND FUNDS TO YOUR ACCOUNT IMMEDIATELY.

Due to the recent movements in the markets you are required to deposit additional cleared funds to cover the following margin requirement.
____________________________________________________________________________

Account                      : [AcctName] [AcctShort]
Date                         : [DateLong]
Time (GMT)                   : [TimeShort]
Total Equity                 : [ReportingCcy] [TotalEquity]
Margin Requirement           : [ReportingCcy] [TotalMargin]
Deficit Margin               : [ReportingCcy] [TotalFreeEquity]
____________________________________________________________________________

It is your responsibility to ensure your account is fully margined at all times. To maintain your open position(s), you must pay the additional
cleared funds immediately. In accordance with our Terms of Business, if you do not send us the required margin as outlined above, we may
place stop loss or liquidation orders to close the open position(s).

To Fund your CMC Markets account please choose one of the following options.

Bank Transfer:

Please visit the Fund Account section of www.cmcmarketsglobal.com/support for the necessary details to organise a bank transfer, or contact
our Helpdesk on +44 (0) 207 170 8430.

Important Note:

Please ensure that any payment you make to us is made from a card or account in your name and not from that of another party. Any
remittances from third party sources will not be accepted.

As we can only allow you to trade with cleared funds in your account, any funds in transit or promised funds will not be credited to your account
until they are received and cleared by us. Please note that Cheques take five working days to clear upon receipt.

Should you have any questions relating to this e-mail then please do not hesitate to contact us on the numbers detailed below.

Regards,

CMC Markets
___________________________________________

Tel: +44 (0) 207 170 8430
Fax: +44 (0) 207 170 8485
Email: services@cmcmarketsglobal.com
Web: http://www.cmcmarkets.com/help
___________________________________________

CMC Markets UK Plc is authorised and regulated by the Financial Services Authority.

All information contained within this email, and any attachments, are subject to CMC Markets standard Terms and Conditions - which can be
found at: http://www.cmcmarkets.com

This email and any attachments, which may only be used by the intended recipients, are confidential and may contain proprietary information,
some or all of which may be legally privileged. Unauthorised disclosure, copying or distribution of this mail or its contents is strictly prohibited.
Should you have received this email in error please immediately return it to the sender or notify the company at misdirect@cmcmarkets.com,
then delete the email and any attachments from your system.

CMC Markets UK Plc takes every effort to ensure that our systems are regularly scanned for viruses and other infections with updated
programs, but cannot guarantee emails sent have not become infected elsewhere, we advise recipients to conduct their own checks as
considered appropriate.

34
Appendix I – Example Liquidation Email
Dear Client,

CMC MARKETS ACCOUNT [AcctName] [AcctShort]

You did not provide us with sufficient Margin to support your open position(s), therefore in accordance with our Terms of Business the following
position(s) have been closed:
_____________________________________________________________________

{TradeList [InstrumentLong] ([InstrumentShort])[IsCRB]. [BuySell] [TradeQuantity] [Currency] at a rate of [TradePrice]. Order ID [OrderID] at
[OrderTime]}
_____________________________________________________________________

The status of your account in view of the above closure(s) is now as follows:
_____________________________________________________________________

Date                                   : [DateLong]
Time (GMT)                             : [TimeShort]
Total Equity                           : [ReportingCcy] [TotalEquity]
Margin Requirement                     : [ReportingCcy] [TotalMargin]
Deficit Margin                         : [ReportingCcy] [TotalFreeEquity]
Minimum permitted equity               : [ReportingCcy] [MinimumEquity]
_____________________________________________________________________

To Fund your CMC Markets account please choose one of the following options.

Bank Transfer:

Please visit the Fund Account section of www.cmcmarketsglobal.com/support for the necessary details to organise a bank transfer, or contact
our Helpdesk on +44 (0) 207 170 8430.

Important Note:

Please ensure that any payment you make to us is made from a card or account in your name and not from that of another party. Any
remittances from third party sources will not be accepted.

As we can only allow you to trade with cleared funds in your account, any funds in transit or promised funds will not be credited to your account
until they are received and cleared by us. Please note that Cheques take five working days to clear upon receipt.

Should you have any questions relating to this e-mail then please do not hesitate to contact us on the numbers detailed below.

Regards,

CMC Markets
___________________________________________

Tel: +44 (0) 207 170 8430
Fax: +44 (0) 207 170 8485
Email: services@cmcmarketsglobal.com
Web: http://www.cmcmarkets.com/help
___________________________________________

CMC Markets UK Plc is authorised and regulated by the Financial Services Authority.

All information contained within this email, and any attachments, are subject to CMC Markets standard Terms and Conditions - which can be
found at: http://www.cmcmarkets.com

This email and any attachments, which may only be used by the intended recipients, are confidential and may contain proprietary information,
some or all of which may be legally privileged. Unauthorised disclosure, copying or distribution of this mail or its contents is strictly prohibited.
Should you have received this email in error please immediately return it to the sender or notify the company at misdirect@cmcmarkets.com,
then delete the email and any attachments from your system.

CMC Markets UK Plc takes every effort to ensure that our systems are regularly scanned for viruses and other infections with updated
programs, but cannot guarantee emails sent have not become infected elsewhere, we advise recipients to conduct their own checks as
considered appropriate.

35
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