Omni (a d/b/a of OTFS Inc, a registered Commodity Trading Advisor with NFA ID 0566836) provides technology that facilitates delivery of trading signals from independent providers (“Strategy Providers”) to your Retail Foreign Exchange Dealer (“RFED”) account. Omni does not manage customer accounts or hold customer funds.

Trading foreign exchange (“forex”) and derivatives involves substantial risk of loss and is not suitable for all investors. Past performance is not necessarily indicative of future results.

This Risk Disclosure Statement highlights significant risks you should carefully consider before using Omni.

1. Fundamental Trading Risks

• Substantial Risk of Loss – Leveraged forex transactions can cause you to rapidly lose all deposited funds and potentially more than your initial deposit.

• Not Exchange-Traded – Off-exchange forex transactions occur directly with your RFED, which acts as your counterparty and may profit when you lose.

• No Central Clearing or SIPC Protection – Retail forex accounts lack the protections provided to futures or securities accounts (e.g., segregation or SIPC insurance). In bankruptcy, you may be treated as a general creditor.

• Dealer Price Discretion – Your RFED sets prices for forex contracts, which may differ from interbank or exchange quotes. Prices may vary between customers.

• No Guarantee of Profit – Neither Omni nor any Strategy Provider can guarantee profits or freedom from loss.

• Past Performance Not Indicative – Historical trading results, even from real-money accounts, cannot predict future performance.

2. Leverage and Margin Risks

• High Leverage / Low Margin – Small price changes can result in disproportionate losses and margin calls.

• Margin Closeouts – If equity falls below required margin, the RFED may liquidate positions without notice.

• Weekend Gaps and Liquidity Drops – Positions cannot be adjusted during weekend market closures; spreads may widen and prices may gap significantly at reopening.

3. Execution Risks

• Slippage – Orders may be filled at worse prices than requested due to rapid market moves or delays.

• Inability to Open/Close Positions – Market conditions, system outages, or illiquidity may prevent execution at desired prices.

• Quoting Errors and Adjustments – Trades may be canceled or adjusted if executed on bad or erroneous quotes.

• Odd Lot Risks – Small trade sizes may execute differently than standard interbank quotes.

4. Technology and Operational Risks

• Electronic Platforms Are Not Exchanges – RFED trading platforms are solely a connection to the dealer; outages or failures may prevent access. Refer to Omni’s EULA for more detail.

• System Failures – Internet, server, or communications failures (yours or the RFED’s) may result in delayed or failed orders.

• One-Click / Immediate Execution – Certain RFEDs execute market orders instantly without cancellation ability.

5. Conflicts of Interest

• Counterparty Conflict – Your RFED profits when you lose, in addition to spreads or fees.

• Paid Solicitors – Introducing brokers or solicitors may be compensated in ways not disclosed to you, creating conflicts.

• Proprietary Trading – Dealers or their affiliates may trade for their own account in ways adverse to your positions.

6. Strategy Provider Risks

• Independent Providers – Traders, strategy providers, or algorithm owners using Omni are independent of Omni. Omni does not endorse or guarantee their strategies.

• Invite-Only Access – You may only follow providers who invite you. Omni does not provide a marketplace for browsing strategies.

• Track Record Limitations – While Omni requires real-money trading history, such performance may still include unrepeatable gains, temporary market conditions, or undisclosed risks.

• Discontinuity Risk – If a Strategy Provider stops publishing signals, your connection may terminate without replacement.

• Responsibility for Selection – You are solely responsible for evaluating whether following a provider’s signals suits your objectives and risk tolerance.

7. Additional Risks

• Bankruptcy of RFED – If your RFED becomes insolvent, your funds may not have priority under U.S. Bankruptcy Code.

• Currency Risk – Depositing in one currency and trading another exposes you to exchange rate fluctuations.

• Settlement Risk – Foreign exchange settlement can be delayed due to time zones or holidays, sometimes requiring borrowing costs.

• Tax and Legal Risks – Forex transactions may have uncertain tax or legal treatment depending on your jurisdiction.

• Customer Profile Suitability – Trading forex may be inappropriate for undercapitalized or financially vulnerable individuals (e.g., students, unemployed, low net worth).

8. Your Responsibilities

• You are solely responsible for:

  • Deciding whether to follow signals via Omni.

  • Understanding and monitoring all risks.

  • Maintaining sufficient capital and margin.

  • Seeking independent financial, legal, or tax advice.

9. Final Acknowledgment

This statement cannot disclose every risk. By using Omni, you acknowledge that:

• Trading forex involves substantial risk of loss.

• Omni does not manage your account or hold your funds.

• You assume all risks of gains and losses.

Trading foreign exchange (“forex”) and derivatives involves substantial risk of loss and is not suitable for all investors. Past performance is not necessarily indicative of future results.