FINANCIAL
PULSE
FINANCIAL
RISK
DISCLOSURE
STATEMENT
FINANCIAL PULSE ORG.
PULSE
DECEMBER 2021
UNIT 5, 45 OAK STREET, PARRAMATTA, [Link]
NSW 2150, AUSTRALIA. support@fi[Link]
FINANCIAL
PULSE [Link]
1. IMPORTANT INFORMATION
Leveraged trading in forex, derivatives, precious metals, CFDs or other off-exchange products (also known as “over-the-counter” or “OTC
derivative products”) on margin carry a high level of risk to your capital. You do not own, or have any rights to the underlying assets. Trading
is not suitable for everyone and may result in losses of all your deposits. You should only trade with money you can afford to lose.
This statement provides you with a non-exhaustive overview of the key risks that you should take into account when deciding whether to
open an account and trade with Financial Pulse ORG. (‘Financial Pulse’). This statement does not explain all of the risks involved in trading or
how the risks relate to your personal circumstances. It is important that you read the relevant legal documentation to fully understand the
risks involved in light of your personal circumstances before deciding to open an account and trade with us. We recommend that you seek
independent advice if you’re unsure.
2. NO PERSONAL ADVICE PROVIDED
Our products and services are provided on an execution-only basis – you are solely responsible for any decisions that you make in relation
to our products and services. Financial Pulse is not a financial advisor nor do we provide any regulatory, tax or legal advice. Sometimes we will
provide you with general factual information about the market and how our various products and services work. Any information and
analysis provided by us is general in nature and does not take into account your or your client’s personal objectives, financial situation or
needs. You should not regard any of the information that we provide to you as an investment recommendation or an offer to make a
transaction. Tax benefits are subject to change and depend on your individual circumstances. We recommend that you seek specialist
advice if you are uncertain about any of these matters.
3. KEY RISKS ASSOCIATED WITH TRADING MARGIN FX
CONTRACTS AND CFDS
(1) Market Risk
(a) This is the risk that the markets move against you. External market forces are difficult to predict and can cause markets and
prices to change quickly. Such forces include changing supply and demand relationships, governmental, national and international
political and economic events and the prevailing psychological characteristics of the marketplace. It is important that you closely
monitor your Positions and markets at all times. As the price of your Position is based on an Underlying Instrument, these
factors may affect your Position and our ability to execute, settle or close out transactions on your behalf.
(b) No CFD or margin FX transactions available via our Trading Platform can be considered “risk free” or “safe”. You may reduce some
of your downside risk by our risk management tools. Further details can be found in section 11.9 of our PDS.
(c) Holding both long (i.e. bought) and short (i.e. sold) Positions is not necessarily less risky than holding a simple long (i.e. bought)
or short (i.e. sold) Position. You may incur further losses holding Positions of both directions than holding Positions of one
direction.
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FINANCIAL
PULSE [Link]
(d) During extreme times of volatility, the Overnight Funding fee may increase signicantly and may quickly erode your initial
deposits even before accounting for market price movements. The latest applicable overnight funding rate is available on the
Trading Platform and upon request. You should closely monitor your positions and the applicable rates before making decisions
to hold your Positions overnight.
(2) Trading Over the Counter and Not on a formal exchange
Financial Pulse products are all Over-The-Counter (“OTC”) products. Unlike securities exchanges, there is no clearing house for Margin FX
Contracts and CFDs. This means that Financial Pulse’s products are not covered by the protections for exchange-traded products arising
from exchange rules, and are not guaranteed by any exchange or clearing house. However, because Financial Pulse endeavours to reflect the
changes in the underlying markets and pass on the changes to your Positions, the rules of the relevant underlying market (if any) or
Exchange may indirectly affect your dealing in the products offered by Financial Pulse. You should consider all of the rules of each relevant
Exchange may be relevant to Financial Pulse contracts. The details of those rules are outside the control of Financial Pulse and they may
Charge at any time and without notice to you.
(3) Conflict of Interests
Trading with Financial Pulse carries an automatic risk of an actual conflict of interest because Financial Pulse is acting as principal in its
Position with you and Financial Pulse sets the price of the contracts as a market maker. Financial Pulse may also be transacting with other
persons or other market participants. Financial Pulse does not guarantee that the price given to you is the best price. You can reduce
the risks to you of unfavourable pricing or opaque pricing by monitoring Financial Pulse contract pricing and by monitoring the underlying
market. Financial Pulse also mitigates this risk by retaining external legal advisors, ongoing Board supervision and implementing compliance
procedures. Further details can be found in section 16 of our PDS.
(4) Loss by Spread
Since Financial Pulse charges a spread on some transactions, the price will have to move in your favour before you can break even. That is,
even if the price does not move, you will be making a loss when entering the transaction because of the spread.
(5) Slippage
In extremely fast moving or illiquid markets, gaps (also known as Slippage) may occur. Slippage occurs when market prices do not
follow a “smooth” or continuous trend and are typically caused by external factors such as world, political, economic and corporate
related events. Should slippage occur in the Underlying Instrument on which your product is based, you may not be able to close out
your Position or open a new Position at the price at which you have placed your order. Further, in instances of slippage, any conditional
orders opened on your Account will be filled at the next best available price which may be substantially different from the price
selected when entering your conditional order.
(6) Margin Call
Should the price of the Margin FX Contract or CFD move against you, you may receive a Margin Call from us preventing your Account
from opening any further exposures and enlivening our discretion to close out your open Positions without further notice. Should we
make a Margin Call, you must increase your Equity to above 100% of Total Initial Margin required to remove the trading restrictions
on your Account and prevent your Positions from being closed out. In the event that your Equity falls below Maintenance Margin
levels, we may also reduce or close all your open Positions without further notice and you will be liable for any shortfall. Positions are
marked-to-market with payments being settled daily to Account for market movements. You must be in a position to fund such
requirements at all times. Margin Calls must be addressed as soon as possible and are only considered paid once we receive cleared
funds in our account. While Financial Pulse will already have an absolute discretion to close out open Positions once a Margin Call is issued,
Financial Pulse may (in its absolute discretion), delay exercising that right to give you an opportunity to address the Margin Call. In some
circumstances, the markets could move against your Position giving Financial Pulse no time to make a Margin Call before your Account has
breached the Maintenance Margin, allowing Financial Pulse to liquidate your Positions in order for Financial Pulse to protect itself and other
clients.
(7) Leverage
As these products might be highly leveraged based on the applicable margin percentage, a small price movement in the price of the
Underlying Instrument on which they are based can result in substantial profits or losses exceeding your Initial Margin. In addition, you
could be required to pay further funds representing losses and other fees on your open and closed Positions. The prices of our
products may be volatile and fluctuate rapidly over wide ranges. Price fluctuations may be as a result of uncontrollable events or
changes in a variety of conditions as described above under Market Risk.
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(8) Liquidity
There may be periods where certain currency pairs or CFDs become illiquid. The lack of liquidity may prevent you from taking Positions
in FX or CFDs or from liquidating from unfavourable Positions resulting in you incurring a loss.
(9) Guaranteed Stop Orders unavailable
Certain products can be traded in conjunction with our limit and stop loss orders which are designed to either optimise your exposure
to the market or limit your loss by instructing that trades be executed at pre-determined price levels. Stop losses are instructions
placed by you with Financial Pulse to close out an open Position if a market trades through a specific level. Stop loss orders are often
used to attempt to limit the amount which can be lost on a Position. You should be aware that stop losses are not guaranteed and the
execution of such orders will depend on market volatility and liquidity. So, whilst stop losses generally allow you to control potential
losses should the market move against you, please be aware that stop loss orders are not guaranteed and may not always limit your
losses the way you anticipate.
(10) Our Right to Close Out and Place Restrictions
(a) Should you fail to pay any amounts due and payable, including Margin Calls, or keep your Equity equal to or above Maintenance
Margin levels, Financial Pulse has an absolute right to close out Positions.
(b) You acknowledge that the trading of Margin FX Contracts or CFDs over certain Underlying Instruments on the Financial Pulse Platform
may become volatile in a very short time period and without any prior warnings. Due to the high degree of risk involved, you
acknowledge and agree that we reserve the right to close all or any open Transactions with respect to any Underlying Instrument
that we determine is volatile in our sole discretion (having regard to our legitimate interests), at the price quoted on the Financial Pulse
Platform at such time without notice.
(c) We reserve the right to require you to close out Transactions in a timely manner in the event that the product is removed from
the Financial Pulse Trading Platform. We will endeavour to provide you with a prior notice and request you to close out relevant
Positions before a deadline. Where Positions remain open after the deadline, we reserve the right to close such Positions on your
behalf at the last available price.
(d) If we receive a reverse request (also known as chargeback) from your credit card issuer or with respect to any other payment
method for any reason, you acknowledge that we reserve the right to:
(i) immediately close any or all of your open Transactions whether at a loss or a profit and liquidate your Account with or
without any notice;
(ii) cancel, re-price, adjust or void past transactions;
(iii) immediately place restrictions on your Account with or without any notice, including: (i) the restriction on making deposits
using any payment method to your Account; (ii) the restriction on requesting withdrawals from your Account; and (iii) the
restriction on opening new Positions on the Financial Pulse’s Trading Platform; the duration of the restrictions will be set at
Financial Pulse’s discretion; and/or
(iv) terminate the Client Agreement.
(e) Financial Pulse reserves the absolute discretion to terminate the Client Agreement with immediate effect or void or re-price or close
out a Position at any time, for any value if in the sole opinion of Financial Pulse, you are suspected of Unauthorised Activities, market
manipulation, false trading, market rigging, fictitious transactions, wash trading, insider trading, short selling, breaching the
financial services laws or breaching the AML/CTF laws.
(f) Financial Pulse may impose volume limits on the size of positions and access to products on your Account to mitigate our risk.
(g) Under the Client Agreement you also indemnify Financial Pulse and its employees, agents and representatives against certain losses
and liabilities. You should read the Client Agreement carefully to ensure you understand these powers and responsibilities.
(11) Electronic Trading Platform and System Risk
(a) We rely on technology to provide our Trading Platform to you. You shall be responsible for providing and maintaining the means
by which to access our Trading Platform, which may include without limitation a personal computer, smartphone, modem and
telephone or other access line. While the internet and the World Wide Web are generally reliable, technical problems or other
conditions may delay or prevent access thereto. If you are unable to access the internet and thus, our electronic Trading Platform,
it will mean you may be unable to trade in a product offered by Mitrade when desired and you may suffer a loss as a result.
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(b) We also rely on a number of technology solutions to provide you with efcient services. Prior to engaging these providers,
Financial Pulse has performed due diligence and entered into service agreements with each provider. Disruption to Financial
Pulse operational processes such as communications, computers, networks or external events may lead to delays in the execution
of or settlement of a transaction. An example of disruption includes the crash of our computer-based trading system. Financial
Pulse mitigates this risk by conducting regular backups and using appropriate IT systems and protections. This means that you may
be unable to trade in a particular market that we offer and you could suffer a Financial loss or an opportunity loss as a result.
(c) We reserve the right to suspend a part of or the entire operation of our Trading Platform and website. In such event, we may, at
our sole discretion (with or without notice), close out your open Positions at prices we consider fair and reasonable.
(12) Regulatory Risk
Changes in taxation and other laws, government, fiscal, monetary and regulatory policies may have a material adverse effect on your
dealings in Margin FX Contracts or CFDs, as may any regulatory action taken against Financial Pulse. We will use our best endeavours to
notify you of a change in legislation which may impact the way that you deal with us.
(13) Counterparty Risk
(a) You must deal directly with Financial Pulse to open and close Positions. Given you are dealing with Financial Pulse as counterparty
to every transaction, you will have an exposure to us in relation to each transaction. This is described as counterparty risk and is
common to all over-the-counter derivatives products. If Financial Pulse becomes insolvent, we may be unable to meet our obligations
to you.
(b) However, while you consider such risk it is important to note that Financial Pulse complies with the specific financial requirements
imposed on our AFSL as set out in ASIC Regulatory Guide 166 and other regulatory financial obligations as an issuer of OTC
derivatives. We monitor our exposure on a regular and frequent basis using real-time software tools and prepare detailed
financial reports to ensure the applicable financial requirements are met. We are required to have our accounts audited at least
annually.
(c) Financial Pulse may choose to limit our exposure to our clients by entering into transactions with hedging counterparties as principal
in the wholesale market. Financial Pulse is therefore exposed to the counterparty risk with the hedging counterparties. If these hedging
counterparties which Financial Pulse deals with become insolvent, we may not have recourse to underlying assets and will become an
unsecured creditor of the hedging counterparties and subsequently may affect our ability to meet our obligations to you.
(d) To mitigate such risk, Financial Pulse has put in place policies, systems and controls in place. We maintain and implement a Hedging
Counterparty Policy, which sets out in detail the factors we take into account when selecting hedging counterparties. Our
Hedging Counterparty Policy is available on our website ([Link]). It may be updated from time to time as
counterparties change. Financial Pulse uses reputable counterparties such as established financial institutions with good credit
standing along with adequate financial resources. In selecting the counterparties, Financial Pulse considers public information, credit
agency reports and the most recent financial statements showing the paid-up capital, assets and liabilities ofthose counterparties.
In addition,Financial Pulse undertakes searches of the relevant regulators’ databases to confirm that the proposed counterparty holds
all the necessary licenses and/or authorities. We also use credit limits to manage our exposure to each counterparty.
(14)
Foreign Exchange Risk
(a) Your Account is maintained in the currency you have nominated, that is, the Base Currency. Where you deal in a product that is
denominated in a currency other than the Base Currency, all Initial and Maintenance Margins, profits, losses, interest rate
payments/receipts and financing credits and debits in relation to that product are calculated using the currency in which the
product is denominated.
(b) Accordingly, your profits or losses may be affected by fluctuations in the relevant foreign exchange rate between the time the
order is placed and the time the Position is closed, liquidated, offset or exercised.
(c) Upon closing a Position that is denominated in a currency other than the Base Currency of your Account, the foreign currency
balance will be converted to the Base Currency of your Account. Any conversion will be at the exchange rate quoted by Financial Pulse.
Until the foreign currency balance is converted to the Base Currency, fluctuations in the relevant foreign exchange rate may
affect the unrealised profit or loss made on the Position.
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PULSE [Link]
(15) Cryptocurrencies Risks
(a) Cryptocurrency CFDs involves high risk as their value can fluctuate significantly. In addition, Cryptocurrencies are subject not
only to markets risks (such as supply and demand), but also technology risks. If you choose to invest in Cryptocurrency CFDs, you
do so acknowledging that these instruments are much more volatile than traditional currencies, so sharp and sudden moves in
the price could see you lose significant amounts of money very quickly.
(b) Financial Pulse does not buy or sell Cryptocurrency, nor does it operate as a digital currency exchange provider. When you trade
Cryptocurrency CFDs with us, you are not buying or selling a specific Cryptocurrency. You are entering into a contract with us
regarding the price movement of the underlying Cryptocurrency you select and as in other CFDs, there is never any physical
delivery. Your account will be credited or debited with any profit or loss derived from the Position.
(c) Cryptocurrencies are digital currencies. It is important to note that while the instrument structure and specifications of such
offerings are substantially similar to that of other CFDs or Margin FX Contracts, the underlying markets are themselves very
different. Each Cryptocurrency is different and subject to its own rules of creation, storage and transfer of ownership of their
various units. Given that Cryptocurrency CFDs do not involve physical delivery, it is beyond the scope of this PDS to describe the
mechanics behind these underlying Cryptocurrency markets. You should familiarise yourself with the operations of the
Cryptocurrency markets on which the CFDs you wish to trade are written, prior to trading.
(d) We base the price of our Cryptocurrency contracts on the underlying market, made available to us by our liquidity providers. You
should be aware that the pricing formation rules of the Cryptocurrency exchanges are not subject to any regulatory supervision
and may be changed at the relevant digital exchange’s discretion at any time. Similarly, such digital exchanges may introduce
trading suspensions or take other actions that may result in suspension or cessation of trading on such exchanges or the price
and market data feed becoming unavailable to us. Due to the volatile nature of Cryptocurrencies, where there is an event of a
consensus among the exchanges and the instrument is no longer offered, we can delist the instrument in short notice. The
above factors could result in a material adverse effect on your open Positions, including the loss of all of your invested amounts.
(e) When you trade CFDs on cryptocurrencies, you need to be aware of the risk of a hard fork occurring. A hard fork is when a single
cryptocurrency splits in two and occurs when a cryptocurrency’s existing code is changed, resulting in both an old and new
version of the cryptocurrency. Financial Pulse reserves the right to determine which blockchain (ledger of cryptocurrency transactions)
and cryptocurrency unit has the majority consensus behind them and use this as the basis for cryptocurrency contracts. We will
endeavour to notify you of potential forks, however it is your responsibility to make yourself aware of the forks that could occur.
(f) Cryptocurrency CFDs are generally considered of a higher risk than other Margin FX or CFD products. You should seek
independent advice before entering into a transaction with us. Cryptocurrencies are also traded over the weekend, therefore the
market is effectively always open unlike other financial products.
(16) Third Party Market Information
(a) Financial Pulse may make available to you through one or more of its services, a broad range of financial information that is generated
internally or obtained from agents, vendors or third-party providers. This includes, but is not limited to, financial market data,
quotes, news, analyst opinions and research reports, graphs or data (Market Information).Market Information provided by us by
email or through our website is not intended as advice. Financial Pulse does not endorse or approve the Market Information and we
make it available to you only as a service for your own convenience. Financial Pulse and its third party providers do not guarantee the
accuracy, timeliness, completeness or correct sequencing of the Market Information or warrant any results from your use or
reliance on the Market Information.
(b) Market Information may quickly become unreliable for various reasons including, for example, changes in market conditions or
economic circumstances. Neither Financial Pulse nor the third-party providers are obligated to update any information or opinions
contained in any Market Information and we may discontinue offering Market Information at any time without notice.
(17) Risk Capital Only
You could lose all of your deposits to establish or maintain a Position. All derivatives trading involves risk and there is no trading
strategy that can eliminate it entirely. The placing of contingent orders (such as a stop-loss order) may not always limit your losses to
the amounts that you may want. Market conditions may make it impossible to execute such orders. In cases where you are speculating
we suggest that you do not risk more capital than you can afford to lose. A good general rule is never to speculate with money which,
if lost, would alter your standard of living.
PAGE 5 OF 5 FIANACIAL PULSE ORG., RISK DISCLOSURE STATEMENT, DECEMBER 2021
FINANCIAL
PULSE
FINANCIAL PULSE ORG.
UNIT 5, 45 OAK STREET, PARRAMATTA, [Link]
NSW 2150, AUSTRALIA.