Simulated Account Disclosure

This Simulated Account Disclosure ("Disclosure") is provided by The Black Vault Funding, Inc. ("Company," "we," "us," or "our"), a Minnesota corporation, to ensure that all program participants fully understand the nature of the accounts and services being offered. This Disclosure supplements the Terms of Service, Risk Disclosure, and all other legal documents governing your participation.

1. No Real Brokerage Relationship

The Company is not a registered broker-dealer, futures commission merchant (FCM), introducing broker (IB), commodity trading advisor (CTA), investment adviser, or any other regulated financial intermediary. The Company does not hold, manage, or invest client funds. No brokerage account is opened in your name at any financial institution as a result of participating in any Company program.

Any simulated "account balance" displayed in the trading platform or Company dashboard is a numerical representation used solely for the purpose of evaluating trading performance under simulated conditions. It does not represent actual money, a credit balance, or any financial claim against the Company or any third party.

2. Simulated (Paper / Demo) Trading Defined

"Simulated trading," also referred to as "paper trading" or "demo trading," means:

• Orders entered in the platform are processed by a simulation engine, not routed to any exchange, dark pool, OTC market, or live brokerage system.
• Fills, prices, and P&L calculations are generated based on data feeds and algorithmic models; they reflect hypothetical outcomes, not actual market executions.
• Simulated fills may differ materially from the prices that would be obtainable in a real, live market due to slippage, liquidity, latency, and other factors not fully replicated by simulation.
• Gains and losses shown in the platform are simulated gains and losses. They do not accrue to any real account, are not reportable as taxable income or loss from market activity, and have no monetary value until and unless a payout is approved and issued under the Company's Payout Policy.

3. "Funded" Status Is a Program Status, Not a Real Account

References to a "funded account," "funded trader," "funded phase," or similar terminology within Company marketing materials, platform interfaces, or communications refer exclusively to a program status within the Company's simulated evaluation framework. Being designated a "funded trader" means only that you have satisfied the evaluation criteria and have been authorized to continue simulated trading with a larger simulated balance and to request discretionary profit allocations from the Company's operating funds under the Payout Policy.

Any simulated profits you generate do not belong to you unless and until the Company approves and issues a payout in accordance with the Payout Policy. Even then, approved payouts are discretionary allocations from the Company's own operating funds, not a return of deposited capital or a share of real trading profits.

4. No SIPC, FDIC, or Government Insurance Protection

The Securities Investor Protection Corporation (SIPC) protects customers of registered broker-dealers. The Federal Deposit Insurance Corporation (FDIC) protects depositors at insured depository institutions. Because the Company is neither a broker-dealer nor a depository institution, and because no real funds are held in your name:

• SIPC protection does not apply to any account or balance associated with Company programs.
• FDIC insurance does not apply to any account or balance associated with Company programs.
• No other government, quasi-governmental, or industry insurance scheme protects your program participation fees or any simulated account balance.

Program fees paid to the Company are fees for access to a technology platform and evaluation service. They are not deposits, investments, or escrow balances.

5. Simulated Performance Does Not Predict Real-World Results

Simulated or hypothetical trading results have inherent limitations. Results achieved in a simulated environment may differ substantially from results that might be achieved in live trading. Key differences include, but are not limited to:

• Execution quality: Simulated fills assume ideal or near-ideal execution. Real markets involve slippage, partial fills, and rejection.
• Market impact: Large orders in real markets move prices. Simulated environments generally do not model market impact.
• Psychological factors: Trading with real money introduces psychological pressures absent from simulated environments, which may significantly affect decision-making and outcomes.
• Liquidity: Simulated platforms may allow execution at sizes that would be impossible or impractical in live markets at the displayed price.
• Platform differences: Execution speed, order types, and platform behavior in live brokerage environments may differ from the simulated platform used for evaluation.

Past simulated performance is not indicative of future results in any environment, simulated or live.

6. No Investment Advisory Services

Nothing provided by the Company — including but not limited to platform analytics, educational content, performance metrics, trade signals, or staff communications — constitutes investment advice, financial advice, trading recommendations, or any form of advisory service regulated under the Investment Advisers Act of 1940, the Commodity Exchange Act, or any applicable state law. You are solely responsible for all trading decisions made in your program account.

7. Program Fees Are Not Refundable Based on Simulated Losses

Because no real capital is deployed, "losses" in a simulated account represent a failure to meet evaluation criteria, not an actual financial loss. Program fees paid to access the evaluation platform are not refundable on the basis that a trader did not meet profit targets, triggered a drawdown limit, or experienced adverse simulated market conditions. See the Refund Policy for the complete terms governing fee refunds.

8. Data Accuracy and Platform Limitations

The Company provides simulated account access through third-party technology platforms and data feeds. The Company does not guarantee the accuracy, completeness, or timeliness of any price data, order fill, or account balance displayed in the platform. Technical errors, data delays, or platform outages may occur. The Company's liability for such occurrences is limited as set forth in the Terms of Service.

9. Regulatory Status

The Company's simulated trading evaluation programs are structured to operate outside the definition of regulated financial services under applicable federal and state law, based on the Company's legal analysis as of the effective date of this Disclosure. Regulatory interpretations may change. The Company makes no representation that its programs will always fall outside applicable regulatory requirements. Participants should consult independent legal counsel if they have questions about the regulatory status of simulated trading programs.

10. Minnesota Consumer Protection Notice

Pursuant to the Minnesota Consumer Fraud Act (Minn. Stat. § 325F.69) and the Deceptive Trade Practices Act (Minn. Stat. § 325D.44), the Company provides this plain-language summary: you are purchasing access to a simulated trading platform and evaluation service. You are not opening a real brokerage account, depositing money into a trading account, or purchasing any financial instrument. The program fees you pay go to the Company's operating account and are not held in trust, escrow, or any segregated fund on your behalf.

11. Acknowledgment

By activating any program account with The Black Vault Funding, Inc., you confirm that you have read, understood, and accepted this Simulated Account Disclosure in its entirety. If you do not agree with any provision of this Disclosure, do not activate or use any program account.

12. Contact

Questions regarding this Disclosure may be directed to:
The Black Vault Funding, Inc.
Email: [email protected]