RES 2A – Rules, Ethics and Skills for Derivatives Exchange Dealers

Correct: Statement I is correct because market participants, including Trading Members and their representatives, have a mandatory duty to immediately report any reasonable suspicion or knowledge of market manipulation to the Exchange. Statement III is correct because the law allows for civil penalties to be calculated as the higher of a fixed dollar amount or a multiple of the financial benefit, specifically up to three times the profit gained or loss avoided.

Incorrect: Statement II is incorrect because the failure to inform the Exchange of prohibited trading practices is specifically classified as a non-compoundable offence, meaning it cannot be settled by a fine alone and is subject to a minimum mandatory penalty. Statement IV is incorrect because the legal framework prevents double jeopardy in this context; if a person has already been convicted or acquitted in a criminal trial, civil penalty proceedings for the same conduct cannot be initiated.

Takeaway: Intermediaries must maintain immediate reporting standards for suspicious activities, as failure to do so results in non-compoundable penalties, while the legal system maintains a strict separation between concluded criminal trials and civil penalty actions. Therefore, statements I and III are correct.

Correct: Filing the investigation report with the Commercial Affairs Department and providing a copy to the regulator within 15 days of the internal referral is the mandatory procedure. The 15-day timeline is specifically triggered by the date the staff member refers the suspicious activity to the firm’s designated internal point of contact.

Incorrect: Filing only with the regulator is insufficient because the law requires the report to be lodged with the Commercial Affairs Department of the police. The option suggesting the timeline begins on the trade execution date is wrong because the filing deadline is linked to the internal referral date. The suggestion of a 30-day filing window is incorrect as the regulations mandate a shorter 15-day period.

Takeaway: Suspicious Transaction Reports must be filed with both the police and the regulator within 15 days of an internal referral to ensure the timely reporting of potential financial crimes.

Correct: Statement I is correct because the exchange has the authority to suspend or restrict the activities of a registered representative immediately upon them being charged with a serious offence, such as fraud, to protect the public and maintain market integrity. Statement II is correct because individuals who traded at the same time as the offender and suffered losses are entitled to seek civil damages, though the total recovery is limited to the profit the defendant gained or the loss they avoided.

Incorrect: Statement III is incorrect because civil proceedings are stayed, meaning they are temporarily paused or put on hold, rather than being dismissed when criminal proceedings begin. Statement IV is incorrect because the Disciplinary Committee is explicitly granted a wide range of powers to address misconduct, which includes the authority to mandate re-education or specific compliance training for the individual involved.

Takeaway: Market misconduct can result in both exchange-led disciplinary actions and civil liabilities, where the total civil recovery for all claimants is capped by the defendant’s total illegal financial benefit. Therefore, statements I and II are correct.

Correct: For listed futures, a customer qualifies if they have transacted in listed SIPs at least 6 times in the preceding 3 years is the right answer because the regulatory criteria for assessing knowledge and experience in listed derivatives require a minimum of 6 transactions in listed specified investment products within the last 3 years.

Incorrect: The option regarding unlisted products and 3 transactions is wrong because the requirement for unlisted specified investment products is also 6 transactions within the preceding 3 years, not 3. The option about non-consecutive work experience is wrong because the 3 years of relevant professional experience must be consecutive within the past 10 years to be considered valid. The option about a diploma in any field is wrong because the educational qualification must be in specific relevant fields such as finance, business, or accountancy, rather than any general subject.

Takeaway: To qualify for trading specified investment products based on experience or education, customers must meet specific thresholds such as 6 recent trades, 3 consecutive years of relevant work, or a degree in a finance-related field.

Correct: Statement I is correct because Sponsored Access is a specific regulatory classification where the customer transmits orders directly to the exchange platform, bypassing the Member’s own internal infrastructure to reduce latency. Statement II is correct because all customers granted direct access must enter into a legally binding agreement that includes a commitment to assist the exchange in any investigations into potential rule violations. Statement IV is correct because the regulatory framework allows a customer to delegate their access to other persons, provided the Member ensures those individuals are also subject to the same proficiency and conduct requirements.

Incorrect: Statement III is incorrect because the requirement to have robust security arrangements in place to prevent unauthorized access is a mandatory condition for all forms of direct connectivity; there is no exemption for Sponsored Access simply because the Member’s infrastructure is bypassed.

Takeaway: While Sponsored Access provides a more direct technical path to the exchange, the Trading Member retains full responsibility for vetting the customer’s financial standing, technical proficiency, and security controls. Therefore, statements I, II and IV are correct.

Correct: The statement regarding the Pre-Settlement Matching Service (PSMS) requiring telephone confirmation is NOT correct. PSMS was specifically introduced to replace manual processes where participants had to agree on trade details over the phone. It provides an automated straight-through-processing environment where instructions are uploaded or input directly into the system without the need for prior verbal communication between counterparts.

Incorrect: The statement about Free-of-Payment (FOP) transactions is true because, in such cases, the participants handle the financial side of the trade independently without involving the central depository. The description of the central depository as a bare trustee is true, as it holds securities for the collective benefit of depositors while facilitating ownership transfers through book-entry. The statement regarding the Qualifying Central Counterparty (CCP) status is true because it allows members to benefit from reduced capital requirements for their exposures under international banking frameworks.

Takeaway: The Pre-Settlement Matching Service (PSMS) is designed to eliminate manual errors and improve efficiency by automating the matching of settlement instructions, removing the need for telephone-based trade verification.

Correct: Failing to provide a timely and sufficiently detailed response to a client’s formal grievance is the right answer because, under the rules for futures trading, the failure to satisfactorily address customer complaints is a specific type of professional misconduct that may be compounded with a fine. The penalty for this specific offense is flexible and depends on factors such as the individual’s role and their history of prior violations.

Incorrect: Providing a material misstatement to the Disciplinary Committee is wrong because making false statements to the Exchange or its committees is a non-compoundable offense that carries a mandatory minimum penalty. Altering internal transaction records without a valid reason is wrong because tampering with or destroying books and records is classified as professional misconduct that is non-compoundable. Refusing to comply with a final arbitration award is wrong because non-compliance with official orders or arbitration awards is strictly non-compoundable and subject to a mandatory minimum penalty.

Takeaway: While most forms of professional misconduct in the futures market carry mandatory minimum penalties, failing to handle customer complaints appropriately is a compoundable offense.

Correct: Statement III is correct because it is a false statement; while the regulations require mandatory error-prevention alerts for price and maximum quantity per order, alerts for all other data fields are considered good practice but are not compulsory for an Order Management System.

Incorrect: Statement I is incorrect because it is a factually true statement; systems must allow for real-time adjustments to credit or quantity limits to manage risk during volatile market conditions. Statement II is incorrect because it is a factually true statement; the doer-checker principle is a required internal control where one person prepares data and a senior staff member verifies it. Statement IV is incorrect because it is a factually true statement; firms are required to monitor credit risks at least daily and all account activity on an intraday basis.

Takeaway: Mandatory system alerts are limited to price and quantity thresholds, while other risk controls like real-time limit adjustments and doer-checker protocols must be strictly maintained. Therefore, statement III is correct.

Correct: Statement I is correct because overseas jurisdictions often have distinct regulations regarding how custodian banks or depositories handle the segregation and protection of client assets, which may differ from Singaporean standards. Statement III is correct because less developed legal systems may lack the precedents or established concepts found in mature systems, making judicial outcomes and damage awards difficult to predict with certainty. Statement IV is correct because Singapore brokers execute trades through foreign intermediaries; if those foreign entities fail or become insolvent, client positions may be closed out automatically to manage risk without the client’s prior consent.

Incorrect: Statement II is incorrect because the Monetary Authority of Singapore does not have the legal authority or jurisdiction to compel foreign regulatory bodies or overseas markets to enforce their own local rules or regulations on behalf of Singapore-based investors.

Takeaway: Investors must recognize that trading on overseas exchanges involves unique risks, including limited regulatory recourse from Singapore authorities and potential uncertainties in foreign legal, clearing, and custodial systems. Therefore, statements I, III and IV are correct.

Correct: Statement I is correct because the regulatory framework specifically requires Members to maintain a detailed register containing the identity and address of every customer granted Sponsored Access, which must be produced upon request. Statement III is correct because the delegation of Sponsored Access is strictly controlled and only permitted for persons regulated by a recognized authority or for SGX Members who are delegating that access to their own related corporations.

Incorrect: Statement II is incorrect because Sponsored Access is not exempt from standard controls; rather, it must comply with the exact same regulatory requirements as Direct Market Access (DMA), including all pre-execution checks. Statement IV is incorrect because the rules do not mandate the use of a proprietary system; instead, pre-execution checks can be performed through either a Clearing Member’s hosted system or the Exchange’s own hosted pre-trade risk controls.

Takeaway: While Sponsored Access provides high-speed market entry for specific participants, it remains subject to the same rigorous pre-execution risk controls as Direct Market Access and carries additional registration and delegation restrictions. Therefore, statements I and III are correct.

Correct: The requirement is satisfied when a customer completes a learning module from an independent body because this demonstrates they have acquired the necessary understanding of the features and risks associated with the specific unlisted product through an approved educational pathway.

Incorrect: Relying on a testimonial from a licensed representative is incorrect because the assessment must be based on objective criteria or approved educational modules, not personal endorsements. Having a high-net-worth account for a specific duration is incorrect because financial status and account history do not serve as a substitute for the specific knowledge or experience required for complex investment products. Using a legal indemnity form is incorrect because firms cannot contract out of their regulatory duty to ensure a customer has the requisite knowledge before trading.

Takeaway: If a customer fails the initial knowledge assessment for unlisted products, they can bridge the gap by completing an approved independent learning module.

Correct: Issuing a Regulatory Notice to all Members at least three weeks before the new algorithm is applied is the right answer because the exchange is required to ensure transparency and fairness by giving all participants sufficient lead time when changing matching logic.

Incorrect: The suggestion to provide a formal written notice four weeks in advance is wrong because the specific regulatory requirement is a three-week notice period via a Regulatory Notice. The option regarding updating the website two weeks prior is incorrect because it fails to meet the minimum three-week notice requirement and the correct communication channel. The option to notify only Market Makers thirty days in advance is wrong because the exchange must notify all Members, not just a specific group, to maintain a fair and transparent market.

Takeaway: When changing trade matching algorithms, the exchange must provide at least three weeks’ notice to all Members via a Regulatory Notice to ensure market transparency.

Correct: Statement I is correct because a sudden and unexplained increase in the intensity of trading from a previously dormant or inactive account is a classic indicator of potential money laundering. Statement II is correct because transactions that do not align with a customer’s known economic background or financial standing lack economic sense and should be scrutinized. Statement III is correct because the unexpected repayment of a delinquent or long-overdue account without a plausible explanation is specifically listed as a suspicious activity. (Statements I, II, and III are correct)

Incorrect: Statement IV is incorrect because providing transparent and easily verifiable documentation is the expected behavior of a legitimate client. Suspicious behavior involves the opposite: providing minimal, false, or misleading information, or providing details that are intentionally difficult or expensive for the firm to verify.

Takeaway: Suspicious transactions are identified by looking for activities that lack economic logic, deviate significantly from a client’s established profile, or involve attempts to obscure information. Therefore, statements I, II and III are correct.

Correct: Statement I is correct because units in a business trust are explicitly listed as excluded investment products. Statement III is correct because units in a collective investment scheme that is a trust, invests primarily in real estate, and is listed on an exchange (commonly known as a REIT) are classified as excluded investment products. Statement IV is correct because spot currency exchange contracts, where the physical exchange of currencies occurs immediately, are considered excluded investment products.

Incorrect: Statement II is incorrect because while general debentures are often excluded investment products, structured notes are specifically carved out from this definition. Because of their complex payoff structures and embedded derivatives, structured notes are treated as specified investment products rather than excluded investment products.

Takeaway: Excluded investment products are generally traditional or less complex instruments like listed shares, REITs, and spot FX, whereas products with embedded derivatives like structured notes are excluded from this category. Therefore, statements I, III and IV are correct.

Correct: Requesting the Exchange to cancel orders on a best-effort basis while providing an indemnity from the Clearing Member is the right answer because the Exchange requires the Clearing Member to protect it against legal claims arising from the request. Furthermore, the Exchange only performs these cancellations on a best-effort basis, meaning there is no guarantee that orders will be cancelled before they are executed in the market.

Incorrect: The option suggesting a guarantee is wrong because the Exchange explicitly operates on a best-effort basis and does not guarantee that execution will be prevented. The option stating that bulk cancellation is prohibited is wrong because the rules allow for the cancellation of all orders originating from a specific Access ID. The option regarding waiting for automatic purging is wrong because the Member has a proactive responsibility to manage resting orders through the Exchange’s cancellation procedures when their own connectivity fails.

Takeaway: When a Member loses connectivity to the Exchange, they may request order cancellation, but this is subject to identity verification, a best-effort execution standard, and a mandatory indemnity from the Clearing Member.

Correct: The first order receives a portion of the incoming quantity first due to its PPM status, with the remaining quantity shared between both orders based on their relative sizes. This occurs because the first order improved the market price, earning it a priority allocation of the incoming trade volume before the standard Pro-Rata distribution takes place.

Incorrect: The option regarding time priority is incorrect because Pro-Rata systems do not prioritize the earliest order for its entire volume. The option suggesting allocation based solely on size is wrong because it ignores the priority given to the Price Point Maker. The option stating the first order is filled for its full 50 lots is incorrect because the priority allocation only applies to a percentage of the incoming order, not the resting order’s total size.

Takeaway: Price Point Maker (PPM) status rewards market participants who improve price transparency by granting them a priority fill percentage before the remaining order volume is distributed pro-rata.

Correct: Identifying the transaction as suspicious is the right answer because the sudden receipt of large funds followed immediately by their use as collateral for financing is a specific red flag. This pattern is recognized as a potential method for money laundering or other illicit activities, regardless of the client’s previous history with the firm.

Incorrect: The suggestion that this is standard behavior for long-term clients is wrong because a client’s history does not negate the suspicious nature of a specific transaction pattern. The idea that only foreign transfers are suspicious is incorrect because internal movements and collateralization are also key indicators of risk. Relying solely on a client’s written declaration is wrong because firms must independently assess suspicious patterns rather than accepting unverified claims of legitimacy.

Takeaway: Any transaction where large sums are deposited and immediately used for margining or financing should be flagged as suspicious, regardless of the client’s profile or explanations provided.

Correct: The order is automatically deleted by the system at the end of the T-session and will not be active during the T+1 session because a Day Order is only valid for the specific trading session in which it was entered. Even if the T+1 session occurs on the same calendar date, the order does not carry over.

Incorrect: The statement that the order remains active for the T+1 session is incorrect because Day orders are session-specific, not calendar-day specific. The claim that the order converts to a GTC order is wrong because the system does not automatically change order types; a GTC order must be specifically selected by the trader. The suggestion that the order is suspended and reactivates the next day is false because the system deletes unfilled Day orders at the end of the session.

Takeaway: For trading on QUEST, the ‘Day’ validity refers strictly to the current trading session (T or T+1) rather than a full calendar day.

Correct: Benefiting from lower capital requirements for trade and default fund exposures is the right answer because SGX-DC is recognized as a Qualifying Central Counterparty (CCP). Under the Basel III framework, being a member of a Qualifying CCP allows financial institutions to maintain lower capital reserves against their exposures, which directly translates to reduced capital costs for the firm.

Incorrect: The suggestion that membership provides an exemption from the Representative Notification Framework is wrong because all individuals performing regulated activities must still be notified to the regulator regardless of the clearing house’s status. The idea that a member can avoid following SGX-DC Clearing Rules is incorrect as these rules are mandatory for all clearing members to ensure market integrity. The claim regarding a waiver of annual license fees is wrong because CCP status impacts capital adequacy requirements, not the administrative fees required to maintain a business license.

Takeaway: Membership in a Qualifying CCP like SGX-DC provides firms with significant capital efficiency by allowing for lower capital charges on trade and default fund exposures.

Correct: Statement I is correct because a Sell Stop Order is designed to trigger when the market price falls to a level below the current market, which is commonly used to exit positions when a support level is broken. Statement II is correct because a Sell MIT Order is used when a trader wants to sell at a price higher than the current market once a specific resistance level is touched. Statement IV is correct because both Stop and MIT orders are conditional orders that are held by the system and not immediately entered into the active order book until the trigger price is reached.

Incorrect: Statement III is incorrect because the trading system allows the instrument being monitored for the trigger (Stop Series) to be different from the instrument that is actually traded upon conversion (Convert to Series). For example, a trigger could be based on a futures contract price while the resulting order is for an option contract.

Takeaway: Stop orders and MIT orders are conditional triggers that remain inactive until a price level is reached, with Stop sell orders triggering below the market and MIT sell orders triggering above the market. Therefore, statements I, II and IV are correct.

Correct: Statement I is correct because Market-to-Limit (MTL) orders with Day validity are designed to match as much as possible at the best current price and then place any remaining volume into the order book as a Limit Order at that same price. Statement II is correct because Market Orders in a continuous matching state prioritize execution speed by sweeping through available prices in the order book until the total quantity is satisfied.

Incorrect: Statement III is incorrect because Stop Orders are kept private and are not displayed to the market until the trigger condition is met and they convert into active orders. Statement IV is incorrect because the Fill-or-Kill (FOK) instruction specifically mandates that the order must be filled in its entirety or not at all; partial fills are strictly prohibited under this validity type.

Takeaway: Traders must distinguish between order types that allow partial fills and those that require total execution to effectively manage liquidity and price risks on the trading system. Therefore, statements I and II are correct.

Correct: Appointing a board of at least two directors with one residing in Singapore, a Singapore-resident CEO, and two full-time representatives is the right answer because these are the minimum statutory requirements for a corporation seeking a license. The board must have at least two members, and both the CEO and at least one director must be residents of Singapore to ensure local accountability and oversight. Additionally, the firm must employ at least two full-time individuals to act as representatives for each regulated activity.

Incorrect: The arrangement involving a CEO residing in the home country is wrong because the CEO of a licensed entity must be a resident in Singapore. The arrangement suggesting only one full-time representative is wrong because the regulations mandate a minimum of two full-time representatives for each regulated activity. The arrangement requiring three directors with two residing in Singapore is wrong because it exceeds the minimum requirement of two directors with one resident, making it an unnecessary constraint for basic licensing compliance.

Takeaway: To obtain a license, a firm must maintain a minimum of two directors (one local), a local CEO, and at least two full-time representatives for each regulated activity.

Correct: Statement II is correct because a Clearing Member that also holds a Trading Membership is permitted to perform both trading and clearing functions. Statement III is correct because the regulatory framework establishes a minimum base capital requirement of $1,000,000 for corporations acting as non-clearing members in the futures market.

Incorrect: Statement I is incorrect because options on equity indices are specifically classified as securities rather than futures contracts, which affects the type of license a corporation must hold. Statement IV is incorrect because Trading Members are explicitly restricted from performing clearing activities and must instead clear their trades through an authorized Clearing Member.

Takeaway: Financial institutions must accurately classify products like equity index options as securities and maintain specific base capital levels based on their membership status and clearing responsibilities. Therefore, statements II and III are correct.

Correct: Statement II is correct because session state triggered orders are always assigned a lower priority than normal resting orders already in the order book at the same price level. Statement III is correct because the trading system allows untriggered SSOs to persist and carry over from the T session to the T+1 session, allowing the order to remain active for the next session’s trigger.

Incorrect: Statement I is incorrect because SSOs and their details are kept hidden from the market and are not visible to other participants until the specific session state is reached and the order is triggered. Statement IV is incorrect because while SSOs carry from T to T+1, they are specifically prohibited from carrying over from a T+1 session to the subsequent day’s T session; they are deleted if not triggered by the end of the T+1 session.

Takeaway: Session State Orders provide execution flexibility while remaining invisible until triggered, but they always yield priority to existing resting orders at the same price and cannot carry over from T+1 to the next day’s T session. Therefore, statements II and III are correct.

Correct: Negotiated Large Trades (NLTs) allow a buyer and seller to negotiate a trade directly rather than routing it through the central order book. This provides execution certainty because the entire quantity can be filled at once at a specific price, helping the trader avoid price slippage and partial fills.

Incorrect: The statement about routing through QUEST is wrong because NLTs are specifically designed to be negotiated directly between parties instead of being routed through the QUEST system. The statement about confidentiality is wrong because while visibility is reduced during execution, the exchange publishes the details of the NLT trade once it has been registered. The statement about triggering stop orders is wrong because strategy and large-scale transactions typically do not set off stop orders in the outright futures contracts.

Takeaway: The NLT facility enables the execution of large orders with price and volume certainty by allowing direct negotiation outside the central limit order book, minimizing market impact.

Correct: The Member must inform the Exchange in writing immediately because the reporting obligation covers any written complaint or investigation involving allegations of fraud or dishonesty. This duty applies regardless of whether the alleged conduct occurred within Singapore or in a foreign jurisdiction, and regardless of whether it was related to the Member’s business activities.

Incorrect: The suggestion to wait for formal criminal charges is wrong because the reporting trigger is the commencement of an investigation or receipt of a written complaint, not the final legal outcome. The idea that private investments are exempt is incorrect because the rules cover breaches involving dishonesty whether in or out of Singapore without limiting it to firm-related activities. Waiting for the completion of internal disciplinary processes is wrong because the notification must be made immediately upon discovery of the allegation.

Takeaway: Trading Members have an immediate duty to report any allegations of fraud or dishonesty involving their representatives to the Exchange, even if the conduct is external to the firm’s operations.

Correct: Statement I is correct because Bank Trading Members are specifically required to notify the exchange at least 7 days before the appointment of a Chief Executive Officer or Deputy Chief Executive Officer takes effect. Statement II is correct because internal control requirements mandate that firms must document in writing the specific limits of discretionary authority granted to officers who can commit the firm to financial undertakings or business risks. Statement IV is correct because the internal audit function is required to verify compliance not just with general laws, but also with the specific business rules of the futures exchange and clearing house.

Incorrect: Statement III is incorrect because the mandatory reporting window for representative misconduct is 14 days from the date of discovery, not 30 days. This requirement ensures that the regulator is promptly informed of any issues regarding the fitness and propriety of individuals in the industry.

Takeaway: Firms must adhere to specific notification timelines for executive appointments and maintain rigorous internal controls, including documented discretionary limits and prompt misconduct reporting within 14 days. Therefore, statements I, II and IV are correct.

Correct: Sarah must refuse to combine the orders because regulations prohibit the aggregation of orders from different customers to meet the minimum volume threshold. Since neither the 35-lot order nor the 40-lot order meets the 50-lot requirement individually, they are ineligible for the NLT facility and must be executed through the standard market system.

Incorrect: Combining the orders to reach 75 lots is wrong because the prohibition on bundling sub-threshold orders is absolute, even if the combined total exceeds the limit. Reporting them as separate NLTs is wrong because any trade below the minimum volume threshold will be rejected by the exchange system. Waiting for more orders to reach 100 lots is wrong because the core requirement is that at least one individual order or leg must meet the threshold independently before any combination is permitted.

Takeaway: To prevent the misuse of the negotiated trade facility, individual customer orders that fall below the minimum volume threshold cannot be combined to qualify for NLT status.

Correct: Statement I is correct because the assessment of a person’s honesty and reputation includes whether they were a director or concerned in the management of a business that went into insolvency or liquidation within one year of them leaving the position. Statement II is correct because the criteria for integrity and reputation specifically include any warnings or disciplinary actions issued by market operators or regulatory authorities, regardless of whether they occurred in Singapore or a foreign jurisdiction.

Incorrect: Statement III is incorrect because the regulatory expectation is that the principal company (the Trading Member) bears the responsibility for ensuring its representatives receive adequate training and meet continuing professional development requirements, not the regulator. Statement IV is incorrect because the assessment of competence and capability is not limited to education; it also requires evaluating the person’s track record, including whether they have ever had a professional license or registration revoked by any exchange.

Takeaway: The fit and proper assessment is a comprehensive review of a candidate’s past professional conduct, including business failures and international regulatory history, with the ongoing duty of competence managed by the principal firm. Therefore, statements I and II are correct.

Correct: Statement I is correct because while verbal approval is permitted for Negotiated Large Trades (NLTs), the regulatory requirement mandates that a tape recording of that specific conversation be kept for record-keeping purposes. Statement III is correct because when a Member acts as the counterparty to their own client’s trade, a higher standard of disclosure is required, specifically necessitating written consent before the trade is executed. Statement IV is correct because a valid blanket approval must clearly outline the customer’s obligations, including the fact that they must accept all trades executed under that specific arrangement.

Incorrect: Statement II is incorrect because the rules explicitly prohibit NLTs where the buyer and seller are the same beneficial owner, even if they use different account numbers. This is to prevent wash trading and ensure that trades represent a genuine transfer of risk between separate entities.

Takeaway: Members must ensure clear customer consent—specifically written consent if the Member is the counterparty—and maintain strict separation of beneficial ownership for all Negotiated Large Trades. Therefore, statements I, III and IV are correct.