Conflicts of Interest Disclosure

I. Affiliated Ownership Structure — FCM and Exchange

The most significant conflict of interest arising from Lumina Markets’ business relates to the common ownership among Lumina Markets, its clearing futures commission merchant (“FCM”), and the exchange on which all trades are executed.

Lumina Markets introduces all customer orders exclusively to Interactive Brokers LLC (“IBKR”), which serves as the sole clearing FCM for all customer accounts. All customer trades are executed exclusively on ForecastEx, LLC (“ForecastEx”), which is a wholly owned subsidiary of Interactive Brokers Group, Inc. Lumina Markets does not evaluate or offer access to alternative clearing firms or execution venues, and customers cannot direct their orders to a different FCM or exchange through Lumina Markets.

Thomas Peterffy is the Chairman and majority shareholder of Lumina Markets, holding approximately 80% of Lumina Markets through Conyers Investments LLC. Mr. Peterffy also holds 74.2% of the voting interest in Interactive Brokers Group, Inc. through IBG Holdings LLC, and serves as Chairman of Interactive Brokers Group, Inc.

As a result of this ownership structure:

Earl Nemser serves as an outside director of Lumina Markets and simultaneously serves as Vice Chairman of Interactive Brokers Group, Inc. As a result, a member of Lumina Markets’ Board of Directors has a material relationship with the Firm’s exclusive FCM and the parent of its exclusive exchange.

In addition, the cash collateral backing customer positions is held at ForecastEx and earns interest, a portion of which is credited to customers as an incentive coupon. Effective August 17, 2026, ForecastEx withholds an administrative clearing fee equal to 50 basis points (0.50%) of that interest before the coupon is paid. Because ForecastEx is under common control with Lumina Markets, this means the affiliated group earns revenue from interest on customer funds. Lumina Markets receives no part of this fee. See the Firm’s Fee Disclosure for further detail.

II. Revenue Model — Financial Incentive to Generate Trading Volume

Lumina Markets’ sole source of revenue consists of exchange rebates paid by ForecastEx, calculated as a percentage of commissions generated on customer transactions. Lumina Markets receives these rebates through IBKR.

This creates a material incentive for Lumina Markets to encourage customer trading activity, as Lumina Markets’ revenue is directly and exclusively tied to transaction volume on ForecastEx. Customers should be aware that this incentive structure may influence the manner in which Lumina Markets presents, describes, or promotes trading on its platform, notwithstanding the Firm’s obligation not to direct customer trading decisions.

III. General Conflicts of Interest

In addition to the affiliated ownership conflicts described above, Lumina Markets has identified the following general circumstances which constitute or may give rise to a conflict of interest:

IV. Procedures for the Identification, Monitoring, Mitigation and Disclosure of Conflicts of Interest

Lumina Markets maintains written procedures reasonably designed to identify, monitor, mitigate, and disclose material conflicts of interest, consistent with its obligations under CFTC Regulation 1.71 and applicable NFA rules. The Chief Compliance Officer ("CCO") is responsible for administering these procedures.

A. Responsibility and Governance

The CCO owns the conflicts-of-interest program, maintains these procedures, and reviews them at least annually and upon any trigger event (defined below). The CCO reports the Firm's identified material conflicts and how they are being managed to senior management, and to the Board of Directors at least annually. Any director, officer, or employee who has a personal or business interest that conflicts, or may conflict, with the Firm's obligations to customers — including the relationships described in Section I — shall disclose that interest to the CCO. Persons with a material relationship to IBKR or Interactive Brokers Group (“IBG”) (including any director serving in roles at both Lumina Markets and IBG) shall not act as the Firm's sole approver of the terms of any arrangement between Lumina Markets and IBKR or ForecastEx, and any such related-party arrangement shall be reviewed for consistency with the Firm's obligations to customers and documented.

B. Conflict Identification and Inventory

The CCO maintains a written Conflicts of Interest Inventory that lists each identified material conflict (including the affiliated-ownership conflict in Section I, the revenue/volume-incentive conflict in Section II, and the general conflicts in Section III), its source, the customers or activities affected, and the monitoring and mitigation controls applied to it. The Inventory is reviewed and updated at least annually and upon any “trigger event,” including: a new business line, product, or execution venue; a new or amended compensation, rebate, or referral arrangement; a change in the Firm's ownership or affiliations; a relevant regulatory development; or a customer complaint indicating a possible conflict. Any employee who becomes aware of a new or potential conflict must report it promptly to the CCO.

C. Ongoing Monitoring

The CCO (or designee) conducts the following monitoring:

D. Mitigation Measures

The Firm mitigates the conflicts identified in this Appendix as follows:

E. Disclosure Procedures

Material conflicts are disclosed to customers at account opening, with the customer's acknowledgment captured and retained, and the disclosure is maintained and kept current on the Firm's website at luminamarkets.com/legal/conflicts. The CCO reviews this disclosure at least annually and upon any material change to confirm it remains accurate and complete, and retains records of each version and of customer acknowledgments.

F. Escalation and Remediation

Newly identified conflicts are assessed by the CCO, who determines the appropriate disclosure and mitigation. Material matters are escalated to senior management and, where appropriate, the Board. Remediation is tracked to completion and documented.

G. Training

Associated Persons and applicable employees receive training on the Firm's conflicts-of-interest policy and these procedures at onboarding and at least annually.

H. Recordkeeping

The Conflicts of Interest Inventory, monitoring reviews, approvals, disclosures and customer acknowledgments, escalations, reports to senior management and the Board, and training records are retained for at least five (5) years, consistent with the Firm's recordkeeping policies.

I. Periodic Review and Approval

The CCO reviews the adequacy and effectiveness of these procedures at least annually, updates them as needed, and obtains the written approval of an appropriate principal for material changes.