Regulatory disclosure

1. What Sentio is

Sentio ("we", "us") is a software product that displays structural pattern analysis of publicly available market data for E-mini S&P 500 (ES) and E-mini Nasdaq-100 (NQ) futures contracts traded on the Chicago Mercantile Exchange (CME). The product surfaces pattern matches against rules that the user ("you", "the trader") either selects from a catalog of built-in models or constructs using the Model Builder feature. All output is generated by deterministic pattern-recognition code operating on candlestick and derived indicator data. Every setup displayed by the product includes the full reasoning trail that produced it and the parameters under which it was evaluated.

2. What Sentio is not

• Sentio does not execute trades, place orders, or connect to any brokerage account for the purpose of order placement.
• Sentio does not provide personalized investment advice tailored to the individual circumstances, financial situation, risk tolerance, or trading objectives of any user.
• Sentio is not registered with the U.S. Commodity Futures Trading Commission ("CFTC") as a Commodity Trading Advisor ("CTA") and is not a member of the National Futures Association ("NFA").
• Sentio is not registered with the U.S. Securities and Exchange Commission ("SEC") as an investment adviser.
• Sentio does not guarantee any specific trading result, profit, or outcome, and does not warrant that any pattern surfaced by the product will result in a profitable trade.

3. Regulatory basis — CFTC Rule 4.14(a)(9)

Section 1a(12) of the Commodity Exchange Act, 7 U.S.C. § 1a(12), defines a Commodity Trading Advisor as, in part, any person who engages in the business of advising others as to the value or advisability of trading commodity interests. CFTC Regulation 17 C.F.R. § 4.14(a)(9) — commonly referred to as the publisher exemption — exempts from CTA registration a person whose commodity-interest trading advice is solely incidental to the conduct of their publishing business, provided the advice is not tailored to the specific trading account of any subscriber and the publisher does not direct client accounts.

Sentio operates squarely within this exemption. The product publishes structural pattern analysis against publicly available market data on rules that are either pre-defined or authored by the user. No output is tailored to any individual user's account, no client account is directed, and Sentio has no capacity to execute or route orders on your behalf.

The relevant regulatory texts are available directly from the CFTC:

• 17 C.F.R. Part 4 — Commodity Pool Operators and Commodity Trading Advisors
• Commodity Exchange Act
• National Futures Association

4. Risk disclosure

Trading futures involves substantial risk of loss and is not suitable for every investor. The value of futures contracts can move rapidly against your position, and losses can exceed the initial margin posted. You should carefully consider whether trading is appropriate for you in light of your circumstances, knowledge, and financial resources. Past performance of any trading pattern, strategy, or model shown by Sentio is not indicative of future results. Historical replay validation performed by the product uses cached data and simulated fills; real-market execution introduces slippage, latency, and market conditions that may materially differ from the replay environment.

5. User responsibility

By using Sentio, you acknowledge that all trading decisions are yours alone. You are solely responsible for evaluating whether any pattern, setup, or output surfaced by the product is appropriate for your account, your risk tolerance, and your trading objectives. You are responsible for placing your own orders, managing your own position size, and complying with all applicable rules of your broker, exchange, and regulator. Sentio provides tooling that helps you enforce discipline rules you have configured; the correctness and appropriateness of those rules are your responsibility.

6. Non-U.S. users

Users accessing Sentio from outside the United States are responsible for compliance with the regulatory framework of their own jurisdiction, including but not limited to the Financial Conduct Authority (UK), the European Securities and Markets Authority (EU / MiFID II), the Investment Industry Regulatory Organization of Canada (Canada / IIROC), the Australian Securities and Investments Commission (Australia / ASIC), and the Securities and Exchange Board of India (India / SEBI). Sentio's publisher classification under U.S. law does not automatically confer an equivalent status in other jurisdictions, and no representation is made as to the availability or suitability of the product outside the United States.

7. Contact

Regulatory questions may be directed to support@sentiotrader.com. This document may be updated from time to time; the "Last updated" date at the top of the page will reflect the most recent revision.