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Reg BI Disclosure

Ultralat Regulation
Best Interest
Disclosure Supplement

About Us

Ultralat Capital Markets, LLC (“Ultralat” or the “Firm” or “Us”) is registered with the Securities and Exchange Commission (SEC) as a broker-dealer and is a member of the Financial Industry Regulatory Authority (FINRA). We offer a variety of accounts and investment options to both retail and institutional clients.

Affiliated Entities

The Firm is affiliated with an investment adviser, Credicorp Capital Advisors LLC, (“Credicorp”) which also does business under the names “UltraAdvisors” and “Ultralat Investment Advisor”. Credicorp is registered with the State of Florida as an Investment Adviser. Credicorp offers a variety of advisory accounts and services. Some of our financial professionals registered with Ultralat may also be registered with Credicorp and in such cases may recommend accounts and services available through Credicorp. You can find more information regarding Credicorp by visiting www.adviserinfo.sec.gov or clicking HERE.

About this Document

This document is meant to provide additional information and disclosures regarding our Firm pursuant to Regulation Best Interest.

Capacity in which your Financial Professional is Acting

Your financial professional is a Registered Representative of our Broker-Dealer. You can check your financial professional at www.brokercheck.finra.org which will allow you to search for your financial professional by name. Their respective profile will show you additional information about your financial professional and you can also find additional information about our firm.

In most cases, when making a recommendation to you regarding investments in your brokerage account or directly with an investment sponsor (known as “direct business”) your financial professional is acting in his/her capacity as a registered representative of our Firm (a broker-dealer). However, there are exceptions and whenever your financial professional acts in a capacity inconsistent with this guidance, you will receive updated notice in writing as to the capacity in which they are acting when making a recommendation.

Material Limitations

You should understand there are material limitations to the recommendations your financial professional provides. The Firm approves and offers only certain account types, products, and securities. There may be additional account types, products, and securities that are not offered by the Firm, which may benefit you and your portfolio. In addition, those that we do offer, may be available at a lower cost through another firm.

Additionally, the financial professionals associated with our Firm are licensed to offer certain account types, products, and securities. In some cases, even when available through our Firm, your financial professional might not be able to recommend a particular account type, product, and/or security which may benefit you and your portfolio. You can check to see the licenses your financial professional holds, by visiting www.brokercheck.finra.org.

Requirements for You to Open or Maintain an Account with Us

There is a $250,000 minimum investment in order to open a brokerage account, but we may reduce or waive this requirement in some circumstances. It is also important to note some products will require a minimum investment, which can be found on their investment prospectus, offering materials, or similar document.

Our Firm’s Investment Approach

The Firm uses its industry knowledge and experience to provide brokerage services to retail and institutional clients. The Firm seeks to understand our clients’ unique investment profiles and recommend investments and strategies consistent with their unique financial needs. However, the products and services offered by the Firm do vary and the investment philosophy, approach, risk, and objective of these investments will too. You should review the prospects or similar offering documents thoroughly before making an investment and contact your financial professional should you have additional questions.

Material Fees, Costs, and Associated Conflicts

The Firm and its associated professionals receive compensation directly from their customers or indirectly from the investments a customer makes. This compensation takes the form of an upfront commission and/or ongoing compensation, known as trailing compensation. It is important to note that the amount of compensation can change over time. In order to receive specific and the most up-to-date information, Customers should review the respective prospectus, offering document, and/or other transaction statement. Customers should discuss with their financial professional if they have any questions regarding compensation and/or conflicts of interest.

Sales Compensation

The Firm receives selling compensation when it buys or sells a security. This selling compensation is also referred to as a commission, markup/markdown, placement fee, or sales charge/load. Typically, the Firm receives selling compensation and may share a certain percentage of the selling compensation with your financial professional.

Because the amount of selling compensation charged can vary between different securities and products, this could create an incentive to sell certain investments over others. It could also create an incentive to conduct a higher number of transactions.

Understanding Share Classes

The amount of upfront selling compensation versus trailing compensation charged on certain products, such as mutual funds will vary, depending on the share class selected. For mutual funds, typically, Class A shares will result in a higher upfront sales charge and lower trailing compensation, while the opposite is true for a Class C. In order to see a complete list of the share classes available for a particular investment and their respective costs, you should review the investment prospectus, offering document, and/or other transaction statement.

Product Costs and Fees

Financial professionals provide recommendations with respect to a broad range of investment products. Many investment products charge fees and costs that are separate from and in addition to the commissions and fees that the Firm and financial professionals receive. You can learn more about these fees and costs charged by an investment product by reviewing the investment product’s prospectus, offering memorandum, or other disclosure documents.

Account Fees

In addition to the commissions and sales charges described above, customers can also be charged direct fees and charges for miscellaneous account services, including, but not limited to transaction processing, transfers, margin, ticket charges, inactivity, and account maintenance. For a complete list of these charges and fees you should review your account agreement and/or fee schedule and discuss with your financial professional.

Registered Representative Specific Compensation

Registered representatives’ compensation may vary. Some are paid a base salary. A registered representative’s compensation package typically includes a percentage of the selling compensation described herein. Accordingly, your sales representative could be incentivized to recommend more costly products or recommend additional transactions to obtain a greater percentage of the overall revenues. In addition, your financial professional may also receive some bonuses or non-cash compensation, such as expense reimbursements.

Additional Compensation from Third Parties

In addition to the sales compensation described above, the Firm also receives additional compensation from third parties. This additional compensation could create an incentive for the Firm to recommend certain investments over others. It’s important to note, however, that the amount of compensation can change and vary between issuers and product sponsors. In order to receive specific and the most up-to-date information, Customers should review the respective prospectus, offering document, and/or other transaction statement.

  • Other Trailing Compensation: The Firm also receives trailing compensation, including 12b-1 fees, which are paid from certain investment sponsors for mutual funds. The amount can vary based on the product and amount invested. For mutual funds, the maximum amount is typically 1.15%.
  • Mutual Fund Concessions and Finder’s Fees: The Firm may receive additional compensation known as concessions or finder’s fees from a mutual fund company, often in cases where the sales charge is waived based on certain criteria. This amount can vary, but the maximum amount is typically 1% of the transaction. The Firm also receives concessions from investment sponsors for other types of investments. These concessions vary from product to product and are generally shared between the Firm and the financial professional. Concessions can be as high as 0.25% of the transaction amount for new issues of certificates of deposit, municipal bonds and other short-term dated bonds, up to 3% of the transaction amount for structured products, and up to 4% of the transaction amount for CEFs.
  • Non-Cash Compensation and Marketing: The Firm and its employees periodically receive compensation that is not transaction based from investment sponsors. This includes entertainments such as tickets to a sports game, costs associated with dinner, small gifts valued at less than $100, or marketing fees for workshops, events, and advertising.
  • Cash Sweeps: The Firm receives compensation from our clearing firm when a cash balance is moved to a particular fund/account which the Firm generates additional compensation from. This amount is usually not shared with your financial professional and can be as high as .35%.
  • Margin: When a customer receives margin, the Firm will receive a percentage of the balance lent from the clearing firm, which typically does not exceed 2%.
  • Clear Through Arrangements: We have and may engage in future agreements with certain affiliated/unaffiliated foreign financial institutions for which we act in a clear-through capacity, providing access to our clearing firm, Pershing. Although the amount of compensation may vary depending on business lines, typically we receive a percentage of the fees charged by the clearing firm and split certain selling compensation generated by these entities.

Additional Conflicts of Interests

Gifts and Entertainment A conflict of interest may arise when an employee receives or offers a gift, entertainment, or anything of value that creates an incentive for an employee, third party service provider, or a client to act in a certain way.

Shared Revenues and Payments from Third Parties As described above, we receive shared revenue, fees, and/or payments from our clearing firm which could create an incentive to offer or recommend certain activities and investments.

Outside Business Activities When approved, registered representatives may engage in certain outside business activities. This may include, but is not limited to real estate, accounting, insurance, legal, and other professions. As a result, financial professional s may be incentivized to recommend certain products or services outside the scope of their relationship with the firm and they may benefit financial from these recommendations. In addition, employees may engage in personal trading or outside business activities (including board memberships/directorships) could conflict with a client or with the firm.

Political and Charitable Contributions The firm and/or its employees charitable and/or political donations could create the perception that the company or employee is seeking a quid pro quo.

Confidentiality The Firm and its employees are periodically exposed to confidential information which may benefit us or a client.

Recommendations to other financial professionals Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be recommended to clients or engaged directly by the client on an as-needed basis. Although not directly compensated for these referrals to outside entities, your financial professional may receive referrals from these professionals, which might incentivize them to recommend a particular professional over another.

Understanding Risk

Our Firm does not provide tax, legal or accounting advice. Accordingly, we encourage each customer to consult their own personal tax, legal and/or accounting advisers in order to understand the potential consequences associated with a particular investment strategy.

Investing in securities involves risk of loss that customers should be prepared to bear. Different types of investments involve varying degrees of risk and there can be no assurance that any specific investment or investment strategy will be profitable for a customer’s investment portfolio. Past performance is not indicative of future results. A customer should not assume that the future performance of any specific investment, investment strategy, or product will be profitable or equal to past or current performance levels. We cannot assure that the investment objectives of any client will be realized. The following is a non-exhaustive list of risks associated with investing. For additional product-specific risks, customers should review their prospectus, offering document, or similar materials and consider them carefully prior to making an investment decision.

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Disclosures

Important Legal Risk Disclosures

Special risks are associated with each type of security or investment vehicle. The price of the shares of the security and income generated from that security can go down as well as up and you may not get back the full amount that you invested. Past performance is no guarantee of future performance. Certain securities or funds that are diversified or hold many different investments with different characteristics are subject to change. Currency fluctuations and interest rates may affect the value of domestic and overseas investments. Investors should take into consideration the risks associated with the regions of the world the fund may invest in, including: currency fluctuations, interest rates, economic instability and political developments. Investments in developing markets involve heightened risk related to the same factors, in addition to those associated with smaller size and lesser liquidity. Further, smaller company stocks have historically exhibited greater volatility than larger-company stocks, particularly over the short term. Please consult the prospectus for a more detailed description of the fund’s risk.

Contents of this website:

The reader or investor should not assume that investments in the securities listed were or will be profitable. The information provided on this web site does not constitute or form part of any offer for shares of the securities noted or an invitation to invest in such shares. Investments in certain types of securities can only be made on the basis of the securities most recent prospectus. Offshore funds may not be offered or sold to citizens or residents of the United States of America. Current performance may be lower or higher than the performance data quoted. Before investing, consider the funds’ investment objectives, risks, charges and expenses carefully. This and other information is available in the prospectus. Please also consult with your professional advisor for current performance before investing.

Share classes

Certain share classes may not be available for each security. Please consult your investment professional to confirm which classes of shares are available.

Questions / Prospectus

For questions or to obtain a free prospectus, please contact us at info@ultralat.com. Investors should read the prospectus carefully before investing.

The Company

Ultralat Capital Markets Inc is a US Broker Dealer registered with the SEC (Securities and Exchange Commission) and is a member of   FINRA  –  Financial Industry Regulatory Authority and SIPC – Securities Investor Protection Corporation.

Other

Investments are not FDIC-insured, may lose value, nor are they deposits of or guaranteed by a bank or any other entity. There is risk with any investment and all risks must be clearly defined and understood before investing any money. Only FDIC insured certificates of deposit and FDIC money markets are insured and guaranteed by the Federal Deposit Insurance Corporation. Investors should carefully consider their investment objectives, risks, time horizon, charges, fees and expenses of any investment product or service.
Past performance is no guarantee for future results. Carefully consider the investment objectives, risks, charges and expenses before investing. This and other information is available in the prospectus. For questions or to obtain a free prospectus, please contact us at info@ultralat.com Investors should read the prospectus carefully before investing.
Offshore funds may not be offered or sold to citizens or residents of the United States of America.
The client login page for Pershing, LLC is owned and operated by Pershing, LLC.

July 14th 2010

Under Federal law and SEC regulations, we are required to provide you with a notice of our privacy policy. This notice describes our policy regarding the collection and disclosure of personal information.

Privacy Policy

We at Ultralat Capital Markets Inc value our customers’ trust and are committed to the responsible management, use and protection of personal information. U.S. broker dealers are required by securities laws and the USA PATRIOT Act to obtain certain information to open and maintain your brokerage account with us, and to process transactions requested by you.

Categories of information we collect

We collect personal information about you from the following sources: (1) information you provide on applications or other forms, such as name, address, income, net worth, investment objectives; (2) information about your transactions with us, our affiliates, or others; and, (3) public sources.

Categories of information we disclose and parties to whom we disclose

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted or required by law or as noted in the next paragraph.

Categories or parties to whom we disclose

We may disclose information about you necessary to open or maintain your account or settle transactions: to our affiliates, our clearing agent, custodians, banks and securities broker-dealers. We may also disclose nonpublic personal information about you to nonaffiliated third parties such as our auditors, attorneys or other professionals who assist us in the conduct of our business, to prevent fraud, or as permitted or required by law. We do not sell or share your personal information to other companies who wish to market their products or services to you. We do not sell or share your information with any non-affiliated third parties.

Confidentiality and security

We restrict access to nonpublic personal information about you to those persons who need to know that information to provide the products and services you request. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information. This policy applies to you even if you are no longer our customer.

Accuracy of information

We will attempt to keep customer information complete, accurate and up to date. If you would like to review the information we keep on file, or if you know there has been a material change in information you provided since opening an account, please contact us. A material change might include but is not limited to a change in employment, retirement, increase or decrease in income or net worth, or a change in investment objectives.

BusinessContinuity Plan Disclosure

Ultralat maintains a Business Continuity Plan (“BCP”) whichis available to customers upon request or at www.ultralat.com. Ultralat willreview the BCP annually for completeness and accuracy and will make changes to theBCP as the firm deems necessary. Ultralat will notify customers if the BCPchanges.

Privacy Policy

Cookies

We use “cookies” on this site. A cookie is a piece of data stored on a site visitor's hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any personally identifiable information on our site.

Updates

Our Privacy Policy may change from time to time and all updates will be posted on this page.

Links

This web site contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

Ultralat Capital Markets, Inc.

Privacy Notice

We collect nonpublic personalinformation about you, including information such as your name, address,account balances and transaction information, from your account application andother forms that you may deliver to us, and from your transactions with us andour affiliates. This is information the regulators consider necessary for theproper servicing of your account.
In order to affect your transactionsand service your account properly, we may disclose all of the information thatwe collect, as described above, to firms that assist us in servicing youraccount, such as the clearing broker dealer which is Pershing.
All records containing your nonpublicinformation are kept at our principle place of business and may also be kept byour service provider(s), such as Pershing. In connection with servicing youraccount, your nonpublic personal information, and no-affiliates who provideservices regarding or relating to your account, including transfer agents orother service companies. Our affiliates and any non-affiliated serviceproviders are required to protect the confidentiality of your information andto use the information only for the purposes for which disclosure to them ismade. Service providers restrict access to nonpublic personal information aboutyou to those employees who need to know that information to provide productsand services to you. We, our affiliates, and the service providers we usemaintain physical, electronic, and procedural safeguards to maintain thesecurity of your nonpublic personal information.
We do not sell nonpublic information.We do not disclose nonpublic personal information about customers tonon-affiliated third parties, except as described in this Privacy Notice orexcept permitted or required by the law.
In the event that you close youraccount or become an inactive customer, we will adhere to the privacy policiesand practices as described in the Privacy Notice.
1/27/2014

Equal Employment
Opportunity

Ultralat Capital Markets Inc (“the Company”) has established and adopted an Equal Employment Opportunity Employment policy (“EEO”), which is part of the Company’s Human Resources Policy. The purpose of this EEO policy is to ensure that all employment decisions are made on a non-discriminatory basis, and without regard to sex, race, color, age, national origin, religion, disability, genetic information, marital status, sexual orientation, gender identity/reassignment, citizenship, pregnancy or maternity, veteran status, or any other status protected by applicable national, federal, state or local law. In some cases, local laws and regulations may provide greater protections than those outlined here.1 Associates will be covered by the laws of their local jurisdiction. An Affirmative Action Program has been developed to identify areas where the Company seeks to increase the representation of minorities and women. In those areas, we have developed action plans and identified good faith efforts that we will undertake in an effort to increase minority and female participation. The Company is committed to these good faith efforts, and we will review them periodically to measure our progress.

1. The Company will recruit, hire and promote without regard to sex, race, color, age, national origin, religion, disability, genetic information, marital status, sexual orientation, gender identity, citizenship, pregnancy or veteran status, or any other status protected by applicable law.

2. The Company will make all decisions of employment with consideration to appropriate principles of Equal Employment and Affirmative Action.

3. Promotional opportunities will be filled based on merit, experience and other job-related criteria.

4. Personnel actions, such as compensation, benefits, transfers, layoffs, company-sponsored training programs, and social and recreational programs, will be administered on a non-discriminatory basis.

Any employee who has a question or concern regarding any type of discrimination or harassment is encouraged to bring it to the attention of his/her manager or senior manager or the Office Manager. For information regarding harassment or discrimination awareness and reporting, please consult the Human Resources Policy