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Revised July 22, 2024
Robinhood Financial LLC & Robinhood Securities, LLC
Customer Agreement
1. Introduction.
This Customer Agreement (“Agreement”) sets out the terms and conditions pursuant to which
Robinhood Financial LLC, Robinhood Securities, LLC, and their agents and assigns (collectively in this
Agreement, “Robinhood”) may open and operate one or more accounts on your behalf for the purchase,
sale or carrying of securities or contracts relating thereto or the borrowing of funds (each, an “Account”),
which transactions are cleared through Robinhood Securities. In this Agreement, “Customer”, “you”, or
“your” (or similar) refer to the Account owner, and “we”, “us” or “our” (or similar) refers to Robinhood.
References to this “Agreement” include these terms and conditions as well as any other agreements or
disclosures that apply to your Account, each as amended or supplemented from time to time.
BY AGREEING TO THIS AGREEMENT AND OPENING OR USING AN ACCOUNT, YOU
EXPRESSLY AGREE TO THE TERMS OF THIS AGREEMENT AND ANY OTHER AGREEMENTS OR
TERMS INCORPORATED INTO IT. CLICKING OR TAPPING “SUBMIT APPLICATION”, “AGREE” OR
ANY SIMILAR BUTTON OR ACKNOWLEDGEMENT AS PART OF THE APPLICATION PROCESS, IS
LEGALLY EQUIVALENT TO MANUALLY SIGNING THIS AGREEMENT, AND YOU WILL BE
LEGALLY BOUND BY THIS AGREEMENT WHEN YOU CLICK OR TAP SUCH BUTTON.
THIS AGREEMENT AND ITS TERMS MAY BE SUPPLEMENTED OR AMENDED FROM TIME TO
TIME BY ROBINHOOD BY NOTICE TO YOU, AND SUCH NOTICE REQUIREMENT MAY BE
SATISFIED BY THE REVISED TERMS BEING POSTED ON THE ROBINHOOD WEBSITE, AND YOU
AGREE TO CHECK FOR UPDATES TO THIS AGREEMENT. BY CONTINUING TO MAINTAIN ANY
ACCOUNT OR ACCESS ANY SERVICES WITHOUT OBJECTING TO ANY REVISED TERMS OF
THIS AGREEMENT, YOU ARE DEEMED TO ACCEPT THE TERMS OF THE REVISED AGREEMENT
AND WILL BE LEGALLY BOUND BY ITS TERMS AND CONDITIONS. IF YOU REQUEST OTHER
SERVICES PROVIDED BY ROBINHOOD THAT REQUIRE YOU TO AGREE TO SPECIFIC TERMS
AND CONDITIONS ELECTRONICALLY (THROUGH CLICKS OR OTHER ACTIONS) OR
OTHERWISE, SUCH TERMS AND CONDITIONS WILL BE DEEMED AN AMENDMENT AND WILL BE
INCORPORATED INTO AND MADE PART OF THIS AGREEMENT. YOU ALSO UNDERSTAND THAT
BY CLICKING OR TAPPING “SUBMIT APPLICATION” YOU HAVE ACKNOWLEDGED THAT THIS
AGREEMENT CONTAINS A PREDISPUTE ARBITRATION CLAUSE IN SECTION 39 HEREIN.
THIS AGREEMENT IS A LEGAL AGREEMENT AND IT IS IMPORTANT THAT YOU CAREFULLY
READ AND UNDERSTAND ITS TERMS BEFORE AGREEING TO IT. IF YOU HAVE ANY
QUESTIONS YOU SHOULD CONTACT help@robinhood.com OR SEEK INDEPENDENT ADVICE.
By entering into this Agreement, you acknowledge receipt of the Robinhood Financial LLC Form
CRS, and you acknowledge receipt of and agree to the terms of the Robinhood Terms and
Conditions, RHF Use and Risk Disclosures, Robinhood Financial Product Features Disclosures,
Day Trading Risk Disclosure, Extended Hours Trading Disclosure, ETF Disclosure, RHF Funds
Availability, RHF and RHS Business Continuity Plan Summary, and FINRA Public Disclosure
Program, which are incorporated by reference into this Agreement. You also acknowledge receipt
of the Robinhood Privacy Policy.
2. Your Account.
2.1. When you open or apply to open an Account to access services on the Robinhood mobile
application(s) (each, an “App”) or on the Robinhood Website (the Apps and the Website,
together with any programs, tools, features, functionality, services, transactions, and Content
provided through or in connection with the Website and the Apps, collectively, the “Platform”),
you are entering into direct contractual relationships with Robinhood Financial and Robinhood
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Securities. “Website” means the robinhood.com website, and any others through which
Robinhood offers services.
2.2. To be eligible to open or have an Account you must be at least 18 years old, and otherwise
be legally permitted to have an Account and in compliance with the terms and conditions of
this Agreement and Applicable Law, as well as any other eligibility criteria we may implement
from time to time. “Applicable Law” includes all federal securities laws and regulations, the
applicable laws and regulations of any state or jurisdiction, the rules of any applicable self-
regulatory organization of which Robinhood is a member and rules, regulations, customs, and
usages of the exchange or market or clearing house, if any, where transactions are executed.
2.3. Your Account is self-directed and, except as provided in Section 2.4 below, you are solely
responsible for any and all orders placed in your Account, for your investment decisions, and
for determining the suitability of any particular transaction, security, or investment strategy.
You agree that all orders entered by you (or placed on your behalf) are based on your own
investment decisions.
2.4. You agree and understand that Robinhood or persons acting on Robinhood’s behalf does not
provide any investment advice or recommend any particular security, transaction, or order, or
other matter connected with your Account, nor will they advise you about the merits of any
action or investment decision relating to your Account or any security you hold, unless
specifically agreed upon in writing and clearly identified by Robinhood as an individualized
investment recommendation for you.
2.5. You appoint Robinhood Financial as your agent for the purposes of carrying out your
directions and instructions to Robinhood Financial in accordance with this Agreement,
including all instructions you input or deliver via the Platform. You authorize Robinhood
Financial to open or close your Account, place and withdraw orders and take such other steps
as are reasonable to carry out your instructions or directions. You understand Robinhood
Financial provides trading and brokerage services through the Platform and you agree to
receive and transmit financial information and instructions through electronic means via the
Platform.
2.6. Robinhood Securities. Robinhood Financial has entered into a clearing agreement with
Robinhood Securities whereby Robinhood Financial will introduce your Account to Robinhood
Securities, and Robinhood Securities will clear all transactions, on a fully- disclosed basis.
You understand that Robinhood Securities carries your Account and is responsible for the
clearing and bookkeeping of transactions, but is not otherwise responsible for the conduct of
Robinhood Financial. You agree that until receipt of written notice from you to the contrary,
Robinhood Securities may accept from Robinhood Financial, without inquiry or investigation,
(i) orders for the purchase or sale of securities for your Account, (ii) any other instructions
concerning your Account or any securities or other assets in your Account, or (iii) any
instructions for the purchase of securities or other property on margin, if you have a Margin
Account. Robinhood Securities shall look solely to Robinhood Financial unless otherwise
directed by Robinhood Financial, and not to you, with respect to any such orders or
instructions; except that Robinhood Securities will deliver confirmations, statements, and all
written or other notices with respect to an Account directly to you with copies to or made
available to Robinhood Financial, and that Robinhood Securities will look directly to you or
Robinhood Financial for delivery of margin, payment, or securities. You agree to hold
Robinhood Securities harmless from and against any Losses arising in connection with the
delivery or receipt of any such communication(s), provided Robinhood Securities has acted in
accordance with the above.
2.7. Joint Accounts. A Robinhood customer in good standing may open a joint Account with one
other owner who is also a Robinhood customer in good standing (“Joint Account”). Each
owner of the Joint Account has full authority over the Joint Account, including the authority to
receive Account Documents (as defined below in Section 34.1), demands, confirmations,
statements, or other communications concerning the Joint Account, and each owner grants to
the other owner limited power of attorney with respect to the Joint Account. Each owner or
Third Party Authorized Representative of the Joint Account is entitled, without the prior
authorization from or notice to the other owner, to, for example, deposit or withdraw money,
securities, or other property from the Joint Account, to make trades in the Joint Account, to
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terminate the Joint Account, and to enable or disable certain features, functionalities, and
services of the Joint Account. You acknowledge that both owners of the Joint Account are
presumed to be able to access the Joint Account when either owner accesses the Joint
Account (whether via App or the Website), and you represent that you consent to any actions
taken by either Joint Account owner with respect to the Joint Account.
Both owners of the Joint Account shall have joint and several liability for the Joint Account or
obligations arising from this Agreement, and all property in the Joint Account for either owner
may be subject to a lien. Robinhood may in its discretion recoup or offset funds across a
customer’s individual Account and Joint Account, including the sale of customer securities and
positions, such as when there is fraudulent activity or indications of fraudulent activity that
create an account deficit in one of the customer’s accounts.
We may place a restriction on the Joint Account if we receive conflicting instructions or there is
a dispute between the Joint Account owners. We may at our discretion require written
instructions from all account holders. We are not responsible for determining the purpose or
propriety of an instruction we receive from any Joint Account holder, or for the disposition of
payments or deliveries among Joint Account holders. You must promptly notify Robinhood if an
owner of the Joint Account dies. Robinhood will have no liability for any loss that may arise due
to taking instructions from one owner or requiring instructions from both owners.
You understand that the only type of joint account ownership offered by Robinhood is Joint
Accounts With Rights of Survivorship. You cannot open a Joint Account if either owner of the
Joint Account is a resident of Louisiana. You further understand and agree that you are
responsible for understanding state laws applicable to your account ownership, including how
state laws impact the disposition of assets, and for ensuring that this ownership structure is
valid in your state(s).
You agree that we may share certain personal information about one owner of the Joint Account
with the other, such as name and email address. You further understand that Robinhood may
contact the Trusted Contact Person listed on any Robinhood Account for any owner of the Joint
Account, as described in Section 5 below, and that any communication with the Trusted Contact
Person may include information about either of the Joint Account owners, the Robinhood
Account for which the Trusted Contact information was provided, any other Accounts at
Robinhood in which any of the Joint Account owners has an interest, or any other information
the Joint Account owners may have provided to Robinhood.
3. Market Data.
We may provide or make available to you certain content, information, or data that may include
information or data relating to securities and the securities markets, including last sale transaction data,
bid and asked quotations, fundamental information, and other security information or data (collectively,
“Market Data”). We obtain Market Data from securities exchanges and markets, third party information
providers, and other third parties that distribute or transmit Market Data (collectively, “Third Party
Providers”). For certain types of Market Data, we are required to include specific terms and conditions in
our agreements with you, or procure that you enter into specific agreements, prior to you obtaining or
being provided access to that Market Data. We do this in the “Market Data Addendum” which you can
find at the end of this Agreement. Receipt and use of Market Data are subject to the terms of this
Agreement as well as to the Market Data Addendum that supplements and forms part of this Agreement,
and is incorporated by reference. By agreeing to this Agreement, opening an Account, or accessing any
services from Robinhood, you agree to the Market Data Addendum.
If we provide or make Market Data available to you, this does not grant you any rights over or in that
Market Data except those rights (if any) expressly granted to you in the Market Data Addendum.
Market Data is provided to you solely on the basis that you represent and warrant that you are a Non-
professional (as defined in the Market Data Addendum) and that you will use any Market Data solely
for your personal non-business use.
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4. Customer Representations and Responsibilities.
4.1. Information Accuracy.
Where you provide Robinhood with any information in any form from time to time in connection with
your Account or your application for an Account or any services, you represent and warrant that such
information is complete, true, accurate, and correct. You acknowledge that knowingly giving false
information for the purpose of inducing Robinhood to extend credit is a federal crime.
If any information that you have provided to Robinhood changes, you agree to promptly notify
Robinhood of such changes in writing within ten days. You agree that this Agreement, the account
application, and any other document you furnish in connection with your Account is Robinhood’s
property.
4.2. About You.
You represent and warrant that:
(a) You are at least 18 years old, and you are of legal age under the laws of the jurisdiction where
you reside.
(b) You are authorized to enter into this Agreement.
(c) You are the sole owner of the Account. No other person has any interest in the Account opened
pursuant to this Agreement.
(d) Except as otherwise disclosed to Robinhood in writing, neither you nor any member of your
immediate family is an employee of any exchange, any corporation of which any exchange owns
a majority of the capital stock, a member of any exchange or self-regulatory organization, a
member of any firm or member corporation registered on any exchange, a bank, trust company,
insurance company or any corporation, firm or individual engaged in the business of dealing
either as a broker-dealer or as principal in securities. You agree to promptly notify Robinhood in
writing if you or a member of your immediate family becomes registered or employed in any of
the above-described capacities.
(e) You are not a “Securities Professional” (as defined in the Market Data Addendum), and you are
using the Account for your own personal, non-business, use.
(f) You are not an officer, director, or 10% stockholder of any publicly traded company.
4.3. Risks.
You acknowledge and understand that all investments involve risk, that losses may exceed the
principal invested, and that the past performance of a security, industry, sector, market, or financial
product does not guarantee future results or returns. You are solely responsible for all investment
decisions associated with your Account including any risks in connection with the purchase or sale of
securities (which includes the risk of loss).
You acknowledge and agree to the Risk Disclosures. “Risk Disclosures” means the risk disclosure
documentation available or referenced on the Website or the Disclosure Library from time to time.
“Disclosure Library” means the disclosure library available on the Website, currently at
robinhood.com/us/en/about/legal, as supplemented from time to time. As of the date of this Agreement,
Risk Disclosures include (without limitation) the RHF Use and Risk Disclosures, Robinhood Financial
Product Features Disclosures, Day Trading Risk Disclosure, Extended Hours Trading Disclosure, ETF
Disclosure, the Characteristics and Risks of Standardized Options, and the Margin Disclosure
Statement.
4.4. Account Defaults.
Your Account comes with many defaulted service instruction features and preferences. You understand
that you are not required to use these defaulted options or preferences and that once your Account is
approved and opened, you have the sole discretion to control and adjust such defaulted service
preferences that relate to your account.
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4.5. Knowledge of Account.
You are solely responsible for knowing the rights and terms for all securities purchased, sold and
maintained in your Account including mergers, reorganizations, stock splits, name changes or symbol
changes, dividends, option symbols, and option deliverables. Certain securities – including bonds,
convertible securities, warrants, stock rights and securities subject to exchange offers or tenders - may
grant you valuable rights that may expire unless you take specific action, and you are solely
responsible for knowing all expiration dates, redemption dates, and the circumstances under which
rights associated with your securities or Property may expire or be called, cancelled, or modified.
Robinhood may, but is not obligated to, notify you of any upcoming expiration or redemption dates, or
take any action on your behalf without specific instructions, except as required by law and the rules of
regulatory authorities.
4.6. Review of Confirmations and Statements.
You agree that it is your responsibility to review order execution confirmations and statements of your
Account promptly upon receipt. These documents will be considered binding on you unless you notify
us of an objection within two days from the date confirmations are sent or within ten days after Account
statements are sent.
Such objection may be oral or in writing, but any oral objection must be immediately confirmed in
writing. In all cases, Robinhood reserves the right to determine the validity of your objection. If you
object to a transaction for any reason, you understand and agree that you are obligated to take action
to limit any losses that may result from such transaction and that you will bear sole responsibility for
any losses relating to the transaction, even if your objection to the transaction is ultimately determined
to be valid. Nothing in this clause shall limit your other responsibilities in this Agreement.
4.7. Orders and instructions.
Any instruction or order given for your Account, including via the Platform or using your Account
username or password, will be treated as being from you and fully authorized by you. You agree that
Robinhood shall be entitled (but not required) to act upon any oral instructions given by you so long as
Robinhood reasonably believes such instruction was actually given by you. You instruct and authorize
Robinhood to rely on such instruction or order without further inquiry, and agree that Robinhood will not
be liable for doing so.
You agree not to allow any person access to your Account, your Account username or password, or
permit any other person to give orders or instructions on your Account to Robinhood, without the prior
consent of Robinhood. If any other person has access to your Account, your Device, your Account
username or password, that is solely at your own risk. Robinhood may execute your orders on any
exchange or market.
Robinhood reserves the right to require full payment in cleared funds prior to the acceptance of any
order. You agree to pay for purchases immediately or on Robinhood’s demand. In the event that you
fail to provide sufficient funds, Robinhood may, at its option and without notice, (i) charge a reasonable
rate of interest, (ii) liquidate the Property subject of the buy order, or (iii) sell other Property owned by
you and held in your Account. Robinhood may also charge any consequential Loss to your Account.
“Property” includes all monies, securities, contracts, investments, and options, whether for present or
future delivery, and all related distributions, proceeds, products, and accessions.
4.8. Assistance by Robinhood.
On your request, Robinhood may provide support, and you understand that when you request support,
help, or assistance from Robinhood in any form orally, electronically, or in writing (each, a
“Support Request”) in using the Platform, any of Robinhood’s services, any investment tools available
on the Platform, or any other information or thing or service provided by Robinhood, that Support
Request and assistance provided relating to it will be limited to functional or operational explanation or
assistance and, if requested by you, to the entry or correction by Robinhood or its Representatives of
information or variables provided by you, and that such assistance and any communication from
Robinhood or its Representatives in connection with a Support Request does not constitute investment
advice, an opinion with respect to the suitability of any transaction, or solicitation of any orders.
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4.9. No Advice.
You understand that Robinhood does not provide any advice to you, and in particular Robinhood does
not provide any tax, legal, financial, or accounting advice. You are encouraged to consult your own tax
advisor or attorney.
4.10. Discontinuation of Services.
You understand that Robinhood may discontinue your Account or any services related to your Account
immediately by providing written notice to you.
Robinhood will not tolerate any foul or abusive language, physical violence, threatening behavior, or
other inappropriate conduct directed toward Robinhood or its or its Affiliates’ officers, employees,
contractors, or customers. Any such behavior, as determined by Robinhood in its sole discretion, may
result in the discontinuation of your Account.
If Robinhood discontinues your Account or any services related to your Account, you agree that
Robinhood is authorized to (i) liquidate any Property in your Account and send you any net proceeds
(after satisfying any Obligations), and (ii) close your Account. This is without limitation to Robinhood’s
other rights under this Agreement or otherwise. “Obligations” includes all indebtedness, debit
balances, liabilities, or other obligations of any kind of you to Robinhood, whether now existing or
hereafter arising.
Robinhood will not be responsible for any Losses caused by Robinhood discontinuing your Account or
any services, or any liquidation of your Property, or closure of your Account, including any tax liabilities.
4.11. No Business Use
You may only use the Platform for your own personal, non-business, non-commercial use.
4.12. Promotions Programs
You agree to the terms or conditions of any Robinhood promotions programs that you participate in,
including but not limited to the Robinhood Stock Referral Program. You understand that any such
promotions may have significant limitations on eligibility or rewards.
4.13. Third Party Authorized Representatives.
You agree not to allow any person access to your Account, or your Account username or password, or
permit any other person to give orders or instructions on your Account to Robinhood, without the prior
consent of Robinhood.
Robinhood may in its sole discretion from time to time permit you to appoint your duly authorized
representative or agent to act on your behalf with respect to your Account (your “Third Party
Authorized Representative”), subject to any conditions that Robinhood may require. You are solely
responsible for any risks associated with your Third Party Authorized Representative, including any
actions, decisions, or conduct of your Third Party Authorized Representative. You instruct Robinhood
to treat any order or instruction from your Third Party Authorized Representative as if that order or
instruction was directly from you for the purposes of this Agreement, and to assume that such order
and instruction is valid and authorized without further inquiry.
Robinhood is not responsible for determining and will not determine whether any Third Party
Authorized Representative has authority to perform any actions generally or specifically with respect to
your Account or your Property, and does not determine the validity of your Third Party Authorized
Representative’s status or capacity. You will be bound by any order or instruction given by your Third
Party Authorized Representative, and irrevocably ratify any action taken by your Third Party Authorized
Representative connected with your Account.
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4.14. Duty to Download and Update Software.
Robinhood requires that to maintain an account on the Platform, you must download, or upon
Robinhood’s request, be able to download, the Mobile App to your mobile device for certain security or
other account-related purposes. Additionally, from time to time, Robinhood will release software
updates for the Apps. You understand and agree that you are responsible for downloading and
upgrading your software and maintaining the latest version of the App on your mobile device. Failing to
do so may result in you encountering content that contains out-of-date, missing or incorrect information
including, among other things, important disclosures and agreement updates, and may impact your
ability to access your Account. Robinhood will not be responsible for any Losses caused by your use of
outdated software or failure to download the App on your mobile device.
5. Account Security.
In order to set up and access your Account, you will be required to create or will be given security
details, including an Account username and password. You are solely responsible for monitoring and
safeguarding your Account and access to your Account. You are solely responsible for keeping your
Account username, password, and other Account details safe, and for the safety and security of any
electronic devices through which you access your Account (which may include your phone, tablet,
computer, or any similar device) (a “Device”). This includes taking all reasonable steps to avoid the
loss, theft, or misuse of such Device, for instance engaging available protections provided by your
Device, such as passcodes, biometric login (such as via a fingerprint or a face-scan), or similar, and
keeping your Account username, password, and other Account details safe and secret at all times. Any
loss or compromise of your Device, your email account, your Account username or password, or other
security details, may result in unauthorized access to your Account by third parties.
You agree to immediately notify Robinhood immediately and in any event within 24 hours if you
become aware of: (i) any loss, theft, or unauthorized use of your Account, Account username or
password; (ii) any failure by you to receive any Account communication such as confirmation of
an order or a statement; (iii) any receipt by you of an Account communication that you do not
recognize such as a confirmation of an order that you did not place; (iv) any inaccurate
information in or relating to your orders, trades, margin status, Account balances, deposits,
withdrawals, securities positions or transaction history; (v) any receipt by you of a security
notification concerning your Account that notifies you of an event or action that you do not
recognize; or (vi) any other unauthorized use or access of your Account. Each of the events
described in (i)-(vi) of this clause will be a “Potential Fraudulent Event”.
Upon request by Robinhood, you agree to report any Potential Fraudulent Event promptly to legal
authorities and provide Robinhood a copy of any report prepared by such legal authorities. You agree
to cooperate fully with the legal authorities and Robinhood in any investigation of any Potential
Fraudulent Event, and to complete any required affidavits promptly, accurately, and thoroughly. You
agree to allow Robinhood access to your Device, and your network in connection with Robinhood’s
investigation of any Potential Fraudulent Event. You acknowledge that if you fail to do any of these
things, you may encounter delays in regaining access to the funds in your Account. You agree to
indemnify and hold Robinhood, its Affiliates, and their respective officers, directors, and employees
harmless from and against any Losses arising out of or relating to any Potential Fraudulent Event.
You understand that, pursuant to FINRA regulations, Robinhood is authorized to contact the “Trusted
Contact Person” (as defined by FINRA Rule 4512) designated for your Account and to disclose
information about any of the account owners, the account for which the Trusted Contact Person was
provided, any other accounts at Robinhood in which any of the account owners has an interest, or any
other information the account owners may have provided to Robinhood. You understand that
Robinhood may contact the Trusted Contact Person(s) for any of the following reasons: (1) to address
possible fraud or financial exploitation; (2) to confirm the specifics of your current contact information;
(3) if there are questions or concerns about your health status; (4) to confirm the identity of any legal
guardian, executor, trustee or holder of a power of attorney; or (5) for any other reasons as permitted
by FINRA Rule 2165. You further agree that: (1) the Trusted Contact authorization does not impose
any obligation that Robinhood communicate with your Trusted Contact Person(s); (2) the Trusted
Contact authorization does not authorize the Trusted Contact Person(s) to make any investment
decisions or transact any business with Robinhood on your behalf; (3) designation of a Trusted Contact
Person is optional and you may change or withdraw it at any time by notifying Robinhood; (4) all
designated Trusted Contact Persons are 18 years of age or older; (5) if there are multiple account
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owners, Robinhood is authorized to follow the instructions of any one or more account owners in
adding a Trusted Contact Person, and Robinhood will not be held liable for information shared with a
Trusted Contact Person without regard to which account owner authorized the designation of the
Trusted Contact Person; and (6) Robinhood is released and discharged from all claims, causes of
action, damages, losses, expenses, costs and liabilities of any kind that may arise out of, relate to, or
are in connection with the release of, or failure to release, personal and/or account information to the
Trusted Contact Person(s).
6. Important Information About Procedures for Opening a New Account or
Maintaining an Account.
To help the government fight the funding of terrorism and money laundering activities, federal law
requires Robinhood to obtain, verify, and record information that identifies each person who opens an
account.
What this means for you: When you open or apply to open an Account, Robinhood will ask for your
name, U.S. residential address, date of birth, social security number, telephone number, citizenship,
and other identifying information that will allow Robinhood to identify you. Robinhood may also ask for
copies of your driver’s license, passport, other unexpired, government-issued identifying documents
with a photograph, or other identifying documents. From time to time, Robinhood may ask you to
confirm or reverify your identity, or may require that you provide certain additional documents, as
necessary.
You understand that Robinhood may take steps to verify the accuracy of the information you provide to
Robinhood relating to your Account in your application or otherwise. You authorize Robinhood or its
agents or third-party vendors to contact any person or firm noted therein or in any other information you
may provide to Robinhood from time to time, or any other normal sources of debit or credit information
and other similar databases, and authorize any such person or entity to furnish such information about
you as may be requested or required by Robinhood. You acknowledge that Robinhood may restrict
your access to your Account pending such verification. You will provide prompt notification to
Robinhood of any changes in the information including your name, address, e- mail address, and
telephone number.
You authorize Robinhood Financial to obtain reports and provide information to others concerning your
creditworthiness and business conduct. Upon your request, Robinhood Financial agrees to provide you
a copy of any report so obtained. Robinhood may retain this Agreement, the Account application, and
all other such documents and their respective records at its sole discretion, whether or not credit is
extended.
U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) Certification. You
acknowledge that you are aware that Robinhood has OFAC sanctions compliance obligations. You also
acknowledge that this Agreement, your Account, and any sub-accounts are subject to U.S. sanctions laws,
rules, and regulations where you will not permit your Account or sub-accounts to be used in a manner that
would cause a violation of the above referenced laws, rules, and regulations. You also specifically
represent and warrant that you have not been designated by OFAC as a Specially Designated National
(“SDN”), that you have no reason to believe that you would be considered a blocked person by OFAC,
and that you are not acting as an agent of any such person. To the extent that OFAC, via laws, rules,
regulations, or Executive Order, has promulgated restrictive measures against a government or regime
(“sanctioned regime”), you further represent and warrant that you are not employed by or acting as an
agent of (1) an entity owned or controlled by a sanctioned regime, (2) a government-controlled entity of a
sanctioned regime, or (3) a government corporation of a sanctioned regime.
Further, you acknowledge and consent to Robinhood restricting your Account and/or any sub-accounts
and canceling any pending orders to the extent Robinhood believes you are accessing these from (1) a
jurisdiction that is subject to comprehensive sanctions by OFAC or (2) any jurisdiction Robinhood has
made a risk-based decision to restrict access to use of its application and website. If this happens, please
contact [email protected], and you may be asked to provide supplemental information as part of this
process. Additionally, you agree that you will notify Robinhood and close your Account and/or any
subaccounts before establishing residency in any jurisdiction subject to U.S. sanctions. Robinhood is not
liable for any Losses, including any trading losses, that you may suffer as a result of the foregoing.
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Politically Exposed Person (“PEP”) Certification. You represent and warrant that you are not a PEP.
To the extent you are or become a PEP in the future while you hold your Account or any subaccounts at
Robinhood, you represent and warrant that you will immediately notify Robinhood and subject yourself to
any due diligence measures deemed appropriate by Robinhood.
A PEP is an individual who is/was or is an immediate family member (spouse, parent, sibling, children, in-
law, or dependent) or close associate (someone who is closely connected to the individual either socially
or professionally) of (1) a senior official in the executive, legislative, administrative, military, or judicial
branches of a non-U.S. government (whether elected or not); (2) a senior official of a major non-U.S.
political party; (3) a senior executive of a non-U.S. government-owned entity; or (4) a foreign individual
who was or has been entrusted with a prominent public function. A senior official or executive includes an
individual with substantial authority over policy, operations, or the use of government-owned resources.
7. Applicable Laws and Regulations.
All transactions in your Account will be subject to all Applicable Laws. In no event will Robinhood be
obligated to effect any transaction or provide any service or take any action that it believes would or
might violate or be contrary to any applicable laws.
8. Erroneous Distributions
You agree to promptly return to Robinhood any assets erroneously distributed to you. In the event that
you sell a security prior to its ex-dividend/distribution date, and you receive the related cash/stock
dividend or distribution in error, you irrevocably direct Robinhood on your behalf to pay such
dividend/distribution to the entitled purchaser of the securities, and guarantee to promptly reimburse
Robinhood for, or deliver to Robinhood, said dividend or distribution.
9. Residual Funds
In the event Your Account is cancelled, closed, or terminated for any reason and thereafter Robinhood
receives funds to be applied to your Account, Robinhood reserves the right to apply the funds to any
obligations you may have in your Account and/or transfer the funds to the balance of any active
account you may own with a Robinhood Affiliate.
You understand that, if you request that all assets be transferred from an Account to another brokerage
firm and subsequently reactivate that Account, you are (i) rescinding any instruction to transfer
securities or other assets from the Account and (ii) instructing Robinhood not to transfer credit balances
that accrue in the Account to the other brokerage firm.
10. Market Volatility; Market Orders; Limit Orders; and Queued Orders.
You understand that, whether you place a market or limit order, you will receive the price at which your
order is executed in the marketplace. Particularly during periods of high volume, illiquidity, fast
movement or volatility in the marketplace, the execution price received may differ from the quote
provided on entry of an order, and you may receive partial executions of an order at different prices.
You understand that Robinhood Financial is not liable for any price fluctuations. You also understand
that price quotes generally are for only a small number of shares as specified by the marketplace, and
larger orders are relatively more likely to receive executions at prices that vary from the quotes or in
multiple lots at different prices.
The default order type when entering an equity order via the Platform may be, as disclosed during the
order entry process, either (i) a market order, (ii) a limit order with a preset limit price set at 5% above
(if a buy order) or 5% below (if a sell order) the last reported trade price for the security on a Nasdaq
exchange (i.e., The Nasdaq Stock Market, NASDAQ OMX BX, or NASDAQ OMX PHLX) at the time the
order was entered, or (iii) a limit order with a limit price set by you. Robinhood will use the following
rounding formulas to determine the limit price for a limit order with a preset limit price: the last trade
price for the security is (i) multiplied by 1.05 (for buy orders) or .95 (for sell orders); and (ii) if the last
trade price is over $1.00, rounded down to two decimal places (for buy orders) or rounded up to two
decimal places (for sell orders); otherwise, rounded down to four decimal places (for buy orders) or
rounded up to four decimal places (for sell orders). You understand that securities may open for trading
at prices substantially higher or lower than the previous closing price or the anticipated price. If you
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place a market order (irrespective of when you place it), you agree to pay or receive the prevailing
market price at the time your market order is executed, which execution may occur on a subsequent
trading day. You understand that the price you pay or receive may be significantly higher or lower than
anticipated at the time you placed the order. To avoid buying a security at a higher price and possibly
exceeding your purchasing power, you understand your option to enter a limit order with a limit price.
You also understand that limit orders may not be executed within a particular period of time, or at all, if
there is not sufficient trading at or better than the limit price you specify, and are subject to any
applicable time-in-force restrictions. The Website contains further information regarding order types
and limitations, which you agree to read and understand before placing such orders.
If Robinhood 24 Hour Market trading is available to you and you enter a limit order that is eligible for
execution during the Robinhood 24 Hour Market, you understand that (1) such orders could be
executed between 12 a.m. and 8 p.m. ET on a full trading day (i.e., Monday - Friday except for holidays
and half-days observed by national securities exchanges), between 12 a.m. and 5 p.m. ET on a half-
day (i.e., a half-day observed by national securities exchanges), and between 8 p.m. and 12 a.m. ET
(the last four hours) on the day before either a full trading day or a half-day; (2) the trade date for an
order that is executed between 8 p.m. and 12 a.m. ET (the last four hours of a day) is the following full
trading day or half-day (including for purposes of clearance, settlement, tax reporting, dividends, and
other corporate actions); (3) you are responsible for the risks associated with the entry of such orders,
and such risks include the risks of Extended Hours Trading described in the Extended Hours Trading
Disclosure; (4) Robinhood deems each such order to be a “not held” order, i.e., an order with respect to
which you have granted Robinhood discretion with respect to the price and time of execution; (5)
Robinhood will route such orders to a market center (a “24H Market Maker”), which may execute the
order on a principal basis or route the order for execution to another market center; (6) between 8 p.m.
and 4 a.m. ET (“Overnight Hours”), Robinhood will route such orders to a single 24H Market Maker,
which may execute the order on a principal basis or route the order for execution to a single alternative
trading system (the “24H ATS”); (7) the 24H ATS is not required to display prices publicly and may
have very limited liquidity and/or high volatility; (8) such an order may not be price protected and so
may be executed by a market center at a price that is worse than prices available at other execution
venues; (9) if the order is unexecuted as of the beginning of, or shortly before, the next Overnight
Hours session, the order will be canceled and, subject to the order’s time-in-force instructions, re-
routed to a single 24H Market Maker, which may execute the order on a principal basis or route the
order for execution to the 24H ATS; (10) if the order is unexecuted as of the end of, or shortly before
the end of, the Overnight Hours session, the order will be canceled and, subject to the order’s time-in-
force instructions, re-routed to a 24H Market Maker, which may execute the order on a principal basis
or route the order for execution to another market center; and (11) if the order is canceled and re-
routed as described in (9) or (10) above, the order will not be eligible for execution during the period of
time between the cancelation of the order and its re-routing.
As a customer of Robinhood, you understand that you have the ability to place certain orders in a
queue for execution the following trading day (“Queued Order”). Queued Order requests are prioritized
based on the order in which they are received, and orders based on Queued Orders are sent out for
execution after the opening of the normal market trading session of 9:30 a.m. to 4:00 p.m. ET (“Market
Hours”) or the pre-market trading session of 7:00 a.m. to 9:30 a.m. ET (“Pre-Market Hours”),
depending on your instruction, on the next day of trading. If you submit a single or multiple Queued
Order requests to buy one or more securities and Robinhood is unable to route orders based on all of
those requests because you have insufficient buying power as of the opening of Market Hours or Pre-
Market Hours, as applicable, you understand that Robinhood will endeavor to cancel one or more of
the Queued Order requests in the order in which they were received until you have sufficient buying
power for the remaining Queued Order requests, if any. You further understand that orders based on
Queued Orders with fractional share components may be aggregated with other such orders. Orders
placed outside of Market Hours are subject to the Extended Hours Trading Disclosure.
A limit order may be designated as “good-’til-cancelled” (“GTC”), which means the order remains valid
until (A) it is executed; (B) you cancel the order; (C) 90 days from when the order is placed (based on
Eastern Time); or (D) the contract to which it relates is closed. You understand that a GTC order placed
with an instruction to execute only during Market Hours, if not executed or cancelled, will stand only
through Market Hours sessions. A GTC order placed with an instruction to execute during either Market
Hours or Extended Hours (defined as, collectively, the Pre-Market Hours and the after-hours trading
session of 4:00 p.m. to 8:00 p.m. ET (“After Hours”)) will stand through Market Hours and Extended
Hours until executed or cancelled. GTC Orders that are placed with either of the above instructions and
are unexecuted at the end of the trading day are re-routed at the start of the appropriate session on the
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following trading day, and this process will be repeated every day for as long as the GTC order remains
valid or expires unexecuted. You further agree that any GTC orders you place should be treated as “do
not reduce” orders. Robinhood may in its discretion cancel any open orders for the purchase or sale of
any securities without notice.
You understand that Robinhood may implement certain risk controls to assist in minimizing adverse
market impact. This may result in your order being queued and/or cancelled.
11. Bulletin Board/Pink Sheet Stocks.
Bulletin board, pink sheet and other thinly-traded securities (collectively “Bulletin Board Stocks”)
present particular trading risks, in part because they are relatively less liquid and more volatile than
actively traded securities listed on a major exchange. You understand that Bulletin Board Stocks may
be subject to different trading rules and systems than other securities and that you may encounter
significant delays in executions, reports of executions, and updating of quotations in trading Bulletin
Board Stocks. Robinhood Financial in its sole discretion may require limit orders on certain Bulletin
Board Stock transactions.
12. Content.
We may provide or make available to you certain content or information which may include news,
articles, commentary, research, links to outside websites, and other information accessible through the
Platform, but excluding brokerage services (such content or information, “Content”). Content may be
prepared by third parties and independent external providers not affiliated with Robinhood
(“Providers”). If we provide or make Content available to you, this does not grant you any rights over or
in that Content. You may not and agree that you will not reproduce, sell, market, distribute, or otherwise
commercially use the Content in any manner. Robinhood may terminate your access to the Content at
any time.
Content is provided or made available to you on an “as is” and on an “as available” basis and should
not be considered as any form of advice or recommendation for you or your Account, or a
recommendation by Robinhood to buy or sell any securities or to engage in any investment strategy.
Your use of any Content is at your own risk. We do not make any warranty of any kind, express or
implied, regarding the Content or the accuracy, completeness, timeliness, or otherwise of the Content.
Robinhood does not produce or provide first-party research providing specific investment strategies
such as buy, sell, or hold recommendations, first-party ratings, or price targets. To the extent any
Content is prepared by Robinhood or its associated persons and made available via that Platform or by
other means, that Content is intended for informational and educational purposes only and does not
constitute either research or a recommendation to enter into any securities transactions or to engage in
any investment strategies.
Any views expressed in any third-party Content are not the views of Robinhood. Robinhood is not
responsible for any third-party website or anything contained on or connected with any third-party
website.
13. Restrictions on Trading, Deposits, Withdrawals and Use of Services.
You understand that Robinhood may at any time, at its sole discretion and without prior notice to you: (i)
prohibit or restrict your access to the use of the Platform or related services; (ii) restrict your ability to
deposit or withdrawal funds, or trade securities in your Account, or (iii) terminate your Account. The
closing of your Account will not affect the rights or obligations of either party that are incurred prior to the
date your Account is closed.
Robinhood may restrict your Account from withdrawals or trading for, but not limited to, the following
reasons: if there is a reasonable suspicion of fraud, diminished capacity, inappropriate activity, or if
Robinhood receives reasonable notice that ownership of some or all of the assets in your Account are
in dispute. Robinhood shall not be liable for any loss that you may incur due to Robinhood’s refusal to
permit any deposit, withdrawal or transaction.
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In the event of a breach or default by you under this Agreement, Robinhood shall have all rights and
remedies available to a secured creditor under all applicable laws and in addition to the rights and
remedies provided herein.
14. Use of the Platform, Market Data and Electronic Services.
14.1 Warranties.
You agree that your use of the Platform or any other service provided by Robinhood or its Affiliates is at
your sole risk. The Robinhood services (including the Platform, the provision of Market Data, Content,
or any other information provided by Robinhood, any of its Affiliates, or any third-party content provider
or market data provider) is provided on an "as is," "as available" basis without warranties of any kind,
either express or implied, statutory (including without limitation, timeliness, truthfulness, sequence,
completeness, accuracy, freedom from interruption), implied warranties arising from trade usage,
course of dealing, course of performance, or the implied warranties of merchantability or fitness for a
particular purpose or application, other than those warranties which are implied by and incapable of
exclusion, restriction or modification under the laws applicable to this Agreement.
From time to time, Robinhood may offer new “beta” features or tools with which its users may
experiment. Such features or tools are offered solely for experimental purposes and without any
warranty of any kind, and may be modified or discontinued at Robinhood’s sole discretion. The
provisions of this section apply with full force to such features or tools.
14.2 Limitation of Liability.
Although considerable effort is expended to make the Platform and other operational and
communications channels available around the clock, Robinhood does not guarantee that these
channels will be available and error free every minute of the day. Interruptions of service due to
maintenance, Platform changes or system failures may occur. ROBINHOOD, ITS AFFILIATES, THEIR
RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES AND AGENTS, AND THE PROVIDERS
(COLLECTIVELY, THE “ROBINHOOD PARTIES”) WILL NOT BE RESPONSIBLE TO YOU OR TO
THIRD PARTIES FOR ANY LOSSES YOU INCUR (MEANING CLAIMS, DAMAGES, ACTIONS,
DEMANDS, INVESTMENT LOSSES, OR OTHER LOSSES, AS WELL AS ANY COSTS, CHARGES,
ATTORNEYS' FEES, OR OTHER FEES OR EXPENSES) BY REASON OF SUCH INTERRUPTIONS
OF SERVICE, EXCEPT WHERE SUCH LOSS RESULTS FROM VIOLATION OF THIS AGREEMENT,
APPLICABLE RULES, OR APPLICABLE STANDARDS OF CONDUCT. THIS PROVISION DOES NOT
RESTRICT OR LIMIT IN ANY WAY YOUR ABILITY TO BRING ANY CLAIM IN ANY FORUM,
INCLUDING IN ARBITRATION, AGAINST ROBINHOOD PARTIES THAT YOU WOULD OTHERWISE
BE ENTITLED TO BRING.
14.3 Operational Interruption and Extraordinary Events.
TO THE EXTENT PERMITTED BY APPLICABLE LAW, THE ROBINHOOD PARTIES WILL NOT BE
RESPONSIBLE TO YOU OR TO THIRD PARTIES FOR ANY LOSSES YOU INCUR (MEANING
CLAIMS, DAMAGES, ACTIONS, DEMANDS, INVESTMENT LOSSES, OR OTHER LOSSES, AS
WELL AS ANY COSTS, CHARGES, ATTORNEYS' FEES, OR OTHER FEES OR EXPENSES) BY
REASON OF EXTRAORDINARY EVENTS OUTSIDE OF THEIR CONTROL OR THAT THEY DID
NOT CAUSE INCLUDING, BUT NOT LIMITED TO, INTERRUPTIONS OF SERVICE DUE TO
GOVERNMENT OR MARKET RESTRICTIONS, SUSPENSIONS OF TRADING, THE ACTION OF
ANY EXCHANGE OR OTHER SELF-REGULATORY ORGANIZATION, HIGH MARKET VOLATILITY
OR TRADING VOLUME, ARMED CONFLICTS, NATURAL DISASTERS, FORCES OF NATURE
(INCLUDING EARTHQUAKES AND STORMS), POWER OUTAGES, NETWORK OR SYSTEM
FAILURES, UNFORSEEABLE SOFTWARE OR HARDWARE MALFUNCTIONS, COMPUTER
VIRUSES, MESSAGE INTERRUPTION, AND INSTANCES OF UNAUTHORIZED ACCESS OR
BREACH OF SECURITY.
Laws can differ jurisdiction by jurisdiction. Robinhood’s responsibility provided for in this
section shall not be construed as limiting your rights under FINRA rules or regulations or
under applicable law to (i) bring a claim against Robinhood in any forum, including arbitration,
that you would be entitled to bring under applicable law or (ii) receive an award or judgment
from Robinhood that you would be entitled to receive under FINRA rules or regulations or
under applicable law.
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14.4 Indemnification.
Except as otherwise provided by law, Robinhood or any of its affiliates or respective partners, officers,
directors, employees or agents (collectively, “Indemnified Parties”) shall have no liability for, and you
agree to indemnify, defend and hold harmless the Indemnified Parties from all Losses that result from: (i)
any noncompliance by you with any of the terms and conditions of this Agreement; (ii) any third-party
actions related to your receipt and use of any Market Data, Content, market analysis, other third-party
content, or other such information obtained on the Platform, whether authorized or unauthorized under
this Agreement; (iii) any third- party actions related to your use of the Platform; (iv) your or your agent’s
misrepresentation or alleged misrepresentation, or act or omission; (v) Indemnified Parties following your
or your agent’s directions or instructions, or failing to follow your or your agent’s unlawful or
unreasonable directions or instructions; (vi) any activities or services of the Indemnified Parties in
connection with your Account (including any technology services, reporting, trading, research or capital
introduction services); or (vii) the failure by any person not controlled by the Indemnified Parties and their
affiliates to perform any obligations to you, except to the extent such Losses result from the Indemnified
Parties’ violation of this Agreement, Applicable Rules, or applicable standards of conduct. Further, if you
authorize or allow third parties to gain access to Robinhood's services, including your Account, you will
indemnify, defend and hold harmless the Indemnified Parties against any Losses arising out of claims or
suits by such third parties based upon or relating to such access and use. Robinhood does not warrant
against loss of use or any direct, indirect or consequential damages or Losses to you caused by your
assent, expressed or implied, to a third party accessing your Account or information, including access
provided through any other third-party systems or sites.
You consent to the use of automated systems or service bureaus by Robinhood and its respective
affiliates in conjunction with your Account, including automated order entry and execution, record
keeping, reporting and account reconciliation and risk management systems (collectively "Automated
Systems"). You understand that the use of Automated Systems entails risks, such as interruption or
delays of service, errors or omissions in the information provided, system failure, and errors in the
design or functioning of such Automated Systems (collectively, a "System Failure") that could cause
substantial damage, expense, or liability to you. As set forth in Section 14.2, you understand and agree
that Indemnified Parties will not be responsible for any of your Losses arising out of or relating to a
System Failure, except to the extent such Losses result from the Indemnified Parties’ violation of this
Agreement, Applicable Rules, or applicable standards of conduct.
You also agree that Indemnified Parties will have no responsibility to you in connection with the
performance or non-performance by any exchange, clearing organization, market data provider, or other
third party (including other broker-dealers and clearing firms, and banks) or any of their respective agents
or affiliates, of its or their obligations relative to any securities. You agree that Indemnified Parties will not
be responsible to you or to third parties for: any Losses (including special, indirect, incidental,
consequential, punitive or exemplary (including lost profits, trading losses and damages)) resulting from
a cause outside the control of the Indemnified Parties, including the failure of mechanical equipment,
unauthorized access, theft, operator errors, government restrictions, force majeure (as defined in this
Agreement), market data availability or quality, exchange rulings or suspension of trading. This
Agreement does not seek indemnification for costs or penalties resulting from the Indemnified Parties’
own violation of the securities laws or FINRA Rules.
Laws can differ jurisdiction by jurisdiction. The indemnity provided for in this section shall not be
construed as limiting your rights under FINRA rules or regulations or under applicable law to (i)
bring a claim against Robinhood, in any forum, including arbitration, that you would be entitled to
bring under applicable law or (ii) receive an award or judgment from Robinhood that you would
be entitled to receive under FINRA rules or regulations or under applicable law.
15. Exchange Traded Funds.
You understand that you should consider the investment objectives and unique risk profile of Exchange
Traded Funds (“ETFs”) carefully before investing, and that ETFs are subject to risks similar to those of
other diversified portfolios. You further understand that leveraged and inverse ETFs may not be
suitable for all investors and may increase exposure to volatility through the use of leverage, short
sales of securities, derivatives, and other complex investment strategies, and that although ETFs are
designed to provide investment results that generally correspond to the performance of their respective
underlying indices, they may not be able to exactly replicate the performance of the indices because of
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expenses and other factors. You further understand that ETFs are required to distribute portfolio gains
to shareholders at year end, which may be generated by portfolio rebalancing or the need to meet
diversification requirements, and that ETF trading will also generate tax consequences.
You understand that you can obtain prospectuses from issuers or their third-party agents who
distribute and make prospectuses available for review. Additional regulatory guidance on ETFs can be
found here.
16. Effect of Attachment or Sequestration of Accounts.
Robinhood shall not be liable for refusing to obey any orders given by or for you with respect to your
Account that has or have been subject to an attachment or sequestration in any legal proceeding
against you, and Robinhood shall be under no obligation to contest the validity of any such attachment
or sequestration.
17. Event of Death.
It is agreed that in the event of your death, the representative of your estate or the survivor or survivors
shall immediately give Robinhood written notice thereof, and Robinhood may, before or after receiving
such notice, take such proceedings, require such papers and inheritance or estate tax waivers, retain
such portion of, or restrict transactions in the Account as Robinhood may deem advisable to protect
Robinhood against any tax, liability, penalty or loss under any present or future laws or otherwise.
Notwithstanding the above, in the event of your death, Robinhood may cancel all open orders, but
Robinhood shall not be responsible for any action taken on such orders prior to the actual receipt of
notice of death. Further, Robinhood may in its discretion close out any or all of the Account without
awaiting the appointment of a personal representative for your estate and without demand upon or
notice to any such personal representative. The estate of any of the Account holders who have died
shall be liable and each survivor shall continue to be liable, jointly and severally, to Robinhood for any
net debit balance or loss in said account in any way resulting from the completion of transactions
initiated prior to the receipt by Robinhood of the written notice of the death of the decedent or incurred
in the liquidation of the Account or the adjustment of the interests of the respective parties, and for all
other obligations pursuant to this Agreement. Such notice shall not affect Robinhood’s rights under this
Agreement to take any action that Robinhood could have taken if you had not died.
18. Tax; Tax Reporting; Tax Withholding.
18.1. Tax.
You acknowledge that it is your responsibility to declare and pay any income, gains, or similar to all
applicable tax authorities, make any tax filings, and to pay any and all taxes, duties, or similar (“tax”)
when due in all applicable jurisdictions. You undertake and warrant to Robinhood that you will do so
and will comply in full with all applicable tax laws and obligations to which you are subject.
18.2. Reporting.
The proceeds of sale transactions and dividends (and substitute payments in lieu of dividends) paid will
be reported to the Internal Revenue Service (“IRS”) in accordance with applicable law.
18.3. U.S. Persons.
This subsection is applicable if you are a U.S. person. Under penalties of perjury, you certify that the
taxpayer identification number that you have provided or will provide to Robinhood (including any
taxpayer identification number on any Form W-9 that you have provided or will provide to Robinhood)
is your correct taxpayer identification number. You certify that you are not subject to backup
withholding and you are a United States Person (including a U.S. resident alien) as such term is
defined in section 7701(a)(30) of the Internal Revenue Code of 1986, as amended (“U.S. Person”). If
a correct Taxpayer Identification Number is not provided Robinhood Financial, you understand you
may be subject to backup withholding tax at the appropriate rate on all dividends, interest and gross
proceeds paid to you. Backup withholding taxes are sent to the IRS and cannot be refunded by
Robinhood Financial. You further understand that if you waive tax withholding and fail to pay sufficient
estimated taxes to the IRS, you may be subject to tax penalties.
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18.4. Non-U.S. Persons.
This subsection is applicable if you are not a U.S. Person. You certify that you fully understand all the
information on any Form W-8BEN that you have submitted or will submit to Robinhood. Under
penalties of perjury, you declare that (i) you have examined all the information (including all the
information in the English language) on any Form W-8BEN that you have submitted or will submit to
Robinhood and (ii) to the best of your knowledge and belief all such information is true, correct, and
complete. You authorize Robinhood to provide any such Form W-8BEN to Robinhood Securities or any
withholding agent that has control, receipt, or custody of the income of which you are the beneficial
owner or any withholding agent that can disburse or make payments of the income of which you are
the beneficial owner. You agree that you will submit a new Form W-8BEN to Robinhood within 30 days
if any certification made on any previously submitted Form W-8BEN becomes incorrect. You
understand that the IRS does not require your consent to any provisions of such Form W-8BEN other
than the certifications required to establish your status as a non-U.S. Person and, if applicable, obtain a
reduced rate of withholding.
19. Equity Orders and Payment For Order Flow.
SEC Rule 607 requires registered broker-dealers to disclose their policies regarding the receipt of
“payment for order flow” in connection with the routing of certain customer orders. “Payment for order
flow” includes, among other things, any monetary payment, service, property, or other benefit that results
in remuneration, compensation, or consideration to a broker-dealer from any broker-dealer or exchange
in return for routing orders. Robinhood Financial routes customer orders in stock and option securities to
Robinhood Securities, which routes orders in options and whole-share orders in stocks to market
centers, including other broker-dealers and/or one or more national securities exchanges. Robinhood
Securities receives payment for order flow from those market centers and shares revenue with
Robinhood Financial. The broker-dealers pay for order flow at the same rate and generally pay
Robinhood Securities (i) for orders in stocks, a percentage of the spread between the execution price of
an executed order and either the National Best Bid (for sell orders) or National Best Offer (for buy
orders), and (ii) for orders in options, a flat rate based on the underlying symbol.
Under applicable exchange fee schedules, Robinhood Securities generally pays an exchange when
taking liquidity on it and is paid by an exchange when providing liquidity to it. Robinhood Securities
transmits customer orders for execution to market centers based on several factors depending in part on
the type of security, including: size of order, trading characteristics of the security, favorable execution
price (including the expected opportunity for price improvement based on historical performance), and
the likelihood of a fill. The market centers to which Robinhood Securities routes customer orders may
execute orders at prices superior to the publicly quoted market. While a customer may not specify that
an order be directed to a particular market center for execution, Robinhood’s order-routing policies,
taking into consideration the factors referenced above, are designed to seek favorable transaction
processing for customers. The nature and source of any payments or credits received by Robinhood
Securities in connection with any specific transactions will be furnished upon written request.
20. Fees and Charges.
You understand that Robinhood does not charge fees or commissions for executing buy and sell
orders. However, you understand that other fees may apply. The current fees are included in the Fee
Schedule available on the Platform. You agree to pay any such fees at the then-prevailing rate. You
acknowledge that the prevailing fees may change and that change may occur without notice. You
agree to be bound by such changes once they are posted in the fee schedule available on the
Platform. Robinhood reserves the right to vary rates and fees among customers in connection with
special offers, promotions, arrangements, or account criteria such as account value/balance or
customer loyalty. You also agree to pay all applicable federal, state, local, and foreign taxes, and any
fees, costs, or expenses incurred by Robinhood in connection with collection of any unpaid balance
due on your Account, including attorney’s fees allowed by law.
You authorize Robinhood to automatically debit your Account for any fees, charges or other amounts
owed to Robinhood by you, and for any taxes owed by you.
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21. ACH Transactions.
21.1. Debit Transactions.
Robinhood will initiate an ACH debit at your request to debit funds from an account that you own at
another financial institution (“External Account”) for deposit into your Account. You understand that in
order for Robinhood to initiate an ACH debit, the financial institution holding your External Account
must participate in the ACH system. You understand that for the ACH transfers to be established, at
least one common name must match exactly between your Account and your External Account. You
authorize Robinhood to take such steps as it deems appropriate to verify your ownership of External
Account, including by telling the bank at which such External Account is held that you have authorized
and consented to such bank disclosing to Robinhood any information that Robinhood may request
about you or your External Account. You also agree to cooperate with Robinhood’s verification of your
ownership of such External Account by promptly providing any identification or other documentation
that Robinhood may request regarding such External Account. You represent and warrant that there
are sufficient funds in your External Account to cover the amount of the deposit to your Account.
Robinhood will initiate the ACH debit to your External Account on the Business Day or next Business
Day after you request the transfer. A transfer request will be deemed to have been made on a
Business Day if it is received by Robinhood by 7:00 p.m. Eastern on such Business Day; if received
after that time, the transfer request will be deemed to have been made on the next Business Day.
“Business Days” are Monday through Friday, excluding U.S. federal holidays.
Within 60 days of the date of your ACH deposit, your funds may only be withdrawn to the External
Account from which such funds were debited.
You understand that an ACH debit transfer may be reversed or rejected if: (A) there are insufficient
funds in your External Account; (B) there is a duplicate transaction; (C) the transaction is denied by the
bank holding your External Account; (D) your External Account does not support ACH transfers; or (E)
suspected fraud or other potential illicit activity. You acknowledge that in the event of an ACH reversal,
you may incur a fee. Before initiating making an ACH debit transfer, you agree to check the most
recent Robinhood Financial Fee Schedule available in the Disclosure Library. You agree that you are
solely liable and responsible for any ACH reversal fees that you incur.
21.2. Credit Transactions.
Robinhood will initiate an ACH credit at your request to transfer funds from your Account to an External
Account; provided, however, that funds deposited by ACH within the previous 60 days, may only be
credited to the External Account from which such funds were debited. You agree that you will have
sufficient Available Funds in your Account to cover the amount of any ACH credit that you ask
Robinhood to initiate. Robinhood will debit the amount of such request from your Account on the
Business Day or next Business Day after you request the transfer. A transfer request will be deemed to
have been made on a Business Day if it is received by Robinhood on such Business Day; if received
after that time, the transfer request will be deemed to have been made on the next Business Day.
You agree that Robinhood may use any means which Robinhood, in its sole discretion, considers suitable
to execute your ACH credit transfers, and that Robinhood may reject any ACH credit request in the event
of suspected fraud or other potential illicit activity.
22. Fractional Shares.
Robinhood may facilitate the holding or trading of a fraction of a share of a security (“Fractional
Shares”) in your Account.
You acknowledge and understand that Robinhood rounds all holdings of Fractional Shares to the fifth or
sixth decimal place (depending on the execution venue), the value of Fractional Shares to the nearest
cent, and any dividends paid on Fractional Shares to the nearest cent. You understand that Robinhood
will not accept dollar-based purchases or sales of less than $1.00 and that you will receive proceeds
from the sale of any whole or Fractional Shares rounded to the nearest cent. You understand that a
dollar-based order is an order to purchase or sell shares that have a notional value of approximately the
dollar value specified by the order and that, if the order is executed, the notional value of the purchased
or sold shares may vary from the dollar value specified by the order.
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You understand that if you enter repeated Fractional Share orders with individual notional values of
less than $0.01, your Account may be restricted.
You understand that a vendor employed by Robinhood will aggregate any proxy votes for Fractional
Shares of Robinhood’s customers with all votes reported to the issuer or issuer’s designated vote
tabulator and that, while Robinhood’s vendor will report such proxy votes on Fractional Shares, the
issuer or tabulator may not fully count such votes.
Robinhood Financial deems each of the following equity orders entered by or on behalf of a customer
to be a not held order, i.e., an order with respect to which the customer has granted Robinhood
Financial discretion with respect to the price and time of execution (a “Fractional Order”): orders (i) for
a share quantity that includes a Fractional Share (fractional share-based orders), (ii) for a dollar amount
(dollar-based orders), (iii) to invest in a portfolio of exchange traded funds (ETFs) pursuant to a
recommendation from Robinhood Financial, or (iv) to invest in a security pursuant to a customer
instruction provided in connection with the customer’s participation in the Paycheck Recurring
Investment (split-your-paycheck) program offered by Robinhood Money, LLC and certain of its
affiliates. As described in Sections 23 and 24 below, orders to invest in a security pursuant to customer
instructions provided in connection with the customer’s participation in the Recurring Investment
program and the Dividend Reinvestment Program, each offered by Robinhood Financial, will be routed
by Robinhood Financial to a certain bulk order engine that is operated by Robinhood Securities
(“BOE”); Robinhood Financial will deem each order that it routes to the BOE to be a not held order.
You understand that when Robinhood executes Fractional Orders utilizing inventory held in its principal
account, the portions of such Fractional Orders that execute against inventory are executed in a
principal capacity. To the extent that Robinhood must purchase or sell whole shares in the market to fill
any portion of your Fractional Order, that portion of the order will be executed in a riskless principal
capacity and will be filled at the execution price Robinhood received for the corresponding whole
shares it purchased and sold in the market. To the extent that Robinhood fills any portion of your
Fractional Order for a national exchange-listed security (“NMS Securities”) out of inventory
(“Inventory Fulfillment”) rather than by purchasing or selling shares in the market or routing to a
market center on an agency basis, Robinhood will endeavor to price that portion of your Fractional
Order at a price (i) between the National Best Bid and the National Best Offer (“NBBO”) at the time of
execution for orders executed during Market Hours, or (ii) between the best bid and the best offer as
reported by an external vendor at the time of execution (“Vendor BBO”), for orders executed during
Extended Hours. For Inventory Fulfillment of any portion of your Fractional Order for a security not
listed on a national exchange (“Non-NMS Security”), executed during Market Hours or Extended
Hours, Robinhood will endeavor to price that portion of your Fractional Order between the Vendor
BBO. Robinhood may execute a Fractional Order in a security as principal while in receipt of a not held
order from you that is in the same security and on the same side of the market as Robinhood; in such
cases, Robinhood may receive the same price as or a better price than the price you receive.
Robinhood generally cancels Fractional Orders, or unexecuted portions of Fractional Orders, if they are
not executed after five minutes of being eligible for execution.
A Fractional Order you enter can be either a market order or a limit order with a preset limit price, as
described in Section 10 above. Robinhood generally cancels Fractional Orders that are limit orders with
preset limit prices, or the unexecuted portions of such orders, if they are unmarketable. Certain
securities are not eligible for fractional trading during Extended Hours. During Extended Hours, orders in
such securities may be placed for whole shares or queued for the opening of Market Hours. Trades
outside of Market Hours are subject to Robinhood’s Extended Hours Trading Disclosure.
You understand that Fractional Shares within your Account (i) are unrecognized, unmarketable, and
illiquid outside the Robinhood platform, (ii) are not transferable in-kind, and (iii) may only be liquidated
and the proceeds withdrawn or transferred out. You acknowledge that, subject to applicable
requirements, Robinhood may report holdings and transactions in your Account in terms of either U.S.
Dollars, shares, or both.
Because Fractional Share positions cannot be transferred, reorganized, or issued in certificate form,
your partial interest will be liquidated, without commission charges to you, at prevailing market prices
in the event your Account is transferred or closed, the stock is reorganized, or stock certificates are
ordered out of your Account. The timing of such liquidations will be at the discretion of Robinhood.
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23. Dividend Reinvestment Program.
Except as expressly stated otherwise, the provisions of this Section will only apply if you are enrolled in
Robinhood’s Dividend Reinvestment Program (“DRIP”). Your enrollment in the DRIP will be activated
within three Business Days after you notify Robinhood of your intention to enroll an eligible security
through the Platform. “Eligible Security” means all shares available for fractional investing through
Robinhood. You understand that in order to be eligible for dividend reinvestment, the securities must be
held in your Account.
You may specify individual securities or have all Eligible Securities in your Account enrolled for
dividend reinvestment. If you choose to reinvest dividends from all Eligible Securities, you understand
that individual securities could subsequently no longer be Eligible Securities at Robinhood’s discretion
or under applicable law. In those cases, only those securities will be discontinued from the DRIP. If you
specify individual securities, you may add additional Eligible Securities to the DRIP at any time if you
hold a position in those securities. Enrollment with respect to these additional Eligible Securities will be
effective within three Business Days after Robinhood receives notification from you through the
Platform. If you maintain open orders for securities you do not already hold, you may not enroll those
securities for dividend reinvestment until your open orders are executed. If your entire Account is set up
for dividend reinvestment, any Eligible Securities you purchase in the future will automatically
participate in the DRIP.
As described below, Eligible Cash Distributions will be reinvested in securities you have selected in the
DRIP, provided that you owned the securities on the record date for determining shareholders eligible
to receive dividends, and continue to hold the securities through the payable date. “Eligible Cash
Distributions” means most cash distributions, including regular and optional dividends, cash-in-lieu
payments, and capital gains distributions. Special dividends, late ex-date, liquidation, and
miscellaneous payments may not be eligible distributions. If an Eligible Cash Distribution is reversed
and/or modified, it may not be reinvested. Optional dividends will be processed in accordance with
dividend reinvestment instructions. Robinhood is permitted to borrow a dividend paying stock in the
normal course of business under certain circumstances and, as a result, in such situations instead of a
dividend payment you may receive a cash in lieu payment. If you receive a cash in lieu payment, you
authorize Robinhood to treat such payment as if it was not “in lieu” and reinvest it accordingly.
Robinhood will credit your Account upon completion of the dividend reinvestment. Robinhood will
reinvest dividends on the Business Day following receipt of funds. In the rare instance in which
Robinhood is unable to reinvest all dividends on the Business Day following receipt, it may reinvest the
remaining funds as soon as reasonably possible thereafter, which may take up to five Business Days.
You will not have use of the funds prior to reinvestment.
You understand that your participation in the DRIP is voluntary and that Robinhood has not made any
recommendation that you should participate. You further understand that Robinhood is not
recommending or offering any advice regarding the purchase of any security included as an Eligible
Security in the DRIP. You further understand that dividend reinvestment does not assure profits on
your investments, nor does it protect against losses in declining markets. Robinhood does not intend to
charge a fee for transactions executed pursuant to the DRIP.
You may terminate your participation in the DRIP, or the enrollment of individual securities in the
DRIP, at any time by giving notice through the Platform. Termination will take effect prior to the next
Eligible Cash Distribution provided your notice to terminate was received at least three Business Days
prior to the record date of that distribution. You understand that your notice to terminate your
participation in the DRIP will not affect any obligations that may result from transactions initiated prior to
Robinhood’s receipt and processing of your notice.
Orders to invest in a security pursuant to your instructions provided in connection with your participation
in the DRIP generally will be routed as dollar-based orders by Robinhood Financial to the BOE. The
BOE will aggregate the orders it receives in a given security on a given day in connection with the
DRIP into one or more bulk orders. Each bulk order may represent orders from multiple customers. The
BOE will convert each bulk order to one or more share-based child orders that the BOE will route to the
market for execution. Robinhood Securities will allocate executions received by the BOE to customers
on a riskless principal basis. The allocations may include Fractional Shares, rounded to six decimal
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places. If the BOE routes multiple child orders to execute a single bulk order, each customer order
represented by the bulk order will receive a share allocation based on the weighted average price per
share of the child order executions. If a bulk order is not fully executed, the customers whose orders
are represented by the bulk order will be refunded the dollar amount corresponding to the unfilled
portion of the bulk order on a pro rata basis. Robinhood Financial will deem each order that it routes to
the BOE to be a not held order, i.e., an order with respect to which the customer has granted
Robinhood Financial discretion with respect to the price and time of execution.
If you participate in the DRIP and the BOE is not utilized (because, e.g., the BOE is not available), you
understand Robinhood will reinvest the dividends of a particular stock at or near the opening price on
the trading day following receipt of the dividend. Robinhood will combine Eligible Cash Distributions
from your Account with those from other Robinhood clients requesting dividend reinvestment in the
same security and use these combined funds to purchase securities on your behalf and on behalf of
these other clients. If the combined reinvested funds do not total the purchase price of at least one
share, the distribution will be invested in Fractional Shares. On that same day, Robinhood will credit
your Account with that number of shares, including Fractional Shares, equal to your Eligible Cash
Distribution divided by the purchase price per share.
Dividend reinvestment may result in your owning interests in Fractional Shares of a security. You will
be entitled to receive future dividend payments on your Fractional Shares, although other corporate
actions may result in allocation of only whole shares and cash in lieu of Fractional Shares as
determined by the issuer. In mandatory corporate reorganizations, your partial interest will be handled
according to the specific terms of the reorganization. In voluntary corporate reorganizations, Robinhood
will act on your instructions with respect only to your whole shares.
Because Fractional Share positions cannot be transferred, reorganized, or issued in certificate form,
your partial interest will be liquidated, without commission charges to you, at prevailing market prices in
the event your Account is transferred or closed, the stock is reorganized, or stock certificates are
ordered out of your Account. The timing of such liquidations will be at the discretion of Robinhood.
Reinvestment of dividends may result in your owning a Fractional Share position in securities that are
callable in part. In the event of a call, Fractional Shares to be called will be determined through a
random selection process. The probability of your fractional share holdings being called will be
proportional to the holdings of all Robinhood clients who own a fractional share position in that security.
Prior to the publication date of such a call, you have the right to withdraw from your Account cash in
lieu of your uncalled, fully paid partial holdings. Once a call is announced, however, all shares, whether
registered or held in street name, participate in the random selection process. If your Fractional Shares
are selected and you no longer hold the shares that you held on the publication date of the call, you will
be responsible for covering those shares.
24. Recurring Investments
Except as expressly stated otherwise, the provisions of this Section will only apply if you are enrolled in
Robinhood’s Recurring Investments (“RI”). As it relates to this Section, “Recurring Eligible Security”
means all shares available for fractional investing through Robinhood that Robinhood supports for
Recurring Investments.
Robinhood will process RI orders on the schedule that you choose for a Recurring Eligible Security. If
Robinhood is unable to process an RI order on the specified day, it will process the order as soon as
reasonably possible thereafter, which may take up to five Business Days. If your RI order falls on a day
that the market is closed, like a weekend or holiday, it will be scheduled for the next trading day. On
partial market holidays, recurring orders will process earlier in the day to accommodate for the early
market close.
You understand that your participation in RI is voluntary and that Robinhood has not made any
recommendation that you should participate. You further understand that Robinhood is not
recommending or offering any advice regarding the purchase of any security included as a Recurring
Eligible Security in RI. You further understand that recurring investment does not assure profits on your
investments, nor does it protect against losses in declining markets.
20
You may delete your recurring investments at any time by giving notice through the Platform. Deleting
a recurring investment will take effect prior to the next scheduled RI order, unless the request to
delete is made fewer than two Business Days prior to the next recurring investment, in which case the
request to delete will take effect prior to the following RI order. If the Platform makes this option
available, you may also pause or skip a specific RI order. You understand that your notice to delete
recurring investments will not affect any obligations that may result from transactions initiated prior to
Robinhood’s receipt and processing of your notice.
Orders to invest in a security pursuant to your instructions provided in connection with your
participation in RI generally will be routed as dollar-based orders by Robinhood Financial to the
BOE. The BOE will aggregate the orders it receives in a given security on a given day in connection
with RI into one or more bulk orders. Each bulk order may represent orders from multiple customers.
The BOE will convert each bulk order to one or more share-based child orders that the BOE will route
to the market for execution. Robinhood Securities will allocate executions received by the BOE to
customers on a riskless principal basis. The allocations may include Fractional Shares, rounded to six
decimal places. If the BOE routes multiple child orders to execute a single bulk order, each customer
order represented by the bulk order will receive a share allocation based on the weighted average
price per share of the child order executions. If a bulk order is not fully executed, the customers
whose orders are represented by the bulk order will be refunded the dollar amount corresponding to
the unfilled portion of the bulk order on a pro rata basis. Robinhood Financial will deem each order
that it routes to the BOE to be a not held order, i.e., an order with respect to which the customer has
granted Robinhood Financial discretion with respect to the price and time of execution.
If you participate in RI and the BOE is not utilized (because, e.g., the BOE is not available), you
understand Robinhood will place an order in the amount specified. RI orders will typically be processed
between 12:00 PM ET and market close on the scheduled date. Robinhood may combine RI orders
from your Account with those from other Robinhood customers requesting recurring investments in the
same security and use these combined funds to purchase securities on your behalf and on behalf of
these other customers. If the combined investing funds do not total the purchase price of at least one
share, the funds will be invested in Fractional Shares. On that same day, Robinhood will credit your
Account with that number of shares, including Fractional Shares, equal to your recurring investment
divided by the purchase price per share.
RI orders may result in your owning interests in Fractional Shares of a security. You will be entitled to
receive future dividend payments on your Fractional Shares, although other corporate actions may
result in allocation of only whole shares and cash in lieu of fractions as determined by the issuer. In
mandatory corporate reorganizations, your partial interest will be handled according to the specific
terms of the reorganization. In voluntary corporate reorganizations, Robinhood will act on your
instructions with respect only to your whole shares.
Because fractional share positions cannot be transferred, reorganized, or issued in certificate form,
your partial interest will be liquidated, without commission charges to you, at prevailing market prices in
the event your Account is transferred or closed, the stock is reorganized, or stock certificates are
ordered out of your Account. The timing of such liquidations will be at the discretion of Robinhood.
Recurring investments may result in you owning a fractional share position in securities that are
callable in part. In the event of a call, Fractional Shares to be called will be determined through a
random selection process. The probability of your fractional share holdings being called will be
proportional to the holdings of all Robinhood customers who own a fractional share position in that
security. Prior to the publication date of such a call, you have the right to withdraw from your Account
cash in lieu of your uncalled, fully paid partial holdings. Once a call is announced, however, all shares,
whether registered or held in street name, participate in the random selection process. If your
Fractional Shares are selected and you no longer hold the shares that you held on the publication date
of the call, you will be responsible for covering those shares.
25. Disclosure of Information.
You agree and understand that all disclosures of your non-public personal information shall be made in
accordance with the terms of this Agreement or the Robinhood Privacy Policy (available in the
Disclosure Library), as applicable. You agree that your consent to sharing certain types of non-public
personal information will remain in effect until you revoke such consent by updating your settings.
21
In addition, you understand and agree that Robinhood may disclose information about your Account
and your related activities to third parties under the following circumstances: (i) As necessary to
complete your Payment transactions; (ii) to investigate any complaint, disputed transaction, transaction
inquiry, or request you make or as necessary to investigate potential fraud, money laundering, or other
misuse related to your Account; (iii) to respond to requests from credit bureaus, creditors, or other third
parties for account-related information, to the extent such inquiries are necessary for processing your
transactions or are usual and customary in the course of servicing similar products or accounts; (iv) as
necessary to comply with any applicable law, regulation, government, or court order or subpoena; or (v)
in accordance with your written permission or as otherwise permitted under the Robinhood Privacy
Policy.
26. Deposits.
26.1. General; Holds.
You acknowledge and agree that funds that you deposit to your Account may be subject to one or
more hold periods, which are described in the RHF Funds Availability schedule available in the
Disclosure Library. You understand and agree that Robinhood reserves the right to modify the RHF
Funds Availability schedule at any time by posting an updated schedule in the Disclosure Library or
otherwise providing notice to you. During the applicable hold period, your funds will not be available
for Payments, withdrawal, or the settling of securities transactions, in each case as described in the
RHF Funds Availability schedule. You further understand and agree that Robinhood reserves the right
to further delay making deposited funds available for periods longer than the hold periods specified in
the RHF Funds Availability schedule to the extent Robinhood determines that additional time is
needed to verify information about the item deposited or the sender or if Robinhood otherwise
believes there is a risk of fraud or other unlawful activity with respect to your Account.
26.2. Mistaken Deposits.
If funds are deposited or transferred into your Account by mistake or otherwise, you agree that
Robinhood may correct the situation and deduct any interest paid by Program Banks (as such term is
defined in Section 27), if applicable, without prior notice to you.
26.3. Returned Funds.
You acknowledge and agree that you are responsible for returned transactions. If you have funds
transferred into your Account and that transfer is returned for any reason, Robinhood may charge the
transfer and interest paid by Program Banks, if applicable, against your Account, without prior notice to
you.
27. Brokerage Cash Sweep Program.
If you enroll in the IntraFi Network Deposit (“IND”) Sweep Program (the “Brokerage Cash Sweep
Program”) you understand that the free credit balances in your Account will be deposited into interest-
bearing accounts at one or more banks (“Program Banks”), in accordance with the IntraFi Network
Deposit Sweep Program Agreement (“IND Disclosures”) available in the Disclosure Library and on the
Platform. By enrolling in the Brokerage Cash Sweep Program, you represent and warrant that you have
reviewed the IND Disclosures and agree to the terms set forth in the IND Disclosures. If you are not
enrolled in the Brokerage Cash Sweep Program, free credit balances in your Account will remain in your
Account, will not earn interest and will not be eligible for FDIC insurance, but will be eligible for SIPC
protection as described in the IND Disclosures. You understand that Robinhood may terminate your
participation in the Brokerage Cash Sweep Program for any reason, upon notice to you.
28. Consent to Redeem Shares.
You understand and agree that whenever it is necessary for Robinhood’s protection or to satisfy a
margin call, deficiency, debit or other obligation owed to Robinhood, Robinhood may (but is not
required to) sell, assign and deliver all or any part of the securities in your Account, or close any or all
transactions in your Account. You understand that Robinhood may, but is not obligated to, attempt to
contact you before taking any such action. You understand and agree that Robinhood reserves the
22
right to take any such action without prior notice or demand for additional collateral, and free of any
right of redemption, and that any prior demand, call or notice will not be considered a waiver of our right
to sell or buy without demand, call or notice.
You further understand that Robinhood may choose which securities to buy or sell, which transactions
to close, and the sequence and timing of liquidation, and may take such actions on whatever exchange
or market and in whatever manner (including public auction or private sale) that Robinhood chooses in
the exercise of its business judgment. You agree not to hold Robinhood liable for the choice of which
securities to buy or sell or of which transactions to close or for the timing or manner of the liquidation.
You also agree not to hold Robinhood liable for taking such action.
You understand and agree that Robinhood is entitled to exercise the rights described in this Section in
its sole discretion, including, but not limited to, whenever any of the following occurs:
• The equity level in your Account falls below required minimums;
• Sufficient funds or securities are not deposited to pay for transactions in your Account;
• You reverse any ACH debit transfer to your Account;
• A petition of bankruptcy or for the appointment of a receiver is filed by or against you;
• An attachment is levied against your Account;
• You die or become incapacitated or incompetent; or
• Your Account is closed.
29. API.
29.1. Overview; Definitions.
Robinhood may, in Robinhood’s sole discretion, provide third parties with an application programming
interface and other materials in accordance with any accompanying documentation (collectively, the
“API Package”) (such third parties, “API Licensees”), to make available certain features and
functionality of Robinhood’s mobile applications, websites, or technology platform via the API
Licensees’ products (such products, the “Licensee Products”). The API Package and the Licensee
Products are collectively referred to as the “API Products”. You may not use the API Package or
develop Licensee Products without Robinhood’s express written consent (and Robinhood may decline
any such request for use or development in its sole discretion).
29.2. Access to Your Personal Information.
Through your use of any API Products, you may be providing API Licensees with access to your
Account and Personal Information. “Personal Information” means any information that identifies,
describes, or is capable of being associated with an individual (including username, logon password,
financial information, trade data, and other financial information). By using any API Products, you
acknowledge that such API Products may employ security, policies, procedures, and systems of API
Licensees which may or may not be less stringent and secure than Robinhood’s. You agree that your
use of any API Products shall be subject to this Agreement, in addition to any other agreements which
you executed with respect to any such API Products. You understand and agree that any end user
agreement that you executed with any API Licensee is concluded between you and such API Licensee
only, and not with Robinhood; and such API Licensee, not Robinhood, is solely responsible for such
Licensee Product and the content thereof. You understand and agree that the API Products may
deliver Personal Information to Robinhood, and that Robinhood is authorized to receive and store such
Personal Information consistent with Robinhood’s then-in-effect policies and procedures. Further, you
agree that the API Products may request Personal Information stored by Robinhood, and you consent
to Robinhood’s disclosure of such Personal Information to the API Products.
29.3. No Recommendations.
To the extent the Licensee Products or API Licensees express opinions or make recommendations,
you understand that such opinions and recommendations are expressed solely by API Licensees and
are not the opinions or recommendations of Robinhood. The existence of any API Products and
Robinhood’s consent to any connectivity between any Licensee Products and Robinhood’s technology,
the Platform, or trading platform(s) does not constitute (i) any recommendation by Robinhood to invest
in any security or utilize any investment strategy; or (ii) any representation, warranty, or other
23
guarantee by Robinhood as to the present or future value or suitability of any sale, trade, or other
transaction involving any particular security or any other investments. The existence of any and all
information, tools and services provided by API Licensees or by the Licensee Products shall not
constitute Robinhood’s endorsement of API Licensees or the Licensee Products.
29.4. Data Provided by Robinhood to API.
From time to time, and subject to then-in-effect agreements between Robinhood and API Licensees,
Robinhood may, in its own discretion, make market data feeds received from third parties available via
the API Products. Robinhood does not make any guarantees in regard to such market data feeds.
Furthermore, API Licensees or Licensee Products may make available to you market data feeds
independent of Robinhood. You acknowledge that from time to time that there may be discrepancy
between the market data presented on the Platform and information provided by any API Products due
to a variety of reasons, including the time to update and transmit such data to a mobile application or
website and latency caused by such API Product’s or your local environment (such as computer set up,
connection speed, etc.). Robinhood is not responsible for the accuracy of any market data displayed on
any API Products or otherwise made available by API Licensees.
29.5. Risks; No Liability.
You acknowledge that there may be latency between the time an order (or other Personal Information)
is submitted from the API Products and the time such order or Personal Information is received by
Robinhood. Latency may also affect order modification and order cancellation requests. The time an
order or a request is actually received by Robinhood (including for execution) will be the official time,
including for the purposes of routing the order to the market for execution. In addition, all orders
submitted to Robinhood are subject to order vetting by Robinhood. Orders created and submitted
through any API Products are not vetted until they are received by Robinhood. It is possible that
Robinhood may reject an order placed through any API Products. Robinhood cannot guarantee that
any order will be accepted when such order is routed to the market for execution, and Robinhood
cannot guarantee that notifications and Personal Information provided to you by Robinhood will be
successfully delivered to or displayed by any API Products.
Without limiting the generality of any other terms in this Agreement, you agree that:
(a) Robinhood or its Affiliates shall not be liable for any Losses as a result of any issues addressed
in this Section, nor shall Robinhood or its Affiliates be liable for any Losses realized for technical
issues involving any API Products or API Licensee technology or product offerings (including
system outages or downtime).
(b) Robinhood or its Affiliates shall not be responsible for any investment research provided by any
API Licensee or any Licensee Products.
(c) Robinhood or its Affiliates makes no representations, warranties or other guarantees as to the
accuracy, timeliness or efficacy of any market data, information, or other functionality made
available by any API Licensee or any API Products.
29.6. Intellectual Property.
Your use of any API Products will not confer to you any title, ownership interest, or intellectual property
rights that otherwise belongs to Robinhood or any of its affiliates. The API Package, including content,
is protected under U.S. patent, copyright laws, international treaties or conventions, and other laws and
will remain Robinhood’s exclusive property, as applicable. Names, logos, and all related product and
service names, design marks, and slogans displayed by or relating to Robinhood or any of its Affiliates
or API Licensees in the context of the API Products shall remain the property of the respective owner,
and use of such property by Robinhood or any API Licensee in marketing or provision of any API
Products does not grant ownership of or entitle you to use any such name or mark in any manner.
29.7. Customer API Representations and Warranties.
You represent and warrant that:
(a) By virtue of utilizing any API Products, you consent to and accept any risk associated with
24
Robinhood’s sharing of Personal Information with any API Licensee and shall not hold Robinhood,
its Affiliates, or their respective officers, directors, or employees responsible for any Losses
resulting from the sharing of such Personal Information.
(b) You agree that your use of any API Products or API Licensee’s content, information, technology,
or functionality is at your own risk.
(c) You agree that Robinhood may revoke any API Licensee or API Products’ authorization at any
time, for any reason, with or without cause and without prior notice to you.
30. Electronic Signatures; Modifications to the Agreement.
You agree to transact business with Robinhood electronically. By electronically signing an application
for an Account, you acknowledge and agree that such electronic signature is valid evidence of your
consent to be legally bound by this Agreement and such subsequent terms as may govern the use of
Robinhood’s services. The use of an electronic version of any document fully satisfies any requirement
that the document be provided to you in writing. You accept notice by electronic means as reasonable
and proper notice, for the purpose of any and all laws, rules and regulations. You acknowledge and
agree that Robinhood may modify this Agreement from time to time and you agree to consult the
Website from time to time for the most up-to-date Agreement. The electronically stored copy of this
Agreement is considered to be the true, complete, valid, authentic and enforceable record of the
Agreement, admissible in judicial or administrative proceedings to the same extent as if the documents
and records were originally generated and maintained in printed form. You agree to not contest the
admissibility or enforceability of Robinhood’s electronically stored copy of the Agreement.
31. Margin Accounts; Margin.
This Section applies to your Account to the extent you elect and are approved for a margin account
(each, a “Margin Account”).
31.1. Margin Account
Any margin extended to you in connection with your Account is provided by Robinhood Securities.
You understand that you are liable for the full amount of funds borrowed in your Margin Account and
will be liable to repay this amount in full on demand.
31.2. Margin Risks.
Margin Accounts are not necessarily appropriate for everyone. Nothing in this Agreement, any
application, or any communication or other statement by Robinhood or its Representatives constitutes
any form of recommendation to open a Margin Account or make any specific investment or strategy.
You understand that margin trading involves interest charges and risks, including the potential to lose
more than deposited or the need to deposit additional collateral in a falling market. Before applying for
a Margin Account and before using margin, you must determine whether this type of account or trading
strategy is right for you given your specific investment objectives, experience, risk tolerance, and
financial situation.
If you have, or have applied or elected to have, a Margin Account, you represent that you have
read and understand the Margin Disclosure Statement, Day Trading Risk Disclosure, and FINRA
Investor Information and that you fully understand the risks involved in borrowing margin and
trading securities on margin. These disclosures contain information on Robinhood’s lending
policies, interest charges, and certain risks associated with Margin Accounts.
31.3. Hypothecation.
Within the limitations imposed by applicable laws, rules and regulations, all securities now or hereafter
held by Robinhood, or carried by Robinhood in any account for you (either individually or jointly with
others), or deposited to secure same, may from time to time, without any notice, be carried in your
general loans and may be pledged, repledged, hypothecated or re-hypothecated, separately or in
common with other securities for the sum due to you thereon or for a greater sum and without retaining
in your possession or control for delivery a like amount of similar securities. The IRS requires Broker
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Dealers to treat dividend payments on loaned securities positions as payments received in lieu of
dividends for 1099 tax reporting purposes. Taxation of substitute dividend payments may be greater
than the rate of taxation on qualified dividends. It is understood, however, that you agree to deliver to
you upon your demand and upon payment of the full amount due thereon, all securities in such
accounts, but without obligation to deliver the same certificates or securities deposited by you
originally. Any securities in your margin or short account may be borrowed by you, or lent to others.
31.4. Interest.
Debit balances in your Account shall be charged with interest in accordance the Margin Disclosure
Statement (available in the Disclosure Library).
31.5. Margin Requirements.
You agree to maintain in your Account with Robinhood such positions and margin as required by all
applicable statutes, rules, regulations, procedures and custom, or as Robinhood deems necessary or
advisable. You agree to promptly satisfy all margin and maintenance calls.
31.6. Breach; Security Interest
Whenever in its discretion Robinhood Securities considers it necessary for Robinhood’s or your
protection or in the event of, but not limited to; (i) any breach by you of this or any other agreement with
Robinhood or its Affiliates or (ii) your failure to pay for securities and other property purchased or to
deliver securities and other property sold, Robinhood Securities may sell any or all securities and other
Property held in any of your Accounts or accounts held with any of our Affiliates (either individually or
jointly with others), cancel or complete any open orders for the purchase or sale of any securities and
other Property, or borrow or buy any securities and other Property required to make delivery against any
sale, including a short sale, effected for you, all without notice or demand for deposit of collateral, other
notice of sale or purchase, or other notice or advertisement, each of which you expressly waive, and
Robinhood Securities may require you to deposit cash or adequate collateral to your Account prior to any
settlement date in order to assure the performance or payment of any open contractual commitments or
unsettled transactions. Robinhood has the right to refuse to execute securities transactions for you at
any time and for any reason.
Any and all securities and other Property now or hereafter held, carried or maintained by Robinhood in or
for any of your Accounts(either individually or jointly with others), now or hereafter opened, including any
accounts in which you may have an interest, shall be subject to a first and prior lien and security interest
for the discharge of all of your Obligations to Robinhood, whenever or however arising and without
regard to whether or not Robinhood have made advances with respect to such securities and other
Property, and Robinhood Securities is hereby authorized to sell or purchase any and all securities and
other Property in any of your Accounts, or to transfer any such securities and other Property among any
of your Accounts, to the fullest extent allowed by law and without notice where allowed by law.
Robinhood shall have the right to transfer securities and other Property so held by Robinhood from or to
any other of your Accounts whenever Robinhood so determines.
31.7. Liquidation
In the event of your death, or in the event the margin in any account in which you have an interest shall
in either Robinhood Securities’ or Robinhood Financial’s discretion become unsatisfactory or be
deemed insufficient, Robinhood is hereby authorized; (a) to sell any or all securities or other Property
which Robinhood may hold for you (either individually or jointly with others); (b) to buy any or all
securities and other Property which may be short in such accounts; or (c) to cancel any open orders
and to close any or all outstanding contracts; all without demand for margin or additional margin, notice
of sale or purchase, or other notice or advertisement, and that any prior demand or notice shall not be
a waiver of Robinhood’s rights provided herein. Robinhood Securities may likewise accept and rely
upon instructions which Robinhood Securities receives from Robinhood Financial to take, make, or
effect any of the aforementioned actions or transactions. Robinhood Securities shall have the discretion
to determine which securities and other Property are to be sold and which orders or contracts are to be
closed. Any such sales or purchases may be made at Robinhood’s discretion on any exchange, the
over-the-counter market or any other market where such business is usually transacted, or at public
auction or private sale, and Robinhood Securities may be the purchaser for its own account.
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31.8. Payment of Indebtedness Upon Demand; Right of Offset.
You shall at all times be liable for the payment upon demand of any Obligations owing from you to
Robinhood, and you shall be liable to Robinhood for any deficiency remaining in any such accounts in
the event of the liquidation thereof (as contemplated in this Section or otherwise), in whole or in part, by
Robinhood or by you; and you shall make payment of such Obligations upon demand. You authorize
Robinhood to recover amounts you owe, and to debit, charge or otherwise exercise a right of offset to
recover funds from the balance in your Account, your external bank account, any Account you own with
an Affiliate of Robinhood, or any other payment instrument linked to your Account. This authorization
and/or right of offset shall survive termination of your Account and this Agreement. If Robinhood’s
attempt to recover funds is not successful, you agree that the authorization and/or right of offset
hereunder includes a grant to Robinhood of any additional authorizations and/or rights of offset required
to recover the amount you owe to Robinhood in complete compliance with any applicable laws, rules or
industry regulations. Robinhood may take these actions without prior notice to you.
31.9. Sales/Short Sales.
You promise to deliver all securities sold in your Account and to provide collateral of a type and
amount acceptable to Robinhood for all short sales in your Account. Robinhood requires that a
security be held in your Account prior to the acceptance of a sell order with respect to such security
unless the order is specifically designated as a “short sale.” If a security is not held in your Account
and a sell order is processed, you must promptly deliver such security to Robinhood for receipt in
good deliverable form on or before the settlement date. Any order accepted without negotiable
certificates or positions in your Account will be subject, at Robinhood’s sole discretion, to
cancellation or buy-in. To ensure this will not occur, you agree to only place sell orders for securities
owned by you and held in your Account at the time your order is placed.
Proceeds of a sale will not be paid to you or released into your Account until Robinhood has received
the security in good deliverable form, whether from a transfer agent or from you and the settlement of
the security is complete. If the security is not received on or before settlement date, or as market
conditions warrant, Robinhood may in its sole discretion purchase the security on the open market for
your Account and may liquidate and close out any and all securities in your Account in order to pay for
such purchase. In the event a security is bought in, you will be responsible for all resulting Losses
incurred by Robinhood.
You understand that you may execute short sales only in a margin Account and that such execution
must comply with applicable short sales rules. You agree to specifically designate any order to sell a
security, which you do not own as a short sale, and understand that Robinhood will mark such order as
a short sale. You agree that any order which is not specifically designated as a short sale is a sale of
securities owned by you, and that you will deliver the securities on or before settlement date, if not
already in the account. If you should fail to make such delivery in the time required, Robinhood is
authorized to borrow such securities as necessary to make delivery for the sale, and you agree to be
responsible for any loss you may thereby sustain, or which you may sustain as a result of your inability
to borrow such securities.
Stock Borrow Fees for Short Selling: You also understand that Robinhood Securities may charge you
fees associated with borrowing stocks as a result of short selling. If you have an open short position in
your Account, whether it is established through short selling, option exercise or assignment, account
transfer, or otherwise, Robinhood Securities can charge a Stock Borrow Fee. The fee is calculated as the
end of day short market value, multiplied by the quoted interest rate, divided by 360. This Stock Borrow
Fee is subject to change on a daily basis and can be charged as long as you hold the open short
position. The daily fees will be aggregated on a monthly basis and will appear on your account
statement. The interest rate charged will vary depending on the supply and demand for the particular
security in the securities lending market. You understand that Robinhood Securities can seek to charge
you any rate consistent with Robinhood Securities’ view of competitive necessities.
31.10. Costs of Collection
Without limitation to any other indemnities in this Agreement, all Losses, including but not limited to
reasonable attorneys’ fees and expenses, incurred and payable or paid by Robinhood in the (i)
collection of a debit balance or any unpaid deficiency in any of your Accounts with Robinhood or (ii)
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defense of any matter arising out of your securities transactions, shall be payable to Robinhood by
you.
31.11. Pattern Day Trader
Robinhood Financial will monitor trading activities and alert or restrict those customers at risk of
qualifying as “pattern day traders.” A pattern day trader, as defined under FINRA Rule 4210(f)(8)(B), is
any customer who executes four or more day trades within five Business Days, provided the number of
day trades is more than six percent of the total trades in the account during that period. All Accounts
designated as a pattern day trading accounts will be required to maintain $25,000 equity at all times in
order to continue day trading. It is important that you fully understand the risks involved in day trading
securities, as described in the Day Trading Risk Disclosure.
32. Extended Trading Hours
In certain circumstances, you may be able to engage in Extended Hours trading, meaning, for purposes
of this section, trading outside of the regular trading hours of 9:30 a.m. and 4:00 p.m. Eastern. This
ability may be limited to certain account types or other eligibility criteria, and the order types available
for Extended Hours trading may be limited. You may not execute Extended Hours trades in an IPO on
its first day of trading. There are unique risks to Extended Hours trading and by participating in this type
of trading, you are deemed to understand and agree to accept such risks, including those set out in the
Extended Hours Trading Disclosure available in the Disclosure Library. If any terms of the Extended
Hours Trading Disclosure conflict with any terms of this Agreement, the terms of this Agreement will
control.
33. Phone Calls.
You agree that, by providing information Robinhood requests, opening or applying to open, or
maintaining an Account, or by downloading any App, Robinhood and its third-party service providers,
including third-party debt collection agencies, may contact you either (i) via mail, phone, or email, or
other details you have provided, or (ii) via any other form of electronic or other communications facility
available via the Platform or a third party service provider such as “chat”, “voice”, or messaging
functionality.
Specifically, if you provide us with a phone number: (a) you represent and warrant that the number
you provide is your phone number, and you will promptly notify us if that changes, and (b) you
consent to receive calls (including text messages) at any time of day made to that phone number that
may be prerecorded or completed with an automatic telephone dialing system (automated calls) for
purposes including but not limited to providing account-related communications (including security
alerts), telemarketing, investigating or preventing fraud, or collecting amounts owed to Robinhood. We
may share your number with third parties that provide services to us in connection with any of the
foregoing purposes, including but not limited to debt collectors. You understand that message,
telephone minute and data rates may apply for calls made to a mobile phone number. You may opt
out at any time from receiving these types of calls orally or in writing to [email protected].
Please note, even if you opt out, we may still make other calls as permitted by law.
34. Consent to Electronic Delivery of Documents.
34.1. Consent.
By agreeing to electronic delivery, you are giving your informed consent to electronic delivery
of all Account Documents. “Account Documents” include notices, disclosures, current and future
account statements, regulatory and shareholder communications (such as prospectuses, proxy
solicitations, and privacy notices), trade confirmations, tax-related documents, and any other
information, documents, data, and records regarding your Account, this Agreement (including
amendments to this Agreement), and the agreements and disclosures governing the services
delivered or provided to you by Robinhood, the issuers of the securities or other property in which you
invest, and any other parties. You agree that you can access, view, download, save, and print any
Account Documents you receive via electronic delivery for your records.
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34.2. Electronic Delivery System.
You acknowledge that Robinhood’s primary methods of communication with you include (A) posting
information on the Website, (B) providing information via the App, (C) sending email(s) to your email
address of record, and (D) to the extent required by law, providing you with notice(s) that will direct you
to the Platform where you can read and print such information. Unless otherwise required by law,
Robinhood reserves the right to post Account Documents on the Website without providing notice to
you. Further, Robinhood reserves the right to send Account Documents to your postal or email address
of record, or via the Platform. You agree that all Account Documents provided to you in any of the
foregoing manners are considered delivered to you personally when sent or posted by Robinhood,
whether you receive it or not.
All email notifications regarding Account Documents will be sent to your e-mail address of record. You
agree to maintain the email address that you have provided Robinhood until you provide Robinhood
with a new one. You agree that Robinhood may send email communications to you at any time of day,
without restriction. You understand that email messages may fail to transmit promptly or properly,
including being delivered to SPAM folders. You further understand that it is your sole responsibility to
ensure that any emails from Robinhood or its Affiliates are not marked as SPAM. If a notification cannot
be delivered to you because you failed to maintain a valid and/or deliverable email address with
Robinhood, such notification will be sent to you via postal mail for a fee, as described in Section 34.3,
below, and in the Fee Schedule. Regardless of whether or not you receive an email notification, you
agree to check the Website regularly to avoid missing any information, including amendments or
supplements to this Agreement, or time-sensitive or otherwise important communications. If you
authorize someone else to access the email account you have provided Robinhood, you agree to tell
them to share the Account Documents with you promptly, and you accept the risk that they will see
your sensitive information. You understand that if you use a work email address or computing or
communications device, your employer or other employees may have access to the Account
Documents.
Additionally, you acknowledge that the Internet is not a secure network and agree that you will not send
any confidential information, including Account numbers or passwords, in any unencrypted emails. You
also understand that communications transmitted over the Internet may be accessed by unauthorized
or unintended third parties and agree to hold Robinhood, its Affiliates, and Robinhood and its Affiliates’
respective officers and employees harmless for any such access regardless of the cause.
You agree to promptly and carefully review all Account Documents when they are delivered and notify
Robinhood Financial in writing within five days of delivery if you object to the information provided (or
other such time specified therein). If you fail to object in writing within such time, Robinhood is entitled
to treat such information as accurate and conclusive. You will contact Robinhood to report any problems
with accessing the Account Documents.
34.3. Costs and Fees.
Potential costs associated with electronic delivery of Account Documents may include charges from
Internet access providers and telephone companies, and you agree to bear these costs. Robinhood
Financial will not charge you additional online access fees for receiving electronic delivery of Account
Documents.
Additionally, if you fail to maintain a valid and/or deliverable email address of record on your Account,
Robinhood reserves the right to charge you a fee for certain documents that must be re-delivered via
postal mail. You will incur such fee for each instance of postal mail delivery until such time as you
update your email address. The types of Account Documents that are subject to these fees and the
current fee amounts are detailed in the Fee Schedule. You agree that Robinhood may deduct these
fees from your Account consistent with the terms of this Agreement, including but not limited to the
provisions in Section 28 of this Agreement.
34.4. Archival.
Upon your request, you may obtain electronic copies of account statements and trade confirmations,
subject to availability.
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34.5. Revocation of Consent.
Consent to electronic delivery of documents is required to establish and maintain an Account with
Robinhood Financial. Subject to the terms of this Agreement, you may revoke or restrict your consent
to electronic delivery of Account Documents at any time by notifying Robinhood Financial in writing of
your intention to do so. However, you understand that if you revoke or restrict your consent to
electronic delivery of Account Documents, Robinhood Financial has the right to restrict and/or close
your Account, and terminate your access to Robinhood’s services. Robinhood may elect to deliver
Account Documents by other means, including paper delivery via postal mail, which will not revoke or
otherwise affect your consent. You understand that neither your revocation or restriction of consent nor
Robinhood Financial’s delivery of paper copies of Account Documents will affect the legal effectiveness
or validity of any electronic communication provided while your consent was in effect.
34.6. Duration of Consent.
Your consent to receive electronic delivery of Account Documents will be effective immediately and will
remain in effect unless and until either you or Robinhood Financial revokes it. You understand that it
may take up to three Business Days to process a revocation of consent to electronic delivery, and that
you may receive electronic notifications until such consent is processed.
34.7. Hardware and Software Requirements.
You understand that in order to receive electronic deliveries, you must have access to a computer or
Mobile Device with Internet access, a valid e-mail address, and the ability to download such
applications as Robinhood Financial may specify and to which you have access. You also understand
that if you wish to download, print, or save any information you wish to retain, you must have access to
a printer or other device in order to do so.
34.8. Consent and Representations.
You hereby agree that you have carefully read the above information regarding informed consent to
electronic delivery and fully understand the implications thereof. Additionally, you hereby agree to all
conditions outlined above with respect to electronic delivery of any Account Document. You will
maintain a valid email address and continue to have access to the Internet. If your email address
changes, you agree to immediately notify Robinhood Financial of your new email address in writing.
35. Recording and Monitoring of Communications.
You understand and agree that Robinhood or our third-party service providers acting on our behalf may
record and monitor any telephone or electronic communications with you. Unless otherwise agreed in
writing in advance, Robinhood does not consent to the recording of telephone conversations by any
third party or by you. You acknowledge and understand that not all telephone or electronic
communications are recorded by Robinhood, and Robinhood does not guarantee that recordings of
any particular telephone or electronic communications will be retained or capable of being retrieved.
36. Rule 14b-1(c)
You acknowledge that Rule 14b-1(c) of the Securities Exchange Act, unless you object, requires
Robinhood to disclose to an issuer, upon its request, the names, addresses, and securities positions of
your customers who are beneficial owners of the issuer’s securities held by us in nominee name.
The issuer would be permitted to use your name and other related information for corporation
communication only. If you wish to object, you agree to send an email to support@robinhood.com with
“Rule 14b-1(c) objection” in the subject.
37. Miscellaneous Provisions.
37.1. Contact Information.
Robinhood Customer Service may be contacted by visiting support.robinhood.com or by email at
help@robinhood.com.
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37.2. Interpretation.
The heading of each provision hereof is for descriptive purposes only and shall not be (1) deemed to
modify or qualify any of the rights or obligations set forth herein or (2) used to construe or interpret any
of the provisions hereunder. When a reference is made in this Agreement to a Section, such reference
shall be to a Section of this Agreement unless otherwise indicated. Whenever the words “include,”
“includes” or “including” are used in this Agreement, they shall be deemed to be followed by the words
“without limitation.” The word “or,” when used in this Agreement, has the inclusive meaning
represented by the phrase “and/or.” Unless the context of this Agreement otherwise requires: (i) words
using the singular or plural number also include the plural or singular number, respectively; and (ii) the
terms “hereof,” “herein,” “hereunder” and derivative or similar words refer to this entire Agreement.
References to any law shall be deemed to refer to such law as amended from time to time and to any
rules or regulations promulgated thereunder. References to “days” means calendar days unless
indicated otherwise.
37.3. Binding Effect; Assignment.
This Agreement shall bind your heirs, assigns, executors, successors, conservators and administrators.
You may not assign this Agreement or any rights or obligations under this Agreement without first
obtaining Robinhood’s prior written consent. Robinhood may assign, sell, or transfer your Account and
this Agreement, or any portion thereof, at any time, without your prior consent.
37.4. Severability.
If any provisions or conditions of this Agreement are or become inconsistent with any present or future
law, rule, or regulation of any applicable government, regulatory or self-regulatory agency or body, or
are deemed invalid or unenforceable by any court of competent jurisdiction, such provisions shall be
deemed rescinded or modified, to the extent permitted by applicable law, to make this Agreement in
compliance with such law, rule or regulation, or to be valid and enforceable, but in all other respects,
this Agreement shall continue in full force and effect.
37.5. Website Postings.
You agree and understand that Robinhood may post other specific agreements, disclosures, policies,
procedures, terms, and conditions that apply to your use of the Platform or your Account, on the Website
from time to time including in the Disclosure Library, and that this includes updates or amendments to
this Agreement or other agreements or Risk Disclosures incorporated in or referenced in this Agreement
(“Website Postings”). You understand that it is your continuing obligation to monitor the Website and
the Disclosure Library for Website Postings and to understand the terms of the Website Postings. You
agree to be bound by the Website Postings (and the most current version of this Agreement) as are in
effect at the time of your access or use of the Platform or the giving of any order or instruction relating to
your Account.
37.6. Entirety of Agreement.
This Agreement, any attachments hereto, other agreements and policies referred to in this Agreement
(including the Website Postings and Risk Disclosures), and the terms and conditions contained in your
Account statements and confirmations, contain the entire agreement between Robinhood and you and
supersede all prior or contemporaneous communications and proposals, whether electronic, oral, or
written, between Robinhood and you, provided, however, that any and all other agreements between
Robinhood and you, not inconsistent with this Agreement, will remain in full force and effect.
37.7. Amendment.
Robinhood may at any time amend this Agreement and any other agreement or document incorporated
or referenced in this Agreement without prior notice to you. The current version of the Agreement will
be posted in the Disclosure Library, and your continued Account activity (including accessing the
Platform or submitting an order or instruction) after such amendment constitutes your agreement to be
bound by all then-in-effect amendments to the Agreement, regardless of whether you have actually
reviewed them. Continued use of the Platform or any other Robinhood services after such posting will
constitute your acknowledgment and acceptance of such amendment. You agree to regularly consult
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the Website and the Disclosure Library for up-to-date information about Robinhood services and any
modifications to this Agreement, Risk Disclosures, or any other agreement incorporated or referenced
in this Agreement or related to services provided to you by Robinhood. Robinhood is not bound by any
verbal statements that seek to amend the Agreement. Any communication from you that purports to
amend or supplement the terms of this Agreement or impose other terms on Robinhood will only take
effect if agreed to in writing and signed by one of our authorized signatories.
37.8. Termination.
Robinhood may terminate this Agreement, or close, deactivate, or block access to your Account at any
time in its sole discretion. You will remain liable to Robinhood for all obligations incurred in your
Account, pursuant to this Agreement, or otherwise, whether arising before or after termination. You
may terminate this Agreement after paying any Obligations owed upon written notice. This Agreement
survives termination of your Account.
If Robinhood terminates this Agreement or closes or deactivates your Account or any services related
to your Account, you agree that Robinhood is authorized to (i) liquidate any Property in your Account
and send you any net proceeds (after satisfying any Obligations), and (iii) close your Account. This is
without limitation to Robinhood’s other rights under this Agreement or otherwise.
Robinhood will not be responsible for any Losses caused by Robinhood discontinuing or closing your
Account or any services, or any liquidation of your Property or closure of your Account, including any
tax liabilities.
37.9. No Waiver; Cumulative Nature of Rights and Remedies.
You understand that Robinhood’s failure to insist at any time upon strict compliance with any term
contained in this Agreement, or any delay or failure on Robinhood’s part to exercise any power or right
given to Robinhood in this Agreement, or a continued course of such conduct on Robinhood’s part,
shall at no time operate as a waiver of such power or right, nor shall any single or partial exercise
preclude any other further exercise. All rights and remedies given to Robinhood in this Agreement are
cumulative and not exclusive of any other rights or remedies to which Robinhood is entitled.
37.10. International Customers.
The products and services described on the Website are offered only to customers located in the United
States. The Platform shall not be considered a solicitation for or offering of any investment product or
service to any person outside the United States. You understand that Robinhood is based in the United
States and that Robinhood accepts only U.S. currency in Robinhood’s customer accounts.
38. Governing Law.
This Agreement and all transactions made in your Account shall be governed by the laws of the State
of California (regardless of the choice of law rules thereof), except to the extent governed by the federal
securities laws, FINRA Rules, and the regulations, customs and usage of the exchanges or market
(and its clearing house) on which transactions are executed.
39. Arbitration.
A. This Agreement contains a pre-dispute arbitration clause. By signing an arbitration
agreement, the parties agree as follows: (1) All parties to this Agreement are giving up the right
to sue each other in court, including the right to a trial by jury, except as provided by the rules of
the arbitration forum in which a claim is filed. (2) Arbitration awards are generally final and
binding; a party’s ability to have a court reverse or modify an arbitration award is very limited. (3)
The ability of the parties to obtain documents, witness statements and other discovery is
generally more limited in arbitration than in court proceedings. (4) The arbitrators do not have to
explain the reason(s) for their award unless, in an eligible case, a joint request for an explained
decision has been submitted by all parties to the panel at least 20 days prior to the first
scheduled hearing date. (5) The panel of arbitrators will typically include a minority of arbitrators
who were or are affiliated with the securities industry. (6) The rules of some arbitration forums
may impose time limits for bringing a claim in arbitration. In some cases, a claim that is ineligible
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for arbitration may be brought in court. (7) The rules of the arbitration forum in which the claim is
filed, and any amendments thereto, shall be incorporated into this Agreement.
B. Any controversy or claim arising out of or relating to this Agreement, any other agreement
between you and Robinhood, any Account established hereunder, any transaction therein, shall
be settled by arbitration before FINRA Dispute Resolution, Inc. (“FINRA DR”) in accordance with
the rules of FINRA DR.
C. If you are a foreign national, non-resident alien, or if you do not reside in the United States,
you agree to waive your right to file an action against Robinhood in any foreign venue.
D. No person shall bring a putative or certified class action to arbitration, nor seek to enforce any
pre-dispute arbitration agreement against any person who has initiated in court a putative class
action; or who is a member of a putative class who has not opted out of the class with respect to
any claims encompassed by the putative class action until: (1) the class certification is denied;
or (2) the class is decertified; or (3) the customer is excluded from the class by the court. Such
forbearance to enforce an agreement to arbitrate shall not constitute a waiver of any rights under
this Agreement except to the extent stated herein.
ACCEPTED AND AGREED: You acknowledge that you have read the preceding terms and conditions
of this Agreement, that you understand them and that you hereby manifest your assent to, and your
agreement to comply with, those terms and conditions by accepting this agreement. YOU ALSO
UNDERSTAND THAT BY ACCEPTING THIS AGREEMENT YOU HAVE ACKNOWLEDGED THAT
THIS AGREEMENT CONTAINS A PREDISPUTE ARBITRATION CLAUSE IN SECTION 39
HEREIN. YOU ALSO AGREE THAT (1) ANY OF YOUR MARGIN ACCOUNT SECURITIES MAY BE
BORROWED BY ROBINHOOD OR LOANED TO OTHERS; (2) YOU HAVE RECEIVED OF A COPY
OF THIS AGREEMENT AND (3) YOU HAVE REVIEWED A COPY OF THE MARGIN DISCLOSURE
STATEMENT, (4) YOU HAVE BEEN PROVIDED WITH AND AGREE TO THE ROBINHOOD
FINANCIAL LLC FORM CRS, ROBINHOOD TERMS AND CONDITIONS, RHF USE AND RISK
DISCLOSURES, ROBINHOOD FINANCIAL PRODUCT FEATURES DISCLOSURES, DAY TRADING
RISK DISCLOSURE, EXTENDED HOURS TRADING DISCLOSURE, ETF DISCLOSURE, RHF FUNDS
AVAILABILITY, RHF AND RHS BUSINESS CONTINUITY PLAN SUMMARY, AND FINRA PUBLIC
DISCLOSURE PROGRAM, WHICH ARE INCORPORATED BY REFERENCE INTO THIS
AGREEMENT.
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Appendix A: Electronic Fund Transfer Services Disclosures
Addendum
The following disclosures apply to EFT transactions.
Solely for purposes of these disclosures: (i) references to the Bank shall include any financial institution
that provides services in connection with ACH, Move Money, or other EFT transactions; (ii) “you” and
“your” mean the owner of the Account; and (iii) “we” and “us” means Robinhood and the Bank collectively.
1. Your Liability.
Tell us AT ONCE if you believe that an electronic fund transfer has been made without your
permission. Telephoning is the best way of keeping your possible losses down. You could
lose all the Available Funds in your Account.
Also, if your statement shows transfers that you did not make, tell us at once. If you do not tell us within 60
days after the statement was mailed to you, or otherwise made available to you, you may not get back any
money you lost after the 60 days if we can prove that we could have stopped someone from taking the
money if you had told us in time. If a good reason (such as a long trip or a hospital stay) kept you from
telling us, we will extend the time periods.
2. Contact in event of unauthorized transfer.
You should call 888-275-8523, visit support.robinhood.com, email us at h[email protected] or write to
us at Robinhood at 85 Willow Road, Menlo Park, CA 94025 if you believe a transfer has been made
without your permission.
3. Business Days
For purposes of these disclosures, our business days are Monday through Friday, excluding U.S.
Federal Holidays.
4. Transfer Types and Limitations.
You may make ACH withdrawals from your Account, either originated through us or originated by a
third party (a “non-originated” withdrawal), subject to the Available Funds in your Account, the
transaction limits described below and in the App and on the Website, and the other terms and
conditions of this Agreement. You also may make ACH deposits to your Account, either originated
through us or originated by a third party (a “non-originated” deposit), subject to the transaction limits
described below and in the App and on the Website.
There are limitations on the frequency and dollar amount of transfers you may make. Transfer limits for
Originated ACH, Debit Card Funding, and Instant Bank Transfers are calculated by aggregating the
amount of such transactions in your brokerage Account as well as the amount of such transactions
originated in any other accounts you may hold with Robinhood affiliate companies. Originated ACH
Withdrawals and Deposits may sometimes be referred to as “Standard Bank Transfers”, “Standard
Bank” or a similar name. Applicable limits are set forth below and in the App and on the Website.
These limits are designed to be flexible to protect the security of Robinhood’s services and your
Account. You understand and agree Robinhood may change these limits at any time in its sole
discretion, including for security reasons, and without advance notice to you, except as otherwise
required by law. Higher limits may be available to you, as determined by Robinhood in its sole
discretion, and will be set forth in the App, if applicable. You understand and agree that Robinhood
reserves the right to restrict, limit or delay any transfer or attempted transfer, for any purpose including,
but not limited to, suspected fraud or other illicit activity and for purposes of maintaining account
security. The following lists the limitations for each type of transaction:
34
Originated ACH Withdrawals:
Originated ACH Withdrawals submitted before 7 p.m. Eastern Time will be counted towards that
business day’s withdrawal limits set forth in the App and on the Website, otherwise, they will count
towards the next business day’s limits.
Originated ACH Deposits:
Originated ACH Deposits submitted before 7 p.m. Eastern Time will be counted towards that business
day’s deposit limits set forth in the App and on the Website, otherwise, they will count towards the next
business day’s limits.
Non-Originated ACH Withdrawals:
Daily Limit: $250,000.00 // Weekly Limit: N/A // Monthly Limit: N/A
Non-Originated ACH Deposits:
Daily Limit: $250,000.00 // Weekly Limit: N/A // Monthly Limit: N/A
Debit Card Funding (“DCF”):
DCF transactions submitted on or before 11:59 p.m. Eastern Time will be counted toward that day’s
DCF limits set forth in the App and on the Website, otherwise, they will count towards the next day’s
limits.
Instant Bank Transfers (“IBT”):
IBT withdrawals and deposits submitted on or before 11:59 p.m. Eastern Time will be counted towards
that day’s limits set forth in the App and on the Website, otherwise, they will count towards the next
day’s limits.
5. Fees.
We will not charge you any fees for initiating EFTs on your behalf.
If you make external transfers of funds from your Account via DCF or IBT, you will be charged a fee, as
outlined in the Fee Schedule.
6. Confidentiality.
We may disclose information to third parties about you or the transfers you make:
1. Where it is necessary or helpful for completing or correcting transactions and resolving claims
regarding transactions;
2. In order to verify the existence and condition of your Account for a third party, such as a credit
bureau or merchant;
3. In order to comply with a valid request by a government agency, a court order, or other legal or
administrative reporting requirements;
4. If you consent by giving us your written permission;
5. To our employees, auditors, affiliates, service providers, or attorneys as needed;
6. In order to prevent, investigate or report possible illegal activity;
7. As permitted by applicable law; or
8. Otherwise as necessary to fulfill our obligations under this Agreement and the terms applicable
to the EFT service you are using.
Please see the Robinhood Privacy Policy, available in the Disclosure Library, and the applicable
Bank’s privacy policy, available at https://www.suttonbank.com/_/kcms-doc/85/49033/WK-Privacy-
Disclosure-1218.pdf, for further details. (The Robinhood Privacy Policy and the applicable Bank’s
privacy policy are referred to collectively as the “Privacy Policies”). You hereby agree to Robinhood’s
and the Bank’s collection, use, and sharing of information about you as provided in the Privacy
Policies, which are made a part of this Agreement. The Privacy Policies also tell you how you can (i)
limit the ways in which Bank and Robinhood share information about you, or (ii) request corrections to
the information that Bank or Robinhood maintain about you. You agree that information you provide in
connection with EFT services you use is being provided directly to both Robinhood as the holder of the
Account associated with the service and the Bank as the provider of the EFT service.
35
7. Documentation.
Preauthorized Credits. If you have arranged to have direct deposits made to your Account at least once
every 60 days from the same person or company, the person or company making the deposit will tell you
every time they send us the money. You can also check your Account online to find out whether or not
the deposit has been made.
Periodic Statements. You will get a monthly Account statement (unless there are no transfers in a
particular month). In any case you will get the statement at least quarterly. You may obtain information
about the Available Funds in your Account.
8. Preauthorized Payments/Stop Payment Procedure and Notice of Varying
Amounts.
You do not have the right to request that Robinhood in advance make regular payments out of your
Account, although you may ask third parties to initiate regular payments out of your Account.
Right to stop payment: If you have automatic recurring payments taken out of your Account, you can
stop any of these payments. Here’s how:
Call us at 888-275-8523, email us at help@robinhood.com, or write us at 85 Willow Road, Menlo
Park, CA 94025, in time for us to receive your request 3 Business Days or more before the payment
is scheduled to be made. If you call, we may also require you to put your request in writing and get
it to us within 14 days after you call.
Notice of varying amounts: If these regular payments vary in amount, the party you are going to pay
is responsible for telling you, 10 days before each payment, when it will be made and how much it will
be. (The party you are going to pay may allow you to choose to get this notice only when the payment
would differ by more than a certain amount from the previous payment, or when the amount would fall
outside certain limits that you set.)
Liability for failure to stop payment of a preauthorized transfer: If you order us to stop a payment
at least three Business Days before the transfer is scheduled and we do not do so, we will be liable for
your losses or damages.
9. Our Liability.
If we do not complete a transaction to or from your Account on time or in the correct amount according
to our Agreement with you, we will be liable for your losses or damages. However, there are some
exceptions. We will not be liable, for instance:
1. If through no fault of Robinhood or the Bank, you do not have enough Available Funds in your
Account to complete the transaction;
2. If there is a hold or your funds are subject to legal or administrative process or other
encumbrance restricting their use;
3. If Robinhood or the Bank have reason to believe the requested transaction is unauthorized;
4. If circumstances beyond the control of Robinhood or the Bank (such as fire, flood, or computer
or communication failure) prevent the completion of the transaction, despite reasonable
precautions that Robinhood or the Bank have taken; or
5. For any other exception stated in this Agreement with you or by applicable law.
10. Errors or Questions About Electronic Transfers.
In case of errors or questions about your electronic transfers, telephone us at 888-275-8523, write us at
85 Willow Road, Menlo Park, CA 94025, or email us at [email protected] as soon as you can.
36
Revised July 22, 2024 Robinhood Market Data Addendum
This agreement (the “Market Data Addendum” or the “Addendum”) supplements and forms part of
the Robinhood Financial LLC & Robinhood Securities, LLC Customer Agreement (as supplemented,
updated and amended from time to time, the “Customer Agreement”). This is the “Market Data
Addendum” referred to in the Customer Agreement and incorporated by reference therein. Capitalized
terms used in this Market Data Addendum and not otherwise defined have the meanings given
to them in the Customer Agreement. This Market Data Addendum may be amended or
supplemented from time to time by notice, as set out in section 4 below.
AS SET OUT BELOW AND WITHOUT LIMITATION, TO RECEIVE NYSE MARKET DATA YOU
AGREE TO THE AGREEMENT FOR MARKET DATA DISPLAY SERVICES AT SECTION 3(A) AND
APPENDIX 1 OF THIS MARKET DATA ADDENDUM, TO RECEIVE NASDAQ MARKET DATA
YOU AGREE TO THE NASDAQ MARKET DATA AGREEMENT AT SECTION 3(B) OF THIS
MARKET DATA ADDENDUM, AND TO RECEIVE OTC MARKETS MARKET DATA YOU AGREE TO
THE OTC MARKETS SUBSCRIBER AGREEMENT REFERENCED AT SECTION 3(C)OF THIS
MARKETS DATA ADDENDUM.
1. No warranty; limitation of liability
Robinhood and/or its affiliates receive Market Data from industry sources and Third Party Providers.
Market Data is provided or made available to you on an "as is" and on an "as available" basis and
should not be considered as any form of advice or recommendation for you or your Account.
Robinhood does not endorse, approve, or provide any view or opinion on any Market Data. Neither
Robinhood nor any Third Party Provider (i) warrants or guarantees the accuracy, timeliness,
completeness or correctness of any Market Data, or (ii) warrants any results or interpretations from any
use or reliance upon Market Data for any purpose. Your use of any Market Data is at your own risk.
Past performance is no guarantee of future results.
NEITHER THE ROBINHOOD PARTIES NOR ANY THIRD PARTY PROVIDER SHALL BE LIABLE IN
ANY WAY FOR (A) ANY INACCURACY, ERROR OR DELAY IN, INTERRUPTION OR OMISSION
OF, ANY MARKET DATA, INFORMATION OR MESSAGE, OR THE TRANSMISSION OR
DELIVERY THEREOF; OR (B) ANY LOSSES (AS DEFINED IN THE CUSTOMER AGREEMENT)
OR DAMAGE ARISING FROM OR IN CONNECTION WITH MARKET DATA OR ANY SUCH
INACCURACY, ERROR, DELAY, INTERRUPTION OR OMISSION, WHETHER DUE TO ANY ACT
OR OMISSION BY ROBINHOOD OR A THIRD PARTY PROVIDER, OR OTHERWISE. ROBINHOOD
AND THE THIRD PARTY PROVIDER(S) ARE NOT RESPONSIBLE FOR, AND YOU AGREE NOT
TO HOLD ANY OF THEM LIABLE FOR, ANY LOSSES, LOST PROFITS, TRADING LOSSES OR
OTHER DAMAGES RESULTING FROM OR IN CONNECTION WITH YOUR USE OF ANY MARKET
DATA, OR FROM OR IN CONNECTION WITH ANY INACCURATE, DEFECTIVE OR UNAVAILABLE
MARKET DATA. THE LIMITATIONS OF LIABILITY IN THIS MARKET DATA ADDENDUM ARE IN
ADDITION TO AND WITHOUT PREJUDICE TO ANY OTHER LIMITATIONS OF LIABILITY IN THE
CUSTOMER AGREEMENT OR OTHER AGREEMENTS YOU MAY HAVE FROM TIME TO TIME
WITH ANY OTHER ROBINHOOD ENTITY OR WITH ANY THIRD PARTY PROVIDER.
We may remove, restrict or terminate access to or provision of any Market Data at any time, or change
any relevant Third Party Provider or any Market Data (and thereby the precise Market Data provided or
made available, or the manner in which any Market Data is provided or made available) at any time.
2. Non-Professional; Restrictions on Use
You may only use (and represent to us that you will only use) Market Data provided to you in connection
with the Platform for your own personal, non-business use, and subject to the terms of the Customer
Agreement including this Market Data Addendum and the agreements constituted hereby.
You must not use Market Data for any purpose not directly related to the Platform or your Account,
and you must not provide, retransmit, redistribute or publish any Market Data to any other person or
entity.
Unless and until you have expressly notified us in writing to the contrary, you represent and warrant to
us on a continuing basis that you qualify as a “Non-professional”. If you think you are or might be a
37
“Securities Professional” or if you think that you do not or might not qualify as a “Non-professional”, you
If you have told us in writing that you are a “Securities Professional” then you represent and warrant to
us that you are a Securities Professional, until you notify us in writing to the contrary.
For these purposes:
“Non-professional” means any natural person who receives market data solely for their own
personal, non-business use and who is not a “Securities Professional.”
A “Securities Professional” for these purposes includes an individual who, if working in the United
States, is:
(a) registered or qualified in any capacity with the Securities and Exchange Commission (the
"SEC"), the Commodities Futures Trading Commission, any state securities agency, any
securities exchange or association, or any commodities or futures contract market or
association, or self-regulatory body;
(b) engaged as an "investment advisor" as that term is defined in Section 202 (a)(11) of the
Investment Advisor's Act of 1940 (whether or not registered or qualified under that Act), or
(c) employed by a bank or other organization exempt from registration under Federal and/or state
securities laws to perform functions that would require that individual to be so registered or
qualified if they were to perform such functions for an organization not so exempt.
A person who works outside of the United States will be considered a “Securities Professional” if they
perform the same function(s) as a person who would be considered a “Securities Professional” in the
United States. Any use of Market Data for business, professional or other commercial purpose is not
compatible with Non-Professional status, even if the commercial use is on behalf of an organization that
is not in the securities industry.
You undertake to continually assess your status as to whether you are a Non-Professional or whether
you are a Securities Professional, and undertake to promptly notify us if your classification as a “Non-
professional” or a “Securities Professional” changes at any time whilst you have an Account. You
acknowledge that we have provided you with an Account and with Market Data in reliance on your
representations and warranties to us as to your status. You indemnify Robinhood for any fees, costs,
losses, liabilities or expenses that Robinhood may incur or suffer, directly or indirectly, in connection
with any such representation or warranty being incorrect or inaccurate in any respect when given or
repeated.
3. Specific Terms required by certain Third Party Data Providers
A. NYSE Market Data
Robinhood may provide or make available to you through the Platform certain Market Data being (a)
last sale information and quotation information relating to securities that are admitted to dealings on the
New York Stock Exchange, (b) such bond and other equity last sale and quotation information, and
such index and other market information, as United States-registered national securities exchanges
and national securities associations may make available and as the New York Stock Exchange may
from time to time designate as "Market Data"; and (c) all information that derives from any such
information (such data or information from time to time being “NYSE Market Data”).
To receive or have made available to you any NYSE Market Data, you enter into the “Agreement for
Market Data Display Services” in the form attached at Appendix 1 to this Market Data Addendum (the
“NYSE Market Data Agreement”) with Robinhood Financial.
The NYSE Market Data Agreement will be deemed to have been executed and entered into by you by
your agreement to the Customer Agreement and this Market Data Addendum, and in addition to being
incorporated into the Customer Agreement by virtue of this Market Data Addendum, constitutes a
separate agreement between you and Robinhood Financial. You acknowledge and agree that the NYSE
38
Market Data Agreement is a legal, valid and binding contract between you (as Subscriber) and
Robinhood Financial, LLC (as Vendor).
B. NASDAQ Market Data
Robinhood Financial may provide or may make available to you through the Platform certain Market
Data that consists of or includes Information owned or provided by NASDAQ (each as defined in
paragraph 12 below). You agree to the terms set out in paragraphs 1-13 below (the “Nasdaq Market
Data Agreement”), which constitute a legally binding agreement between you and Robinhood Financial.
Certain defined terms are set out in paragraph 12.
1. Use of Data. You are only permitted to access, view, or use any Information for your personal,
non-business, use. You undertake to only use Information for your personal, non- business,
purposes. You agree not to sell, lease, furnish or otherwise permit or provide access to the
Information to any other Person or to any other office or place. You agree not to engage in the
operation of any illegal business use or permit anyone else to use the Information, or any part
thereof, for any illegal purpose or violate any NASDAQ or SEC Rule or other applicable law,
rule or regulation. You agree not to present the Information rendered in any unfair, misleading
or discriminatory format. You agree to take reasonable security precautions to prevent
unauthorized Persons from gaining access to the Information.
2. Proprietary Data. You acknowledge and agree that (i) NASDAQ has proprietary rights to the
Information that originates on or derives from markets regulated or operated by NASDAQ, and
compilation or other rights to Information gathered from other sources; and (ii) NASDAQ's third-
party information providers have exclusive proprietary rights to their respective Information. In
the event of any misappropriation or misuse by you of any Information, NASDAQ or its third-
party information providers shall have the right to obtain injunctive relief for its respective
materials.
3. Modifications. NASDAQ may from time to time, in its sole discretion, make modifications to its
system or the Information. Such modifications may require corresponding changes to be made
in Robinhood's service or in the way Information is provided or presented to you, and may
affect your access to or use of some or all of the Information. NASDAQ and Robinhood shall
not be responsible for such effects.
4. Reporting and Audit. If requested by Robinhood Financial or NASDAQ, you undertake to
provide reasonable cooperation including: (i) promptly providing information or materials in
response to any reasonable request; and (ii) making available for examination all records,
reports, payments, and supporting documentation, in each case relating to the Information,
necessary to reach a conclusion as to your compliance with these terms.
5. System. You acknowledge that NASDAQ, in its sole discretion, may from time-to-time make
modifications to its system or the Information. Such modifications may require corresponding
changes to be made in the way Information may be displayed or provided to you. NASDAQ
shall not be responsible for such effects.
6. No endorsement. NASDAQ does not endorse or approve any equipment, Robinhood, or
Robinhood’s service. Robinhood makes no representations or warranties in connection with
NASDAQ or Information.
7. Limitations of Liability.
a. Except as may otherwise be set forth herein, NASDAQ shall not be liable to you or any
other Person for indirect, special, punitive, consequential or incidental loss or damage
(including, but not limited to, trading losses, loss of anticipated profits, loss by reason
of shutdown in operation or increased expenses of operation, cost of cover or other
indirect loss or damage) of any nature arising from any cause whatsoever, even if
NASDAQ has been advised of the possibility of such damages.
b. NASDAQ shall not be liable to you or any other Person for any unavailability,
interruption, delay, incompleteness or inaccuracy of the Information. This section shall
not relieve NASDAQ, you, or any other Person from liability for damages that result
from their own gross negligence or willful tortious misconduct or from personal injury or
wrongful death claims. You understand and agree that the terms of this section reflect
a reasonable allocation of risk and limitation of liability.
8. Disclaimers of Warranties. NASDAQ and its third-party information providers make no
warranties of any kind — express, implied or statutory (including without limitation, timeliness,
truthfulness, sequence, completeness, accuracy, freedom from interruption), any implied
warranties arising from trade usage, course of dealing, course of performance or the implied
warranties of merchantability or fitness for a particular use or purpose or noninfringement.
39
9. Third-Party Information Providers’ limitation of liability. NASDAQ’s third-party information
providers shall have no liability for any damages for the accuracy of or for delays or omissions
in any of the Information provided by them, whether direct or indirect, lost profits, special or
consequential damages of you or any other Person seeking relief through you, even if the third-
party information providers have been advised of the possibility of such damages. In no event
will the liability of the third-party information providers or their affiliates to you or any other
Person seeking relief through you pursuant to any cause of action, whether in contract, tort or
otherwise, exceed the fee paid by you or any other Person seeking relief through you, as
applicable.
10. Claims and Losses. You will indemnify NASDAQ and hold NASDAQ and its employees,
officers, directors and other agents harmless from any and all Claims or Losses imposed on,
incurred by or asserted as a result of or relating to: (a) any noncompliance by you with the
terms and conditions hereof; (b) any third-party actions related to your receipt and use of the
Information, whether authorized or unauthorized; (c) a claim of infringement or other violation
of an intellectual property right by you or your actions or omissions, equipment or other
property.
11. Termination. You acknowledge that NASDAQ, when required to do so in fulfillment of
statutory obligations, may by notice to Distributor unilaterally limit or terminate the right of any
or all Persons to receive or use the Information and that Distributor will immediately comply
with any such notice and will terminate or limit the furnishing of the Information and confirm
such compliance by notice to NASDAQ. Any affected Person will have available to it such
procedural protections as are provided by the Act and applicable rules thereunder. In the event
of your breach, discovery of the untruth of any of your representations, or where directed by
the SEC in its regulatory authority, NASDAQ may terminate this Nasdaq Market Data
Agreement with not less than three (3) days written notice to you provided either by NASDAQ
or Robinhood.
12. Definitions. The following terms have the following meanings:
a. “Act” shall mean the Securities Exchange Act of 1934, applicable only to Information
disseminated from a NASDAQ Market in the United States.
b. “Information” means certain market data and other data disseminated that has been
collected, validated, processed, and recorded by the System or other sources made
available for transmission to and receipt from either a Vendor or from NASDAQ
relating to: (a) eligible securities or other financial instruments, markets, products,
vehicles, indicators, or devices; (b) activities of NASDAQ; (c) other information and
data from NASDAQ. Information also includes any element of Information as used or
processed in such a way that the Information can be identified, recalculated or re-
engineered from the processed Information or that the processed Information can be
used as a substitute for Information.
c. “NASDAQ” means collectively NASDAQ, Inc., a Delaware limited liability company and
its subsidiaries and Affiliates.
d. “NASDAQ Markets” shall mean the regulated securities and options exchange
subsidiaries of NASDAQ and other regulated market subsidiaries of NASDAQ,
including, but not limited to, The NASDAQ Stock Market.
e. “Person” means any natural person, proprietorship, corporation, partnership or other
entity whatsoever.
f. “SEC” means the U.S. Securities and Exchange Commission.
g. “System” means any system NASDAQ has developed for the creation and/or
dissemination of Information.
13. Amendments. This Nasdaq Market Data Agreement may be amended or modified as set out
in section 4 of this Market Data Addendum.
C. OTC Markets Market Data
Robinhood may provide or make available to you through the Platform certain Market Data that is
provided directly or indirectly by OTC Market Group, Inc. and its affiliates (“OTC Markets Market
Data”). As a condition of receiving any OTC Markets Market Data, you are deemed to enter into an
agreement with Robinhood Financial in the form of the OTC Markets Subscriber Agreement, as defined
below, as amended from time to time.
The OTC Markets Group Market Data Subscriber Agreement in the form attached as Appendix A to the
OTC Markets Group Market Data Distribution Agreement (the “OTC Markets Subscriber Agreement”)
(which may be described as the ‘Market Data Distribution Agreement Subscriber Addendum’) is
40
incorporated by reference into this Market Data Addendum. For the purposes of the OTC Markets
Subscriber Agreement Robinhood Financial is the “Vendor”, and you are the “Subscriber”. The current
version of the OTC Markets Subscriber Agreement is available on the OTC Markets Group website
(https://www.otcmarkets.com/market-data/agreements-and-forms) or on request from Robinhood
Financial.
By opening an Account or accessing the Platform you expressly acknowledge that (i) you have read
and understood the OTC Markets Subscriber Agreement, and (ii) that OTC Markets Group and its
affiliates are a third party beneficiary of the agreement between you and Robinhood in the form of the
OTC Markets Subscriber Agreement. The OTC Markets Subscriber Agreement (and therefore the
agreement in the form of the OTC Markets Subscriber Agreement between you and Robinhood
Financial constituted by this Market Data Addendum) may be amended by OTC Markets Group from
time to time.
D. FactSet Market Data
Robinhood may provide or make available to you through the Platform certain Market Data that is
provided directly or indirectly by FactSet Research Systems, Inc. or its affiliates (“FactSet”) (such
Market Data, “FactSet Market Data”). In respect of any FactSet Market Data that is provided or made
available to you, you will receive only a limited right to use that FactSet Market Data for your own non-
commercial use. FactSet Market Data is copyrighted works of FactSet and must not be reproduced,
republished, retransmitted, or redistributed in any form. Neither Robinhood nor FactSet makes any
warranty, express or implied, as to the accuracy of the FactSet Market Data or results obtained from
any use of the FactSet Market Data. FactSet does not make any express or implied warranties of any
kind regarding the FactSet Market Data, including, without limitation, any warranty of merchantability or
fitness for a particular purpose or use. FactSet will not be liable for any lost profits or other incidental or
consequential damages in connection with Your use of the FactSet Market Data. Copyright © 2020
FactSet Research Systems Inc. All rights reserved.
E. Morningstar Market Data
Robinhood may provide or make available to you through the Platform certain Market Data that is
provided directly or indirectly by Morningstar, Inc. or its affiliates (“Morningstar”) (such Market Data,
“Morningstar Market Data”) ©2020 Morningstar. All Rights Reserved. The Morningstar Market Data:
(1) is proprietary to Morningstar Research Services LLC, Morningstar, Inc. and/or their content
providers; (2) may not be copied or distributed; and (3) is not warranted to be accurate, complete or
timely. Neither Morningstar Research Services, Morningstar nor their content providers are responsible
for any damages or losses arising from any use of this information. Morningstar does not make any
express or implied warranties of any kind regarding the Morningstar Market Data, including, without
limitation, any warranty of merchantability or fitness for a particular purpose or use. Access to or use of
any Morningstar Market Data does not establish an advisory or fiduciary relationship with Morningstar
Research Services, Morningstar, Inc. or their content providers. Past performance is no guarantee of
future results.
4. Amendments and Modifications
THIS MARKET DATA ADDENDUM AND ITS TERMS AND ANY AND ALL AGREEMENTS
CONSTITUTED BY IT MAY BE SUPPLEMENTED OR AMENDED FROM TIME TO TIME BY
ROBINHOOD BY NOTICE TO YOU, AND SUCH NOTICE REQUIREMENT MAY BE SATISFIED BY
THE REVISED MARKET DATA ADDENDUM BEING POSTED ON THE ROBINHOOD WEBSITE. BY
CONTINUING TO MAINTAIN ANY ACCOUNT OR ACCESS THE PLATFORM OR ANY MARKET
DATA, YOU ARE DEEMED TO ACCEPT THE TERMS OF THE REVISED MARKET DATA
ADDENDUM AND WILL BE LEGALLY BOUND BY ITS TERMS.
5. Governing Law and Jurisdiction
Section 38 (Governing Law) and Section 39 (Arbitration) of the Customer Agreement apply to and are
incorporated into this Addendum as if set out in full.
41
APPENDIX 1: NYSE Market Data Agreement
AGREEMENT FOR MARKET DATA DISPLAY SERVICES
(Usage-Based Services/Nonprofessional Subscriber Status) (Electronic Version)
Robinhood Financial, LLC (“Robinhood Financial”) agrees to make certain data (referred to in this
agreement as "Market Data") available to you pursuant to the terms and conditions set forth in this
agreement. By agreeing to the Customer Agreement and the Market Data Addendum you agree to
comply with the terms and conditions of this agreement. References to “Subscriber” or “you” in this
agreement means the Customer under the Customer Agreement, and references to “this agreement”
means the agreement between you and Robinhood Financial constituted by these terms.
1. Market Data Definition – For all purposes of this agreement, "Market Data" means (a) last
sale information and quotation information relating to securities that are admitted to dealings on the
New York Stock Exchange ("NYSE"), (b) such bond and other equity last sale and quotation
information, and such index and other market information, as United States-registered national
securities exchanges and national securities associations (each, an "Authorizing SRO") may make
available and as the NYSE may from time to time designate as "Market Data"; and (c) all information
that derives from any such information.
2. Proprietary Nature of Data – Subscriber understands and acknowledges that each
Authorizing SRO and Other Data Disseminator has a proprietary interest in the Market Data that
originates on or derives from it or its market(s).
3. Enforcement – Subscriber understands and acknowledges that (a) the Authorizing SROs
are third-party beneficiaries under this Agreement and (b) the Authorizing SROs or their authorized
representative(s) may enforce this Agreement, by legal proceedings or otherwise, against
Subscriber or any person that obtains Market Data that is made available pursuant to this
Agreement other than as this Agreement contemplates. Subscriber shall pay the reasonable
attorney's fees that any Authorizing SRO incurs in enforcing this Agreement against Subscriber.
4. Data Not Guaranteed – Subscriber understands that no Authorizing SRO, no other entity
whose information is made available over the Authorizing SROs' facilities (an "Other Data
Disseminator") and no information processor that assists any Authorizing SRO or Other Data
Disseminator in making Market Data available (collectively, the "Disseminating Parties") guarantees
the timeliness, sequence, accuracy or completeness of Market Data or of other market information or
messages disseminated by any Disseminating Party. Neither Subscriber nor any other person shall
hold any Disseminating Party liable in any way for (a) any inaccuracy, error or delay in, or omission of,
(i) any such data, information or message or (ii) the transmission or delivery of any such data,
information or message, or (b) any loss or damage arising from or occasioned by (i) any such
inaccuracy, error, delay or omission, (ii) non- performance or (iii) interruption in any such data,
information or message, due either to any negligent act or omission by any Disseminating Party, to
any "force majeure" (e.g., flood, extraordinary weather conditions, earthquake or other act of God, fire,
war, insurrection, riot, labor dispute, accident, action of government, communications or power failure,
equipment or software malfunction) or to any other cause beyond the reasonable control of any
Disseminating Party.
5. Permitted Use – Subscriber shall not furnish Market Data to any other person or entity. If
Subscriber receives Market Data other than as a Nonprofessional Subscriber, it shall use Market Data
only for its individual use in its business.
6. Dissemination Discontinuance or Modification – Subscriber understands and
acknowledges that, at any time, the Authorizing SROs may discontinue disseminating any category of
Market Data, may change or eliminate any transmission method and may change transmission
speeds or other signal characteristics. The Authorizing SROs shall not be liable for any resulting
liability, loss or damages that may arise therefrom.
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7. Duration; Survival – This Agreement remains in effect for so long as Subscriber has the
ability to receive Market Data as contemplated by this Agreement. In addition, Robinhood Financial
may terminate this Agreement at any time, whether at the direction of the Authorizing SROs or
otherwise. Paragraphs 2, 3 and 4, and the first two sentences of Paragraph 8, survive any termination
of this Agreement.
8. Miscellaneous – The laws of the State of New York shall govern this Agreement and it
shall be interpreted in accordance with those laws. This Agreement is subject to the Securities
Exchange Act of 1934, the rules promulgated under that act, and the joint-industry plans entered into
pursuant to that act. This writing contains the entire agreement between the parties in respect of its
subject matter. Subscriber may not assign all or any part of this Agreement to any other person. The
person executing this Agreement below represents and warrants that he or she has legal capacity to
contract and, if that person is executing this Agreement on behalf of a proprietorship or a business,
partnership or other organization, represents and warrants that he or she has actual authority to bind
the organization.
By agreeing to this agreement, you acknowledge that you have read the preceding terms and
conditions of this agreement, that you understand them and that you manifest your assent to, and
your agreement to comply with, those terms and conditions by agreeing to this agreement.
9. Nonprofessional Subscriber definition -"Nonprofessional Subscriber" means any natural
person who receives market data solely for his/her personal, non- business use and who is not a
“Securities Professional.” A “Securities Professional” includes an individual who, if working in the
United States, is:
(a) registered or qualified with the Securities and Exchange Commission (the "SEC"), the
Commodities Futures Trading Commission, any state securities agency, any
securities exchange or association, or any commodities or futures contract market or
association.
(b) engaged as an "investment advisor" as that term is defined in Section 202 (a) (11) of
the Investment Advisor's Act of 1940 (whether or not registered or qualified under that
Act), or
(c) employed by a bank or other organization exempt from registration under Federal
and/or state securities laws to perform functions that would require him or her to be
so registered or qualified if he or she were to perform such functions for an
organization not so exempt.
A person who works outside of the United States will be considered a “Securities Professional” if he or
she performs the same functions as someone who would be considered a “Securities Professional” in
the United States.
Subscriber may not receive Market Data as a “Nonprofessional Subscriber” unless they fall within
Paragraph 9’s definition of “Nonprofessional Subscriber.”
10. Permitted Receipt - Subscriber may not receive Market Data from Robinhood
Financial, and Robinhood Financial may not provide Market Data to Subscriber, on a
“Nonprofessional Subscriber” basis unless Robinhood Financial first properly determines that
Subscriber qualifies as a “Nonprofessional Subscriber” as defined in Paragraph 9 and Subscriber in
fact qualifies as a “Nonprofessional Subscriber.”
11. Permitted Use – If Subscriber is a Nonprofessional Subscriber, he or she shall
receive Market Data solely for his or her personal, non-business use.
12. About you - in connection with your Account and the Customer Agreement you
have provided to Robinhood Financial the following information, and you represent and warrant that
such information continues to be true, complete and accurate in all respects:
● Your name
● Your address
● Your employer
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● Your occupation and job description
In connection with your Account and the Customer Agreement you have confirmed to
Robinhood Financial that you are not a Securities Professional, and in particular you confirm and
warrant as follows:
● You use Market Data solely for your personal, non-business use
● You do not receive Market Data for your business or any other entity
● You are not currently registered or qualified with the SEC or the CFTC
● You are not currently registered or qualified with any securities agency, any securities
exchange, association or regulatory body, or any commodities or futures contract
market, association or regulatory body, in the United States or elsewhere
● Whether you are located within or outside the United States, you do not perform any
functions that are similar to those that require an individual to register or qualify with
the SEC, the CFTC, any other securities agency or regulatory body, any securities
exchange or association, or any commodities or futures contract market, association
or regulatory body
● You are not engaged to provide investment advice to any individual or entity
● You are not engaged as an asset manager
● You do not use the capital of any other individual or entity in the conduct of your
trading
● You do not conduct trading for the benefit of a corporation, partnership, or other entity
● You have not entered into any agreement to share the profit of your trading or receive
compensation for your trading activities
● You are not receiving office space, and equipment or other benefits in exchange for
your trading or work as a financial consultant to any person, firm, or business entity.
● You will notify and update Robinhood Financial promptly in writing of any change in
your circumstances that may cause you to cease to qualify as a Nonprofessional
Subscriber or that may change your responses to any of the following statements or
may cause any of them to be untrue in respect of you.
13. Certification. By executing this agreement, Subscriber hereby certifies that he or
she falls within Paragraph 9's definition of "Nonprofessional Subscriber" and that the personal and
employment information that he or she has provided to Robinhood Financial in connection with their
Account and confirmed in Paragraph 12 is truthful and accurate.
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