Why did I receive this payment?

You have been identified as an affected client entitled to a payment as a result of a settlement between Titan Global Capital Management USA LLC (“Titan”) and the Securities and Exchange Commission (“SEC”). As part of the settlement, Titan has agreed to make a pro rata distribution to individuals who paid advisory fees to Titan between June 1, 2021 and October 3, 2022.

What is the settlement about?

The order announces a settlement between Titan and the SEC that primarily covers certain legacy marketing and disclosure issues involving Titan’s cryptocurrency strategy between June 1, 2021 and October 3, 2022. The SEC order states that Titan did not implement policies and procedures that were reasonably designed to comply with marketing regulations and made certain misleading representations. The settlement also covers policy and procedure issues, and a customer agreement issue.

Although Titan reached a settlement with the SEC, Titan neither admits nor denies any wrongdoing. Titan fully cooperated with the SEC’s inquiry and is pleased to have reached a resolution of these issues.

A copy of the Order is posted on the SEC website here:

https://www.sec.gov/files/litigation/admin/2023/ia-6380.pdf

If you were affected and have an active Titan account, you will receive an email from Titan at the email address currently associated with your Titan account. If you need to update your email address on file, please email [email protected] with this request and our Client Experience team will assist. If you were affected and your Titan account is no longer active, you will be sent a check to your last known address.

I am no longer a Titan client - how will you send me the funds if I am affected?

If you paid Titan advisory fees between June 1, 2021 and October 3, 2022, and are no longer a Titan client, you will be sent a check to your last known address. If you believe that your email address and/or physical address have changed since you were a Titan client, you can email [email protected] and provide us with your current details. Having your current email address and/or physical address will allow us to communicate with you regarding payment details. Affected former clients will not receive any notification other than the physical check itself.

I was invested in crypto but I didn't receive anything/someone I know did - am I entitled to compensation?

Affected clients who paid advisory fees to Titan between June 1, 2021 and October 3, 2022 will be entitled to receive a pro rata payment regardless of whether or not they were invested in our cryptocurrency strategy. Affected clients entitled to compensation will be notified. If you are not notified, you are not entitled to receive compensation.

I paid advisory fees to Titan between June 1, 2021 and October 3, 2022, but did not receive a payment - Why?

The Fair Fund authorizes Titan to distribute the settlement amount on a pro rata basis based on the amount of advisory fees paid by advisory clients between June 1, 2021 and October 3, 2022. The settlement terms also include a de minimis threshold. This means that no payment is due if the total pro rata amount an affected client would otherwise receive is less than $10, which may explain why you did not receive a payment.

Why did I receive this amount?

The Fair Fund authorizes Titan to distribute the settlement amount on a pro rata basis based on the amount of advisory fees paid by affected clients between June 1, 2021 and October 3, 2022. The calculation methodology and payment file were reviewed and approved by the SEC.

If I received a check, how long do I have to cash the check?

Original distribution checks must be negotiated within 90 days of the check date. If your check was a replacement check, it must be negotiated within 30 days of the check date. It is important you deposit the check as soon as possible to ensure you receive the payment allocated to you from the distribution. Checks WILL NOT be honored if it is not negotiated within 90 days of the check date (or 30 days if you were issued a replacement check). All distribution checks not cashed within the allotted time frame listed on your check (usually 90 or 30 days) will be voided at the distribution bank and all unclaimed monies will be paid to the U.S. Treasury per the terms of the settlement.

What are the tax ramifications of this distribution?

We cannot provide you with tax advice. However, there is information about the potential tax consequences of this distribution in a Statement to Affected Clients, which is available on the “Tax Information” page of the Titan Fair Fund website. The Statement to Affected Clients is not intended as tax advice but describes the tax-reporting positions taken and points out some issues affected clients should consider. You should review the information in the Statement of Affected Clients with your tax advisor.

What if I don't receive a payment but I believe I should? What do I need to do if I disagree with the amount of the payment I received?

The payment amounts were calculated on a pro-rata basis based on the amount of advisory fees paid by clients to Titan between June 1, 2021 and October 3, 2022. The payment amounts have been approved by the SEC. The settlement terms also include a de minimis threshold. This means that no payment is due if the total pro rata amount a client would otherwise receive is less than $10, which may explain why you did not receive a payment.

I have more than one Titan account. Will I receive one payment or multiple payments?

If the total settlement payment amount owed to you is above the de minimis threshold of $10, you will receive a separate payment for each applicable Titan account.

I am a current Titan client who received a payment. Where can I see what was paid?

The payment will be reflected in the Cash balance of your account within the Titan app or website, beginning on Tuesday, January 30, 2024. The payment will also appear on your January 2024 account statement. You can access your statements directly in the Titan app by heading to the Account tab > Documents. If you prefer to use the website, you can access statements online by logging into titan.com and selecting Documents on the left side of the screen. Your January 2024 account statements will become available within the first 5-7 business days of February.

I am a current Titan client who was affected and only have an IRA account at Titan. Will this payment count as a contribution to my IRA?

If you receive a payment to an IRA account, please consult your tax advisor to confirm the treatment of your payment. For more information, please review the Tax Information section of this website.

If I receive a payment in the form of a check and need the check reissued, how long will it take to reissue the check?

Reissuance times may vary depending on the type of account and the reason for reissuance. More information will be available after a reissuance request is submitted.

I am a former Titan client and have not received a check. Where is it?

All former Titan clients are not automatically entitled to payment. Only former clients who paid by advisory fees to Titan between June 1, 2021 and October 3, 2022 are eligible for a pro rata settlement payment and only if the pro rata payment is greater than the de minimis threshold of $10. If you are a former client and believe you are entitled to payment or have questions about the status of your check, please call us at 844-253-1470.

How can I contact Titan?

For questions specifically about the SEC settlement and distribution, use the same phone number you used to contact us, which is 844-253-1470. For questions about your accounts held with Titan, please contact Titan directly at [email protected]. Titan’s Client Experience team operates Monday-Friday from 9am-6pm EST.

Will I receive an IRS Form 1099 to use when filing my taxes for 2023/2024?

If you are a US person for US tax purposes, you will not receive a Form 1099 for the principal component of the reimbursement but may receive a Form 1099 for the interest component if you were invested in a taxable account and the interest component is $600 or more. This reporting position may not be dispositive of the tax consequences to you. We recommend that you consult with your tax advisor regarding the proper treatment of the principal component.

Titan has prepared a Statement to Affected Clients which provides information to help you and your tax advisor determine the U.S. federal income tax consequences of the distribution payment. Please refer to the Tax Information tab on this website.