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Securities offered through GT Securities, Inc., member FINRA, SIPC. Gavilan Commodities, LLC and GT Securities, Inc. are separate, unaffiliated entities.

COMMODITIES DISCLOSURE

“Pursuant to an exemption from the Commodity Futures Trading Commission in connection with accounts of qualified eligible persons, this brochure or account document is not required to be, and has not been, filed with the Commission. The Commodity Futures Trading Commission does not pass upon the merits of participating in a trading program or upon the adequacy or accuracy of commodity trading advisor disclosure. Consequently, the Commodity Futures Trading Commission has not reviewed or approved this trading program or this brochure or account document.”

The risk of loss in commodity interest trading can be substantial. You should, therefore, carefully consider whether such trading is suitable for you in light of your financial condition. The high degree of leverage that is often obtainable in commodity interest trading can work against you as well as for you. All investments in the commodity interest market should be made with risk capital only. Investors should never invest more than they can comfortably afford to lose. As with all trading strategies, past performance is not necessarily indicative of future results.

LIABILITY DISCLAIMER & TERMS OF SERVICE

This Website is maintained and operated by Gavilan Commodities, LLC (“GAVCOM”). GAVCOM’s business consists of providing consulting services to clients on strategic business matters. GAVCOM is not a registered broker/dealer or an Investment Advisor. GAVCOM does not offer or participate in offers of securities for sale or provide investment advice to others. Nothing on this Website is intended to constitute (i) an offer to sell or buy, or a solicitation of an offer to sell or buy securities from GAVCOM; (ii) investment advice or an offer to provide such advice; or (iii) a basis for making any investment decision.

GAVCOM provides a wide range of services to strategic commodities players, investment banks, private equity funds, and other clients based on the following terms:

Advice to Private Equity, Venture Capital and Strategic Investors — GAVCOM provides consulting services to clients on either a retainer or project basis. These include identifying potential investment opportunities, introduction to strategic industry companies, evaluation of transactions being contemplated by clients, development of strategic plans for company’s growth initiatives and coaching of company management teams. These services are provided by contract directly to clients and do not place GAVCOM in the role of a Broker/Dealer.

Financial Transaction Advice — GAVCOM is not a registered Broker/Dealer and does not act as an agent for buyers or sellers of businesses. This is consistent with the Securities and Exchange Act of 1934 which directs that brokers and dealers in securities register with the Securities and Exchange Commission (the “SEC”) and become members of the Financial Industry Regulatory Authority (“FINRA”). The SEC considers the term “broker” to generally include persons providing advice regarding financial transactions who accept “transaction-based” compensation. Transaction-based compensation is defined as any commission or finder’s fee which is dependent or based upon the execution of a transaction. More broadly, advisers on buying or selling companies are subject to SEC regulation because transaction advice generally involves the transfer of securities — typically, equity interests in the company being bought or sold. If potential clients require assistance in executing a transaction involving the purchase or sale of securities, as opposed to the sale of assets or negotiation of licensing arrangements, GAVCOM typically introduces them to an investment bank. Clients enter into a contract with such investment bank to receive the requested services.

Modification of These Terms — We reserve the right to modify these Terms at any time. Please check these Terms periodically for changes. Your continued use of this Website after the posting of changes constitutes your binding acceptance of such changes.

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