Regulatory Guide 227 (RG 227) issued by Australian Securities and Investment Commission sets out 7 disclosure benchmarks for over the counter contracts for difference. Product Disclosure Statements must address the benchmarks on an "if not, why not" basis. The table below set out Bacera Co Pty Ltd.'s disclosure against the benchmarks for Bacera's PDS.

Benchmark	Meets RG 227 Requirements?	Explanation
Client Qualification	Yes	Bacera assesses a potential client's qualifications and trading experience during the account opening process. Potential clients are required to read our PDS and declare they understand the risks involved in opening a CFD trading account with Bacera.
Opening Collateral	No	This benchmark requires an issuer to only accept cash or cash equivalents (such as credit cards) as opening collateral when establishing an account and limits credit payments to $1000 per deposit. Bacera does not place limits on credit card deposits because it does not want to restrict the manner in which clients fund their accounts.
Counterparty Risk – Hedging	Yes	Bacera maintains a written policy to manage its exposure to market risk from open positions. See Section 5.3 of our PDS ("Bacera as a Counter Party") for more information regarding Bacera's Hedging policy.
Counterparty Risk – Financial Resources	Yes	Bacera maintains and applies policies to ensure that it meets the financial requirements of a holder of an Australian Financial Services License. See section 5.2 of our PDS ("Bacera as Market Maker") for more information. Copies of Bacera's latest audited financial statements are available to prospective client upon request.
Client Money	Yes	Bacera has a well-defined Client Money policy and holds client money in segregated trust accounts with an authorized deposit-taking institution. Bacera does not use client money for any purpose, including meeting obligations incurred by us when hedging with other counterparties or meeting the trading obligations of other clients. See Section 2.13 of our PDS ("Client Funds") for more information.
Suspended or halted underlying assets	Yes	Bacera does not allow trading in positions when there is a trading halt in an Underlying Asset or Underlying Market. For more information regarding Bacera's discretion, please refer to Section 2.22 of our PDS.
Margin Calls	Yes	Bacera has a clear policy in relation to margin and Bacera's rights to close out positions. See Section 2.17 ("Margin Call") of our PDS for more information.