New Member Deposit Program Terms & Conditions

All new Members are eligible for the New Member Deposit Program, subject to the eligibility requirements below:

How to Participate

Terms and Conditions

1. Description of Promotion

Welcome to the New Member Deposit Program (the “Promotion”), where participants who have a Novig Account (as defined below), have not previously traded on the Exchange, and meet the requirements described in this Promotion will receive $50 in Trade Credits (referred to as “Deposit Credits” in the program terms Novig has filed with the Commodity Futures Trading Commission (the “Incentive Filing”)) after making a deposit of $10 or more. The Promotion is sponsored by Ludlow Exchange, LLC, d/b/a Novig (“Novig” or the “Exchange”), a Commodity Futures Trading Commission-designated contract market, located at 169 Madison Avenue #2199, New York, NY 10016. The terms “you” or “your” mean the person who participates in this Promotion. Participation in this Promotion is expressly conditioned upon acceptance of and compliance with these Terms and Conditions, the Ludlow Rulebook (the “Rulebook”), and the Ludlow Member Agreement (the “Member Agreement”). Capitalized terms used but not defined in these Terms and Conditions have the meanings given to them in the Rulebook and the Member Agreement. ANY DISPUTE RELATING TO THIS PROMOTION WILL BE RESOLVED IN ACCORDANCE WITH SECTION 11 BELOW, AND PARTICIPANTS WAIVE THE ABILITY TO BRING CLAIMS IN A CLASS ACTION FORMAT.

2. Promotion Period

The Promotion will begin at 8:00 AM Eastern Time (“ET”) on October 1, 2026 (the “Implementation Date”) and will continue for one year from the Implementation Date, unless extended, suspended, or terminated earlier by the Chief Regulatory Officer as described in Section 10 (the “Promotion Period”). Deposits made before the Implementation Date do not qualify. Notice of the Promotion’s effective period, and of any extension, suspension, or termination, will be posted on the Novig website.

3. Eligibility

You are eligible for the Promotion if you: (i) have been approved for Membership and have opened a trading account; (ii) have not previously traded on the Exchange; (iii) complete a deposit of at least $10.00 during the Promotion Period; and (iv) are not the subject of an open compliance investigation or review and do not have a suspended account or suspended account privileges for any compliance or financial reason. You must meet each of these requirements at the time you make your qualifying deposit and at the time Trade Credits are issued. For purposes of this Promotion, a “new Member” is a Member who has not previously traded on the Exchange.

The following are not eligible to participate, even if the requirements above are satisfied: (i) Affiliates of the Exchange (as defined in the Rulebook); (ii) Members who have executed a market maker agreement or entity onboarding agreement with the Exchange; and (iii) Introducing Brokers, Futures Commission Merchants, and customers thereof when transacting via the IB or FCM. All Promotion participants remain subject to the Rulebook.

Each person may participate in this Promotion only once. If your Social Security number is associated with another Novig Account in Novig’s records, you may not participate again.

4.Action Required

During the Promotion Period, you must have a verified Novig Account, link your payment method of choice, and make a qualifying deposit of $10.00 or more to receive the Trade Credits described in this Promotion.

5. Registration Procedures

To qualify for the Promotion, eligible individuals must register a Novig Account and verify their identity in order to trade on the Novig platform (a “Novig Account”). Creating a Novig Account is free. By submitting your information and creating a Novig Account, you agree to the Member Agreement and the Rulebook, and consent to the Novig Privacy Policy. If you do not agree to these terms, you cannot create a Novig Account or participate in this Promotion.

6. Limitations on Participation

In addition to the eligibility requirements in Section 3, the Chief Regulatory Officer may at any time revoke your eligibility and disqualify trades or activity inconsistent with the purpose of this Promotion or the Rulebook, including where you are found, following review by the Compliance Department, to have: (a) tampered with the registration process or the operation of the Promotion; (b) acted in violation of these Terms and Conditions; or (c) acted in a manner inconsistent with these Terms and Conditions or the Rulebook. This Promotion is void where prohibited by law. Trade Credits issued under this Promotion may not be combined with any other Incentive Program or promotion offered by Novig.

7. Trade Credits and Redemption

The $50 in Trade Credits is issued as five (5) Trade Credits of $10.00 each. Trade Credits issued under this Promotion are non-transferable and non-withdrawable, and have value usable solely for trading on the Exchange. When applied to a trade, a Trade Credit functions as buying power that collateralizes your position in the same manner as deposited funds, consistent with the fully-collateralized nature of Novig’s markets. Trade Credits may be used on any Contract listed for trading on Novig, at prices no less than $0.01 and no greater than $0.60 per Contract. You may apply no more than one Trade Credit to any single trade; if the value of a Trade Credit exceeds the amount applied to a trade, the unused remainder is forfeited and does not carry over to any subsequent trade. Trade Credits may not be deployed through programmatic or automated trading. Each Trade Credit expires thirty (30) calendar days after issuance; any Trade Credit not used within that period is forfeited.

Proceeds from a trade made using a Trade Credit settle to your account as ordinary funds and are withdrawable under Novig’s standard withdrawal procedures. You are not required to meet any trading volume requirements before withdrawing proceeds.

8. Anti-Abuse, Adjustment, and Clawback

Novig may adjust, cancel, or claw back any Trade Credit, or the value of any Trade Credit used, where:

(i) Novig’s Compliance Department determines that you provided false or fraudulent information on your Membership application, or that the Trade Credit was obtained or used through fraud, misrepresentation, collusion, multi-accounting, identity duplication, or other bonus abuse, or otherwise inconsistent with these Terms and Conditions or the Rulebook;

(ii) your qualifying deposit fails to clear, is reversed, or is returned for any reason;

(iii) the Trade Credit was issued or used in error, regardless of fault, including through technical malfunction, system error, or administrative mistake;

(iv) the underlying trade is voided, reversed, or cancelled; or

(v) Novig is required by Applicable Law or by directive of a competent regulatory authority to revoke a Trade Credit that has been issued to you but not yet applied to a trade.

In the circumstances described in clauses (i) and (ii), you will also be disqualified from this Promotion. Any correction under clause (iii) will be computed from and supported by Novig’s records of Promotion activity. Novig will notify you of any clawback or correction.

9. Complaints and Cancellation

Should you wish to cancel your participation in this Promotion at any time, please contact [email protected]. Any unused Trade Credits will be forfeited on cancellation. Proceeds that have already settled to your account are not affected. Complaints about this Promotion may also be sent to [email protected].

10. Monitoring, Modification, and Termination

Novig conducts ongoing surveillance of activity under this Promotion pursuant to Chapter 9 of the Rulebook. The Chief Regulatory Officer retains sole discretion to amend, modify, suspend, or terminate this Promotion at any time, subject to applicable CFTC filing requirements. This includes where Novig is prevented from continuing the Promotion by a Force Majeure event, or where a Force Majeure event corrupts or interferes with the administration, integrity, operation, or security of the Promotion. A “Force Majeure” event means any event beyond Novig’s control, including, but not limited to, fire, flood, epidemic, earthquake, explosion, labor dispute or strike, act of God or public enemy, communications or equipment failure, utility or service interruptions, riot or civil disturbance, terrorist threat or activity, war (declared or undeclared), interference with the Promotion by any party, or any federal, state or local government law, order, or regulation, order of any court or jurisdiction, or other cause not reasonably within Novig’s control. Notice of any modification, suspension, or termination will be posted on the Novig website. A suspension or termination may take effect immediately. No modification, suspension, or termination will reduce or revoke a Trade Credit that has already been issued to you, except as provided in Section 8.

11. Dispute Resolution

Any dispute relating to this Promotion is a “Dispute” governed by the informal dispute resolution, mandatory arbitration, and class action waiver provisions of the Member Agreement (Sections 22–25) and Chapters 10–11 of the Rulebook, including the opt-out rights and carve-outs set forth therein.

12. Additional Terms

Administration: Administration of this Promotion is at the sole discretion of Novig. Questions relating to eligibility will be determined by the Compliance Department under Section 3. Any other questions concerning this Promotion will be resolved at the sole discretion of Novig and its decisions will be final and binding with respect thereto.

Indemnification and Limitation of Liability: Your indemnification obligations under Section 18 of the Member Agreement, and the limitation of liability set forth in Rule 12.3 of the Rulebook, apply in full to your participation in this Promotion.

Relationship to the Incentive Filing and Rulebook: These Terms and Conditions describe the Promotion in plain language and are subject to the Incentive Filing and the Rulebook.