Window Trading. We consider our Window Trading, often referred to as “a Window”, to be an innovative way to execute orders efficiently. Instead of being executed immediately, Window orders are processed one or more times per day and executed. The current number and timing of Windows available to you is as provided on our websites or is as negotiated with your Advisor, Manager, or third-party brokerage firm. We may provide from time to time fewer or additional Windows for various reasons and at different fees. We reserve the right to add, remove and change Window Trade deadlines, without notice, at any time. We retain discretion as to the timing of a Window Trade, and therefore we cannot guarantee that every Window will occur as scheduled or at all. You understand and agree that your order will not be routed for execution immediately once the deadline for submitting an order to a Window has passed because additional processing is necessary (e.g., your order is combined with other orders in the same security and on the same side of the market, if any, and certain price validations are performed) and we may vary the time at which the combined order is routed to the market, or the amount of the combined order that is routed to the market, to prevent other market participants from anticipating our orders and trading in a manner that negatively impacts our execution quality or to attempt to maximize the numbers of shares executed in any particular order routed for execution. You further understand and agree that there may be times when Windows are delayed or are cancelled for various reasons, such as quote vendor failures, computer failures or events affecting the markets. When you submit an order to participate in a Window Trade, you are not instructing us to execute your order immediately when we receive it, but instead you are instructing us to treat your order as “not held” and to execute it in the next scheduled Window, which could be the same day you submit your order or the following trading day and the timing of which will occur in our sole discretion but generally around the times posted on our websites. In this regard, you are providing us discretion as to the timing of when we will attempt to execute your order and the price to be obtained. To execute Window orders, we generally send an aggregate order, or multiple aggregate orders to a market center for execution, which market center may include GSCO, or to a mutual fund company for fulfillment. The aggregate order(...
