As a user of this online trading system, you agree to the following Terms of Service:

Please read the Bullion Direct Terms of Service. By using our services you accept and agree to abide by all of these Terms of Service.

In this Agreement, "the customer" refers to the individuals, corporations or parties who are the account holders, have an interest in the account(s) and sign this Agreement.

1. Parties.

This Agreement is entered into between Bullion Direct, Inc. ("Bullion Direct") and Customer(s) ("Customer") signing below.

2. Purpose of Agreement.

This Agreement provides for the establishment of an account for Customer with Bullion Direct for the purchase, sale, and storage of commodities approved for IRAs and shall apply to all such transactions between Customer and Bullion Direct. IMPORTANT NOTE: Customer must sign Sterling Trust Company's IRA account opening form which includes the related IRA custodial account agreement to establish a Self-Directed IRA account with Sterling Trust Company. Customer agrees to download such documents and remit to Sterling Trust Company.

3. Acknowledgment of Risk.

Because of the unpredictable nature of the commodities markets, the purchase and sale of commodities involve a high degree of risk and are not suitable for all persons. Customer represents that he has read and understands this Agreement and represents that he is aware of the nature and extent of his rights and the risks involved under this Agreement. Customer further acknowledges his understanding that transactions subject to this Agreement are cash trades with Bullion Direct and that such trades are not subject to regulation by the Commodity Futures Trading Commission or the National Futures Association.

4. Establishment of Account.

a. Upon execution of this Agreement by the parties above, an account will be established by Bullion Direct in the name Sterling Trust Company for the benefit of (Customer) IRA. Customer may direct Sterling Trust Company, as the Custodian of customerÕs self-directed IRA, on CustomerÕs behalf to deposit good funds to be held on account by Bullion Direct and Customer may also request that any cash balances be paid to Sterling Trust Company as custodian for the benefit of customerÕs IRA.

b. Bullion Direct will maintain adequate procedures to ensure the confidentiality of all account information. All passwords are confidential, and Customer agrees to be fully responsible for all activities under Customer's password including, but not limited to, all orders entered into the electronic trading systems.

c. Bullion Direct may, from time to time, amend, change or modify the terms and Terms of Service set forth in this Agreement. Bullion Direct will post such amendments, changes or modifications on the Bullion Direct Internet web site, www.Bullion Direct.com, or may otherwise cause the Terms of Service to be delivered to customer. Customer's continued account activity, whether conducted via the Internet or other means, constitutes Customer's agreement to be bound by such amendments, changes or modifications to these Terms of Service. Bullion Direct may justifiably rely upon such account activity as evidence of the acceptance of any such amendments, changes or modifications. Bullion Direct shall not be bound by any verbal representations.

d. Bullion Direct shall send all mail to Customer's address as it appears on customer's account or at any other address as Customer may direct. Any such communications sent by mail, email, telegraph, messenger or otherwise, will be considered personally delivered, whether or not Customer actually receives it.

5. Terms of Purchase, Sale and Delivery.

a. Purchase Price. Commodity may be purchased or traded on the online Nucleo™ marketplace. If purchased through Nucleo™ as a limit order, purchase price shall be the limit price or better as available on the Nucleo™ marketplace. If purchased through Nucleo™ as a market order, purchase price shall be the best available price meeting matching criteria. Shipping, handling, and clearing fees will apply as discussed below in this agreement.

b. Customer Purchases. At the time of confirmation of a purchase, CustomerÕs cash account will be debited the full amount due

c. Delivery to Customer or on Customer's Behalf. Upon receipt of good funds or other acceptable consideration from Customer or on Customer's behalf in full payment for the purchase of commodities, Bullion Direct shall, as agreed, either deliver the commodities (i) to Customer in accordance with Individual Retirement Account regulations, or (ii) to Customer's appointed agent or designee in accordance with Individual Retirement Account regulations, or, (iii) deliver or deposit such commodities for the benefit of Customer to or with such Depository or depositories used for the purpose of safekeeping Customer commodities (collectively referred to as "Depository"). Bullion Direct will choose the Depository, which will be a qualified third party or Bullion Direct. Sterling Trust Company as customerÕs IRA custodian does not and will not act as a depository for the safekeeping of customerÕs commodities.

d. Storage. Title to commodities purchased by Customer shall pass to Customer upon delivery to Customer, Customer's appointed agent or designee or to Depository to be held for Customer. Commodities transferred to Depository for Customer will be delivered as an undivided share of a fungible lot and held in safekeeping on a fungible basis with the commodities of other Depository Customers. Upon delivery of commodities for Customer to Depository, Customer will receive title to an undivided share of the commodities so held. Notwithstanding the passage of title to Customer, Bullion Direct may act as agent of the owner of the commodity.

e. Delivery to Bullion Direct. Customer commodities sold to Bullion Direct which are at Depository may be delivered to Bullion Direct at Depository.

f. Payment. Customer payments to Bullion Direct must come from Sterling Trust Company, Custodian FBO: (customer) IRA. Bullion Direct may expand or limit the form of acceptable payment at any time within the guidelines of IRA regulations.

6. Charges Associated with the Account.

a. Clearing Charge. Customer will pay to Bullion Direct for each purchase or sale a clearing fee of 1% of each transaction.

b. Shipping and Handling Charges. Shipping and handling charges apply upon personal delivery of commodities to Customer or from Customer to Bullion Direct. Such charges do not apply to commodities delivered to and received from Depository for the benefit of Customer. Shipping charges will vary depending on weight, value, destination, and method of shipment. The shipping and handling charges are automatically computed at the time the order is placed. Customer will be notified when placing the shipping order of the exact amount of shipping and handling.
Customer may arrange to have any stored commodity shipped in accordance with Individual Retirement Account regulations. However, customer must satisfy all payments due Bullion Direct before shipment.

c. Storage Charge. A storage charge of $49.95 will be billed directly to your Sterling Trust Company IRA account and continue to be billed every calendar year. This charge will not be prorated.

d. Adjustment of Charges. Bullion Direct reserves the right to change prospectively at any time and at its sole discretion the rate of any of its commissions, shipping, or handling.

7. Discretionary Authority and Authorized Customer Orders.

a. Discretionary Authority. Bullion Direct and its Account Representatives shall neither accept nor exercise any authority to direct or control purchases or sales in Customer's account; provided however, this provision shall not limit in any way Bullion Direct's right under paragraphs 10 or 11 of this Agreement.

b. Authorized Customer Orders. Orders placed by Customers must be for specified quantities of commodities at Bullion Direct's prevailing quoted price at the time the order is placed, if the order is placed as a market order on Bullion Direct's Nucleo™ platform. No other types of orders can be accepted.

8. Limit Orders.

On the Nucleo™ platform, Bullion Direct will accept orders for purchases or sales of commodities to be executed at prices that are higher or lower than market prices. Such orders may be placed only under Bullion Direct's Nucleo™ program. Unless otherwise specified, limit orders are effective for up to thirty days from the time the order is placed. However, they may be canceled early. Limit orders will only be fulfilled if another Customer agrees to the price requested or a better price, less commission owed to Bullion Direct.

Customer may cancel a limit order that has not been fully or partially filled at any time. A forced liquidation by Bullion Direct of any existing position in Customer's account due to insufficient equity or default will cancel pending limit orders for that account.

Bullion Direct reserves the right to refuse acceptance of a limit order from Customer at any time. Bullion Direct may cancel existing limit orders at any time.

Limit orders may be placed only on the preceding terms.

9. Customer Acknowledges:

Investments in commodities involve risk as well as opportunity. Historically, there have been periods of varying length during which prices of commodities have moved adversely. Market prices are volatile and unpredictable and may be affected by a variety of factors including, among others, general economic conditions, political events, monetary policies of various countries, fluctuations in production and demand, stock-piles, speculative activity and the degree of concern people have about these matters. It is impossible to forecast accurately how or to what degree these or other factors will affect prices. Investments in commodities should only be made with discretionary funds and not with monies necessary to cover or produce an investor's day-to-day living expenses.

What is suitable for one customer with a given financial means may not be suitable for the investment goals or emotional makeup of a second customer of the same means. Before Customer chooses to invest, Customer must determine in Customer's own mind Customer's ability to understand the investment and to meet all financial commitments to be made. Customer must also determine Customer's ability to accept, among other things, when purchasing on credit or borrowing commodities, that Customer may be called to provide substantial additional funds and that some or all of Customer's collateral may be foreclosed upon without advance notice. Persons with limited investment experience or low incomes or assets should be particularly sensitive to the risk and requirements involved in commodity investing.

Transactions in Bullion Direct commodities involve commissions, spreads and, for credit purchases, finance and service charges. Shipping charges and a sales or use tax may also be payable. These charges can result in a loss despite favorable price movement.

Bullion Direct may not be able to contact Customer at all times that Customer would like. These and other circumstances may make it impossible at times for Bullion Direct to stay in close touch with Customer concerning Customer's account. Therefore, it is Customer's responsibility to monitor Customer's account and to stay in touch with Bullion Direct concerning your account and market conditions. Do not wait to be contacted. Any representations that Customer will be notified or that Customer's commodity will be sold at particular price levels if the market turns against Customer are not authorized by Bullion Direct and may not be relied upon. Neither Bullion Direct nor its representatives can guarantee any market movement.

While Bullion Direct intends to maintain a buy and sell market for its commodities, there is no guarantee that Bullion Direct will continue to do so. In the event that Bullion Direct is unable or unwilling to quote firm prices at any time, Customer may be obliged to dispose of Customer's commodities in another market.

Bullion Direct will rely upon instructions and orders given by Customer on Bullion Direct's Internet site. Once a trade is placed by Customer and accepted by Bullion Direct, a contract is created. Trades may be reversed only upon mutual consent of the parties to this agreement. In times of highly volatile markets, Bullion Direct Internet and phone lines may be busy due to the volume of incoming and outgoing calls. It is also possible for lines to fail for reasons beyond Bullion Direct's control. Because of this, Customer is advised and will be responsible to have alternative methods to communicate with Bullion Direct (e.g., telegraph, courier messenger service, etc.) should it become necessary to do so.

In purchases of commodities on credit, it is possible for Customer to lose substantially more than his or her initial down payment. In such cases, Customer can lose up to the full amount of the commodities purchased.

Customer's account with Bullion Direct is self-directed. This means Customer makes and is responsible for all trading decisions for Customer's account. If Customer ever believes that a transaction has been entered for Customer's account with Bullion Direct that has not been authorized by Customer, or that a transaction has been accepted by Bullion Direct for Customer's account and has not been executed by Bullion Direct, Customer will immediately notify Bullion Direct's Compliance Department by email at compliance@Bullion Direct.com and immediately confirm such notification in writing to Bullion Direct at 700 Lavaca St. LL 1 Austin, TX 78701. If Customer fails to make such notification on the business day on which the event first became known to Customer, Customer waives all right to contest such order, matter or omission and Customer's account will stand, as in, as of the end of such business day. Tax consequences of transactions with Bullion Direct are the sole responsibility of Customer.

10. Security Agreement.

a. Property and Rights Subject to Security Interest. As security for the performance of all of Customer's obligations hereunder, whether now existing or hereafter incurred, Customer hereby grants Bullion Direct a security interest in each and every commodity purchased by Customer from Bullion Direct and all other sums, property and rights, whether individually or jointly held, at any time standing to Customer's credit on Bullion Direct's books or at any time in Bullion Direct's possession or Depository's possession, for any purpose.

b. Bullion Direct Rights and Remedies. Upon default under this Agreement, Bullion Direct shall have, in addition to all other rights and remedies conferred on Bullion Direct hereby, all rights and remedies of a secured party under the Texas Business and Commerce Code.

c. UCC Filing. Bullion Direct may file this Agreement and such other documents as Bullion Direct may request, which Customer agrees to provide, in order to perfect Bullion Direct's security interest hereunder.

11. Acceleration Upon Default.

Upon default by Customer, Bullion Direct may, at its election, declare any or all of Customer's obligations immediately due and payable.

12. Miscellaneous.

a. Notices. All communications shall be sent to Bullion Direct at compliance@Bullion Direct.com or 700 Lavaca St. LL 1 Austin, TX 78701 and to Customer at the address set forth following the signatures to this Agreement or such other address subsequently provided to Bullion Direct by Customer in writing. All communications given by Bullion Direct to Customer by mail shall be effective 48 hours after deposit in the United States mail, postage prepaid, or upon receipt, whichever is earlier; if hand delivered, when delivered to Customer's address; if telephonic, at the time of such phone conversation or facsimile transmission; if telegraphic, when deposited with a public telegraph company for transmittal, charges prepaid; or if by e-mail, when the e-mail is sent to the e-mail address provided by Customer.

b. Disclosure of Information to Sterling Trust Company. Information concerning CustomerÕs account, including balances and trading activity, will be disclosed to Sterling Trust Company, Custodian FBO: (Customer) IRA.

c. Force Majeure. In the event of adverse conditions in the market place or other factors beyond the control of Bullion Direct, including, but not limited to, acts of God, national emergencies, adverse governmental actions, or suspension of trading of silver, gold, platinum or palladium futures contracts by U.S. commodity exchanges, or the delivery of the commodities underlying such contracts, or the failure or delay of suppliers, the maximum time for delivery of such commodities may be extended indefinitely during the period of such adverse circumstances. Bullion Direct will not be responsible for delays or failures in the transmission, receipt or execution of orders, payments, deliveries or information due to the incapacity or failure of computer, transmission or communication facilities which are beyond the control of Bullion Direct.

d. Possible Equipment Failure - Transactions executed through the Bullion Direct system are at risk from the potential interruption or failure of the Bullion Direct computer system. In that event, it might not be possible to enter new orders or to cancel existing orders for some time. In addition, a system interruption or failure could result in the existing queue being lost. Under such circumstances, it will be necessary for orders to be re-entered, and each one will be given priority according to the price and time at which it is re-entered into the system. Because of this, a customer may designate when an order is placed whether it is to be purged from the system failure.

e. Limitation of Liability - Bullion Direct will not be liable for losses as a result of any failure of or delay in the system, except that (1) Bullion Direct may be held liable for willful or wanton misconduct, and (2) Bullion Direct may be held liable for negligent actions of its employees, up to $100,000.00. Bullion Direct will not be responsible for any consequential damages.

f. Entire Agreement. This Agreement constitutes the entire and whole Agreement among its parties and is intended as a complete and exclusive statement of the terms of their agreement. This Agreement may be amended only upon execution of a subsequent agreement between the parties or upon Customer's failure to object, within 10 days, to modifications contained in written material sent to Customer by Bullion Direct. This Agreement shall supersede any oral representations between the parties.

g. Individual Authority of Customer. Any party accepting this Agreement as Customer is authorized to deal fully with the account opened hereunder, for purposes of placing orders, receiving funds or commodities or otherwise. Any action taken by any such party shall be binding on all other parties with an interest in that account. Each such party shall hold Bullion Direct harmless for relying hereon. All obligations of Customer under this Agreement are joint and several.

h. Electronic Recordation. Bullion Direct may electronically record any conversation between Bullion Direct, its employees or agents and Customer or his agents.

i. Waiver. Failure to exercise or delay in exercising any right, power or remedy hereunder by Bullion Direct shall not operate as a waiver thereof, nor shall any single or partial exercise of any right, power or remedy of Bullion Direct hereunder preclude any other or future exercise thereof or the exercise of any other right, power or remedy.

j. Depository Indemnification. Customer agrees that Depository may act upon any instruction received from Bullion Direct concerning delivery, transfer, sale or disposition of commodities held by Depository on Customer's behalf. Customer further agrees to indemnify the Depository from any liability to Customer for actions taken by Depository in conformity with such instruction.

k. Governing Law. This Agreement is entered into in accordance with and shall be governed by Texas law; provided that, if any Texas law shall dictate that the laws of another jurisdiction be applied in any proceeding, such Texas laws shall be superseded by this paragraph and the remaining laws of Texas shall nonetheless be applied in such proceeding.

l. Location of Legal Proceedings. Any proceeding brought by Customer relating to this Agreement shall be commenced in Travis County, Texas.

m. Texas Contract: The formation of this Agreement constitutes the making of a contract within Travis County, Texas, notwithstanding the manner, timing or location of the delivery of receipt of the acceptance of this Agreement by either party hereto. The making of this contract will cause the following events, among others, to occur in Travis, County, Texas; the solicitation and negotiation of this contract will have taken place and been completed in Travis County, Texas; the contract will be executed in Travis County, Texas; initial payment monies and any subsequent monies paid by Customer will be delivered to and paid in Travis County, Texas; and written confirmation of each transaction will be provided from Travis County, Texas. Customer and Bullion Direct agree that Travis County, Texas is a mutually and reasonably convenient place for any hearing concerning disputes relating to this Agreement, and agree to submit to the jurisdiction of courts in Travis County, Texas with respect to any claim or controversy relating to this Agreement.

n. Waiver of Jury Trial. By signing this Agreement, Customer waives Customer's right to a jury trial and agrees to pursue matters solely before a judge or magistrate with respect to any claim, action or proceeding brought by Customer against Bullion Direct, its partners, employees, representatives, Customer, agents or affiliates, past or present, concerning any transaction between Customer and Bullion Direct, or the construction, performance or breach of this or any other agreement between Customer and Bullion Direct.

o. Assignment. The provisions of this Agreement shall be continuous and shall inure to the benefit of Bullion Direct, its successors and assigns, and shall be binding upon Customer and/or the estate, personal representatives, administrators and successors of Customer. Bullion Direct may assign its rights and delegate its duties as to any or all transactions under this Agreement. Customer shall not delegate any obligations hereunder without the prior written consent of a duly authorized officer of Bullion Direct, and any attempt at such delegation without such consent shall be void.

p. Transaction Charges. Customer agrees that to the extent that any finance or other charges imposed by Bullion Direct are held to be in excess of those allowable under any law, such charges shall be reduced to the legal maximum.

q. Severability. In the event that any provisions of this Agreement shall be determined by a court of competent jurisdiction to be unenforceable in any jurisdictions, such provisions shall be unenforceable in that jurisdiction and the remainder of this Agreement shall remain binding upon the parties as if such provisions were not contained herein. The enforceability of such provisions shall otherwise be unaffected and remain enforceable in all other jurisdictions.

r. Obligations Due in U.S. Currency. Customers shall pay all obligations owing under this Agreement in the currency of the United States of America.

s. Taxpayer I.D. Number. Customer certifies under the penalties of perjury that the Taxpayer Identification Number (Social Security Number) or Employer Identification Number provided below is correct and that Customer has not been notified by the Internal Revenue Service that he is a "payee under-reporter" under section 3406(a)(1)(c) of the Internal Revenue Code.

t. Termination. Bullion Direct has the right to terminate the terms of this agreement upon 2 days notice to Customer.