Webull Canada Crypto Limited

Webull Canada Crypto Limited (Webull) is admitted to membership in the Canadian Investment Regulatory Organization, as an Investment dealer, effective June 17, 2026.

The head office is located at 401-320 Bay Street, Toronto ON M5H 0B6

Head Office Telephone: +1-888-228-0958

The Executives are:

• CONSTANTINO, Michael - Chief Executive Officer
• COE, Kirk - Chief Compliance Officer
• ENGELSOHN, Moshe- Chief Financial Officer

Concurrent with the approval of the membership of Webull, the CIRO Board of Directors also granted exemptive relief from certain requirements of the Investment Dealer and Partially Consolidated Rules (IDPC Rules) to Webull. In particular, the Board provided:

• relief from the requirement under IDPC Rule 4456 to maintain a financial institution bond (“FIB insurance") providing coverage for all types of losses specified in that Rule, subject to the conditions described below.
• relief from the requirement under IDPC Rule subsection 4455(1) to have mail insurance that covers 100% of losses from any outgoing shipments of negotiable or non-negotiable securities by registered mail.

1. Authority to Grant Exemptions

IDPC Rule 1302 permits the CIRO Board of Directors to exempt a Dealer Member from any provision of the Rules where it is satisfied that to do so would not be prejudicial to the interests of Dealer Members, their clients or the public. In granting an exemption, the Board may impose such terms and conditions as are considered necessary.

2. Exemptions Granted and Conditions

As is standard for exemption orders of this type, the exemption order also specified that:

• The Board of Directors reserves the right to revoke the exemptive relief granted to Webull, at any time, upon notice to the applicant.
• The exemptive relief is void upon the earliest of the following taking place:
  • The implementation of any material amendments to the rules by CIRO or the provincial securities commissions relating to insurance requirements. CIRO, and not Webull, will determine whether any rule amendments implemented are considered to be related to insurance requirements and are considered to be material, thus rendering this exemption order void.
  • Webull’s breach of any of the representations made in the Application,
  • Webull’s breach of any of the conditions relating to the exemptive relief granted, with respect to the Insurance Exemption.

Staff will only recommend approval of exemptive relief of this type under exceptional circumstances, and where the Dealer Member demonstrates that it has taken all reasonable steps to comply with CIRO Rules.

In addition, in connection with Webull’s application for membership, Webull made certain representations and agreed to provide certain undertakings to CIRO.

Insurance Exemption

1. The relief and its conditions apply only to Webull Canada Crypto Limited’s (Webull’s) distribution of crypto contracts and operation of a platform that facilitates the buying, selling, and holding of crypto assets.
2. Webull shall obtain a Financial Insurance Bond (FIB) policy that provides coverage for all its crypto assets held in internal custody as well as external custody (currently Coinbase Custody Trust Company, LLC) once one becomes available to Webull.
3. Webull will make best efforts to promptly obtain additional or excess FIB coverage with respect to crypto assets held in cold storage to address any coverage deficiency.
4. Webull shall obtain an FIB policy pertaining to crypto assets held that satisfies the following:
   1. the loss coverage under the FIB policy must be equal to CIRO’s minimum insurance coverage formula for assets held
   2. the terms and conditions of the FIB policy must be acceptable to CIRO
   3. any insurance deductible under the FIB policy must be deducted when Webull determines its risk adjusted capital.
5. Webull must ensure that a Webull Trust Account is opened at an “Acceptable Institution” for the purposes of IDPC Rule 1201 and Form 1 and is operated in a manner acceptable to CIRO.
6. Webull must, in the event it determines that it has a coverage deficiency in any of its securities locations, fund a Webull Trust Account dedicated to covering an amount greater than or equal to CIRO’s minimum FIB insurance coverage formula for client assets.
7. Webull is prohibited from using client free credit cash balances to fund the Webull Trust Account.
8. When determining its risk adjusted capital, Webull must deduct the Trust Account balance.
9. Webull must obtain and review the SOC 2 Type 2 reports from its custodians on an annual basis, and obtain an annual SOC 2 report, that includes testing that covers the applicable controls securing its internal custody solution.

For questions and further information regarding this Bulletin, please contact [email protected].