Risk & Simulated Performance Disclosure

DAS Replay — operated by Shark Belly Industries LLC, a New Mexico limited liability company 1209 Mountain Road Pl NE, Ste H, Albuquerque, NM 87110 · hello@email.dasreplay.com

Short forms

Short form (footer, share pages, emails, marketing that shows P&L):

Simulated results on historical data. No real money traded. Not investment advice; not a broker or adviser. Hypothetical performance has inherent limitations and does not guarantee future results. Trading involves substantial risk of loss. See dasreplay.com/risk-disclosure.

Micro label (share-card images, video overlays, social stills):

SIMULATED RESULTS · Hypothetical, not real trading · dasreplay.com/risk-disclosure

1. What DAS Replay is

In short: DAS Replay is training software. It replays past market data so you can practice. No real money is involved.

1.1. DAS Replay is a market-replay simulator for education and practice. It plays back historical market data on a clock, and you place practice orders against it.

1.2. No real money is traded. Your orders are never sent to any broker, exchange or trading venue. DAS Replay does not hold funds, open brokerage accounts, route orders, or connect to your brokerage account.

1.3. Every balance, position, fill and profit or loss (P&L) shown in DAS Replay is simulated.

2. Not investment advice; not a broker or adviser

In short: We teach with a simulator. We don’t tell anyone what to trade, and we are not licensed to.

2.1. Not advice. Nothing in DAS Replay is investment, trading, financial, tax or legal advice. This includes the app, the help center, our emails, blog, social media posts and videos. Nothing is a recommendation or solicitation to buy, sell or hold any security, futures contract, currency, commodity or other instrument.

2.2. Not a regulated firm. Shark Belly Industries LLC is not a broker-dealer, futures commission merchant, introducing broker or retail foreign exchange dealer. It is not an investment adviser, commodity trading advisor (CTA) or commodity pool operator. It is not registered with the SEC, CFTC, FINRA, NFA or any state securities regulator.

2.3. Impersonal and educational. The same content and tools are offered to every user. Nothing is tailored to your finances, your positions, your goals or your real-world trading account. We do not manage or direct anyone’s account.

2.4. Instruments are practice material. Our library includes US equities, forex pairs, spot gold and silver, and futures. We choose them because they provide practice data. Their inclusion is not an endorsement or recommendation of any instrument.

2.5. Scanner alerts are historical and algorithmic. Some desks show scanner alerts, such as HOD Momentum, Top Gainers and Small-Cap Momentum.

DAS Replay’s own algorithm computes these alerts over historical market data. They replay on past dates only.
They are not live signals and not recommendations.
Every user who replays the same date sees the same alerts. Nothing is selected for you.
They are not a reproduction of any third-party scanner (for example, Trade Ideas or a broker’s scanner).
A ticker appearing in a scanner means only that it met a mechanical rule on that past date.
When our product or marketing says an alert “fired”, “triggered” or was “live”, it means the moment on the recorded tape at which our algorithm flagged the ticker. It does not mean a real-time alert was sent, and it does not mean the alert matches what a live scanner showed at the time.

2.6. Your decisions are your own. You alone are responsible for your trading and investment decisions, including any made after using DAS Replay. Before trading with real money, consider consulting a licensed financial professional who knows your circumstances.

3. Trading is risky

In short: Most retail day traders lose money. Leverage can cost you more than you put in.

3.1. Trading securities, futures, forex and metals involves substantial risk of loss. It is not suitable for everyone. Only trade money you can afford to lose.

3.2. Day trading. Most retail day traders lose money. Fast markets, gaps, trading halts, wide spreads and thin liquidity can cause losses much larger than you planned. Small-cap and low-float stocks are especially volatile and can move many percent in seconds.

3.3. Leverage and margin. Leveraged products magnify gains and losses. With margin accounts, futures and leveraged forex or metals, you can lose more than you deposit. You may also be required to add funds at short notice, or be liquidated at a loss.

3.4. Futures. Futures are highly leveraged. A small price move can cause a large loss relative to the margin posted, and positions may be liquidated without your consent.

3.5. Forex and spot metals. Currency and metals prices move around the clock and can gap. Leverage, financing (swap) charges and the rules in your country vary by jurisdiction and provider.

Practicing a product in DAS Replay does not mean it is available to you, legal for you, or available at the leverage shown.
Forex desk. The simulated margin model is patterned on US retail forex margin (for example, 2% on major pairs, or 50:1). It is a model. Your broker’s margin, leverage and closeout rules may differ.
Metals desk. The simulated margin model caps leverage at 20:1 for spot gold (XAU) and 10:1 for spot silver (XAG). These caps are patterned on the retail limits used in the European Union. They are not an NFA or CFTC rule.
Not an offer. DAS Replay does not offer, arrange or recommend leveraged metals or forex trading. Leveraged over-the-counter spot metals are generally not available to US retail customers.

3.6. Short selling. Short sales carry theoretically unlimited loss. They can also be affected by borrow availability, locate and borrow fees, short-sale restrictions and forced buy-ins.

3.7. Skills do not transfer automatically. Practice in a simulator does not remove the emotional, financial and execution pressures of live trading. Good simulated results do not mean you will trade profitably with real money.

4. Simulated and hypothetical performance

In short: Everything you see as P&L in DAS Replay, on share cards or in our marketing is simulated. It is not a real trading record, and it predicts nothing.

4.1. Required-form legend (CFTC Rule 4.41(b)(1)(i))

We adopt the following legend for any simulated or hypothetical results we show, including in-app results, share cards, challenges and marketing:

These results are based on simulated or hypothetical performance results that have certain inherent limitations. Unlike the results shown in an actual performance record, these results do not represent actual trading. Also, because these trades have not actually been executed, these results may have under-or over-compensated for the impact, if any, of certain market factors, such as lack of liquidity. Simulated or hypothetical trading programs in general are also subject to the fact that they are designed with the benefit of hindsight. No representation is being made that any account will or is likely to achieve profits or losses similar to these being shown.

4.2. In plain English

Not real money. No trade in DAS Replay was ever executed in a real market.
Fills are estimates. A model decides whether and at what price your order “fills”. A real market could have filled you at a worse price, a better price, or not at all.
Hindsight. You are replaying the past. Even when the future is hidden from you, choosing which days and tickers to replay, and replaying a day more than once, gives an advantage that live traders do not have.
No prediction. A simulated profit, win rate or return does not mean you, or anyone, will earn similar results with real money.
Past performance, real or simulated, does not guarantee future results.

4.3. What is real and what is simulated

The table shows how each part of the desk is produced today. “Historical data” means data we license from third-party market-data vendors and replay as it was recorded. We do not guarantee that it is complete or accurate (see §4.5).

Element	Real, simulated or derived	Notes
Equity trades (time & sales), best bid/offer (NBBO), bars	Real historical data	Replayed from vendor records. Not live.
Halt / short-sale-restriction state	Derived from real data	Inferred from the historical tape. Halts are inferred from trade condition codes and can be missed or mistimed.
News headlines	Real historical data	Revealed on the replay clock at their recorded time.
Company fundamentals	Real historical data	From a third-party vendor.
Forex and spot metals quotes	Real historical data	Quotes only. The feed has no trade sizes. “Volume” on these desks is a count of quote updates, not traded volume.
Futures trades and top-of-book quotes (L1)	Real historical data	No real depth beyond the best bid/offer.
Futures orderflow (CVD, volume profile, aggressor side)	Derived	Computed by us from historical trades.
Continuous futures chart	Derived (display only)	Contracts are stitched together for display. Not back-adjusted.
Scanner alerts	Derived	Our own algorithm run over historical data (§2.5). Alert timing can differ from what a live scanner would have shown.
Float / shares outstanding	Derived	Estimated from SEC filings and vendor snapshots. Some values are extracted from filings by an AI language model and may contain errors.
Your orders, fills and P&L	Simulated	Produced by our fill model. When a resting limit order fills from the queue, the filled quantity is trimmed by a small random amount (up to 5%), so the same order can fill in slightly different pieces.
Order latency	Simulated	Pseudo-random delays drawn from the latency profile you choose. Repeatable for the same session.
Queue position	Simulated	The real queue is unknown. We estimate your place in line.
Marketable-order misses	Simulated	On the equities desk, and for marketable futures limit orders, about 3% of marketable orders are modeled as routing misses. They rest as limit orders instead of filling at once.
Fast-market slippage	Simulated	When the tape moved against your order quickly just before it filled, a fixed price penalty is added to the fill (never past your limit price).
”Walking the book” (fills beyond the best price)	Simulated	Price levels beyond the best bid/offer are modeled, not recorded.
Forex and metals fills	Simulated	Fills follow the recorded quotes after a modeled delay, with a modeled cap on the size that can fill at each quote update. Large orders fill in pieces over time.
Equity Level 2 depth and market-maker IDs (MMIDs)	Simulated (display only)	The inside row shows the real NBBO price, size and venue. Every level beyond the inside quote, and its MMIDs, is built for display. Not a record of the real book, and never used to decide your fills.
Short locates, borrow / hard-to-borrow status and fees	Simulated	No historical borrow data is used. Availability and fees are modeled.
Margin, buying power, liquidation	Simulated	Modeled rules. They may differ from any broker’s.
Metals leverage caps	Simulated	A modeled regime (20:1 gold, 10:1 silver, patterned on EU retail limits). It may not match what any provider offers you (§3.5).
Metals overnight financing	Not charged	A modeling choice, not a broker record.
Forex overnight financing	Simulated	Modeled from the two currencies’ central-bank policy-rate differential (published rate data) less a 1% a year markup on both sides, so most positions pay. The Wednesday rollover counts triple. Not any broker’s swap table.
Futures commissions and margins	Simulated	Default schedules. For some contracts (COMEX GC, MGC, SI, SIL) the values are provisional placeholders.
Starting balance and account	Simulated	Chosen by you or set by a challenge. Not real funds.

4.4. Known model limitations

Like any simulator, our fill model simplifies real markets. The known limitations are:

No market impact. Your simulated orders never move the replayed market. In reality, especially in thin stocks, a large order can push the price against you.
Depth is modeled. Beyond the best bid/offer, we assume liquidity similar to the top of book. In thin small caps this can be optimistic: real depth may be thinner, and real fills worse.
Queue and latency are estimates. Your place in line, your order delays, routing misses and fast-market slippage are modeled, not measured.
Not yet validated against real executions. We have not yet completed a systematic comparison of simulated fills with real broker executions. We design the model to lean against the trader when uncertain, but we cannot guarantee it does so in every case.
Data gaps and errors. Vendor data can have missing periods, bad prints or corrections. Some dates, tickers or contracts may be unavailable, incomplete or mislabeled. Futures dates are available only where prepared, and spot-metals history begins in August 2025. Halts are inferred from trade codes and can be missed.
Float and corporate actions. Float estimates can be wrong. This includes around reverse splits and for foreign issuers.
Scanner timing. Historical alerts are computed after the fact by our algorithm. They can fire earlier or later than a live scanner would have, and can include or omit names a live scanner would not.
Service interruptions. A server restart, network drop or deploy can end or reset a session. Positions, P&L and locates in progress may be lost.
Rewinding. Rewinding or jumping within a session can change or reset realized results, and some order history may not be kept.
Forex and metals quotes. Quotes come from one data vendor’s records. Spreads may be wider or narrower than your broker’s, and fill sizes are capped by a model, not by recorded trades.
Other rules not modeled. Some real-world rules and costs may be simplified or absent. Examples: pattern-day-trader rules, exchange and regulatory fees, taxes, and broker-specific order handling.

4.5. Data accuracy

We receive market data, news and fundamentals from third parties and do not independently verify it. It is provided “as is”, may contain errors or omissions, and is for practice only. Do not rely on it for real trading decisions or for any regulatory, tax or reporting purpose.

In short: Any P&L on a share card, challenge or our website is simulated or illustrative, never a real trading result.

5.1. Share cards and spectate links. Share cards, spectate pages and challenge or head-to-head cards show results from simulated sessions.

“Verified” or “computed by the simulator” means only one thing: the figures were calculated by DAS Replay from the user’s simulated fills, rather than typed in.
It does not mean the results were achieved in a real market, audited, or typical.

5.2. Challenges. A challenge replays the same historical session for each participant with pinned settings. Challenge results are simulated. Winning a challenge does not indicate real-world trading skill or future results. Challenges currently carry no prizes.

5.3. Examples on our website and social media. P&L figures, calendars, account balances and trade statistics shown in marketing are illustrative examples from the simulator. They are not real trading results, not typical results, and not a promise of any result.

5.4. Third-party results. We may refer to publicly reported results of other traders. We do not verify them, and they are not typical. They do not suggest that you will achieve similar results by using DAS Replay.

5.5. If you share your results, keep them labeled as simulated. Do not present them as real trading performance (see our Terms).

6. Beta and availability

DAS Replay is in active development. Features, data coverage and the fill model change over time, so results from different periods may not be comparable. See our Terms for service availability.

7. Contact

Questions about this disclosure: hello@email.dasreplay.com, or Shark Belly Industries LLC, 1209 Mountain Road Pl NE, Ste H, Albuquerque, NM 87110.