Terms and Conditions

CONSUMER CARDHOLDER AGREEMENT

The purpose of this Agreement is to inform you of certain rights which you have under the Electronic Fund Transfers Act (EFTA) and to inform you of the terms and conditions on the use of your personal card.

As used in this brochure, the words “we“, “our” and “us” means IPN B, LLC doing business as Paybotic Financial and the words “you” and “your” means the Cardholder. The word “Card” refers to Mastercard, unless otherwise specifically described. By signing, accepting and using your card, you agree to the terms and conditions of this Disclosure and Agreement. This Disclosure Statement/Account Agreement (the “Agreement“) is in addition to the Terms and Conditions applicable to your account(s) (“Account“) as outlined in the Deposit Account Disclosure.

1. Use of your Card: When you use your Card to make an authorized transaction, you are authorizing us to withdraw funds from your account for the amount of the transaction. You will be assigned a Personal Identification Number (“PIN“) for use with your Card. You acknowledge that the PIN which you use with your Card is an identification code that is personal and confidential and that the use of the PIN is a security method by which we are helping you to maintain the security of the Account(s). Therefore, YOU AGREE TO TAKE ALL REASONABLE PRECAUTIONS THAT NO ONE ELSE LEARNS YOUR PIN.ATM Transactions: You may use your Card with your PIN at designated ATMs to conduct any of the following transactions for each of the Checking, Savings and Money Market Accounts you have requested to be accessed by your Card: (a) withdraw cash; and (b) perform account balance inquiries.Purchase (POS) Transaction: You may use your Card with your PIN at designated retail establishments (“Merchant“) to purchase goods and services and/or to obtain cash where permitted by the Merchant (“Purchase.”) The amount of such Purchases (including any cash obtained) will be deducted from your primary Account.Mastercard Transactions: You may use your Card to Purchase goods and services everywhere that Mastercard debit Cards are accepted. When you use your Card to make Purchases at Merchants authorized to accept Mastercard debit Cards, the Merchant will obtain authorization for the amount of the transaction and if approved, we will reduce the amount of the available balance in your Account by placing a temporary hold for the amount of the transaction. When the actual transaction is processed by us, your Account will be debited and the temporary hold will be released. You agree to hold us harmless if we dishonor other POS or ATM transactions while the temporary hold is in place.
2. Limitations on the Use of Your Card. You may use your Card to withdraw/spend funds up to $5,000 each business day inclusive of PIN Purchase Transactions at Merchants that accept Mastercard debit cards and ATM withdrawals. In addition, you may use your Card to make ATM withdrawals up to $2,000 each business day (4 transactions per day for a maximum of $500 for each transaction.) Each Purchase and/or ATM withdrawal will be debited from your primary checking Account provided the funds are available in your Account.You will be denied the use of your Card if you exceed the daily withdrawal or Purchase limit, do not have adequate funds available in your Account, you do not enter the correct PIN or you exceed the frequency of usage limitation. For your security, if we notice excessive use of your Card that appears suspicious, we may restrict further use of your Card until we confirm the activity with you.
3. POS Purchases Right to Stop Payment. You are not permitted to stop payment on any Purchases made using your Card. Any claims regarding merchandise or services purchased using your Card must be resolved by you directly with the Merchant. If you assert a claim against a Merchant, you are still obligated to pay us the total amount of the sales slip.
4. Purchase Refunds. Any refund made to you by a Merchant must be made by credit to your Account. No cash refunds are permitted.
5. Illegal Activities. You agree not to use your Card or Account to engage in activities deemed illegal by federal and/or state laws, including but not limited to internet gaming. If you use your Card to engage in activities deemed to be illegal, you understand you will be liable for any transactions conducted.
6. Recurring Charges. If you have provided your Card number to a Merchant for payments to be automatically charged to your Account on a recurring basis (for example monthly membership fees to an internet access provider), it is your responsibility to cancel your authorization with the Merchant before closing your Account with us. If you fail to do so, you will be liable for all recurring transactions received after you have closed the Account.
7. Liability for Unauthorized Use. CONTACT US AT ONCE if you believe your Card, your PIN, or both has been lost or stolen or used without your permission.You could lose all money in your Account(s) (plus your maximum overdraft line of credit, if applicable) if you take no action to notify us of a loss. If you notify us within two (2) business days after learning of the loss, theft or unauthorized use of your Card, you can lose no more than $50.00 if someone used your Card to make unauthorized withdrawals at ATMs or Purchases not processed through the Mastercard network.If you do not contact us within two (2) business days after you learn of a loss, theft or unauthorized use and we can prove that we could have prevented someone from using your Card and PIN without your permission had you contacted us, you could lose as much as $500.00 for unauthorized ATM withdrawals and Purchases not processed through the Mastercard network.Also, if your balance history shows transfers or Purchases that you did not make and you do not contact us within sixty (60) days after noticing the error, you may not get back money lost after the sixty (60) day deadline, if we can prove that had you contacted us the losses would have been prevented.

   In accordance with Mastercard regulations, you will not be liable for any unauthorized point of sale (“POS“) Purchases processed as credit transactions through the Mastercard network. You must notify us of any unauthorized POS Purchases within sixty (60) days after the first statement on which the unauthorized transaction(s) appeared was mailed to you.

   If you assert a claim regarding the loss, theft or unauthorized use of your Card, you agree to assist us in our investigation and agree to provide us with all pertinent information. You also agree to provide us with police reports and any other documentation we may request.

   YOU AGREE THAT IF YOU GIVE YOUR CARD AND PIN TO SOMEONE ELSE TO USE, YOU ARE AUTHORIZING THEM TO ACT ON YOUR BEHALF AND YOU WILL BE RESPONSIBLE FOR ANY USE OF THE CARD BY THEM.

8. Loss or Theft of Your Card: If you believe your Card or PIN has been lost or stolen or that an unauthorized transfer or Purchase from any of your Accounts has occurred or may occur, call us at 844-442-0420 or email us at support@payboticfinancial.com.
9. Business Days. Our business days are Monday through Friday, excluding Federal Holidays.
10. In Case of Errors or Questions About Your Transactions. Telephone us at 844-442-0420 or email us at support@payboticfinancial.com as soon as you can, if you think your statement or receipt is wrong or if you need more information about a transaction listed on the statement or receipt. We must hear from you no later than sixty (60) days after we sent you the FIRST statement on which the problem or error appeared. You must provide us with the following:
    1. Your name, Account number and Card number.
    2. Describe the error or the transaction you are unsure about, and explain as clearly as you can why you believe it is an error or why you need more information; and
    3. Tell us the dollar amount of the suspected error.If you tell us orally, we may require that you send us your complaint or question in writing within ten (10) business days. We will tell you the results of our investigation within ten (10) business days (twenty [20] business days if the transfer occurred within (30) days after the first deposit to the Account was made) after we receive your request and will correct any error promptly. If we need more time, however, we may take up to forty-five (45) days (ninety (90) days if the transfer involved a foreign initiated transfer, a POS transaction or occurred within thirty (30) days after the first deposit to the account was made) to investigate your complaint or question. If we decide to do this, we will credit your account within ten (10) business days (twenty (20) business days if the transfer occurred within thirty (30) days after the first deposit to the Account was made), so that you will have the use of the money during the time it takes us to complete our investigation. If we ask you to put your complaint or question in writing and we do not receive it in writing within ten (10) business days, we may not credit your Account.If we decide that there is no error, we will send you a written explanation within three (3) business days after we finish our investigation. You may ask for copies of the documents that we used in our investigation. We will debit your Account for any funds we had provisionally credited while we conducted our investigation. We will continue to honor checks, drafts or similar paper instruments payable to third parties and preauthorized transfers from your Account using these funds for five (5) business days after we send you our written explanation.
11. Disclosure of Account Information. We will not disclose information about your account or the transactions you make, except:
    1. Where it is necessary to complete transactions;
    2. To verify the existence and standing of your Account with us upon the request of a third party, such as a credit bureau;
    3. To comply with government agency or court orders;
    4. In accordance with your written permission;
12. Our Liability for Failure to Complete an Electronic Fund Transfer Transaction. If we fail to complete a transaction on time or in the correct amount, when properly instructed by you, we will be liable for damages caused by our failure unless:
    1. There are insufficient funds in your Account to complete the transaction through no fault of ours;
    2. The funds in your Account are subject to legal process;
    3. The transaction you request would exceed the funds in your Account plus any available overdraft credit;
    4. The ATM has insufficient cash to complete the transaction;
    5. Your Card has been reported lost or stolen and you are using the reported Card;
    6. We have a reason to believe that the transaction requested is unauthorized;
    7. The failure is due to an equipment breakdown which you knew about when you started the transaction;
    8. The failure was caused by circumstances beyond our control, despite reasonable precautions we have taken, such as power outages, flood, fire or other catastrophes;
    9. You attempt to complete a transaction which is not a permissible transaction listed above; or
    10. The transaction would exceed your daily withdrawal limits.In any case, we shall only be liable for actual proven damages if the failure to make the transaction resulted from a bona fide error despite our procedures to avoid such errors.
13. Liability. If the Card is issued for a joint Account, each of you agrees to be jointly and severally liable under the terms of this Agreement and the Agreement for such Account.You agree that if you make deposits to your Account(s) with items other than cash (checks, drafts or other items, if applicable) and we make funds available to you from such deposits prior to their collection, we may deduct the amounts of such funds from your Account(s) which are not collected or, if the funds in your Account(s) are insufficient at such time, you will promptly pay to us any amount of such funds which are not collected.
14. Amendment of this Agreement. You agree that from time to time we may amend or change the terms of this Agreement. We may do so by notifying you in writing of such amendments or changes and your use of your Card after the effective date of any such amendment or change shall constitute your acceptance of and Agreement to such amendment or change.
15. Ownership. You agree that any Card we issue is our property and you will surrender it to us upon our request. You agree we may terminate your Card at any time without notice to you.
16. Notices. Notices required to be mailed by us under this Agreement will be mailed to you at the most recent address in our records.
17. Cancellation of Card. You may cancel your Card at any time by returning the Card to us, along with a written request to cancel the Card. We may cancel this Agreement at any time. You will be responsible for all transactions completed prior to the cancellation of your Card or this Agreement.

PRIVACY NOTICE

ACH AUTHORIZATION & AGREEMENT DISCLOSURE

ACH AUTHORIZATION AND DISCLOSURE

ACH debit payments are the transfer of funds from the bank account you have indicated for the purpose of making a payment for your Merchant as defined below.

By submitting your order or saving your bank account herein, you authorize your Merchant, and, if applicable, your Merchant’s affiliated entities (collectively "Merchant") to debit the bank account specified below for any amount owed for charges arising from your use of the Merchant's services and/or purchase of products from the Merchant, pursuant to the Merchant’s website and terms, until this authorization is revoked.

If you use the Merchant’s services or purchase more than one of the Merchant’s products periodically pursuant to the Merchant’s terms, you authorize the Merchant to debit your bank account periodically. Payments that fall outside of the periodic debits authorized above will only be debited after your authorization is obtained.

You may amend or cancel this authorization at any time by providing notice to the Merchant with thirty (30) days’ notice prior to the scheduled debit.

ERROR RESOLUTION DISCLOSURE:

IN CASE OF ERRORS OR QUESTIONS ABOUT YOUR ELECTRONIC TRANSFERS

For purposes of this disclosure, the terms "you" and "your" refer to the customer and the terms "our", "we", and "us" refer to IPN, LLC doing business as Paybotic ("Paybotic.") The term "account" includes any demand deposit, negotiable order of withdrawal account, savings deposit, money market account or other non-time deposit account.

Telephone us at (833)420-7300, write us at 1800 S Australian Ave, West Palm Beach, FL 33409, or email us at support@payboticfinancial.com, as soon as you can, if you think your statement or receipt is wrong or if you need more information about a transfer on the statement or receipt. We must hear from you no later than sixty (60) days after we sent you the FIRST statement on which the error or problem appeared.

1. Tell us your name and account number (if any).
2. Describe the error or the transfer you are unsure about and explain as clearly as you can why you believe it is an error or why you need more information.
3. Tell us the dollar amount of the suspected error and the date when the transfer took place.

If you tell us orally, we may require that you send us your complaint or question in writing within ten (10) business days from the date you orally represented the issue to us.

We will determine whether an error occurred within ten (10) business days after we hear from you and will correct any confirmed error promptly. If we need more time, however, we may take up to forty-five (45) days to investigate your complaint or question. If we decide to do this, we will provide you with a provisional credit to your account within ten (10) business days for the amount you think is in error so that you will have use of the money during the time it takes us to complete our investigation. If we ask you to put your complaint or question in writing and we do not receive it within ten (10) business days, we may not provide a provisional credit to your account

For errors involving new accounts, point-of-sale, or foreign-initiated transactions, we may take up to ninety (90) days to investigate your complaint or question. For new accounts, we may take up to twenty (20) business days to credit your account for the amount you think is in error following confirmation thereof.

We will advise you of the results of our investigation within three (3) business days after completion. If we decide that an error did not occur, we will withdraw any previously issued provisional credit placed in your account and send you a written explanation of our decision. Note that you may ask for copies of the documents that we used in our investigation.

REG DD DISCLOSURE

For purposes of this disclosure, the terms "you" and "your" refer to the customer and the terms "our", "we", and "us" refer to IPN B, LLC doing business as Paybotic Financial ("Paybotic.") The term "account" includes any demand deposit, negotiable order of withdrawal account, savings deposit, money market account or other non-time deposit account.

Your Paybotic account is not an interest-bearing account.

For all interest-bearing accounts provided by Paybotic, the following will apply:

The interest rate and annual percentage yield associated with an interest-bearing account may change while it is open.

Current Rate Information.
The interest rate on an interest-bearing account can fluctuate at any given time depending on market rates. The interest rate on an interest-bearing account is XX% with an annual percentage yield of XX%.

Determination of Rate.
At our discretion, we may change the interest rate on an interest-bearing account.

Frequency of Rate Changes.
We may change the interest rate on an interest-bearing account at any time.

Limitations on Rate Changes.
There are no maximum or minimum interest rate limits for an interest-bearing account.

Compounding and Crediting.
Interest is compounded daily and credited to an interest-bearing account monthly. If you close an interest-bearing account, you will still receive all interest accrued while the account was open. The cut off time for interest calculation will be 11:59 p.m. EST.

Minimum Balance Requirements.
No minimum balance is required to open or to obtain an interest-bearing account’s annual percentage yield. Your account statement cycle is monthly.

Daily Balance Method.
We use the Daily Balance Method an interest-bearing account which applies a daily periodic rate to the account balance that has accrued in the account each day. Interest will be calculated daily, including holidays and weekends. This means that the interest from an interest-bearing account is calculated every day on 365 days a year and 366 days a year for leap years.

Accrual on Non-Cash Deposits.
Interest begins to accrue on the business day you deposit noncash items (for example, checks). The cut off time for interest calculation will be 4:00 p.m. EST. All deposits after the cut off time will have the posting day of the following business day.

Transaction Limitations.
If an interest-bearing account is a savings account, currently there is no withdrawal limitation on a savings account due to the Covid-related policy implemented by the Federal Reserve. You may make more than six (6) withdrawal(s) from your savings account every quarter. However, should the withdrawal limitations be re-established, you will only be allowed six (6) withdrawal(s) from your savings account every quarter.

E-SIGN CONSENT DISCLOSURE

Federal law requires you receive certain disclosures and information about the products, services or accounts you may receive or access in connection with your relationship with us (“Required Information.”) With your consent we can deliver Required Information to you by a) displaying or delivering the Required Information electronically; and/or b) requesting that you print or download the Required Information and retain it for your records.

This notice contains important information before you consent to electronic delivery of Required Information. Your consent also permits the general use of electronic records and electronic signatures in connection with the Required Information.

After you have read this E-sign Disclosures and Consent, if you agree to receive Required Information from us electronically, and if you agree to the general use of electronic records and electronic signatures in connection with our relationship, please “SIGN” below and return to:

IPN, LLC doing business as Paybotic

120 S. Dixie Hwy, Unit 201 West Palm, Beach FL 33401

Statement of electronic disclosures:

If you consent to electronic disclosures, that consent applies to all Required Information we give you or receive from you in connection with our relationship and the associated notices, disclosures, and other documents.

You agree to print out or download Required Information when we advise you to do so and keep it for your records. If you are unable to print or download any Required Information, you may call us and request paper copies. If you need to update your e-mail address or other contact information with us, you may do so by calling us and requesting necessary updates.

Your consent does not mean that we must provide the Required Information electronically. We may at our option deliver Required Information on paper. We may also require that certain communications from you be delivered to us on paper at a specified address.

Withdrawing Consent

You have the right to withdraw electronic consent. However, any documents you signed electronically before you withdrew your consent will be considered legally valid and enforceable. Any electronic documents or disclosures may be obtained in paper form and delivered by mail. The procedure to withdraw the electronic consent can be accomplished by choosing and clicking on the “Opt Out” tab. You may, or may not, incur additional charges by Opting Out of the electronic consent, or for receiving paper copies of documents. Please refer to our fee schedule for our current fees related to these matters. This fee schedule may change from time to time; you will be notified of any such change.

Hardware and Software Requirements

In order to use electronic signatures and to receive and save any document or communication electronically, you must have:

• A computer, mobile device, or other electronic device with internet access; and
• A secure internet browser with 128 – bit encryption; and
• A program that reads and displays PDF files such as Adobe Acrobat Reader; and
• An active email address.

To print and save your document or communication in electronic form using your computer, you will need:

• A Printer (to print paper copies); and
• A hard drive or other storage device (to download and save electronic copies).

To print and save your document or communication in electronic form using your mobile or electronic device, you will need:

• A printer capable of printing the screen shots on your mobile or electronic device (to print paper copies); and
• An electronic device capable of taking a screen shot that can be printed (to save electronic copies).

Changes to Hardware and /or Software Requirements.

You will be notified of any changes to the hardware and/or software requirements that may create a material risk that you will not be able to receive, view, print or save a document or communication.

I have read the information about the use of electronic records, disclosures, notices, and e-mail, and consent to the use of electronic records for the delivery of Required Information in connection with our relationship. I will be able to view this information using my computer and software. I have an account with an internet service provider, and I am able to send e-mail and receive e-mail with hyperlinks to websites and attached files. I also consent to the use of electronic records and electronic signatures in place of written documents and handwritten signatures.

By:

Name:

Title:

REG CC DISCLOSURE

Funds Availability Policy

Overview

It is the policy of Paybotic Financial (“Paybotic Financial” or the “Company”) to comply with the Expedited Funds Availability Act (“EFAA”) and its implementing Regulation CC, which are applicable based on Paybotic Financial’s offering of deposit transaction accounts through its relationship with Regent Bank (the “Bank”).

The regulation sets forth the requirement that depository institutions make funds deposited into transaction accounts available according to specified time schedules and that they disclose their funds availability policies to their customers, and Paybotic Financial complies with these requirements on behalf of the Bank.

Scope

This Policy applies to Paybotic Financial executive management, employees, and third-party service providers.

Key Definitions

1. Account. An account is a ‘‘deposit’’ (as defined in the Board’s Regulation D, in 12 CFR 204.2(a)(1)(i)) that is a ‘‘transaction account’’ (as defined in 12 CFR 204.2(e)). ‘‘Account’’ encompasses consumer and corporate accounts and includes accounts from which the account holder is permitted to make transfers or withdrawals by any of the following:

   • Negotiable instrument
   • Payment order of withdrawal
   • Telephone transfer
   • Electronic payment
2. Business and Banking Days.
   • A business day is any day except Saturday, Sunday, and a legal holiday (standard Federal Reserve holiday schedule).
   • A banking day is a business day on which a bank is open for substantially all its banking activities. Even though a bank may be open for regular business on a Saturday, that day is not considered a banking day for purposes of Regulation CC because Saturday is never a ‘‘business day’’ under the regulation. The fact that one branch is open to the public for substantially all its banking activities does not necessarily mean that specific day is a banking day for the other branches of the bank.
3. Electronic payment. A wire transfer or an ACH credit transfer.
4. Government Checks. U.S. Treasury checks, USPS money orders, state and local government checks, and checks drawn on a Federal Reserve Bank or an FHLB.
5. New Account. The first thirty calendar days an account is open, beginning on the date the account is established (an account is not considered “new” if each customer on the account has had, within thirty calendar days before the account is established, another account at the Company for at least thirty calendar days).

Responsibilities

Board of Directors

The Board of Directors (“Board”) is ultimately responsible for the Company’s compliance with applicable regulations, as well as setting an appropriate culture of Compliance throughout the organization and ensuring compliance functions have the appropriate level of staffing, prominence and authority throughout the organization. The Board will receive periodic reporting from Compliance including any issues or updates related to Regulation CC.

Chief Compliance Officer

The Paybotic Financial Compliance Officer, or appointee, is designated by the company and is responsible for owning, maintaining and enforcing this Policy. The Compliance Officer will institute proper controls that ensure the requirements of this Policy are followed. Additionally, the Compliance Officer identifies and ensures Company managers and employees who are affected by this Policy are made aware of its requirements. The Compliance Officer will review and approve this Policy annually, or more frequently if regulatory changes take place or the Company makes changes to its products or processes.

Business Owners and Operational Managers

Business owners and operational managers are responsible for implementing and maintaining processes to meet the requirements outlined in this Policy. Business owners and operational managers should review and understand this Policy; complete all assigned training related to Regulation CC; escalate any identified issues or errors to Compliance upon discovery; and develop and implement corrective action plans where necessary to address audit findings or compliance issues.

Policy Requirements

This Policy outlines availability and disclosure requirements under Regulation CC. However, it should be noted that Paybotic Financial only permits the following types of deposits:

• ACH transfers
• Direct deposit

Paybotic Financial does not accept the following types of deposits:

• Deposits made in cash or deposits in foreign currency;
• ATM deposits; or
• Checks of any kind, including personal checks, cashier’s checks, money orders, mobile check deposits, foreign currency and cash that is sent to the Bank

Funds Availability

It is Paybotic Financial’s policy to make funds available based on requirements set forth under Regulation CC.

Paybotic Financial generally allows a withdraw of funds deposited in an account on the first business day after the day the deposit is received. Same-day availability for electronic direct deposits, is permitted.

Exceptions

It may be determined by Paybotic Financial that a delay in the ability to withdraw funds is necessary, and a deposit hold past the first business day is placed. In such a case, the funds will generally be available by the second business day after the day of the deposit.

While this is Paybotic Financial’s general policy, there are other exceptions that may exist as set forth in the regulation, for the following situations:

• New accounts
  • These are exempted from the availability schedules for deposits of local checks. However, next-day availability is required for electronic payments.
  • The first $5,525 of a day’s aggregate deposits of government checks (including federal, state, and local governments), cashier’s, certified, teller’s, depository, or traveler’s checks (as of time of deposit) must be given next-day availability. The amount in excess of $5,525 must be made available no later than the ninth business day following the day of deposit.
• Large deposits
  • A hold may be applied to the amount in excess of $5,525 on any one day
• Checks that have been returned unpaid and are being redeposited
  • The Company may delay the availability of funds from a check if the check had previously been deposited and returned unpaid
  • Note, this exception does not apply to checks that were previously returned unpaid because of a missing endorsement or because the check was post dated when presented
• Deposit to accounts that have been repeatedly overdrawn
  • The customer’s account may be considered repeatedly overdrawn if:
    • On six or more banking days within the preceding six months, the account balance is negative, or the account balance would have become negative if checks or other charges to the account had been paid; or
    • On two or more banking days within the preceding six months, the account balance is negative, or the account balance would have become negative, in the amount of $5,525 or more, if checks or other charges to the account had been paid.
• Cases in which the Company has reasonable cause to believe the check being deposited is uncollectible
  • The basis for reasonable cause may include, for example, communication with the paying bank indicating that:
    • A stop-payment order has been placed on the check
    • There are insufficient funds in the drawer’s account to cover the check
    • The check will be returned unpaid
  • The reasonable-cause exception may also be invoked in cases in which
    • The check was deposited six months after the date of the check (stale date)
    • The check was postdated (future date)
    • The depositary bank believes that the depositor may be engaged in check kiting
    • The depositary bank has other confidential information, such as the insolvency or pending insolvency of the customer
  • The reasonable-cause exception may not be invoked because of either
    • The race or national origin of the depositor or
    • The fact that the paying bank is located in a rural area and the depositary bank will not have time to learn of nonpayment of the check before the funds have to be made available under the availability schedules in place.
• Emergency conditions
  • An interruption of communications or computer or other equipment facilities; or
  • Suspension of payments by another depository institution, war, or an emergency condition beyond the control of the depositary bank.

Notice of Exceptions

• The customer’s account number;
• The date of the deposit;
• The amount of the deposit that will be delayed;
• The reason why the exception was invoked; and
• The day the funds will be available for withdrawal (unless unknown due to emergency situation).

This notice will be delivered to the customer no later than the business day following the banking day of deposit.

Disclosures of Funds Availability

Paybotic Financial complies with the availability disclosure requirements of Section 229.16(b) by including the availability schedule in the Paybotic Financial Funds Availability Policy Disclosure.

Additionally, Paybotic Financial will comply with Section 229.18(d) by providing the above Funds Availability schedule upon request. Finally, Paybotic Financial will comply with Section 229.18(e) by notifying consumers at least 30 days prior to a change to the availability schedule with an adverse impact or within 30 days after the change if it results in faster availability.

Monitoring and Testing

Paybotic Financial will ensure that compliance with EFAA requirements is independently monitored on an ongoing basis. Reporting of the results will be maintained and reported to the Board.

Training

Employees of the Company determined to have a job function impacted by EFAA requirements will receive training at least annually.

Record Retention

Certain requirements under Regulation CC specifically require Paybotic Financial to maintain evidence of compliance for at least two years. This includes notices required when a “reasonable cause” exception is invoked.

Policy History

The history of this document is outlined in the table below.

Date of Action	Responsible Party	Description of Policy Action
12/08/2022	Head of Compliance	First version published

Reg CC Funds Availability Reference Aid 7/1/2020

Types of Deposited Items	Deposited In a Payee's		Account		Deposited in Foreign ATM
	Yes (i.e., check payable to Mbr/Acct Hldr)		No (i.e., check not payable to Mbr/Acct Hldr)
	In Person	Not in Person	In Person	Not in Person
Cash	Next Day Avail.	2 Day	NA, follow holds to the left		5 day*

Types of Deposited Items	Deposited In a Payee's Account				Deposited in Foreign ATM
	Yes (i.e., check payable to Mbr/Acct Hldr)		No (i.e., check not payable to Mbr/Acct Hldr)
	In Person	Not in Person	In Person	Not in Person
Electronic Deposits – Wire	Next Day Availability		NA, follow holds to the left		NA
Electronic Deposits – ACH	SAME Day actually received		NA, follow holds to the left		NA

Types of Deposited Items	Deposited In a Payee's Account				Deposited in Foreign ATM
	Yes (i.e., check payable to Mbr/Acct Hldr)		No (i.e., check not payable to Mbr/Acct Hldr)
	In Person	Not in Person	In Person	Not in Person
On Us < $5525	Next Day Availability up to $5525				5 day*
New Account	$0 Next Day, No Maximum hold				No Max
Large Deposit > $5525	On amounts up to $5525, Next Day Availability Only on amounts >$5525, 2 day				5 day up to $5525 11 day > $5525
Redeposited Items (A)	$0 Next Day, 2 day				11 day
Repeat Overdraft Acct (B)
Reasonable Cause
Emergency Condition**	$0 Next Day, No Limit

Types of Deposited Items	Deposited In a Payee's Account				Deposited in Foreign ATM
	Yes (i.e., check payable to Mbr/Acct Hldr)		No (i.e., check not payable to Mbr/Acct Hldr)
	In Person	Not in Person	In Person	Not in Person
Regular Checks < $5525	Next day $225, 2nd day $450 cash by 5PM, 3rd day remainder up to $5525.				5 day*
New Account	$0 Next Day, No Maximum hold				No Max
Large Deposit > $5525	On amts up to $5525, Next day $225, 2nd day $450 cash by 5PM, 3rd day remainder to $5525. Only on amounts >$5525, 7 day				5 day up to $5525 11 day > $5525
Redeposited Items (A)	$0 Next Day, 7 day				11 day
Repeat Overdraft Acct (B)
Reasonable Cause
Emergency Condition**	$0 Next Day, No Limit

Types of Deposited Items	Deposited In a Payee's Account				Deposited in Foreign ATM
	Yes (i.e., check payable to Mbr/Acct Hldr)		No (i.e., check not payable to Mbr/Acct Hldr)
	In Person	Not in Person	In Person	Not in Person
US Treasury Checks < $5525 RTTN begins with "0000"	Next Day Avail. up to $5525		Next Day $225, 2nd day $450 cash by 5pm, 3rd day remainder up to $5525		5 day*
New Account	Next Day up to $5525, 9 day on amounts > $5525		0$ Next day No Max hold		No Max
Large Deposit > $5525	On amounts up to $5525, Next Day Avail.		Next Day $225, 2nd day $450 cash by 5pm, 3rd day remainder up to $5525		5 day up to $5525
	Only on amounts >$5525, 7 day				11 day > $5525
Redeposited Items (A)	$0 Next Day, 7 day				11 day
Repeat Overdraft Acct (B)
Reasonable Cause
Emergency Condition**	$0 Next Day, No Limit

Types of Deposited Items	Deposited In a Payee's Account				Deposited in Foreign ATM
	Yes (i.e., check payable to Mbr/Acct Hldr)		No (i.e., check not payable to Mbr/Acct Hldr)
	In Person	Not in Person	In Person	Not in Person
US Postal Money Orders Max Domestic = $1000 Max Foreign = $700 Gov't (state or local)  FRB or FHLB  Cashiers, Teller, Certified	Next Day Avail. up to $5525	$225 Next Day, 2 day on remainder up to $5525	Next Day $225, 2nd day $450 cash by 5pm, 3rd day remainder up to $5525		5 day*
New Account Large Deposit > $5525	Next day up to $5525	$0 Next Day 2 day up to $5525	0$ Next day No Max hold		No Max 5 day up to $5525
	9 day on amt > $5525
	Next Day up to $5525	$225 Nex Day, 2 day on rest up to $5525	Next Day $225, 2nd day $450 cash by 5pm, 3rd day remainder up to $5525
	Only on amounts >$5525, 7 day				11 day > $5525
Redeposited Items (A)	$0 Next Day, 7 day				11 day
Repeat Overdraft Acct (B)
Reasonable Cause
Emergency Condition**	$0 Next Day, No Limit

*Note that 229.12(d) allows hold on Foreign ATM deposits to be extended by 1 day beyond the 5 if $450 cash available by 5PM on 5th day.

** Emergency condition = interruption of communication, computer, weather delay, or other conditions beyond our control.

1. Repeated Items – exception does not apply if the check is corrected for missing endorsement or post dated check now good
2. Repeated Overdraft Account = in the past 6 mo's the account was negative 6 days or had a negative balance of at least $5525 two days

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USA PATRIOT ACT (KYC) DISCLOSURE

Customer Identification

To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account.

Please provide the following information. Paybotic requires two forms of identification for each borrower to comply with Section 326 of the Act.

Customer's Name	Transaction I.D. Number
Address	Date of Birth
City, State Zip	Social Security #/Tax ID #

IMPORTANT – Information listed below must be exactly as indicated on the document.

Primary Forms of Identification – must display Customer’s name

Document	Country/State of Origin	ID Number	Date of Birth	Expiration Date
State Issued Driver License
State Issued ID Card
Military ID Card
Passport
US Alien Registration Card
Canadian Driver License

Secondary Forms of Identification-must display Customer’s name

Document	Name of Issuer on Form	ID Number	Issuance Date	Expiration Date
Social Security Card	U.S. Govt.
Government Issued Visa
Birth Certificate
Non-US/Canadian Driver License
Most Recent Signed Tax Returns	Fed    State	TIN:
Property Tax Bill		APN:
Voter Registration Card
Organizational Membership Card
Bank/Investment/Loan Statements
Paycheck stub with name
Most Recent W-2
Home/car/renter insurance papers
Recent utility bill

Comments:

I certify that I have personally viewed and accurately recorded the information from the documents identified above, and have reasonably confirmed the identity of the applicant.

Signature	Title
Printed Name	Date

* For persons without a SSN/TIN, the ID number must be from one of the following: passport, alien ID card, or any other government issued document evidencing nationality or residence and bearing a photograph or similar safeguard.

APP END USER LICENSE AGREEMENT

This End User License Agreement ("Agreement") is a binding agreement between you ("End User" or "you") and IPN B, LLC, a Florida limited liability company doing business as Paybotic Financial ("Paybotic"). This Agreement governs your use of the Paybotic Financial Application, (including all related documentation, the "Application."). The Application is licensed, not sold, to you.

BY DOWNLOADING THE APPLICATION, YOU: (A) ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS AGREEMENT; (B) REPRESENT THAT YOU ARE AUTHORIZED WITH PROPER CREDENTIALS AND PASSWORDS TO ACCESS AND USE THE APPLICATION; AND (C) ACCEPT THIS AGREEMENT AND AGREE THAT YOU ARE LEGALLY BOUND BY ITS TERMS. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT DOWNLOAD, INSTALL, OR USE THE APPLICATION AND DELETE IT FROM YOUR MOBILE, DESKTOP, OR OTHER DEVICE.

1. License Grant. Subject to the terms of this Agreement, Paybotic grants you a limited, non-exclusive, and nontransferable license to:

   1. Download, install, and use the Application for your use on a mobile, desktop, or other device owned or otherwise controlled by you ("Device") strictly in accordance with the Application’s documentation; and
   2. Access, stream, download, and use on such Device the Content and Services (as defined in Section 5) made available in or otherwise accessible through the Application, strictly in accordance with this Agreement and the Terms of Use applicable to such Content and Services as set forth in Section 5.

2. License Restrictions. Licensee shall not:

   1. Copy the Application, except as expressly permitted by this license;
   2. Modify, translate, adapt, or otherwise create derivative works or improvements, whether or not patentable, of the Application;
   3. Reverse engineer, disassemble, decompile, decode, or otherwise attempt to derive or gain access to the source code of the Application or any part thereof;
   4. Remove, delete, alter, or obscure any trademarks or any copyright, trademark, patent, or other intellectual property or proprietary rights notices from the Application, including any copy thereof;
   5. Rent, lease, lend, sell, sublicense, assign, distribute, publish, transfer, or otherwise make available the Application, or any features or functionality of the Application, to any third party for any reason, including by making the Application available on a network where it is capable of being accessed by more than one device at any time; or
   6. Remove, disable, circumvent, or otherwise create or implement any workaround to any copy protection, rights management, or security features in or protecting the Application; or
   7. Use the Application in, or in association with, the design, construction, maintenance, or operation of any hazardous environments or systems, including any power generation systems; aircraft navigation or communication systems, air traffic control systems or any other transport management systems; safety-critical applications, including medical or life-support systems, vehicle operation applications or any police, fire, or other safety response systems; and military or aerospace applications, weapons systems, or environments.
3. Reservation of Rights. You acknowledge and agree that the Application is provided under license, and not sold, to you. You do not acquire any ownership interest in the Application under this Agreement, or any other rights thereto other than to use the Application in accordance with the license granted, and subject to all terms, conditions, and restrictions, under this Agreement. Paybotic and its licensors and service providers reserve and shall retain their entire right, title, and interest in and to the Application, including all copyrights, trademarks, trade secrets, and other intellectual property rights therein or relating thereto, except as expressly granted to you in this Agreement.
4. Collection and Use of Your Information. You acknowledge that when you download, install, or use the Application, Paybotic may use automatic means (including, for example, cookies and web beacons) to collect information about your Device and about your use of the Application. You also may be required to provide certain information about yourself as a condition to downloading, installing, or using the Application or certain of its features or functionality, and the Application may provide you with opportunities to share information about yourself with others. All information we collect through or in connection with this Application is subject to our Privacy Policy: https://payboticfinancial.com/privacy-policy/. By downloading, installing, using, and providing information to or through this Application, you consent to all actions taken by us with respect to your information in compliance with the Privacy Policy. You hereby grant us a perpetual non-exclusive royalty free right and license to copy, modify, and use any information and data supplied by you or collected on your behalf so that we may enhance the Application and our Services, including but not limited to the right to use, repurpose, and monetize aggregate data and to create analytical trend data (in anonymous form) that may be shared with or sold to third parties. In no event will any information be disclosed in a manner that allows particular customers or individuals to be identified. Notwithstanding the foregoing, you agree that your username and/or login name, may appear in a list of participating organizations for reports containing such analytical trend data.
5. Content and Services. The Application may provide you with access to Paybotic’s website located at www.payboticfinancial.com (the "Website" or "Platform") and products and services accessible thereon, and certain features, functionality, and content accessible on or through the Application may be hosted on the Website (collectively, "Content and Services.") Your access to and use of such Content and Services are governed by Website’s and Platform’s Terms of Use and Privacy Policy located at https://payboticfinancial.com/terms-and-conditions/ and https://payboticfinancial.com/privacy-policy/, which are incorporated herein by this reference. Your access to and use of such Content and Services may require you to acknowledge your acceptance of such Terms of Use and Privacy Policy and/or to register with the Website and/or Platform, and your failure to do so may restrict you from accessing or using certain of the Application’s features and functionality. Any violation of such Terms of Use will also be deemed a violation of this Agreement.
6. Geographic Restrictions. The Content and Services are based in the State of Florida in the United States and provided for access and use only by persons located in the United States. You acknowledge that you may not be able to access all or some of the Content and Services outside of the United States and that access thereto may not be legal by certain persons or in certain countries. If you access the Content and Services from outside the United States, you are responsible for compliance with local laws.
7. Updates. Paybotic may from time-to-time in its sole discretion develop and provide Application updates, which may include upgrades, bug fixes, patches, other error corrections, and/or new features (collectively, including related documentation, "Updates"). Updates may also modify or delete in their entirety certain features and functionality. You agree that Paybotic has no obligation to provide any Updates or to continue to provide or enable any particular features or functionality. Based on your Mobile Device settings when your Mobile Device is connected to the internet either:
   1. The Application will automatically download and install all available Updates; or
   2. You may receive notice of or be prompted to download and install available Updates.

      You shall promptly download and install all Updates and acknowledge and agree that the Application or portions thereof may not properly operate should you fail to do so. You further agree that all Updates will be deemed part of the Application and be subject to all terms and conditions of this Agreement.

8. Third-Party Materials. The Application may display, include, or make available third-party content (including data, information, applications, and other products, services, and/or materials) or provide links to third-party websites or services, including through third-party advertising ("Third-Party Materials"). You acknowledge and agree that Paybotic is not responsible for Third-Party Materials, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality, or any other aspect thereof. Paybotic does not assume and will not have any liability or responsibility to you or any other person or entity for any Third-Party Materials. Third-Party Materials and links thereto are provided solely as a convenience to you, and you access and use them entirely at your own risk and subject to such third parties’ terms and conditions.

9. Term and Termination.

   1. The term of Agreement commences when you download or install the Application and will continue in effect until terminated by you or Paybotic as set forth in this Section 9.
   2. You may terminate this Agreement by deleting the Application and all copies thereof from your Device.
   3. Paybotic may terminate this Agreement at any time without notice if it ceases to support the Application, which Paybotic may do in its sole discretion. In addition, this Agreement will terminate immediately and automatically without any notice if you violate any of the terms and conditions of this Agreement.
   4. Upon termination:
      1. All rights granted to you under this Agreement will also terminate; and
      2. You must cease all use of the Application and delete all copies of the Application from your Device and account.
   5. Termination will not limit any of Paybotic’s rights or remedies at law or in equity.
10. Disclaimer of Warranties. THE APPLICATION IS PROVIDED TO LICENSEE "AS IS" AND WITH ALL FAULTS AND DEFECTS WITHOUT WARRANTY OF ANY KIND. TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, PAYBOTIC, ON ITS OWN BEHALF AND ON BEHALF OF ITS AFFILIATES AND ITS AND THEIR RESPECTIVE LICENSORS AND SERVICE PROVIDERS, EXPRESSLY DISCLAIMS ALL WARRANTIES, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE, WITH RESPECT TO THE APPLICATION, INCLUDING ALL IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT, AND WARRANTIES THAT MAY ARISE OUT OF COURSE OF DEALING, COURSE OF PERFORMANCE, USAGE, OR TRADE PRACTICE. WITHOUT LIMITATION TO THE FOREGOING, PAYBOTIC PROVIDES NO WARRANTY OR UNDERTAKING, AND MAKES NO REPRESENTATION OF ANY KIND THAT THE APPLICATION WILL MEET YOUR REQUIREMENTS, ACHIEVE ANY INTENDED RESULTS, BE COMPATIBLE, OR WORK WITH ANY OTHER SOFTWARE, APPLICATIONS, SYSTEMS, OR SERVICES, OPERATE WITHOUT INTERRUPTION, MEET ANY PERFORMANCE OR RELIABILITY STANDARDS OR BE ERROR-FREE, OR THAT ANY ERRORS OR DEFECTS CAN OR WILL BE CORRECTED.

    SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF OR LIMITATIONS ON IMPLIED WARRANTIES OR THE LIMITATIONS ON THE APPLICABLE STATUTORY RIGHTS OF A CONSUMER, SO SOME OR ALL OF THE ABOVE EXCLUSIONS AND LIMITATIONS MAY NOT APPLY TO YOU.

11. Limitation of Liability. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT WILL PAYBOTIC OR ITS AFFILIATES, OR ANY OF ITS OR THEIR RESPECTIVE LICENSORS OR SERVICE PROVIDERS, HAVE ANY LIABILITY ARISING FROM OR RELATED TO YOUR USE OF OR INABILITY TO USE THE APPLICATION OR THE CONTENT AND SERVICES FOR:
    1. PERSONAL INJURY, PROPERTY DAMAGE, LOST PROFITS, COST OF SUBSTITUTE GOODS OR SERVICES, LOSS OF DATA, LOSS OF GOODWILL, BUSINESS INTERRUPTION, COMPUTER FAILURE OR MALFUNCTION, OR ANY OTHER CONSEQUENTIAL, INCIDENTAL, INDIRECT, EXEMPLARY, SPECIAL, OR PUNITIVE DAMAGES.
    2. DIRECT DAMAGES IN AMOUNTS THAT IN THE AGGREGATE EXCEED THE AMOUNT ACTUALLY PAID BY YOU FOR THE APPLICATION.

       THE FOREGOING LIMITATIONS WILL APPLY WHETHER SUCH DAMAGES ARISE OUT OF BREACH OF CONTRACT, TORT (INCLUDING NEGLIGENCE), OR OTHERWISE AND REGARDLESS OF WHETHER SUCH DAMAGES WERE FORESEEABLE OR PAYBOTIC WAS ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. SOME JURISDICTIONS DO NOT ALLOW CERTAIN LIMITATIONS OF LIABILITY SO SOME OR ALL OF THE ABOVE LIMITATIONS OF LIABILITY MAY NOT APPLY TO YOU.

12. Indemnification. You agree to indemnify, defend, and hold harmless Paybotic and its officers, directors, employees, agents, affiliates, successors, and assigns from and against any and all losses, damages, liabilities, deficiencies, claims, actions, judgments, settlements, interest, awards, penalties, fines, costs, or expenses of whatever kind, including attorney’s fees, arising from or relating to your use or misuse of the Application or your breach of this Agreement, including but not limited to the content you submit or make available through this Application.
13. Export Regulation. The Application may be subject to U.S. export control laws, including the U.S. Export Administration Act and its associated regulations. You shall not, directly or indirectly, export, re-export, or release the Application to, or make the Application accessible from, any jurisdiction or country to which export, re-export, or release is prohibited by law, rule, or regulation. You shall comply with all applicable federal laws, regulations, and rules, and complete all required undertakings (including obtaining any necessary export license or other governmental approval), prior to exporting, re-exporting, releasing, or otherwise making the Application available outside the U.S.
14. U.S. Government Rights . The Application is commercial computer software, as such term is defined in 48 C.F.R. § 2.101. Accordingly, if you are an agency of the U.S. Government or any contractor therefor, you receive only those rights with respect to the Application as are granted to all other end users under license, in accordance with: (a) 48 C.F.R. § 227.7201 through 48 C.F.R. § 227.7204, with respect to the Department of Defense and their contractors, or (b) 48 C.F.R. § 12.212, with respect to all other U.S. Government licensees and their contractors.
15. Severability. If any provision of this Agreement is illegal or unenforceable under applicable law, the remainder of the provision will be amended to achieve as closely as possible the effect of the original term and all other provisions of this Agreement will continue in full force and effect.
16. Governing Law. This Agreement is governed by and construed in accordance with the internal laws of the State of Florida without giving effect to any choice or conflict of law provision or rule. Any legal suit, action, or proceeding arising out of or related to this Agreement or the Application shall be instituted exclusively in the federal courts of the United States or the courts of the State of Florida in each case located in West Palm Beach and Palm County. You waive any and all objections to the exercise of jurisdiction over you by such courts and to venue in such courts.
17. Limitation of Time to File Claims. ANY CAUSE OF ACTION OR CLAIM YOU MAY HAVE ARISING OUT OF OR RELATING TO THIS AGREEMENT OR THE APPLICATION MUST BE COMMENCED WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES OTHERWISE SUCH CAUSE OF ACTION OR CLAIM IS PERMANENTLY BARRED.
18. Entire Agreement. This Agreement, and our Privacy Policy constitute the entire agreement between you and Paybotic with respect to the Application and supersede all prior or contemporaneous understandings and agreements, whether written or oral, with respect to the Application.
19. Waiver. No failure to exercise, and no delay in exercising, on the part of either party, any right or any power hereunder shall operate as a waiver thereof, nor shall any single or partial exercise of any right or power hereunder preclude further exercise of that or any other right hereunder. In the event of a conflict between this Agreement and any applicable purchase or other terms, the terms of this Agreement shall govern.