Lead Bank Accountholder AgreementAnytime Capital / US Business

1.1 Eligible Customers. To be eligible for an Account, you must be (a) a corporation, limited liability company, partnership, or other legal entity duly organized, validly existing, and in good standing under the laws of a U.S. state or the District of Columbia, or (b) an individual who is a United States resident, the age of majority in his or her state of residence, and operating a business as a sole proprietor; and in either case you must have a principal place of business in the United States and be capable of entering into a legally binding agreement.

1.2 Program Approval. Before loading funds into or using your Account, you must be an approved customer of both Program Manager and Platform Provider, including completing the customer identification and beneficial ownership requirements in Section 2 and agreeing to their respective terms of service.

1.3 One Account. You may hold only one Account under the Program at a time unless we expressly permit otherwise.

1.4 Business Purpose Representation. You represent and warrant, on the date you accept this Agreement and on each day your Account remains open, that: (a) your Account is and will be used solely for business, commercial, or agricultural purposes, and not for personal, family, or household purposes; (b) you are not a “consumer” with respect to the Account for purposes of the Electronic Fund Transfer Act, Regulation E, or any other consumer protection law; (c) if you are a sole proprietor, you will not commingle personal funds in the Account or use it for personal transactions; (d) you are duly organized (if an entity), have full power and authority to enter into and perform this Agreement, and this Agreement has been duly authorized by all necessary action; (e) the individual accepting this Agreement and each Authorized Representative has actual authority to act for you; (f) all information you have provided to Bank, Program Manager, or Platform Provider is true, complete, and current, and you will promptly update it if it changes; (g) you are not, and are not owned or controlled by, a person subject to sanctions administered by OFAC or any other applicable sanctions authority; and (h) your use of the Account will comply with all applicable laws.

1.5 Consequence of Misuse. If we determine that your Account is being used for personal, family, or household purposes, we may close it. You acknowledge that the protections available to consumers under Regulation E and other consumer laws are not available to you and that this Agreement allocates risk on that basis.

2.1 Customer Identification Program. To help the federal government fight the funding of terrorism and money laundering, federal law requires us to obtain, verify, and record information that identifies each business that opens an Account and certain individuals associated with it. We will ask for your legal name, physical address, taxpayer identification number, formation documents, and other identifying information, and may ask to see additional documents at any time. If we ask for specific identifying documents or information and they are not provided, we may immediately close or suspend your Account.

2.2 Beneficial Ownership Certification. If you are a legal entity, you must provide, and certify the accuracy of, the name, address, date of birth, and identification number of (a) each individual who directly or indirectly owns 25% or more of your equity interests, and (b) one individual with significant responsibility to control, manage, or direct you, in each case as required by 31 C.F.R. § 1010.230. You must notify us promptly, and in any event within 30 days, of any change in your beneficial ownership or control, and must re-certify upon request.

2.3 Ongoing Due Diligence. We may request additional information about you, your owners, your Authorized Representatives, the nature of your business, the source of your funds, and the purpose of your transactions at any time. You agree to provide it promptly. We may suspend or close your Account if you do not.

2.4 Verification Before Use. We may restrict funding, transfers, or other Account functionality until our customer identification and beneficial ownership review is complete.

3.1 Nature of the Account. Your Account is a non-interest-bearing business transaction account held directly with Lead Bank in Fiat Currency (as defined below), which reflects your balance and all transactions associated with your Account. You acknowledge and agree that: (i) the value available in your Account is limited to the Fiat Currency funds credited to it; (ii) your Account does not have an expiration date; (iii) your Account is not a credit account and does not provide a credit feature, overdraft protection, or the ability to access credit; and (iv) your Account is not a consumer “prepaid account” and is not subject to Regulation E.

3.2 Definitions. “Fiat Currency” is government-issued currency, including U.S. Dollars. “Stablecoin” is a type of cryptographic digital asset that can be redeemed at face value for Fiat Currency. YOUR ACCOUNT ONLY HOLDS FIAT CURRENCY AND DOES NOT HOLD ANY STABLECOINS, CRYPTOCURRENCY, VIRTUAL CURRENCY, DIGITAL ASSET, OR OTHER DIGITAL TOKEN. Bank has no relationship with, and assumes no responsibility for, the Wallet (which holds your Stablecoin balance), the blockchain network(s) on which the Wallet operates, or the issuer of any Stablecoin.

3.3 Fiat Currency Balance; FDIC Insurance. The Fiat Currency balance in your Account is held by Bank. At this time, your Account balance is not eligible for FDIC pass-through deposit insurance, and you should not rely on FDIC insurance with respect to your Account balance. You will not receive interest on the funds in your Account.

3.4 Stablecoin Balance. Your Stablecoin balance is held in your Wallet, is separate from your Account, and is not held by Bank. Any Stablecoin balance held in your Wallet is not a deposit or other obligation of, and is not guaranteed by, Bank or any other bank; is not insured by the FDIC or any other governmental agency; and is subject to risk, including possible loss of value. Stablecoin activity is governed by the Grid Terms and, as applicable, your separate arrangements regarding the Wallet.

3.5 Business Use Only. Your Account may only be used for business, commercial, or agricultural purposes. See Sections 1.4 and 1.5.

3.6 Optional Card. You may request one or more Cards at any time through Platform Provider. A Card is an access device that permits an Authorized Cardholder (as defined in the Card Supplement) to initiate transactions drawing on your Account balance and, where enabled, on your Wallet. Issuance and use of Cards is governed by the Card Supplement, which you must separately accept. Declining, cancelling, or never requesting a Card does not affect the terms of this Agreement or your ability to use your Account for the transactions described in Sections 4 and 5.

3.7 Fee Schedule. The fees that apply to your Account are set out in Exhibit A (Fee Schedule), which is part of this Agreement. Section 9 describes how fees are allocated among Bank, Program Manager, and Platform Provider; Exhibit A states the fees themselves. We may change the Fee Schedule as provided in Section 20.

4.1 Funding Methods. You may fund your Account by:

(a) Wire transfer to your Account;

(b) ACH credit initiated by you or by a third party you authorize;

(c) FedNow or other instant payment network transfer;

(d) Direct deposit or other recurring ACH credits from your customers, payment processors, or other payors; and

(e) Stablecoin Sale, as described in Section 4.2.

4.2 Stablecoin Sales. You may instruct LSP to sell Stablecoins from your Wallet and credit the Fiat Currency proceeds to your Account (a “Stablecoin Sale”). Initiating a Stablecoin Sale authorizes LSP to (i) sell Stablecoins from your Wallet in the amount you specify or in an amount sufficient to produce the Fiat Currency amount you specify, and (ii) credit the Fiat Currency proceeds to your Account.

4.3 Stablecoin Sale Disclaimer. Bank is not involved in the movement, custody, purchase, or sale of any Stablecoin. Bank does not guarantee the price of any Stablecoin. Stablecoin Sales are conducted by LSP and are governed by separate terms between you and LSP. YOU ACKNOWLEDGE THAT STABLECOIN VALUES CAN DEVIATE FROM THEIR INTENDED PEG AND THAT NEITHER BANK NOR PROGRAM MANAGER GUARANTEES ANY PARTICULAR VALUE OR CONVERSION RATE.

A Stablecoin Sale may fail or be delayed for reasons including insufficient Wallet balance, congestion, unavailability, or outage of the underlying blockchain network, or deviation of the relevant Stablecoin’s value from its intended peg. See Section 13 for related liability provisions.

4.4 Funds Availability. Funds added by wire transfer or ACH credit will be available in your Account on the business day they are received, subject to Exhibit B. Funds added by FedNow or other instant payment network transfer will be available as described in Exhibit C. Funds from a Stablecoin Sale will be available in your Account promptly after the sale settles. We may delay availability of any credit where we have reason to believe it may be returned, reversed, or recalled, or as otherwise described in Exhibit B.

4.5 Provisional Credit. Any credit to your Account for an ACH entry or other funds transfer is provisional until we receive final settlement. If we do not receive final settlement, we may reverse the credit and you agree to repay us the amount credited. Under the NACHA Operating Rules and Article 4A, we are not required to give you notice of receipt of an ACH credit; the credit will appear in your Account history.

4.6 Funding Limits. We may impose limits or restrictions on the amount, number, frequency, or type of funding transactions, and may change these at any time. We will use reasonable efforts to notify you of a reduction in a limit, but may impose a limit immediately and without prior notice where we consider it necessary to manage risk or to maintain or restore the security of your Account or the Program.

4.7 Returned, Reversed, and Recalled Credits. If a credit to your Account is later returned, reversed, recalled, dishonored, or otherwise not finally settled, including an ACH return or reversal, a wire recall, a FedNow request for return of funds, or a credit reversed by the originator, you authorize us to debit your Account for the amount of that credit, plus any related third-party fee, without prior notice to you. We may do so even if you have already spent or transferred the funds, in which case Section 8.2 (Negative Balance) applies. If the credit funded a Stablecoin Purchase, the resulting negative balance is your obligation, and neither Bank nor Program Manager has any right or ability to recover Stablecoins from your self-custody Wallet.

4.8 Sanctions and Legal Holds. We may delay, reject, block, freeze, or refuse to process any funding transaction or outbound transfer in order to comply with applicable sanctions laws administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) or other applicable law. Funds that are blocked under sanctions laws may be required to be held in a blocked account and may not be returned to you or released to any other person unless and until authorized by OFAC. We may be prohibited by law from telling you the reason for any such action.

4.9 Fees for Funding. Fees for funding your Account, if any, are set out in Exhibit A. You should consult with your Platform Provider or Program Manager to determine any fees that may be associated with transactions that are related or incidental to your use of the Account, including Stablecoin Sales. See Section 9.

5.1 Outbound Transfer Methods. Subject to the limits in this Agreement and to Platform Provider’s enablement of the relevant feature, you may transfer funds out of your Account by:

(a) ACH credit to an external account you own or are authorized to use;

(b) Wire transfer to an account you designate;

(c) FedNow or other instant payment network transfer; and

(d) Stablecoin Purchase, as described in Section 5.3.

Platform Provider determines which of the foregoing methods are available to you. Not all methods are available to all accountholders.

5.2 Authorization; Cutoff Times. You authorize us to debit your Account for the amount of each outbound transfer you initiate, plus any applicable fee. Transfer instructions received after the applicable cutoff time stated in Exhibit B, or on a day that is not a business day, will be processed on the next business day, except that transfers sent over an instant payment network that operates continuously may be processed on any day.

Once you authorize an outbound transfer, you may not cancel or amend it, except as provided in Section 10.5 or as otherwise required by applicable law.

5.3 Stablecoin Purchases. You may instruct LSP to use Fiat Currency from your Account to purchase Stablecoins on your behalf and deliver them to your Wallet (a “Stablecoin Purchase”). INITIATING A STABLECOIN PURCHASE CONSTITUTES YOUR EXPRESS AND IRREVOCABLE CONSENT TO THE DEBIT OF YOUR ACCOUNT AND THE PURCHASE OF STABLECOINS ON YOUR BEHALF. Section 4.3 applies equally to Stablecoin Purchases.

5.4 Accuracy of Transfer Instructions; Reliance on Account Numbers. You are solely responsible for the accuracy of the information you provide, including the recipient’s account number, routing number, wallet address, and name. Consistent with UCC §§ 4A-207 and 4A-208, we and the receiving bank may rely exclusively on the account number and routing number you supply, even if they identify a person or account different from the one you named, and we have no duty to detect the inconsistency. You are bound by, and bear the loss of, any transfer sent to the account number you provided. Transfers to an incorrect destination may be irreversible, and we may be unable to recover the funds. Blockchain transactions in particular cannot be reversed.

5.5 Insufficient Funds. If your Account balance is insufficient to cover an outbound transfer, the transfer will be declined. Bank does not offer overdraft services in connection with your Account.

5.6 Transfer Limits. We may impose limits or restrictions on the amount, number, frequency, or type of transfers, and may change these at any time. We will use reasonable efforts to notify you of a reduction in a limit, but may impose a limit immediately and without prior notice where we consider it necessary to manage risk or to maintain or restore the security of your Account or the Program.

5.7 International Transfers. If you send a transfer to a recipient outside the United States, the transfer is governed by this Agreement, Article 4A, and the rules of the applicable payment system. Because you are not a consumer, the Remittance Transfer Rule (Regulation E, Subpart B) does not apply, and you do not have the disclosure, cancellation, or error-resolution rights it provides. International transfers may be subject to intermediary bank fees, currency conversion, and the laws of other jurisdictions, and may be delayed or blocked by sanctions screening.

5.8 Uses Not Permitted. You may not write checks against your Account. You may not enable third parties to make ACH debits from your Account. You may not use your Account for any illegal transaction, for any transaction prohibited by Platform Provider’s Terms of Service, the Grid Terms, or applicable sanctions laws, or for any of the following: money services business activity on behalf of others; gambling; the sale of controlled substances; or any business or activity that Bank or Program Manager has designated as prohibited or restricted. You may not use your Account to hold or transmit funds on behalf of third parties unless we have expressly approved you to do so in writing.

6.1 Authorized Representatives. You must designate one or more individuals authorized to act on your behalf with respect to the Account, including to open and close the Account, initiate and approve transfers, designate and remove other Authorized Representatives and Authorized Cardholders, accept amendments to this Agreement, and receive notices (each, an “Authorized Representative”). Your initial Authorized Representative is the individual who accepts this Agreement on your behalf. You may designate additional or replacement Authorized Representatives through the Platform app or as we otherwise permit.

6.2 Reliance. We and Program Manager may rely on any instruction, authorization, or communication that is given by an Authorized Representative, or that is initiated using credentials assigned to you or to an Authorized Representative, without further inquiry into the identity or authority of the person giving it. Any such instruction is binding on you whether or not it was actually authorized by you, subject only to Section 10.2. We are not required to verify that an instruction is consistent with your internal policies, board resolutions, or any limitation on an Authorized Representative’s authority of which we have not received written notice and had a reasonable opportunity to act.

6.3 Removal. You must notify us promptly, through the Platform app or as we otherwise permit, when an Authorized Representative’s authority ends. You remain responsible for all instructions given by a former Authorized Representative until we have received your notice and had a reasonable time to act on it.

6.4 Conflicting Instructions. If we receive conflicting instructions from Authorized Representatives, or if we become aware of a dispute concerning ownership or control of you or the Account, we may in our discretion refuse to act on any instruction, freeze the Account, or require instructions from all Authorized Representatives or a court order before acting, without liability to you.

6.5 Recurring Credits. You are responsible for confirming receipt of any recurring credit to your Account by reviewing your Account history. We are not obligated to notify you of the receipt or non-receipt of a credit.

7.1 Access and Credentials. Platform Provider determines how you access your Account, including through the Platform app and any credentials, biometrics, multifactor authentication, or other authentication methods it makes available. You are solely responsible for safeguarding all credentials assigned to you or your Authorized Representatives, for controlling who has access to them, and for all transactions initiated using them.

7.2 Account Information. Your Account balance and transaction history are available through the Platform app, and by calling 855-516-0103 or emailing support@lightsparkpayments.com. You may request a written history of Account transactions covering at least the prior 24 months by writing to us at 8605 Santa Monica Blvd, PMB 64461, West Hollywood, CA 90069, United States. Fees for written histories, if any, are set out in Exhibit A.

7.3 Electronic Statements. We will make a periodic Account history available to you electronically through the Platform app or website monthly. You agree that the electronic history constitutes your account statement for all purposes, including Section 12, and that we are not required to mail paper statements.

7.4 Your Duty to Review. You must promptly and carefully review each Account history and each transaction confirmation we make available to you. You must notify us of any unauthorized, erroneous, or missing transaction within the time stated in Section 12. Failure to do so has the consequences stated in Section 12.

7.5 Receipts. You may obtain a receipt at the time you make a transaction at a terminal, where applicable.

8.1 Fraud Prevention. We may block, suspend, or close your Account at any time, with or without notice, if we reasonably believe fraudulent, suspicious, or criminal activity is occurring, or activity inconsistent with this Agreement, or if we consider it necessary to manage risk or comply with law. We incur no liability for unavailability of funds resulting from such action.

8.2 Negative Balance. If a negative balance occurs in your Account for any reason, you agree to pay the amount owed immediately on demand. If not paid within ten (10) days, we may close your Account and pursue collection, and you agree to pay our reasonable costs of collection, including attorneys’ fees. Because your Wallet is a self-custody wallet over which neither Bank nor Program Manager has signing authority, neither Bank nor Program Manager has any right to initiate a transfer from your Wallet without your independent authorization.

8.3 Right of Setoff. To the extent permitted by law, we may, without prior notice or demand, set off any amount you owe us or any of our affiliates under this Agreement, the Card Supplement, or otherwise against any balance in your Account or in any other account you maintain with us, whenever due. This right is in addition to any security interest or other right we may have.

8.4 Security Interest. To secure your obligations under this Agreement and the Card Supplement, you grant us a security interest in your Account and all funds credited to it from time to time.

9.1 Account Fees. The fees Bank and Program Manager charge in connection with your Account are set out in Exhibit A. You should consult with your Platform Provider to determine any fees that may be associated with transactions that are related or incidental to your use of the Account, including Stablecoin Sales and Stablecoin Purchases.

9.2 Platform Provider Fees. Platform Provider may charge you fees for its own services in connection with the Account. These fees are Platform Provider’s own fees, payable by you to Platform Provider. Neither Bank nor Program Manager charges, sets, collects, or receives any share of these fees. Platform Provider will disclose these fees to you directly in its Terms of Service or a separate fee schedule.

Program Manager and Platform Provider have a separate commercial agreement under which Platform Provider pays Program Manager for services. Program Manager’s compensation under that agreement is not determined by, and does not vary with, the fees Platform Provider charges you.

9.3 Network and Third-Party Fees. Certain fees may apply that are imposed by parties other than Bank or Program Manager, including wire transfer fees imposed by intermediary or beneficiary banks, fees relating to blockchain networks, and fees imposed by a receiving institution, if any. You are responsible for all such fees.

9.4 No Overdraft or Credit Fees. Bank does not offer overdraft services or a credit feature in connection with your Account, and no related fees apply.

9.5 Card Fees. If you obtain a Card, additional fees may apply as described in the Card Supplement and Exhibit A.

9.6 Payment of Fees. You authorize us to debit fees from your Account when they are incurred. If your Account balance is insufficient, the fee will create a negative balance and Section 8.2 applies.

10.1 Application of Article 4A. Each wire transfer, ACH credit, FedNow transfer, and other funds transfer you initiate from your Account is a “payment order” and a “funds transfer” governed by Article 4A of the Uniform Commercial Code as enacted in Missouri (“Article 4A”), together with the operating rules of the applicable payment system (including the NACHA Operating Rules, the Federal Reserve’s Operating Circulars, and the FedNow Service participant rules). This Section 10 supplements Article 4A. In the event of a conflict, this Agreement controls to the extent Article 4A permits variation by agreement.

10.2 Security Procedure. You and we agree that the security procedure for verifying that a payment order was issued by you consists of the credentials, multifactor authentication, device registration, transaction limits, and other controls made available through the Platform app and described in Platform Provider’s documentation, as they may be updated from time to time (the “Security Procedure”). You agree that the Security Procedure is commercially reasonable for your Account in light of the size, type, and frequency of payment orders you expect to issue and the security procedures available. If you decline any additional security procedure we or Platform Provider offer, you agree to be bound by any payment order, whether or not authorized, that is accepted by us in good faith and in compliance with the Security Procedure you have chosen.

10.3 Effect of Verified Payment Orders. Consistent with UCC § 4A-202, a payment order received by us in your name is effective as your order, whether or not you actually authorized it, if we accepted it in good faith and in compliance with the Security Procedure and any written instructions you have given us restricting acceptance of payment orders. You bear the risk of loss for any payment order that is so verified, including payment orders initiated by a former employee, a person who obtained your credentials, or a person acting outside the scope of authority you granted.

10.4 Your Security Obligations. You must maintain the confidentiality of all credentials, implement reasonable internal controls over who may initiate and approve payment orders, use the multifactor authentication and other controls made available to you, monitor your Account daily, and notify us immediately of any suspected compromise. If you fail to do so, you are precluded from asserting that a payment order was unauthorized.

10.5 Cancellation and Amendment. A payment order is irrevocable once we have accepted it, except that we may, in our discretion and as a courtesy, attempt to cancel or amend a payment order at your request if we have not yet executed it. We have no obligation to do so and no liability if the attempt is unsuccessful. Instant payments cannot be cancelled once accepted. See Exhibit C.

10.6 Rejection. We may reject any payment order for any reason, including insufficient funds, a limit, suspected fraud, sanctions screening, or failure to comply with the Security Procedure. We will use reasonable efforts to notify you of a rejection through the Platform app, but our failure to do so does not create liability beyond the interest, if any, required by Article 4A.

10.7 Notice of Errors and Unauthorized Payment Orders. You must examine each Account history and transaction confirmation promptly on receipt. You must notify us of any unauthorized or erroneous payment order within thirty (30) days after the Account history reflecting it is first made available to you. If you do not, you are precluded from asserting the error or lack of authorization against us and from recovering any interest under UCC § 4A-204 or § 4A-304.

10.8 Interest and Damages. Our liability for an unauthorized or erroneous payment order, or for a delay in executing a payment order, is limited to the amounts expressly provided by Article 4A. We are not liable for consequential, special, punitive, or indirect damages in connection with any payment order, and you expressly waive any such damages to the fullest extent permitted by UCC § 4A-305. Any interest we owe under Article 4A will be calculated at the federal funds rate published by the Federal Reserve Bank of New York for the applicable period.

11.1 Notices. We may provide notices via mail, email, SMS (if opted in), in-app posting, push notification, or other reasonable means. Notice to any Authorized Representative is notice to you. Notice is effective when sent or posted.

11.2 Consent to Electronic Communications. You consent to receive all communications, notices, disclosures, statements, and agreements relating to your Account electronically, with the same legal effect as written, signed communications. You agree that electronic records maintained by us or Program Manager are admissible evidence of the transactions and communications they reflect. You must maintain a valid email address and the hardware and software necessary to receive and retain electronic communications. If you withdraw this consent, we may close your Account.

12.1 Regulation E Does Not Apply. Because your Account is a business account, the liability limits, error-resolution procedures, provisional-credit requirements, and investigation timelines of the Electronic Fund Transfer Act and Regulation E do not apply. Your rights and our obligations with respect to unauthorized transactions and errors are as stated in this Section 12, in Section 10, and in the Card Supplement.

12.2 Your Liability for Unauthorized Transactions. You are liable for all transactions initiated using your Account credentials, by any Authorized Representative or Authorized Cardholder, or in compliance with the Security Procedure, whether or not actually authorized by you, until we have received notice from you that the credentials have been lost, stolen, or compromised or that the person’s authority has ended, and have had a reasonable opportunity to act on that notice. You are also liable for any transaction resulting from your failure to comply with Section 7.1, Section 10.4, or the Card Supplement.

12.3 Reporting. You must notify us immediately at 855-516-0103, and confirm in writing to support@lightsparkpayments.com, if you believe your credentials have been compromised or that any transaction on your Account was unauthorized or erroneous. In all cases you must notify us within thirty (30) days after the Account history reflecting the transaction is first made available to you. If you do not, the Account history is deemed correct and accepted by you, and you may not assert the unauthorized transaction or error against us. Where a shorter period applies under the Card Supplement or the rules of a payment network, the shorter period controls.

12.4 Our Investigation. On timely notice, we will investigate in a commercially reasonable manner. We are not required to provide provisional credit, to complete our investigation within any specific period, or to reimburse you except as expressly provided in Section 13 or as required by Article 4A. If our investigation determines that we are liable under this Agreement, we will credit your Account for the amount for which we are liable. We will inform you of the results of our investigation.

12.5 Recovery Efforts. If a transaction was unauthorized or erroneous, we may, but are not obligated to, attempt to recover the funds from the receiving institution or beneficiary. Any recovery is on a best-efforts basis, is not guaranteed, and may be subject to the cooperation of third parties. Amounts recovered will be credited to your Account net of any costs of recovery.

12.6 Wire, ACH, and Instant Payments. Payment orders are further governed by Section 10 and Exhibit C. Where Section 10 or Exhibit C states a different rule, it controls as to the payment order concerned.

12.7 Verification Required. Until our customer identification and beneficial ownership review under Section 2 is complete, we may decline to investigate any claimed unauthorized transaction or error and may restrict Account functionality. You acknowledge that funds in an Account for which verification is incomplete are at greater risk in the event of unauthorized use.

13.1 Our Liability. We are liable to you only for our own gross negligence or willful misconduct, and for such liability as Article 4A imposes on us and does not permit us to vary by agreement. We are not liable for any loss arising from: insufficient funds through no fault of ours; access blocked after you reported compromise or for reasons stated in Section 8; legal process or sanctions compliance; our reasonable suspicion of unauthorized or unlawful activity; incorrect or incomplete instructions or information supplied by you; the acts or omissions of any Authorized Representative, Authorized Cardholder, or third party including Platform Provider, any payment network, any receiving or intermediary bank, or any blockchain network; the unavailability or failure of any Stablecoin Sale or Stablecoin Purchase; or circumstances beyond our reasonable control.

13.2 Exclusion of Consequential Damages. TO THE FULLEST EXTENT PERMITTED BY LAW, NEITHER BANK NOR PROGRAM MANAGER WILL BE LIABLE TO YOU FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF PROFITS, REVENUE, BUSINESS, GOODWILL, OR DATA, ARISING OUT OF OR IN CONNECTION WITH THIS AGREEMENT, THE ACCOUNT, OR ANY TRANSACTION, WHETHER IN CONTRACT, TORT, OR OTHERWISE, AND WHETHER OR NOT FORESEEABLE OR ADVISED OF THE POSSIBILITY.

13.3 Cap on Liability. TO THE FULLEST EXTENT PERMITTED BY LAW, AND EXCEPT FOR LIABILITY THAT ARTICLE 4A DOES NOT PERMIT US TO LIMIT, THE AGGREGATE LIABILITY OF BANK AND PROGRAM MANAGER TO YOU ARISING OUT OF OR IN CONNECTION WITH THIS AGREEMENT, THE CARD SUPPLEMENT, AND THE ACCOUNT IN ANY TWELVE-MONTH PERIOD WILL NOT EXCEED THE GREATER OF (A) THE TOTAL FEES PAID BY YOU TO BANK AND PROGRAM MANAGER UNDER EXHIBIT A DURING THAT PERIOD AND (B) $1,000.

13.4 Indemnification. You will indemnify, defend, and hold harmless Bank, Program Manager, and their respective affiliates, directors, officers, employees, and agents from and against any and all claims, losses, liabilities, damages, penalties, costs, and expenses (including reasonable attorneys’ fees) arising out of or relating to: (a) your use of the Account or any Card, or any transaction initiated using your credentials or by an Authorized Representative or Authorized Cardholder; (b) your breach of this Agreement or the Card Supplement, or any inaccuracy in your representations and warranties; (c) our acting on any instruction we reasonably believed to have been given by you or an Authorized Representative; (d) any claim by a third party, including a payee, payor, Authorized Cardholder, or your owner or creditor, relating to the Account; (e) any legal process relating to you or the Account; or (f) your violation of any law or payment network rule. This Section 13.4 survives termination.

14.1 Closure by You. You may close your Account by contacting Platform Provider through an Authorized Representative. You remain liable for obligations arising before closure and for any transactions that post after closure. Any remaining Fiat Currency balance will be returned to your Wallet via a Stablecoin Purchase or, at your election and where supported, transferred to an external account you designate, except that we may retain amounts sufficient to cover pending transactions, fees, negative balances, and amounts subject to setoff, and may decline to return a balance under $1.00 to the extent permissible under applicable law. You may not close your Account while it is under investigation, subject to a pending dispute, in debt to us, or subject to a hold or legal restriction.

14.2 Closure by Us. We may close or suspend your Account at any time, with or without cause, on notice to you, and immediately without prior notice where we consider it necessary to manage risk, comply with law, or respond to suspected fraud or a breach of this Agreement.

14.3 Effect on Cards. Closing your Account automatically and immediately terminates all Cards issued on it and the Card Supplement. Cancelling a Card does not close your Account. See Section 12 of the Card Supplement.

14.4 Inactivity and Unclaimed Property. If your Account remains inactive for the period specified by the applicable unclaimed property law, we may be required to remit your balance to the applicable state. We will attempt to notify you before doing so at the contact information we have on file. If your balance is remitted to a state, you may be able to reclaim it from that state.

14.5 Dissolution, Bankruptcy, and Change of Control. You must notify us immediately if you dissolve, cease operations, file or become subject to any bankruptcy, insolvency, receivership, or similar proceeding, or undergo a change of control. On receipt of such notice or of any conflicting claim to the Account, we may place a hold on your Account, decline transactions, and refuse to release funds until we receive documentation satisfactory to us establishing who is entitled to them. Because your Wallet is a self-custody wallet, neither Bank nor Program Manager can access, transfer, or recover any Stablecoin balance held in your Wallet under any circumstances, including your dissolution or insolvency. Access to your Wallet depends entirely on the private keys or recovery credentials you control.

15.1 Privacy Policy. Information about you and your Account (“Accountholder Information”) is subject to Bank’s Privacy Policy, available at https://www.lead.bank/legal/privacy. You acknowledge that the Gramm-Leach-Bliley Act privacy provisions apply to consumers and not to business customers, and that our handling of your information is governed by this Agreement and the Privacy Policy.

15.2 Disclosure. We may disclose Accountholder Information to Program Manager, Platform Provider, our service providers, payment networks, and other financial institutions as necessary to provide the Account and process transactions; to verify the existence and condition of your Account for a third party; to comply with law, legal process, or regulatory request; to protect against fraud; with your consent; and as otherwise described in the Privacy Policy.

15.3 Information About Individuals. You represent that you have obtained all consents required to provide us with information about your owners, Authorized Representatives, Authorized Cardholders, and other individuals, and that our collection and use of that information as described in this Agreement and the Privacy Policy is permitted.

16.1 For customer service, contact Program Manager at 855-516-0103 or support@lightsparkpayments.com.

17.1 We may monitor or record calls for quality assurance or as legally required, and may contact you and your Authorized Representatives at the numbers you provide using an automatic dialing system, prerecorded messages, or automated texts for informational purposes, subject to applicable law. You represent that you have authority to provide those numbers and to consent on behalf of the individuals who use them.

18.1 We will comply with any subpoena, levy, garnishment, restraining order, or other legal process relating to you or your Account that we believe in good faith to be valid, without independent verification and without notice to you unless required by law. We may deduct related expenses, including attorneys’ fees, from your Account or other accounts. We may place a hold on your Account pending resolution of legal process. You agree to indemnify us for compliance with such process.

19.1 THE ACCOUNTS, ALL BANK SERVICES, AND ACCOUNT FEATURES ARE PROVIDED “AS IS”, “WHERE IS” AND “AS AVAILABLE”. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, WE MAKE NO REPRESENTATIONS OR WARRANTIES OF ANY KIND TO YOU REGARDING THE ACCOUNTS, ANY FEATURE THEREOF, OR ANY SUBJECT MATTER COVERED BY THE SUBSTANCE OF THIS AGREEMENT, WHETHER EXPRESS OR IMPLIED, INCLUDING, WITHOUT LIMITATION, ANY IMPLIED WARRANTIES OF MERCHANTABILITY, SATISFACTORY QUALITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT OF INTELLECTUAL PROPERTY RIGHTS. WE MAKE NO WARRANTIES OR REPRESENTATIONS THAT THE ACCOUNTS WILL MEET YOUR REQUIREMENTS OR THAT USE OF THE ACCOUNTS WILL BE UNINTERRUPTED OR ERROR-FREE. WE WILL NOT BE RESPONSIBLE FOR ANY SERVICE INTERRUPTIONS, INCLUDING, BUT NOT LIMITED TO, POWER OUTAGES, SYSTEM FAILURES OR OTHER INTERRUPTIONS THAT MAY AFFECT THE RECEIPT, PROCESSING, ACCEPTANCE, COMPLETION OR SETTLEMENT OF TRANSACTIONS OR USE OF THE ACCOUNTS.

TO THE EXTENT THAT WE MAY NOT AS A MATTER OF APPLICABLE LAW DISCLAIM ANY IMPLIED WARRANTY, THE SCOPE AND DURATION OF SUCH WARRANTY WILL BE THE MINIMUM PERMITTED UNDER APPLICABLE LAW.

20.1 Amendment. We may amend this Agreement, the Card Supplement, or Exhibit A at any time by posting the amended terms in the Platform app or otherwise notifying you. Amendments that increase your fees or reduce your rights will take effect no earlier than fourteen (14) days after notice, except that amendments required by law, by a payment network, or to address security or fraud may take effect immediately. Your continued use of the Account after the effective date constitutes acceptance. If you do not agree to an amendment, your sole remedy is to close your Account before it takes effect.

20.2 Termination. Either party may terminate this Agreement by closing the Account under Section 14. Termination does not affect obligations arising before termination.

IT IS IMPORTANT THAT YOU READ THIS ARBITRATION AND DISPUTE RESOLUTION AGREEMENT CAREFULLY. IT PROVIDES THAT YOU MAY BE REQUIRED TO SETTLE A CLAIM OR DISPUTE THROUGH ARBITRATION, EVEN IF YOU PREFER TO LITIGATE SUCH CLAIMS IN COURT. BY ACCEPTING THE AGREEMENT, YOU ACKNOWLEDGE AND AGREE TO BE BOUND BY THIS ARBITRATION AND DISPUTE RESOLUTION AGREEMENT AND THAT YOU ARE WAIVING RIGHTS YOU MAY HAVE TO LITIGATE ANY CLAIM OR DISPUTE IN A COURT OR BEFORE A JURY, TO PARTICIPATE IN A CLASS ACTION IN COURT, TO CLASS ARBITRATION, OR OTHER REPRESENTATIVE ACTION WITH RESPECT TO SUCH CLAIMS AND DISPUTES.

21.1 This Arbitration and Dispute Resolution Agreement describes how a Dispute (as defined below) may be arbitrated. In this Arbitration and Dispute Resolution Agreement, “We” and “Us” mean the Bank and/or the Bank’s assignee or its employees, assignees, or any third party providing any goods or services in connection with the origination, servicing and collection of amounts due under the Agreement, including the Program Manager and Platform Provider, if such third party is named as a party between You and Us. “You” and “Your” mean the Customer, its Authorized Representatives, its Authorized Cardholders, and its owners, successors, and assigns. (This definition applies solely within this Section 21 and does not modify the party definitions in the Preamble.)

21.2 What “Disputes” are Subject to Arbitration? Unless otherwise stated in this Arbitration and Dispute Resolution Agreement, any “Dispute” between You and Us shall, at the election of You, Us, or our respective successors, assignees or related third parties (together, the “Parties”), be resolved by neutral, binding arbitration, and not by a court of law. This procedure includes any Dispute over the interpretation, scope, or validity of this Agreement, the Card Supplement, the Arbitration and Dispute Resolution Agreement or the arbitrability of any issue, with the sole exception of the Parties’ waiver of any right to bring a class action or to participate in a class action as provided for below, which shall be solely determined by the appropriate court, if necessary.

21.3 In this Arbitration and Dispute Resolution Agreement, the word “Dispute” has the broadest possible meaning. “Dispute” means any action, dispute, claim, or controversy of any kind arising out of, in connection with or in any way related, even indirectly, to the Agreement or the Card Supplement. Accordingly, and by way of example only, “Dispute” includes claims related to: Your application; information You have provided to Us; information and disclosures We have provided to You; any prior agreements between You and Us; servicing; collections; privacy; and customer information. The term “Dispute” also includes, without limitation: claims in tort or contract; claims under statutes or common law; claims at law or in equity; other past, present or future claims, counterclaims, cross-claims, third party claims, interpleaders or otherwise; and any claim relating to the interpretation, applicability, enforceability or formation of this Arbitration and Dispute Resolution Agreement, including, but not limited to, any claim that all or any part of this Arbitration and Dispute Resolution Agreement is void, voidable or unconscionable, or that any party has waived its right to seek arbitration of a Dispute under this Arbitration and Dispute Resolution Agreement.

21.4 Notwithstanding the foregoing, “Dispute” does not include (a) any individual action brought by You in small claims court, unless such action is transferred, removed or appealed to a different court; or (b) any action by Us to collect amounts You owe, to enforce Our security interest or right of setoff, or to obtain provisional or injunctive relief, which We may bring in any court of competent jurisdiction.

21.5 What Rules and Procedures Apply? Either You or We may require any Dispute to be arbitrated and may do so before or after a lawsuit has been started over the Dispute or with respect to other Disputes, counterclaims, or third-party claims brought later in the lawsuit. If You or We elect to arbitrate a Dispute, this Arbitration and Dispute Resolution Agreement applies. A Dispute shall be fully resolved by binding arbitration. Judgment on the arbitration award may be entered in any court with jurisdiction. All statutes of limitation that otherwise would apply to an action brought in court will apply in arbitration. The arbitrator must decide Disputes based on the substantive law of Missouri, including statutes of limitation and evidentiary privileges, and the arbitrator may hear dispositive motions. The arbitrator is authorized to award all remedies permitted by the substantive law that would apply if the action were pending in court, subject to Section 13.

21.6 It is expressly agreed that this Agreement evidences a transaction in interstate commerce. Any arbitration shall be governed by and conducted under: (a) the Federal Arbitration Act, 9 U.S.C. §§ 1 et seq. (“FAA”) and not by any state arbitration law; (b) the Commercial Arbitration Rules (“Arbitration Rules”) of the American Arbitration Association (“AAA”) (the “Arbitration Administrator”) in effect at the time arbitration is requested; and (c) this Arbitration and Dispute Resolution Agreement. A copy of the Arbitration Rules may be obtained, free of charge, from the AAA at www.adr.org or by calling 1-800-778-7879. If the terms of this Arbitration and Dispute Resolution Agreement and the Arbitration Rules conflict, the terms of this Arbitration and Dispute Resolution Agreement shall control to the extent of the conflict. The arbitrator shall have all powers provided by the Arbitration Rules and this Arbitration and Dispute Resolution Agreement.

21.7 If AAA is unable or unwilling to serve, and You and We cannot otherwise agree on a substitute administrator or arbitrator, then a court with appropriate jurisdiction shall appoint an arbitrator. The fees of the Arbitration Administrator and the arbitrator shall be shared equally by the Parties, and each Party shall bear the expense of its own attorneys, experts and witnesses, except that the arbitrator may award the prevailing Party its reasonable attorneys’ fees and costs, and except as otherwise required by the Arbitration Rules or applicable law.

21.8 The arbitrator may decide that an in-person hearing is unnecessary and that he or she can resolve the Dispute based on the papers submitted by You or Us and/or through a virtual or telephonic hearing. Any in-person hearing will take place in Kansas City, Missouri, unless the Parties agree otherwise. Notice of the time, date and location shall be provided to You and Us in accordance with AAA’s rules and procedures.

21.9 The arbitrator’s decision is final and binding, except for any right of appeal provided by the FAA, 9 U.S.C. §§ 1 et seq. However, if the amount of the Dispute exceeds $50,000 or involves a request for injunctive or declaratory relief that could foreseeably involve a cost or benefit to either party exceeding $50,000, any party can appeal the award to a three-arbitrator panel administered by the Arbitration Administrator, which panel shall reconsider any aspect of the initial award requested by the appealing party. The decision of the panel shall be by majority vote. Reference in this Arbitration and Dispute Resolution Agreement to “the arbitrator” shall mean the panel of arbitrators if an appeal of the arbitrator’s decision has been taken. The costs of such an appeal will be borne in accordance with Section 21.7.

21.10 Pre-Dispute Resolution Process. Before arbitration can begin, You must provide a written notice to Us via email at support@lightsparkpayments.com and include Your legal name, full account number, mailing address, telephone number, email address, and a description of Your Dispute that includes what relief you seek (“Notice”). The Notice must be signed by an Authorized Representative. After We receive Your Notice, You and We shall attempt to resolve Your Dispute within 60 days of our receipt of Your Notice. This time period can be extended by agreement and is referred to as the “Pre-Arbitration Resolution Period”. Any applicable limitations period (including statute of limitations) will be tolled during the Pre-Arbitration Resolution Period. Engaging in this Pre-Arbitration Resolution process is a requirement that must be fulfilled before commencing arbitration. AAA does not have authority to administer or adjudicate the Dispute unless and until all Pre-Arbitration Resolution requirements have been met.

21.11 Class Action Waiver. If You or We elect to arbitrate a Dispute, (a) neither You nor We may participate in a class action in court or in a class-wide arbitration, either as a plaintiff, defendant or class member; (b) neither You nor We may act as a private attorney general in court or in arbitration; (c) Disputes brought by or against You may not be joined or consolidated with Disputes brought by or against any other person; and (d) the arbitrator shall have no power or authority to conduct a class-wide arbitration, private attorney general arbitration or joined or consolidated arbitration (this sentence including subparts (a) through (d) hereof is referred to in this Arbitration and Dispute Resolution Agreement as the “Class Action Waiver”). This Arbitration and Dispute Resolution Agreement governs Disputes between You and Us. It does not amend, supersede, or override any arbitration agreement between You and any other person, including the arbitration agreement in the Grid Terms.

21.12 Jury Waiver. YOU AND WE HEREBY EXPRESSLY AND IRREVOCABLY WAIVE ANY RIGHT TO A TRIAL BY JURY OF ANY DISPUTE, WHETHER OR NOT ARBITRATED. This waiver will remain enforceable even if any portion of this Arbitration and Dispute Resolution Agreement is otherwise found to be unenforceable. The Parties agree that this waiver is made knowingly, willingly, and voluntarily.

21.13 Severability. If it is determined that any paragraph or provision in this Arbitration and Dispute Resolution Agreement is illegal, invalid, or unenforceable, such illegality, invalidity or unenforceability shall not affect the other paragraphs and provisions of this Arbitration and Dispute Resolution Agreement. The remainder of this Arbitration and Dispute Resolution Agreement shall continue in full force and effect as if the severed paragraph or provision had not been included. Notwithstanding this severability provision, if a court of competent jurisdiction determines that the Class Action Waiver is void, illegal, invalid, or unenforceable, the Parties agree that the Class Action Waiver shall not be severed and this Arbitration and Dispute Resolution Agreement shall be void in its entirety.

21.14 Survivability. This Arbitration and Dispute Resolution Agreement will survive and continue in full force and effect notwithstanding cancellation, termination, amendment, payment in full, discharge in bankruptcy, or other expiration or conclusion of the Agreement, the Card Supplement, or any other contract or transaction between the Parties, unless otherwise agreed in writing. In addition, You understand and acknowledge that the rights and responsibilities afforded to Us under this Arbitration and Dispute Resolution Agreement survive any assignment of the Agreement by Us and that We can enforce this Arbitration and Dispute Resolution Agreement in the event a Dispute arises after the assignment of the Agreement.

22.1 Assignment. You may not assign your Account or your rights or obligations under this Agreement without our prior written consent. We may assign or transfer this Agreement and our rights and obligations under it to any affiliate or successor, or to any purchaser of the Program, without your consent.

22.2 Compliance with Laws and Network Rules. Use of your Account is subject to all applicable laws and the rules and customs of any clearinghouse, payment system, or network involved in your transactions, including the NACHA Operating Rules, which are incorporated by reference and which you agree to be bound by as if you were a party to them. You agree not to initiate any transaction in violation of U.S. law.

22.3 Account Established under U.S. Law. Your Account is established by a U.S. domiciled financial institution under U.S. law, and Bank does not participate in any direct marketing outside of the United States.

22.4 No Waiver. We do not waive our rights by delaying or failing to exercise them at any time.

22.5 Survival. All provisions of this Agreement which by their nature extend beyond the termination of this Agreement, including, without limitation, Sections 8.2, 8.3, 10.7, 10.8, 12, 13, 18, 19, and 21, shall survive the termination or expiration of this Agreement.

22.6 Choice of Law and Venue. This Agreement will be governed by the laws of the State of Missouri, without regard to its conflict of laws principles, except to the extent governed by federal law. Subject to Section 21, you irrevocably submit to the exclusive jurisdiction of the state and federal courts located in Jackson County, Missouri, for any action not subject to arbitration, and waive any objection to venue in those courts.

22.7 Severability. If any provision of this Agreement is determined to be invalid or unenforceable under any rule, law or regulation of any governmental agency, local, state, or federal, the validity or enforceability of any other provision of this Agreement shall not be affected.

22.8 Privity. This Agreement is intended solely for the benefit of you and Bank and is not intended to confer any rights or place any obligations on any other person or entity, including but not limited to the Program Manager and/or the Platform Provider, except that Program Manager is an intended third-party beneficiary of Sections 13 and 21.

22.9 Entire Agreement. This Agreement, together with the Card Supplement (if accepted by you), Exhibits A through C, and any other terms and conditions, policies, appendices, or agreements referenced herein, constitutes the entire agreement between the parties concerning the Account and governs your use of the Account, subject to the Grid Terms and any Platform Provider Terms of Service, which continue to govern their respective subject matter as described in the Preamble.

22.10 Relationship to Other Agreements; Order of Precedence.

(a) Subject-Matter Allocation. The Bank Agreements and the Grid Terms govern different subjects:

Within its allocated subject, each agreement controls in full. Neither agreement’s “entire agreement” provision (including Section 22.9 of this Agreement) operates to displace the other with respect to the other’s allocated subject.

(b) Non-Waivable Rights. Nothing in the Grid Terms, the Platform Terms, or any agreement between you and any other person limits, waives, or reduces any right you have under this Agreement or under applicable law that cannot lawfully be waived. Where any other agreement purports to reduce such a right with respect to a transaction governed by the Bank Agreements, this Agreement controls and that right applies in full.

(c) Conflicts Within the Bank Agreements. If a term of this Agreement conflicts with a term of the Card Supplement, Section 1.2 of the Card Supplement controls. If a term of this Agreement conflicts with a term of an Exhibit, the Exhibit controls with respect to its subject matter.

(d) No Third-Party Enlargement. This Section 22.10 allocates precedence among agreements. It does not make Bank a party to the Grid Terms or the Platform Terms, does not make LSP or Platform Provider a party to this Agreement, and does not enlarge Bank’s obligations beyond those stated in the Bank Agreements.

22.11 Counterparts; Electronic Acceptance. This Agreement may be accepted electronically, and electronic acceptance by an Authorized Representative is binding on you as if executed by hand.

By applying for, activating, or using the Account, you acknowledge that you have read, understood, and agree to be bound by this Agreement, and the individual accepting on your behalf represents that he or she is an Authorized Representative with authority to bind you.

You acknowledge that this is a business account, that the consumer protections of Regulation E do not apply, and that you are responsible for all transactions initiated using your credentials or by your Authorized Representatives and Authorized Cardholders as provided in Sections 6, 10, and 12.

You are not agreeing to receive a Card by accepting this Agreement. Cards are optional and are governed by the separate Card Supplement, which you may accept at any time.

This Exhibit is part of the Lead Bank Business Accountholder Agreement.

This Fee Schedule applies to your Account. If you have also accepted the Card Supplement, it applies to your Cards and to Card transactions. Fees that apply only if you have a Card are marked “Card only.”

Fees Charged by Platform Provider. In addition to the fees listed above, Anytime Capital may charge its own fees for access to and use of your Account. These are Anytime Capital’s fees, not Lead Bank’s, and are disclosed to you by Anytime Capital.

Contact us. For questions, to learn about the terms and conditions, to obtain your account balance, to request a written transaction history, or to report an unauthorized transaction or error, contact us at: 855-516-0103; support@lightsparkpayments.com; 8605 Santa Monica Blvd, PMB 64461, West Hollywood, CA 90069; support.lightspark.com.

This Exhibit is part of the Lead Bank Business Accountholder Agreement.

Lead Bank, Member FDIC. Lead Bank is a member of the FDIC. However, the funds in your Account are not eligible for FDIC deposit insurance. See Section 3.3.

This Exhibit describes when funds credited to your Account become available and when we process your instructions.

Deposits

We do not accept check or cash deposits. Funds from ACH credits, wire transfers, FedNow or other instant payments, and Stablecoin Sales are generally available on the business day we receive them. Once funds are available, we will use them to pay transactions you have authorized. You cannot withdraw funds in cash.

Business Days and Cutoff Times

For purposes of this Exhibit, every day is a business day except Saturdays, Sundays, and days on which banks in Kansas City, Missouri are authorized or obligated to close.

Instructions received after the cutoff, or on a non-business day, are processed on the next business day.

Holds

We may delay the availability of any credit, or place a hold on funds in your Account, where we have reason to believe the credit may be returned, reversed, or recalled; where we suspect fraud or unlawful activity; where required by legal process or sanctions screening; or during the first 30 days your Account is open. We will notify you of a hold through the Platform app where practicable.

Questions

Phone: 855-516-0103 · Email: support@lightsparkpayments.com · Mail: 8605 Santa Monica Blvd, PMB 64461, West Hollywood, CA 90069, United States

This Exhibit is part of the Lead Bank Business Accountholder Agreement.

1. Instant Payments via FedNow

1.1 What instant payments are

FedNow® is a real-time payment service operated by the Federal Reserve Banks that allows you to send and receive instant credit transfers in U.S. dollars 24 hours a day, 7 days a week, including nights, weekends, and holidays.

You should understand the following before using instant payments:

Payments are routed by number, not by name. Instant payments are routed and posted based on the account number and routing number you provide. The recipient name you enter is not used to validate the payment and is not matched against the name on the receiving account. If you enter an incorrect account or routing number, your payment may be delivered to the wrong person, and you bear that loss. See Section 5.4 of the Agreement.

Payments are final. Once an instant payment is accepted and posted to the receiving account, it is final and cannot be reversed, canceled, or recalled through the FedNow Service.

Payments move at any hour. Instant payments may be sent and received at any time, including outside of business days and banking hours.

Instant payments are domestic and credit-only. The FedNow Service supports U.S. dollar payments between participating U.S. financial institutions. It cannot be used to pull or debit funds from another party’s account.

1.2 Sending an instant payment

When you submit an instant payment, you issue a payment order under Section 10 of the Agreement and Article 4A. You authorize us to transfer the amount you specify from your Account to the account you identify. You are responsible for the accuracy of the payment details you provide.

Because instant payments are final once accepted, we cannot guarantee recovery of a payment sent in error, to the wrong recipient, or as a result of fraud or a scam. If you tell us a payment was sent in error or without your authorization, we may, in our discretion, submit a request for return of funds to the receiving institution. A request for return of funds is a best-effort request only. The receiving institution is not obligated to return the funds, and return depends on the cooperation of the receiving institution and its customer.

Before an instant payment is accepted, we may decline it, hold it for review, or limit your use of instant payments, where we believe the payment may be fraudulent, unauthorized, unlawful, or inconsistent with our risk, sanctions, or compliance policies, or where required by applicable law.

Limits. Your ability to send instant payments is subject to limits on total outflow per calendar day and per rolling 30-day period, and may also be subject to a maximum amount for any single payment. These limits are set in connection with your account program and are based on factors including your account activity and risk profile. Your current limits are available in the Anytime Capital app. We may change these limits at any time, and may reduce them immediately and without prior notice where we consider it necessary to manage risk.

1.3 Receiving instant payments and funds availability

When we receive an instant payment to your Account and accept it for posting, we will generally make the funds available in your Account immediately, 24 hours a day, 7 days a week, including weekends and holidays. We do not apply routine or multi-day holds to instant payment credits.

In limited circumstances, we may delay availability of instant payment funds, for example, where we believe a transaction may be fraudulent, unauthorized, or otherwise requires additional review to comply with applicable law or our risk policies. If we delay availability, we will place a hold on the funds and will notify you where practicable. We will restore availability once our review is complete, or return the payment if we determine it cannot be posted.

If, because of an error or exception (for example, a closed or invalid account), we cannot automatically post an instant payment to your Account, Exhibit B applies to that transaction instead.

1.4 Use of instant payment transaction data

We process certain payment transactions using the FedNow Service. In connection with those transactions, transaction records and related information, including payment details, account and routing numbers, payment identifiers, timestamps, and amounts, may be used and disclosed by Lead Bank and by the Federal Reserve Banks for purposes of operating, maintaining, and improving the FedNow Service. This includes any related directory services, routing, screening, risk, compliance, and fraud-prevention services that support the FedNow Service. By using instant payments, you authorize us to share and disclose instant payment transaction information as necessary for these purposes.

1.5 Fraud monitoring and data sharing

To help protect you, other customers, and the financial system from fraud and abuse, we may collect, use, and retain fraud-related information about instant payment activity. This may include device and network information, behavioral and transactional patterns, internal risk scores and flags, and investigation and case-management notes. We may use this information to detect, investigate, and prevent fraud, security incidents, and misuse of your Account. We may share fraud-related data with our service providers, the Federal Reserve Banks, and other financial institutions involved in a transaction, where reasonably necessary for these purposes or as required by law.

1.6 Fees for instant payments

Fees for sending and receiving instant payments, if any, are listed in Exhibit A. Any such fee will be shown to you in the payment flow before you confirm a transaction.

1.7 Errors and unauthorized transactions

If you believe an instant payment to or from your Account was unauthorized or made in error, contact us immediately by calling 855-516-0103 or emailing support@lightsparkpayments.com. Your rights and obligations with respect to unauthorized or erroneous instant payments are governed by Sections 10 and 12 of the Agreement, not by Regulation E. Prompt notice matters: because instant payments are final once accepted, our ability to help recover funds decreases significantly with time, and your failure to report within the period stated in Section 12.3 precludes your claim.