How Paxnova Trust operates, in writing.

Paxnova Trust Bank, N.A. is a national banking association chartered by the Office of the Comptroller of the Currency (OCC). Our principal regulators include:

• Office of the Comptroller of the Currency (OCC) — primary prudential supervisor
• Federal Deposit Insurance Corporation (FDIC) — deposit insurance and resolution authority
• Federal Reserve Bank of San Francisco — for monetary-policy-related supervision
• Consumer Financial Protection Bureau (CFPB) — consumer-protection rules
• Financial Crimes Enforcement Network (FinCEN) — Bank Secrecy Act administrator
• Office of Foreign Assets Control (OFAC) — sanctions enforcement
• Securities and Exchange Commission (SEC) and FINRA — for our broker-dealer affiliate
• Each state where we operate — through the state banking department

Paxnova Trust maintains a comprehensive Bank Secrecy Act and Anti- Money Laundering compliance program reasonably designed to detect and report money laundering, terrorist financing, and other illicit finance activity. The program includes:

• A board-approved policy and a designated BSA Officer
• Risk-based customer due diligence (CDD) and enhanced due diligence (EDD) for higher-risk relationships
• Beneficial ownership identification for legal-entity customers (FinCEN's CDD Rule, 31 CFR § 1010.230)
• Real-time and post-transaction surveillance with case management and SAR filing
• Currency Transaction Reports (CTRs) for cash transactions over $10,000
• OFAC sanctions screening on every transaction and party
• Annual independent testing and ongoing training for relevant employees

As required by Section 326 of the USA PATRIOT Act, we obtain, verify, and record information identifying every person and entity that opens an account: name, date of birth (for individuals), tax identification number, and a physical address. We may also ask for a government-issued photo ID or perform documentary or non- documentary verification (electronic identity-proofing, knowledge-based questions, public records).

When you apply for a credit product, we may obtain a consumer report. Under the Fair Credit Reporting Act (15 U.S.C. § 1681) you have the right to:

• Receive a free copy of the report we used if we deny your application
• Dispute inaccurate or incomplete information directly with the consumer reporting agency
• Place a fraud alert or security freeze on your file
• Opt out of prescreened credit offers at 1-888-5-OPT-OUT or optoutprescreen.com

We furnish accurate account information to the major consumer reporting agencies on a monthly basis and investigate every dispute within the time periods required by law.

The federal Equal Credit Opportunity Act (15 U.S.C. § 1691) prohibits creditors from discriminating against any applicant on the basis of race, color, religion, national origin, sex (including sexual orientation and gender identity), marital status, age (provided the applicant has the capacity to contract); because all or part of the applicant's income comes from any public assistance program; or because the applicant has in good faith exercised any right under the Consumer Credit Protection Act.

Paxnova Trust is also an Equal Housing Lender under the Fair Housing Act. Our lending decisions are based on creditworthiness — not on any prohibited basis. We file Home Mortgage Disclosure Act (HMDA) data annually and make our modified Loan Application Register available to the public on request.

The Community Reinvestment Act (12 U.S.C. § 2901) requires us to help meet the credit needs of the entire communities we serve, including low- and moderate-income (LMI) neighborhoods. Our most recent CRA Performance Evaluation from the OCC rated Paxnova Trust Outstanding. Our CRA Public File — including the full evaluation, our assessment areas, and our affiliate-CRA election — is available at every branch and online at paxnovatrust.com/about#community.

We honor the protections of the Servicemembers Civil Relief Act (50 U.S.C. App. § 3901 et seq.) for active-duty servicemembers, including a 6% cap on pre-service obligations, foreclosure protections, and lease-termination rights. Eligible servicemembers can submit a written request along with a copy of their orders to scra@paxnovatrust.com for prompt application of these benefits.

Regulation E (12 CFR Part 1005) gives you rights when an electronic fund transfer (EFT) is made from your consumer account. If your statement shows an EFT you did not authorize, notify us within 60 days of the statement to limit your liability:

• Within 2 business days of learning of the loss or theft: up to $50
• After 2 business days but before 60 days: up to $500
• After 60 days: potentially unlimited for the unauthorized transfers in that period

To dispute an EFT, call 1-800-PAXNOVA-1, send a secure message in the app, or write to our Compliance Officer at the address below.

Regulation Z (12 CFR Part 1026) implements the Truth-in-Lending Act and gives you the right to dispute billing errors on credit-card statements within 60 days, to receive periodic statements with clear cost disclosures, and to have your liability for unauthorized credit-card use capped at $50. We will not bill you for any disputed amount or interest on that amount while we investigate.

Our Funds Availability Policy explains when deposits become available for withdrawal. Most electronic deposits (direct deposit, wires, internal transfers) are available the same business day. Most checks are available the next business day, subject to standard exception holds for new accounts, large deposits ($5,525 or more in a single banking day), and certain repeated overdrafts. Our full policy is included in your Deposit Account Agreement.

We work hard to resolve every concern internally. If you are not satisfied with our response, you may escalate to our regulators:

• OCC Customer Assistance Group — for national banks. Online: helpwithmybank.gov · Phone: 1-800-613-6743 · Mail: P.O. Box 53570, Houston, TX 77052
• Consumer Financial Protection Bureau (CFPB) — Online: consumerfinance.gov/complaint · Phone: 1-855-411-2372
• FDIC Consumer Response Center — Phone: 1-877- ASK-FDIC · Online: fdic.gov

Employees, customers, vendors, and members of the public can report suspected misconduct anonymously through our EthicsLine, operated by an independent third party. Federal law protects whistleblowers from retaliation; Paxnova Trust does not tolerate retaliation in any form. Reports involving financial reporting are also escalated to our Audit Committee independently of management.

Paxnova Trust Bank, N.A.
Attn: Chief Compliance Officer
1000 N Point St, San Francisco, CA 94109
Email: compliance@paxnovatrust.com
Phone: 1-800-PAXNOVA-1