Effective June 1, 2026

Cardholder Agreement

This Cardholder Agreement governs your use of the Initio Visa® commercial card (the "Card"), including the Initio Black Card. The Card is issued by Column N.A., Member FDIC, pursuant to a license from Visa U.S.A. Inc. Use of the Card constitutes acceptance of these terms.

1. Card use

The Card is for business purposes only. You agree not to use the Card for personal, family, or household purposes, or for any illegal transaction, including unlawful internet gambling.

2. Authorized users

You may issue Cards to employees, contractors, and other persons you designate ("Authorized Users"). You are responsible for all use of Cards issued to Authorized Users, including ensuring they comply with this Agreement.

3. Credit limit and float

Initio establishes credit limits at its discretion based on deposit balances and business activity. Initio Black Card customers may access an extended 60–75 day grace period ("Float") at Initio's discretion. The Float is not a contractual entitlement and may be reduced or revoked at any time.

4. Liability for unauthorized use

For commercial Cards, your liability for unauthorized use is governed by your Treasury Services Agreement and Visa's Zero Liability Policy. Notify us immediately at cards@initiotreasury.com or by freezing the Card in the dashboard if a Card is lost, stolen, or compromised.

5. Rewards (Growth Points)

Initio Growth Points are a loyalty program offered by Initio, not Column. Points are not cash, have no cash value, and are governed by the Growth Points program rules in your dashboard. Initio may modify or terminate the program at any time.

6. Foreign transactions

Transactions in a currency other than U.S. dollars are converted at the exchange rate established by Visa on the date the transaction is processed. There is no foreign transaction fee.

7. Disputes

To dispute a transaction, contact us within 60 days of the statement date at disputes@initiotreasury.com. We will investigate and respond per Visa Operating Rules.

8. Termination

You or Initio may close any Card at any time. Closure does not relieve you of liability for amounts owed.

Questions? Email compliance@initiotreasury.com or write to Initio Capital, Inc., Compliance Dept., 548 Market St #95421, San Francisco, CA 94104.