Deposit Account Agreement
This Deposit Account Agreement ("Agreement") governs your demand deposit account ("Account") opened through Initio Treasury, a service of Initio Capital, Inc. ("Initio"). The Account is held at and issued by Column N.A., a national bank chartered under the laws of the United States and a member of the Federal Deposit Insurance Corporation ("Column" or the "Bank"). Initio is not a bank.
1. Opening Your Account
To open an Account, you must complete the application, agree to this Agreement, the Privacy Notice, the E-Sign Consent, and the Truth-in-Savings Disclosure, and successfully complete the Bank's Customer Identification Program ("CIP") as required by Section 326 of the USA PATRIOT Act.
2. FDIC Insurance
Funds in your Account are insured by the FDIC up to the standard maximum deposit insurance amount of $250,000 per depositor, per insured bank, for each account ownership category. Coverage applies to funds held at Column N.A.; balances swept to other program banks via the optional Cash Sweep Program may be eligible for additional insurance subject to separate disclosures.
3. Your Funds
You authorize Column to hold, invest, transfer, and otherwise handle the funds in your Account subject to this Agreement and applicable law. Initio acts as your agent for the limited purpose of providing the technology platform; Initio does not take possession of your funds.
4. Funds Availability
Availability of deposited funds is governed by Regulation CC and the separate Funds Availability Disclosure. Generally, funds from electronic deposits are available the business day after deposit; check deposits may be held up to seven business days.
5. Fees and Interest
Fees are disclosed in the current Fee Schedule on the Pricing page. Interest, if any, is paid pursuant to the Truth-in-Savings Disclosure. Annual Percentage Yield (APY) is variable and may change at any time without prior notice.
6. Electronic Transfers
Transfers via ACH, Fedwire, RTP/FedNow, and book transfer are governed by NACHA Operating Rules, the Federal Reserve's Operating Circulars, and applicable network rules. Reg E (12 CFR §1005) applies to consumer accounts; commercial accounts are governed by your Treasury Services Agreement and applicable UCC Article 4A.
7. Right to Refuse, Freeze, or Close
Initio and the Bank may, at our discretion and as required by law, decline transactions, freeze the Account, or close the Account, including in connection with our BSA/AML program, sanctions screening (OFAC), or upon suspected fraud or unlawful activity. We will provide notice when permitted by law.
8. Arbitration; Class Waiver
Disputes will be resolved through binding individual arbitration administered by JAMS in San Francisco, California, with the right to opt out within 30 days of opening the Account by emailing legal@initiotreasury.com. You waive the right to participate in class actions to the maximum extent permitted by law.
9. Changes to This Agreement
We may amend this Agreement upon at least 30 days' notice for adverse changes, or immediately for security or legal-compliance reasons. Continued use of the Account constitutes acceptance.
10. Governing Law
This Agreement is governed by federal law and the laws of the State of California, without regard to conflict-of-law principles.