Effective June 1, 2026

Important Information About Procedures for Opening a New Account

USA PATRIOT Act — Customer Identification Program Notice

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.

What this means for you

When you open an Account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. For business accounts, we will collect information about the legal entity and each beneficial owner who owns 25% or more of the entity, as well as one individual with significant management control.

We may also ask to see your driver's license, passport, EIN letter, or other identifying documents, and we may verify your information through third-party identity verification services (including Alloy) and government databases. We screen all customers against the Office of Foreign Assets Control ("OFAC") Specially Designated Nationals list and other applicable sanctions lists.

If we cannot verify your identity

If we are unable to verify your identity to our satisfaction, we may decline to open the Account, restrict access to the Account, or close it. We will notify you in accordance with applicable law.

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