Compliance Appendix
Privacy Policy (with Compliance Appendix)
Effective Date: 11/16/2025
Last Updated: 11/17/2025
(Sections 1–11 remain as drafted previously, covering Introduction, Scope, Information Collection, Use, Sharing, Security, Retention, Rights, International Transfers, Updates, and Contact.)
Compliance Appendix – Privacy Policy
| Regulation / Statute | Governing Authority | Key Requirement / Relevance |
|---|---|---|
| Gramm-Leach-Bliley Act (GLBA) | Federal Trade Commission (FTC) | Requires financial institutions to explain information-sharing practices and safeguard sensitive data. |
| SEC Regulation S-P | Securities and Exchange Commission (SEC) | Mandates privacy notices and protection of nonpublic personal information of clients. |
| FINRA Rule 3110 (Supervision) | Financial Industry Regulatory Authority (FINRA) | Requires supervisory systems to protect client data and ensure compliance. |
| Bank Secrecy Act (BSA) | U.S. Department of Treasury / FinCEN | Establishes AML and recordkeeping obligations, including reporting suspicious activity. |
| USA PATRIOT Act | Federal Government | Expands AML/KYC requirements for financial institutions. |
| California Consumer Privacy Act (CCPA) | State of California | Grants rights to access, delete, and opt out of personal data sales. |
| State Data Protection Laws | State Regulators | Varying state-level privacy and data security obligations (e.g., New York SHIELD Act). |
Terms of Service (with Compliance Appendix)
Effective Date: [Insert Date]
Last Updated: [Insert Date]
(Sections 1–12 remain as drafted previously, covering Acceptance of Terms, Services Provided, Eligibility, Client Responsibilities, Disclaimers, Intellectual Property, Limitation of Liability, Indemnification, Termination, Governing Law, Amendments, and Contact.)
Compliance Appendix – Terms of Service
| Regulation / Statute | Governing Authority | Key Requirement / Relevance |
|---|---|---|
| Securities Act of 1933 | SEC | Governs registration and disclosure requirements for securities offerings. |
| Securities Exchange Act of 1934 | SEC | Establishes ongoing reporting obligations and antifraud provisions. |
| Investment Advisers Act of 1940 | SEC | Regulates advisory activities, fiduciary duties, and compliance obligations. |
| SEC Regulation D (Rule 501, 506) | SEC | Defines accredited investor criteria and exemptions for private placements. |
| FINRA Rule 2111 (Suitability) | FINRA | Requires firms to ensure investment recommendations are suitable for clients. |
| FINRA Rule 2210 (Communications with the Public) | FINRA | Governs advertising, marketing, and client communications. |
| Regulation Best Interest (Reg BI) | SEC | Requires broker-dealers to act in the best interest of retail customers. |
| State Usury Laws | State Regulators | Limit interest rates on private lending transactions to prevent predatory practices. |
| State Lending Licensing Statutes | State Banking Departments | Require licensing and compliance for private lending activities. |
| Truth in Lending Act (TILA) | Federal Reserve / CFPB | Ensures clear disclosure of loan terms and costs to borrowers. |
Regulatory Disclaimer
All advisory, private lending, and investment services offered by [Your Firm Name] are conducted in compliance with applicable U.S. federal and state regulations, including SEC rules, FINRA oversight, and state lending statutes. Certain offerings may be limited to accredited investors under Regulation D. Advisory engagements, including fractional COO client services, are subject to fiduciary and supervisory standards. Participation in lending or investment opportunities involves risk and is governed by applicable securities and lending laws.
Risk Disclosure
Investing in real estate, private lending, and related opportunities involves significant risk. Participants may lose part or all of their principal investment. These offerings are often illiquid, meaning they cannot be easily sold or exchanged, and returns are not guaranteed. Market conditions, borrower performance, and regulatory changes can materially affect outcomes. Past performance is not indicative of future results. Clients should carefully review all offering documents and consult independent financial, legal, and tax advisors before committing capital.
