Table of Contents

Regulatory Disclosure & Disclaimer

FACTWAGON ENTERPRISE SOLUTIONS
IMPORTANT LEGAL DISCLOSURES AND RISK ACKNOWLEDGEMENTS

CORPORATE IDENTIFICATION

FactWagon Enterprise Solutions
10 South First Street
San Jose, California 95113
United States of America
Email: compliance@factwagon.com

FactWagon Enterprise Solutions is a Delaware corporation providing enterprise financial technology infrastructure, business intelligence platforms, and institutional consulting services to corporate clients, financial institutions, and business organizations globally.

1. NATURE OF SERVICES – NOT FINANCIAL ADVICE

1.1 Technology and Information Services Only

FactWagon Enterprise Solutions operates exclusively as a business-to-business (B2B) technology platform provider, data analytics firm, and business consulting organization. The Company provides:

Financial technology infrastructure and software-as-a-service (SaaS) platforms
Commercial lending workflow automation and credit decisioning tools
Supply chain finance technology and invoice processing systems
ESG compliance software and sustainability reporting frameworks
Business intelligence, data analytics, and industry benchmarking services
Strategic consulting and technology implementation services

1.2 No Licensed Financial Services

CRITICAL DISCLOSURE: FactWagon Enterprise Solutions is NOT:

(a) A registered investment advisor (RIA) with the U.S. Securities and Exchange Commission (SEC) or any state securities regulator;

(b) A broker-dealer, securities intermediary, or FINRA member organization;

(d) A licensed money transmitter, payment processor, or money services business (MSB);

(e) An insurance company, insurance broker, or licensed insurance agent;

(f) A commodity trading advisor (CTA) or commodity pool operator (CPO) registered with the CFTC;

(g) A financial planner, wealth manager, tax advisor, or accounting firm.

1.3 Information Only – Not Recommendations

All content, data, analytics, reports, credit scores, risk assessments, and communications provided through the Platform or Services constitute general business information, analytical tools, and educational material only. Nothing provided by FactWagon constitutes:

Investment advice or recommendations to buy, sell, or hold securities
Credit recommendations or lending decisions (final credit decisions remain with institutional lenders)
Tax advice, legal counsel, or accounting services
Guarantees of loan approval, credit availability, or financing terms
Predictions of investment performance, business outcomes, or financial returns
Personal financial planning or individualized investment strategies

Institutional Clients must conduct independent analysis, engage qualified licensed professionals (attorneys, CPAs, registered advisors), and exercise independent judgment before making financial, investment, lending, or business decisions.

2. NO FIDUCIARY DUTY

FactWagon Enterprise Solutions does not act in a fiduciary capacity with respect to Client financial decisions, lending determinations, investment strategies, or capital allocation. Our relationship with Institutional Clients is limited to technology platform provision, data analytics services, and business consulting as specified in executed service agreements.

FactWagon owes no duty to:

Make lending decisions or extend credit on behalf of clients
Recommend specific investments, securities, or financial products
Act in Client’s best financial interest beyond contractual service obligations
Monitor Client portfolios, credit exposures, or investment positions
Provide ongoing suitability assessments or financial advice

3. FORWARD-LOOKING STATEMENTS

3.1 Identification and Risks

Certain Platform content may contain “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995, including projections, forecasts, estimates, predictions, and statements regarding:

Future economic conditions, interest rate environments, or market trends
Anticipated regulatory changes or policy implementations
Projected loan performance, default rates, or credit quality metrics
Expected technology developments or platform capabilities
Hypothetical scenarios, stress tests, or financial modeling assumptions

Forward-looking statements are identified by terms such as “may,” “will,” “expect,” “anticipate,” “believe,” “estimate,” “project,” “forecast,” “predict,” or similar expressions.

3.2 Material Risks and Uncertainties

Forward-looking statements are subject to substantial risks and uncertainties. Actual results may differ materially due to:

Economic downturns, recessions, or financial market volatility
Interest rate changes, inflation, or monetary policy shifts
Regulatory developments, enforcement actions, or legislative changes
Credit market disruptions, liquidity crises, or lending contractions
Cybersecurity incidents, technology failures, or data breaches
Competitive pressures, industry consolidation, or market disruptions
Geopolitical events, trade disputes, or international conflicts
Natural disasters, pandemics, or Force Majeure events

FactWagon assumes no obligation to update forward-looking statements except as required by law. Forward-looking statements speak only as of the date made and should not be relied upon as accurate predictions.

4. COMMERCIAL LENDING RISK DISCLOSURES

4.1 Credit Risk and Loan Performance

No Guarantee of Loan Approval or Performance:
FactWagon’s credit decisioning tools, underwriting platforms, and risk scoring models provide analytical frameworks only. Final lending decisions remain with institutional lenders who bear all credit risk. FactWagon provides no guarantees regarding:

Loan approval rates or credit availability
Borrower creditworthiness or repayment capacity
Loan portfolio performance or default rates
Collateral values or recovery rates upon default
Economic conditions affecting borrower industries

Historical Performance Not Indicative:
Past loan performance, default statistics, or portfolio metrics do not predict future results. Credit quality can deteriorate rapidly due to economic downturns, industry disruptions, or borrower-specific circumstances.

4.2 Regulatory Compliance Responsibility

Lender Compliance Obligations:
Institutional lenders utilizing FactWagon platforms remain solely responsible for compliance with:

Truth in Lending Act (TILA) and Regulation Z disclosures
Equal Credit Opportunity Act (ECOA) and fair lending requirements
Fair Credit Reporting Act (FCRA) and permissible purposes
Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) obligations
Know Your Customer (KYC) and Customer Identification Program (CIP) requirements
State licensing requirements for lenders and loan servicers
Usury laws, interest rate caps, and fee limitations

FactWagon’s technology facilitates compliance workflows but does not constitute legal advice or regulatory guidance. Lenders must engage qualified compliance counsel.

5. FINTECH INFRASTRUCTURE DISCLAIMERS

5.1 API and Integration Risks

Third-Party Dependencies:
FactWagon integrates with third-party banking-as-a-service (BaaS) providers, payment processors, credit bureaus, and financial data aggregators. FactWagon is not liable for:

Third-party service outages, API failures, or data inaccuracies
Changes to third-party terms, pricing, or service availability
Regulatory actions against third-party providers
Security breaches or data incidents at third-party systems

Implementation Responsibility:
Clients are responsible for proper API implementation, error handling, security controls, data validation, and testing before production deployment.

5.2 Data Accuracy and Timeliness

Information Provided “As Is”:
Financial data, credit reports, transaction records, and analytics are provided “as is” without warranties of accuracy, completeness, or timeliness. FactWagon:

Does not independently verify all third-party data sources
Cannot guarantee absence of errors, omissions, or outdated information
Does not warrant real-time data delivery or uninterrupted access
Disclaims liability for decisions based on inaccurate or delayed data

Independent Verification Required:
Clients must independently verify critical information, cross-reference multiple data sources, and conduct appropriate due diligence before making material business decisions.

6. ESG AND SUSTAINABILITY DISCLOSURES

6.1 ESG Data and Reporting

No Audit or Verification Services:
FactWagon provides software tools for ESG data collection, carbon accounting, and sustainability reporting but does not:

Audit or verify the accuracy of client-submitted ESG data
Provide assurance services on sustainability reports
Certify compliance with ESG frameworks (GRI, SASB, TCFD)
Validate carbon offset claims or climate commitments

Framework Interpretation:
ESG reporting frameworks evolve continuously. Clients should engage qualified sustainability consultants and obtain third-party assurance for material ESG disclosures.

6.2 Climate Risk Modeling

Climate risk models, scenario analysis, and transition risk assessments are based on assumptions, projections, and historical data that may not accurately predict future climate impacts, regulatory changes, or technology developments.

7. LIMITATION OF LIABILITY FOR BUSINESS LOSSES

TO THE MAXIMUM EXTENT PERMITTED BY LAW, FACTWAGON SHALL NOT BE LIABLE FOR:

(a) Lending losses, credit defaults, or loan portfolio deterioration;

(b) Investment losses, trading losses, or diminution in asset values;

(d) Regulatory penalties, enforcement actions, or compliance failures;

(e) Data breaches, cybersecurity incidents, or privacy violations (except gross negligence);

(f) Damages arising from reliance on Platform data, analytics, or recommendations;

(g) Third-party claims by borrowers, investors, regulators, or counterparties.

Clients assume full responsibility for all business risks, financial decisions, and regulatory compliance obligations associated with their use of Services.

8. PROFESSIONAL CONSULTATION REQUIREMENT

Before making material business, lending, or financial decisions, Clients should consult:

Legal Counsel: For regulatory compliance, contract review, and legal risk assessment
Certified Public Accountants (CPAs): For tax planning, financial statement audits, and accounting treatment
Registered Investment Advisors: For investment advice and portfolio management (if applicable)
Compliance Consultants: For AML/KYC programs, regulatory examinations, and policy development
Cybersecurity Experts: For security architecture, penetration testing, and incident response
Sustainability Advisors: For ESG strategy, carbon accounting verification, and climate risk assessment

FactWagon’s technology platforms and consulting services supplement but do not replace professional judgment and expert guidance.

9. REGULATORY COMPLIANCE STATUS

9.1 State and Federal Compliance

FactWagon maintains all necessary business licenses and operates in compliance with:

California Corporations Code and Delaware General Corporation Law
Export Administration Regulations (EAR) and sanctions compliance (OFAC)
CAN-SPAM Act for commercial email communications
Telephone Consumer Protection Act (TCPA) for telephonic communications

9.2 Industry Standards

FactWagon adheres to industry best practices including:

SOC 2 Type II security and availability controls
Payment Card Industry Data Security Standard (PCI DSS) Level 1
NIST Cybersecurity Framework alignment
ISO/IEC 27001 information security management principles

References to compliance standards indicate FactWagon’s internal operational controls and do not constitute regulatory endorsement of Client business models or activities.

10. GOVERNING LAW

These Regulatory Disclosures are governed by the laws of the State of California, United States of America, without regard to conflict of laws principles. Disputes are subject to exclusive jurisdiction of courts in Santa Clara County, California.

11. CHANGES TO DISCLOSURES

FactWagon reserves the right to modify these Regulatory Disclosures at any time by posting revised versions on the Platform. Material changes will be communicated to active Institutional Clients via email notification.

12. CONTACT INFORMATION

FactWagon Enterprise Solutions
Compliance and Legal Department
10 South First Street
San Jose, California 95113
United States of America

Email: compliance@factwagon.com
Phone: +1 (408) 555-3228
Subject Line: “Regulatory Disclosure Inquiry”

ACKNOWLEDGMENT

BY ACCESSING THE PLATFORM OR UTILIZING SERVICES, INSTITUTIONAL CLIENTS ACKNOWLEDGE READING AND ACCEPTING THESE REGULATORY DISCLOSURES AND RISK ACKNOWLEDGEMENTS. CLIENTS REPRESENT POSSESSING THE SOPHISTICATION, RESOURCES, AND EXPERTISE NECESSARY TO EVALUATE RISKS ASSOCIATED WITH THEIR BUSINESS ACTIVITIES.