1. Regulatory Information

1.1 Network Pay LLC (Agent of Payee — Fiat Payment Collection)

Full Legal Name: Network Pay LLC Common Name: Network Pay Entity Type: Montana Limited Liability Company Jurisdiction: Montana, United States Operating Address: 1001 S Main St Suite 600, Kalispell, MT 59901

Services: Fiat payment collection as an authorized agent of payee on behalf of sellers (Principals), including credit card, debit card, ACH, and wire transfer payment processing

Operating Model: Agent of Payee (AoP) Regulatory Status: Exempt from state money transmitter licensing under the agent of payee exclusion in all 50 U.S. states

1.2 Agent of Payee Status

Network Pay LLC operates as an authorized agent of payee, collecting fiat currency payments on behalf of sellers (Principals) pursuant to written agency agreements. This means:

• Network Pay is appointed by each Principal (seller) as its limited agent for payment collection
• Payment to Network Pay satisfies the Payor's (customer's) payment obligation to the Principal
• Network Pay's obligation is to remit collected funds to the Principal, not to the Payor
• The Principal bears all commercial risk of the transaction
• Network Pay does not sell, resell, or take title to any products or services

Network Pay is NOT:

• A Money Services Business (MSB) — Network Pay's AoP activities do not constitute money transmission
• Registered with FinCEN — MSB registration is not required for AoP activities
• A bank or depository institution
• A money transmitter
• A marketplace facilitator

1.3 Affiliated Entities

Network Pay LLC is affiliated with:

| Entity | Role | Regulatory Status | | :--- | :--- | :--- | | Network Clearing LLC | Agent of Payee for digital asset payment collection; cross-border settlement | Montana LLC; FinCEN-registered MSB |

Network Pay coordinates with its affiliate to provide integrated payment services, but each entity operates under its own regulatory framework and terms.

1.4 Partnership Services

Network Pay LLC processes payments through partnerships with:

• Card networks (Visa, Mastercard, American Express, Discover) for card payment processing
• Payment processors (licensed processors for card authorization and settlement)
• ACH network operators for bank transfer processing
• Banking partners for wire transfer processing and fund segregation

When services are provided through partners, applicable partner terms may also apply.

2. Risk Disclosures

2.1 General Service Risks

Payment processing services involve certain risks:

• Processing Risk: Payments may be delayed, declined, or fail due to technical issues, financial institution processing, or security screening
• Authorization Risk: Your card issuer or bank may decline transactions for reasons outside Network Pay's control
• System Risk: Our services may experience temporary interruptions or outages
• Fraud Risk: Despite industry-standard security measures, no payment system is completely immune to fraud

2.2 Agent of Payee Risks

Because Network Pay is the Principal's agent (not the seller):

• Fulfillment Risk: The Principal is responsible for delivering products/services. Network Pay does not guarantee fulfillment, quality, or delivery
• Refund Risk: Refund decisions are made by the Principal, not Network Pay. Network Pay cannot independently issue refunds
• Principal Insolvency Risk: If the Principal becomes insolvent or ceases operations, Network Pay is not responsible for unfulfilled orders. However, your payment obligation was satisfied upon payment to Network Pay
• Dispute Risk: Product/service disputes must ultimately be resolved with the Principal

2.3 Not Insured

Network Pay is not a bank. Funds processed through Network Pay are not insured by:

• The Federal Deposit Insurance Corporation (FDIC)
• The Securities Investor Protection Corporation (SIPC)
• Any other government deposit insurance program

Collected Funds are held in segregated FBO Accounts at banking partners for the benefit of Principals. These funds are the property of the Principal upon receipt by Network Pay.

3. No Financial Advice Disclaimer

3.1 No Advice

Network Pay does not provide investment, financial, legal, or tax advice. We provide payment collection services only. Any information on our Platform is for general informational purposes and should not be construed as advice.

3.2 No Fiduciary Duty

Network Pay is not your financial advisor or fiduciary. Our relationship with you is that of payment agent (on behalf of the Principal) and payor.

4. Service Execution Standards

4.1 Payment Processing Standards

Network Pay is committed to:

• PCI-DSS compliance for secure handling of cardholder data
• Encryption of all payment data in transit and at rest
• Tokenization of card numbers to prevent exposure
• Real-time fraud monitoring using industry-standard systems
• Timely processing of authorized transactions

4.2 Processing Partners

Payments are processed through:

• Licensed card payment processors
• Card networks (Visa, Mastercard, American Express, Discover)
• ACH network (for bank transfers)
• Banking partners (for wire transfers)

5. Fees and Charges

5.1 Payor Fees

Network Pay generally does not charge fees directly to Payors. Transaction processing fees are paid by the Principal under their agency agreement.

5.2 Third-Party Fees

You may be charged fees by your own financial institution, including foreign transaction fees, cash advance fees, or wire transfer fees. Network Pay is not responsible for third-party fees.

5.3 Fee Disclosure

Any fee charged directly to you will be disclosed before you complete the transaction.

6. Complaints and Disputes

6.1 How to Contact Us

If you have a complaint or concern, please contact us:

• Email: support@networkpay.us
• Mail: Network Pay LLC, 1001 S Main St Suite 600, Kalispell, MT 59901

6.2 Complaint Process

We will:

1. Acknowledge receipt within 2 business days
2. Investigate the complaint, coordinating with the Principal as needed
3. Provide a resolution or status update within 5 business days

6.3 Regulatory Complaints

If you are not satisfied with our response, you may contact:

• Consumer Financial Protection Bureau (CFPB): www.consumerfinance.gov/complaint
• Montana Department of Administration, Banking and Financial Institutions Division
• Federal Trade Commission (FTC): www.ftc.gov/complaint

6.4 Dispute Resolution

Disputes are subject to the dispute resolution provisions in our Payment Terms, including binding arbitration in Montana under AAA rules.

7. Privacy and Data Protection

7.1 Privacy Policy

Our collection, use, and sharing of your personal information is described in our Privacy Policy, available at networkpay.us/privacy-policy.html.

7.2 Data Security

We implement industry-standard security measures to protect your information, including PCI-DSS compliance, encryption, and tokenization. However, no system is completely secure, and we cannot guarantee absolute security.

7.3 Your Rights

You have rights to access, correct, and delete your personal information, subject to legal and regulatory retention requirements. See our Privacy Policy for details.

8. Intellectual Property

8.1 Ownership

All content, trademarks, logos, and intellectual property on our Platform are owned by Network Pay LLC or our licensors.

8.2 Limited License

We grant you a limited, non-exclusive, non-transferable license to access and use our Platform for the purpose of making payments.

8.3 Restrictions

You may not:

• Copy, modify, or distribute our content
• Reverse engineer or decompile our software
• Use our trademarks without permission
• Frame or link to our Platform without authorization

9. Contact Information

Network Pay LLC 1001 S Main St Suite 600 Kalispell, MT 59901

Customer Support: Email: support@networkpay.us

Compliance Inquiries: Email: compliance@networkpay.us

Privacy Requests: Email: privacy@networkpay.us

Legal Notices: Email: legal@networkpay.us

Last Updated: February 20, 2026
Version: 2.1

© 2026 Network Pay LLC. All rights reserved.