TrueOwn Loan Officer Terms of Service

1. Who We Are

TrueOwn ("TrueOwn," "we," "us," or "our") operates the LO Portal.

You can reach us at lo-support@trueown.com for LO Portal matters, or at the addresses in Section 20.

2. What TrueOwn Is and What It Is Not

What TrueOwn is: a software platform that helps licensed mortgage professionals stay engaged with their past and current clients by monitoring client mortgages for savings opportunities (PMI cancellation, escrow issues, refinance opportunities, and related events) and delivering LO-branded communications to clients who consent to receive them.

What TrueOwn is not:

• TrueOwn is not a mortgage lender, broker, or loan originator. We do not take applications, originate loans, or negotiate loan terms.
• TrueOwn is not your employer, sponsoring lender, or compliance department. Nothing in TrueOwn substitutes for your own compliance program or your sponsoring lender's requirements.
• TrueOwn is not a law firm. These Terms are not legal advice.
• TrueOwn is not affiliated with any government agency, including NMLS, CFPB, HUD, VA, or FHA.
• TrueOwn is not a credit reporting agency and is not a user of consumer reports under FCRA (you and your sponsoring lender retain those roles where applicable).

3. Eligibility and Account

To use the LO Portal, you must:

• Be a natural person at least 18 years old;
• Hold a current Mortgage Loan Originator ("MLO") license in good standing in the state of Florida, registered through NMLS, and provide your NMLS ID at account creation;
• Be authorized by your sponsoring lender (if any) to use third-party client engagement technology, and not be operating in violation of any employment or sponsorship agreement;
• Provide accurate account information and keep it current, including prompt notification of any license suspension, revocation, or change of sponsorship.

We may verify your NMLS status at any time. If your license lapses or is revoked, your LO Portal access will be suspended.

Florida-only scope. TrueOwn currently supports client data and communications only for homeowners whose mortgaged property is located in Florida. You must not upload or use client data for homeowners in other states until TrueOwn announces support for those states.

4. Your Compliance Responsibilities

TrueOwn provides tooling; you own compliance. You are solely responsible for:

4.1 Licensing. Maintaining your MLO license under the federal SAFE Act and Florida Chapter 494, and any additional state licenses where you operate.

4.2 Sponsoring-lender policies. Following your sponsoring lender's marketing, advertising, client-contact, and third-party-technology policies.

4.3 RESPA. Not using TrueOwn to give or receive anything of value for the referral of settlement services in violation of RESPA Section 8. TrueOwn does not pay or accept referral fees in connection with loan origination activity.

4.4 TILA and MAP Rule. Ensuring every communication sent in your name through TrueOwn complies with Truth in Lending (Regulation Z) advertising rules and the FTC Mortgage Acts and Practices Rule (12 CFR Part 1014), including the MAP Rule's 24-month recordkeeping requirement. TrueOwn retains copies of templates sent under your name and will make them available to you on request, but you are the regulated advertiser and are ultimately responsible for retention.

4.5 TCPA and CAN-SPAM. Ensuring you have a lawful basis (including any required prior express written consent for marketing SMS) to contact each client, and honoring opt-out requests. TrueOwn's platform enforces global opt-out — once a client unsubscribes, you cannot use TrueOwn to send them further marketing.

4.6 ECOA and Fair Lending. Not using TrueOwn in a way that causes disparate treatment or disparate impact based on protected characteristics.

4.7 FCRA and trigger leads. Not supplying consumer report information to TrueOwn unless you have a permissible purpose and all required disclosures, and not using TrueOwn to facilitate trigger-lead activity prohibited by the federal Homebuyers Privacy Protection Act (effective March 5, 2026) or applicable state laws.

4.8 State advertising and UDAAP. Ensuring the content of communications you approve complies with Florida advertising rules, UDAAP standards, and any applicable state laws.

5. Client Data — Your Representations and Warranties

When you upload, import, or otherwise share information about any individual ("Client Data") with TrueOwn, you represent and warrant that:

5.1 Lawful collection. The Client Data was lawfully collected by you or your sponsoring lender in the ordinary course of a bona fide mortgage business relationship.

5.2 Authority to share. You have the right, under applicable law and under any agreement with your sponsoring lender, employer, or prior employer, to share the Client Data with TrueOwn for the purposes described in these Terms and the DPA.

5.3 Required consents. You have obtained any consents required under:

• The Gramm-Leach-Bliley Act and Regulation P, including any opt-out-based disclosures to non-affiliates;
• The Fair Credit Reporting Act, if any FCRA-regulated data is included (we ask that you not upload FCRA-regulated data);
• The Homebuyers Privacy Protection Act (effective March 5, 2026);
• Any applicable state privacy law (including FDBR, CCPA, VCDPA, TDPSA, and others, as applicable to your clients).

5.4 Client-level hygiene. You have not uploaded Client Data about:

• Any individual who has opted out of marketing communications from you or your sponsoring lender;
• Any individual who has requested that their information not be shared with third-party service providers;
• Any individual who is subject to an active "do not contact" or "no solicitation" request;
• Any individual whose property is not located in a state currently supported by TrueOwn.

5.5 Accuracy. The Client Data is, to the best of your knowledge, accurate as of the date of upload.

5.6 Material representation. Each representation in this Section 5 is material. TrueOwn relies on these representations to process Client Data on your behalf. If any representation is inaccurate, you indemnify TrueOwn under Section 14, and we may immediately suspend or terminate your account under Section 17.

6. LO-Branded Communications

TrueOwn generates communications to your clients that display your name, photo (if uploaded), NMLS ID, sponsoring lender (if applicable), and contact information. You authorize TrueOwn to send such communications on your behalf.

6.1 Your acknowledgments:

• You are the regulated advertiser for purposes of the MAP Rule, state mortgage advertising rules, CAN-SPAM, and TCPA.
• TrueOwn will include footer identification stating that the communication is sent on your behalf by TrueOwn, along with TrueOwn's physical address.
• Client opt-outs are honored globally across TrueOwn. Once a client unsubscribes, we will not send them further marketing communications on your behalf.
• TrueOwn may pause or decline to send any communication we reasonably believe violates applicable law, our policies, or these Terms.

6.2 Content review. TrueOwn provides templates and reasonable visibility into communications scheduled under your name. We encourage you to configure compliance review with your sponsoring lender; we do not automatically submit materials to any third party for review on your behalf.

6.3 No rate quotes. You may not use TrueOwn to quote specific interest rates, APRs, or loan terms to individual clients as "available to you" or similar language that could constitute a firm offer or an advertisement of specific credit terms without the disclosures required by Regulation Z. TrueOwn's rate-watch alerts (when enabled) are informational comparisons based on published market rates.

7. Access to Client Data Within the Portal

Your access to individual client records via the LO Portal is read-only and gated by each client's consent.

• You may see whether a client has engaged with a TrueOwn communication, created an account, and (where the client consents) a summary of savings opportunities in their file.
• You may not see Plaid-connected balances, uploaded documents, detailed escrow data, or Plaid access tokens. These are the homeowner's, accessible only to the homeowner and to TrueOwn for the purpose of providing the service.
• You may not export, resell, or share Client Data accessed through TrueOwn with any third party (including other LOs, marketing vendors, lead-generation services, or companies other than your sponsoring lender).
• You may not use Client Data accessed through TrueOwn for any purpose other than servicing your existing client relationship consistent with applicable law.

The DPA governs in greater detail how TrueOwn processes Client Data on your behalf.

8. Fees

8.1 Subscription. LO Portal access is provided under the subscription tier you select at signup (for example, a free introductory tier or a paid tier). Fees, trial periods, billing frequency, and included features are disclosed in-product at the time of purchase.

8.2 Billing. We use Stripe for payment processing. By providing payment information, you authorize us to charge your payment method for the applicable subscription fee.

8.3 Changes to fees. We may change fees for future billing periods with at least 30 days' notice by email or in-product notice.

8.4 No refunds. Subscription fees are non-refundable except where required by law or as expressly stated at the time of purchase. If you cancel, access continues through the end of your current billing period and will not renew.

8.5 Taxes. Fees are exclusive of applicable taxes. You are responsible for any taxes arising from your use of the LO Portal, other than taxes based on TrueOwn's net income.

8.6 No referral-fee structure. TrueOwn does not pay you, and you do not pay TrueOwn, any fee in exchange for the referral of settlement services. Subscription fees are for access to software, not for referrals.

9. Prohibited Uses

You will not:

• Use TrueOwn in a way that violates RESPA Section 8 (anti-kickback);
• Upload Client Data about individuals for whom you do not have a lawful basis to share that information;
• Use TrueOwn to originate loans, quote specific rates, or negotiate loan terms;
• Use TrueOwn to engage in mortgage loan origination activities in states where you are not licensed;
• Use TrueOwn to make representations TrueOwn has not authorized about TrueOwn's services (including representations to clients, regulators, or investors);
• Reverse-engineer, scrape, circumvent access controls, or attempt to access data other than through the intended interfaces;
• Use TrueOwn to send communications to clients in violation of TCPA, CAN-SPAM, or state-equivalent laws;
• Use TrueOwn to facilitate trigger-lead activity prohibited by the Homebuyers Privacy Protection Act or state law;
• Share your login credentials with anyone else, including colleagues at your sponsoring lender (each user needs their own account);
• Use TrueOwn in any way that violates your sponsoring lender's policies or your employment agreement.

10. Your Intellectual Property and License to TrueOwn

You retain ownership of Client Data and other content you upload. You grant TrueOwn a limited, non-exclusive, worldwide license to host, process, transmit, and display that content solely to provide the LO Portal services to you and to deliver communications to your clients as authorized. This license terminates upon deletion of the content or termination of your account, subject to legally required retention.

11. TrueOwn Intellectual Property

TrueOwn owns the Platform, including software, templates, documentation, and trademarks. We grant you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to use the LO Portal for your internal business use during the term of your subscription. You may not remove TrueOwn's branding except as expressly authorized (for example, in white-label arrangements governed by a separate written agreement).

12. Confidentiality

Each party will protect the other's confidential information with at least the same degree of care it uses to protect its own confidential information, and in no event less than reasonable care, and will use the other party's confidential information only for purposes of performing under these Terms. Confidential information does not include information that is publicly known, independently developed, or rightfully received from a third party without obligation of confidentiality.

13. Disclaimers

TrueOwn is provided "as is" and "as available." To the fullest extent permitted by law, we disclaim all warranties, express or implied, including warranties of merchantability, fitness for a particular purpose, non-infringement, and any warranties arising from course of dealing or usage of trade.

We do not warrant that:

• TrueOwn will be uninterrupted, secure, or error-free;
• AVM estimates, servicer data, or third-party data are accurate or current;
• Any client will engage with TrueOwn or produce savings or referrals;
• Any regulator or auditor will accept TrueOwn's tooling as substitute for your own compliance program.

14. Indemnification

You agree to indemnify, defend, and hold TrueOwn and its affiliates, officers, directors, employees, and agents harmless from any claim, damage, liability, cost, or expense (including reasonable attorneys' fees) arising out of:

• Your use of TrueOwn;
• Any Client Data you uploaded, including any claim that the data was shared without a lawful basis or in violation of any privacy law;
• Your violation of these Terms, the DPA, or any law;
• Communications sent in your name through TrueOwn (regardless of whether TrueOwn generated the template), including any claim under TCPA, CAN-SPAM, the MAP Rule, or RESPA;
• Any dispute between you and your sponsoring lender, employer, or prior employer regarding your use of TrueOwn or the Client Data.

This indemnification survives termination.

15. Limitation of Liability

To the fullest extent permitted by law:

• TrueOwn will not be liable for any indirect, incidental, consequential, special, exemplary, or punitive damages, including lost profits, lost commissions, lost clients, lost data, or reputational harm.
• Our total aggregate liability to you for all claims relating to TrueOwn will not exceed the greater of (a) the amount you paid us in the 12 months preceding the claim, or (b) five hundred U.S. dollars ($500).
• Nothing in these Terms limits liability for gross negligence, willful misconduct, or fraud.

16. Dispute Resolution — Arbitration and Class Action Waiver

Please read this section carefully. It affects your legal rights.

16.1 Informal resolution. Before filing any formal claim, you agree to first contact us at legal@trueown.com and give us 60 days to try to resolve the dispute informally.

16.2 Binding arbitration. Any dispute arising out of or relating to these Terms or the LO Portal that is not resolved informally will be resolved by binding arbitration administered by the American Arbitration Association under its Commercial Arbitration Rules. Arbitration will take place in Miami-Dade County, Florida. The arbitrator's decision will be final and binding.

16.3 Class action waiver. You and TrueOwn agree that each party may bring claims against the other only in an individual capacity, not as a plaintiff or class member in any class, collective, or representative action.

16.4 Exceptions. Either party may bring an individual claim in small-claims court and seek injunctive relief for intellectual property infringement or breach of confidentiality.

16.5 Opt-out. You may opt out of the arbitration and class-action waiver in Section 16 by sending written notice to legal@trueown.com within 30 days of creating your account. Notice must include your name, email, and a statement that you wish to opt out of Section 16.

17. Term, Suspension, and Termination

17.1 Term. These Terms begin when you create an LO account and continue until terminated.

17.2 Termination by you. You may terminate at any time in your account settings or by emailing lo-support@trueown.com. Termination takes effect at the end of your current billing period.

17.3 Termination or suspension by TrueOwn. We may suspend or terminate your account immediately if:

• You breach these Terms, the DPA, or your compliance obligations;
• Your MLO license lapses, is suspended, or is revoked;
• We reasonably believe Client Data was uploaded without a lawful basis;
• Your sponsoring lender notifies us of a restriction affecting your use of the Platform;
• Required by law or regulator.

17.4 Effect of termination. On termination:

• Your access to the LO Portal ends;
• Client Data you uploaded is handled in accordance with the DPA;
• Homeowner accounts created through your enrollment remain with the homeowner — we do not delete a homeowner's account because your LO account ended;
• Sections 5, 9, 10, 12, 13, 14, 15, 16, and 19 survive.

18. Changes to These Terms

We may update these Terms from time to time. If we make material changes, we will notify you by email or in-product notice at least 30 days before the change takes effect. Your continued use of the LO Portal after the effective date constitutes acceptance.

19. Miscellaneous

Governing law. These Terms are governed by the laws of the State of Florida, without regard to conflict-of-laws principles. Subject to Section 16 (arbitration), any action must be brought in the state or federal courts located in Miami-Dade County, Florida.

Entire agreement. These Terms, together with the DPA and any fee disclosures, are the entire agreement between you and TrueOwn regarding your use of the LO Portal.

Order of precedence. In the event of a conflict, the DPA controls over these Terms with respect to TrueOwn's processing of Client Data.

Severability. If any provision is held unenforceable, the remaining provisions remain in effect.

No waiver. Our failure to enforce any provision is not a waiver of our right to enforce it later.

Assignment. You may not assign these Terms without our consent. We may assign them to a successor in connection with a merger, acquisition, or sale of assets.

Notices. We may give you notice by email or through the LO Portal. Notices to us must be sent to legal@trueown.com.

Force majeure. Neither party is liable for delays or failures caused by events beyond its reasonable control.

Independent contractors. Nothing in these Terms creates a partnership, employment, agency, or joint venture relationship. You are not an agent of TrueOwn and you may not bind TrueOwn to any obligation.

20. Contact Us

TrueOwn

• LO Support: lo-support@trueown.com
• Privacy: privacy@trueown.com
• Legal: legal@trueown.com
• Security: security@trueown.com