Escrow Policy

TrustBridge Escrow Inc. ("TrustBridge") operates as a licensed, neutral escrow agent providing secure transaction facilitation services to buyers and sellers engaged in commercial transactions. Our escrow services are designed to mitigate counterparty risk by acting as an independent intermediary that holds funds in trust until all conditions of a transaction have been satisfied by the respective parties. This Escrow Policy ("Policy") governs all escrow transactions facilitated through the TrustBridge platform and supplements the Terms of Service, which are incorporated herein by reference.

TrustBridge is registered as a Money Services Business (MSB) with the Financial Crimes Enforcement Network (FinCEN) and maintains escrow licenses in all jurisdictions where such licensure is required. Our operations are subject to ongoing regulatory examination and oversight by applicable state and federal regulatory authorities. TrustBridge adheres to the highest standards of fiduciary duty and is committed to acting in the best interests of all transaction participants in accordance with its obligations as a neutral escrow agent.

By initiating, participating in, or otherwise engaging with any escrow transaction on the TrustBridge platform, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy should be read in conjunction with our Terms of Service, KYC & AML Policy, and Privacy Policy, which together form the complete legal framework governing your use of TrustBridge's services. In the event of any conflict between this Policy and the Terms of Service with respect to escrow-specific matters, this Policy shall control.

All funds deposited into escrow through the TrustBridge platform are held in segregated trust accounts maintained at federally chartered banking institutions insured by the Federal Deposit Insurance Corporation (FDIC). Client escrow funds are held separately from TrustBridge's corporate operating capital at all times and are never commingled with TrustBridge's own funds or the funds of other clients. Each escrow transaction is assigned a unique trust account reference number for precise tracking and reconciliation purposes, and all fund movements are recorded in an immutable audit trail.

TrustBridge maintains banking relationships with multiple FDIC-insured institutions to ensure redundancy, operational continuity, and adequate deposit insurance coverage. In the event that aggregate client deposits at any single institution approach FDIC insurance limits, TrustBridge will distribute funds across multiple institutions to maximize deposit insurance protection. TrustBridge performs daily reconciliation of all trust accounts to ensure that the total funds held correspond to the aggregate of all active escrow obligations. Independent audits of trust accounts are conducted annually by a licensed certified public accounting firm.

Interest earned on escrowed funds, if any, shall be handled in accordance with the applicable escrow agreement and governing law. Unless otherwise specified in the transaction-specific escrow agreement, interest accrued on escrowed funds during the holding period shall be retained by TrustBridge as partial compensation for the custody and administration of the trust accounts. TrustBridge reserves the right to change its trust account banking partners at any time, provided that all replacement institutions are FDIC-insured and meet TrustBridge's internal risk management and due diligence standards.

TrustBridge accepts escrow deposits through multiple payment methods to accommodate the diverse needs of our Users. Accepted payment methods include Automated Clearing House (ACH) transfers, domestic and international wire transfers, debit card payments, and such other payment methods as TrustBridge may support from time to time. The availability of specific payment methods may vary based on the User's jurisdiction, the transaction value, and the User's verification tier. All deposits are subject to payment processing verification and anti-fraud screening before being credited to the escrow trust account.

Deposit clearing times vary depending on the payment method selected. ACH transfers typically clear within two (2) to three (3) business days. Domestic wire transfers generally clear within one (1) business day, while international wire transfers may require three (3) to five (5) business days depending on the originating country and intermediary banking arrangements. Debit card deposits are typically processed within one (1) business day, subject to issuing bank authorization. TrustBridge will notify all transaction participants when deposited funds have cleared and are available for escrow, at which point the applicable inspection period or holding period shall commence.

Once deposited and cleared, escrowed funds shall be held by TrustBridge in trust for the duration of the escrow period as defined by the transaction-specific escrow agreement. During the holding period, TrustBridge shall not release, transfer, or otherwise disburse the escrowed funds except in accordance with the release conditions set forth in this Policy, the applicable escrow agreement, or a valid court order. TrustBridge reserves the right to place a temporary hold on deposited funds if there is reason to suspect that the deposit was made using fraudulent, unauthorized, or otherwise irregular payment methods, and such hold shall remain in effect until the matter has been investigated and resolved to TrustBridge's satisfaction.

Each escrow transaction includes a configurable inspection period during which the buyer is entitled to examine, test, and evaluate the goods, services, or digital assets received from the seller to determine whether they conform to the specifications, quality standards, and representations set forth in the underlying transaction agreement. The standard inspection period ranges from three (3) to fourteen (14) business days, as selected by the parties at the time of transaction initiation. The specific inspection period applicable to each transaction is clearly displayed during the transaction setup workflow and is confirmed by both parties prior to escrow funding.

The inspection period commences upon the earlier of: (a) the buyer's acknowledgment of receipt of the goods, services, or deliverables, as confirmed through the platform; or (b) the delivery tracking confirmation indicating successful delivery, as verified by the applicable shipping carrier or delivery service. During the inspection period, the buyer must actively inspect the received items and indicate acceptance or rejection through the platform. If the buyer fails to indicate acceptance or rejection within the inspection period, TrustBridge may, at its discretion, automatically release the escrowed funds to the seller, provided no dispute has been initiated.

Requests for inspection period extensions must be submitted through the platform prior to the expiration of the original inspection period and are subject to mutual agreement by both parties. TrustBridge may grant a reasonable extension of the inspection period at its discretion in cases involving complex deliverables, international shipping delays, or other extenuating circumstances. In no event shall the total inspection period, including any extensions, exceed thirty (30) business days unless expressly agreed to in writing by all parties and approved by TrustBridge. Buyers who routinely fail to complete inspections within the designated period may be subject to reduced inspection period options for future transactions.

Escrowed funds shall be released to the seller upon the occurrence of any of the following conditions: (a) the buyer affirmatively accepts the goods, services, or deliverables through the platform during or after the inspection period; (b) the inspection period expires without the buyer having initiated a rejection or dispute through the platform; or (c) a dispute initiated by the buyer has been resolved in favor of the seller through TrustBridge's dispute resolution process or through binding arbitration. Upon the satisfaction of any applicable release condition, TrustBridge will process the fund release within one (1) to three (3) business days, less any applicable escrow fees and charges.

TrustBridge processes fund releases through the seller's designated payment method as recorded in their account profile. Available disbursement methods include ACH transfer, domestic wire transfer, and international wire transfer. The specific processing time for fund releases depends on the selected disbursement method and the seller's banking institution. Sellers are responsible for ensuring that their payment information is accurate and up-to-date; TrustBridge shall not be liable for any delays or losses resulting from incorrect or outdated payment information provided by the seller.

In certain circumstances, TrustBridge may delay the release of funds for additional review, including but not limited to: (a) transactions flagged by automated fraud detection systems; (b) transactions subject to pending regulatory inquiries or law enforcement requests; (c) transactions involving parties subject to enhanced due diligence requirements; or (d) situations where TrustBridge has reasonable grounds to believe that the release of funds may facilitate a violation of applicable law, these Terms, or TrustBridge's compliance policies. In such cases, TrustBridge will use commercially reasonable efforts to complete its review and process the release or provide notice of the basis for the delay within a reasonable timeframe.

In the event that the seller fails to deliver the goods, services, or deliverables within the timeframe specified in the escrow agreement, or if the buyer's rejection of the delivered items is upheld through the dispute resolution process, the escrowed funds shall be refunded to the buyer in full, less any applicable non-refundable processing fees that were disclosed at the time of transaction initiation. Full refunds are also issued in cases where the seller is unable to fulfill the transaction due to account suspension, regulatory action, or other circumstances that render delivery impossible.

In cases of partial delivery or where the delivered goods, services, or deliverables materially deviate from the agreed specifications but retain some value, TrustBridge may facilitate a pro-rated refund based on the assessed value of the shortfall. Pro-rated refund calculations are determined through TrustBridge's dispute resolution process, taking into account the nature and extent of the deficiency, the representations made by the seller, and any supporting evidence provided by both parties. Both parties will be notified of the proposed pro-rated refund amount and will have an opportunity to accept or contest the determination before the refund is processed.

Refunds are processed through the buyer's original payment method whenever possible. If the original payment method is no longer available or valid, TrustBridge will process the refund to an alternative payment method designated by the buyer and verified in accordance with TrustBridge's security and compliance procedures. Standard refund processing times are three (3) to five (5) business days from the date the refund is authorized, though actual receipt of funds may take additional time depending on the buyer's financial institution. TrustBridge is not responsible for any delays in refund processing caused by the buyer's banking institution or payment processor.

TrustBridge charges escrow facilitation fees based on the total transaction value as set forth in the fee schedule below. All fees are transparently disclosed to both the buyer and seller prior to the confirmation of any escrow transaction and are displayed prominently during the transaction initiation workflow. By confirming a transaction, both parties acknowledge and agree to the applicable fee. Unless otherwise specified in the escrow agreement, the escrow fee is typically borne by the buyer, though the parties may mutually agree to an alternative fee allocation arrangement.

A minimum fee of $5.00 applies to all transactions regardless of the calculated percentage. For enterprise clients with recurring high-volume transaction needs, TrustBridge offers customized fee arrangements that may include volume-based discounts, fixed per-transaction fees, or monthly subscription pricing. Enterprise fee arrangements are available upon request and are subject to a separate written agreement. Additional charges may apply for ancillary services including wire transfer disbursements ($25.00 per domestic wire, $45.00 per international wire), expedited processing ($15.00 per request), and currency conversion (at prevailing market rates plus a 0.5% conversion fee).

Escrow fees are calculated at the time of transaction initiation based on the transaction value and the fee schedule in effect at that time. Fees are deducted from the escrowed funds at the time of fund release or refund processing, as applicable. TrustBridge reserves the right to modify its fee schedule at any time upon thirty (30) days' prior notice to registered Users. Fee modifications shall apply only to transactions initiated on or after the effective date of the change. In the event that a transaction is cancelled prior to the commencement of the escrow holding period, TrustBridge may retain a nominal administrative fee to cover payment processing costs.

TrustBridge employs a three-tier dispute resolution framework designed to resolve transaction disputes efficiently, fairly, and in accordance with the principles of due process. Tier 1: Automated Resolution. Upon the initiation of a dispute by either party, TrustBridge's automated dispute resolution system will analyze the available transaction data, delivery confirmations, communication records, and applicable escrow terms to determine whether the dispute can be resolved automatically based on objective criteria. Automated resolution is typically completed within twenty-four (24) to forty-eight (48) hours and is applicable to clear-cut cases such as confirmed non-delivery, documented delivery confirmation with no inspection period activity, or mutual agreement between the parties.

Tier 2: Human Mediation. If the dispute cannot be resolved through automated means, it is escalated to a trained TrustBridge dispute resolution specialist who will conduct a thorough review of the case. The specialist will communicate with both parties, request additional evidence or documentation as needed, and facilitate negotiation toward a mutually acceptable resolution. Both parties are required to respond to requests for information within five (5) business days of receipt. The mediation process typically takes five (5) to ten (10) business days from the date of escalation. The mediator's proposed resolution is non-binding and serves as a recommendation to the parties.

Tier 3: Binding Arbitration. If the dispute remains unresolved after the mediation process, either party may request binding arbitration in accordance with the dispute resolution provisions set forth in TrustBridge's Terms of Service. Arbitration is conducted by a qualified, independent arbitrator under the rules of the American Arbitration Association (AAA). The arbitrator's decision is final, binding, and enforceable in any court of competent jurisdiction. During the pendency of any dispute, escrowed funds shall remain in TrustBridge's custody and shall not be released to either party unless directed by the dispute resolution outcome, mutual agreement of the parties, or a valid court order.

TrustBridge acts solely as a neutral escrow agent and facilitator of transactions between buyers and sellers. TrustBridge is not a party to the underlying transaction between the buyer and seller and makes no representations or warranties regarding the quality, safety, legality, merchantability, fitness for a particular purpose, or condition of any goods, services, or digital assets that are the subject of an escrow transaction. TrustBridge does not inspect, test, evaluate, or validate the items or services being exchanged and shall not be liable for any loss, damage, or claim arising from defects, misrepresentations, or other issues related to the subject matter of the underlying transaction.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, TRUSTBRIDGE'S AGGREGATE LIABILITY ARISING OUT OF OR RELATED TO ANY ESCROW TRANSACTION SHALL NOT EXCEED THE TOTAL ESCROW FEES ACTUALLY COLLECTED BY TRUSTBRIDGE IN CONNECTION WITH THAT SPECIFIC TRANSACTION. IN NO EVENT SHALL TRUSTBRIDGE BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO LOSS OF PROFITS, LOSS OF DATA, LOSS OF BUSINESS OPPORTUNITY, OR BUSINESS INTERRUPTION, ARISING OUT OF OR IN CONNECTION WITH ANY ESCROW TRANSACTION OR THIS POLICY.

TrustBridge shall not be liable for any delay, failure, or interruption in the performance of its obligations under this Policy resulting from causes beyond its reasonable control, including but not limited to acts of God, natural disasters, epidemics or pandemics, war, terrorism, civil unrest, labor disputes, governmental action or regulation, banking system failures, power outages, telecommunications failures, or cyberattacks (collectively, "Force Majeure Events"). In the event of a Force Majeure Event, TrustBridge's obligations shall be suspended for the duration of the event, and TrustBridge shall use commercially reasonable efforts to resume performance as soon as practicable following the cessation of the Force Majeure Event.

Users who wish to close their TrustBridge account must ensure that all active escrow transactions in which they are a participant have been completed, cancelled by mutual agreement, or otherwise resolved in accordance with this Policy before account closure can be processed. TrustBridge will not close an account or release a User from their escrow obligations while any transaction remains in an active, pending, or disputed state. Upon submission of an account closure request, TrustBridge will review the User's transaction history and confirm that no outstanding escrow obligations exist before processing the closure.

In the event that TrustBridge terminates a User's account due to a violation of the Terms of Service, suspected fraudulent activity, or regulatory action, any active escrow transactions involving the terminated User shall be handled on a case-by-case basis with the objective of protecting the legitimate interests of all transaction participants. TrustBridge may, at its discretion, facilitate the completion of pending transactions, return escrowed funds to the depositing party, or hold funds pending the resolution of any ongoing investigation or legal proceeding. TrustBridge will communicate with all affected transaction participants regarding the status and resolution of their pending transactions.

Following account closure, TrustBridge shall retain all transaction records, escrow agreements, and related documentation for a period of not less than five (5) years in accordance with applicable regulatory requirements, including the Bank Secrecy Act and FinCEN recordkeeping regulations. Certain provisions of this Policy, including but not limited to the sections on Liability, Dispute Handling, and Regulatory Compliance, shall survive the termination of the User's account and shall continue in full force and effect with respect to any transactions initiated prior to termination.

TrustBridge is registered as a Money Services Business (MSB) with the Financial Crimes Enforcement Network (FinCEN) and maintains all required state-level money transmitter and escrow agent licenses in jurisdictions where such licensure is required for the provision of escrow services. TrustBridge's regulatory status and license numbers are available upon request and are filed with the Nationwide Multistate Licensing System and Registry (NMLS). TrustBridge is committed to maintaining full compliance with all applicable federal, state, and local laws and regulations governing escrow services, money transmission, and financial intermediation.

TrustBridge cooperates fully with all regulatory examinations, audits, and inquiries conducted by applicable supervisory authorities, including FinCEN, state banking departments, and state attorneys general. TrustBridge maintains a comprehensive compliance program that includes written policies and procedures, designated compliance personnel, independent testing, employee training, and ongoing monitoring of regulatory developments. TrustBridge files all required reports with regulatory authorities, including Suspicious Activity Reports (SARs), Currency Transaction Reports (CTRs), and such other reports as may be required by applicable law.

For questions regarding TrustBridge's regulatory status, licensing, or compliance program, or to report a concern regarding compliance matters, please contact our compliance department at escrow@trustbridge.com. You may also direct regulatory inquiries to TrustBridge Escrow Inc., Compliance Department, 123 Financial District, New York, NY 10004, United States of America. TrustBridge is committed to transparency and will respond to all regulatory and compliance inquiries in a timely manner.