Stablecoin DAA Addendum
Effective date:
Stablecoin Addendum to Commercial Deposit Account Agreement
This Stablecoin Addendum ("Addendum") establishes the terms and conditions under which Column National Association ("Bank") agrees to allow you to convert certain Supported Stablecoins to and from Fiat currency (the "Stablecoin Services"). This Addendum supplements, amends, and forms a part of your Commercial Deposit Account Agreement with Bank (the "Agreement"). If there is any conflict between this Addendum and the Agreement, this Addendum shall govern with regard to the Stablecoin Services, but only to the extent of such inconsistency. By using the Stablecoin Services, you agree that you are bound by and will comply with this Addendum, the Agreement, Applicable Law, and any other terms, conditions, or agreements applicable to the Stablecoin Services.
IMPORTANT. THE STABLECOIN SERVICES INVOLVE THE RECEIPT AND CONVERSION OF DIGITAL ASSETS. DIGITAL ASSETS, INCLUDING STABLECOINS, ARE NOT LEGAL TENDER, ARE NOT BACKED BY THE GOVERNMENT, AND ARE NOT FDIC-INSURED. YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND ACCEPT THE RISKS DESCRIBED IN THIS ADDENDUM.
IF YOU DO NOT AGREE TO THIS AGREEMENT, DO NOT ENROLL IN OR USE THE STABLECOIN SERVICES.
1.Definitions
Unless otherwise defined in this Addendum, capitalized terms have the meanings assigned in the Agreement.
“Applicable Blockchain” means each distributed ledger network supported by Bank for the Stablecoin Services.
“Digital Asset” means any digital asset (including a virtual currency or virtual commodity) which is a digital representation of value based on (or built on top of) a cryptographic protocol of a computer network. A “Digital Asset” is presumed to be a “Controllable Electronic Record” as defined in Article 12 Section 102 of the Uniform Commercial Code (“UCC”).
“Digital Asset Payment Address” means the digital asset payment address (i.e., a digital asset “wallet”) custodied by the Bank in a non-fiduciary capacity on your behalf in connection with the Stablecoin Services. Digital Asset Payment Addresses are available only on Applicable Blockchains, and Digital Asset Payment Address is used to mean both an individual address on an individual Applicable Blockchain and the collective of all such addresses custodied by Bank on your behalf. For the avoidance of doubt, neither you nor Servicer will have direct access to the private keys associated with the Digital Asset Payment Address nor the ability to sign transactions from the Digital Asset Payment Address.
"Conversion" means the exchange of one currency to another (which includes Fiat and Supported Stablecoins) as made available by or through the Stablecoin Services.
"Conversion Request" means your instruction for Bank to undertake a Conversion.
“Daily Conversion Limit” means the maximum aggregate U.S. dollar-equivalent amount of Supported Stablecoins that may be converted on your behalf in any single calendar day, as communicated through the Slash App and subject to adjustment by Bank and Slash at any time.
"Digital Asset Wallet" means, the third-party wallet or address you designate for ultimate receipt or delivery of Supported Stablecoins, for Fiat-to-Supported Stablecoin or Supported Stablecoin-to-Fiat Conversions.
"Fiat Account" means your deposit account(s) under the Agreement. For purposes of Conversions, “Fiat Account” refers to your Transactional Account.
"Fiat Currency" or “Fiat” means U.S. dollars.
"Supported Stablecoins" means certain Fiat-referenced U.S. dollar-denominated stablecoin assets on Applicable Blockchains that are expressly supported by the Stablecoin Services from time to time. For the avoidance of doubt, Supported Stablecoins exclude algorithmic stablecoins, Supported Stablecoin equivalents on unsupported blockchain protocols, non-stablecoin digital assets, and any unsupported, delisted, or excluded protocols or functionalities. A Supported Stablecoin is a form of Digital Asset.
2.Eligibility
To access the Stablecoin Services, you must first establish and maintain a Fiat Account with Bank in good standing. You will only be able to access the Stablecoin Services in connection with your Fiat Account. Your use of the Stablecoin Services is subject to terms hereunder and in the Agreement, and the Stablecoin Services shall constitute a service offered by the Bank under and in connection with the Fiat Account.
To be eligible for the Stablecoin Services, you must also agree to this Addendum, including any eligibility criteria contained therein. If enabled for your Fiat Account, you may elect to access the Stablecoin Services through the mechanism provided by Servicer.
3.Access
If you elect to access the Stablecoin Services, Bank will establish a Digital Asset Payment Address held in your name. All Digital Asset Payment Addresses are owned by Bank, and you do not have any ownership interest in, or direct access to, any Digital Asset Payment Address or associated private keys. Bank and Slash may deny, condition, suspend, or revoke your access to the Stablecoin Services at any time, for any reason or no reason, in their sole discretion.
You own the Digital Assets in your associated Digital Asset Payment Address, as well as the Fiat credited to your Fiat Account following Conversion. The Digital Assets stored in the Digital Asset Payment Address are not commingled with other Digital Assets without express action taken by you and are held in custody pursuant to the terms of this Addendum.
You may view your Digital Asset Payment Address and associated QR codes through the Slash App, including on mobile. You are solely responsible for providing accurate Digital Asset Payment Address information to counterparties.
You may be required to complete a purpose of use questionnaire or provide additional information regarding your anticipated stablecoin activity, counterparties, and sources of funds before gaining access to the Stablecoin Services, or you may be required to provide such information with respect to a specific Conversion Request. You represent that all such information is true, accurate, and complete, and you agree to promptly update it if it changes.
4.Account Closure; Dormancy
If you close your Fiat Account, you may no longer access the Stablecoin Services. Bank will cancel any transactions that have not been completed, and you will remain liable and responsible for any and all obligations related to your Fiat Account. Bank reserves the right to place a hold on, close, deactivate, or delete the Digital Asset Payment Address at its discretion if we suspect irregular, fraudulent, suspicious, unlawful or otherwise unauthorized activity. We may attempt to notify you of such a hold but are not required to provide notice prior to placing the hold or thereafter. We also may attempt to contact you to obtain additional information regarding the activity related to the Digital Asset Payment Address. We reserve the right to maintain any hold on the Digital Asset Payment Address until we receive the requested information. You agree that we may maintain such hold until all issues, including claims against you or us, concerning Digital Assets held in the Digital Asset Payment Address have been resolved fully to our sole satisfaction. Bank will not be held liable for any loss you incur if the Digital Asset Payment Address is restricted or subject to a hold. Notwithstanding the foregoing, we may collect on any debt arising out of any illegal or unlawful transaction, to the extent permissible under Applicable Law.
If your Fiat Account is closed, we will attempt to return any Digital Assets in the Digital Asset wallet to you as described below. You may also request deactivation or closure of your associated Digital Asset Payment Address through Slash. Bank may but is not obligated to close or delete the Digital Asset Payment Address at your request. If your Fiat Account is closed, or if the Digital Asset Payment Address is closed or deactivated at your request, we will attempt to return any remaining Digital Assets in the Digital Asset Payment Wallet to a Digital Asset Wallet address that you specify to Servicer, or if no such address is provided in the timeframe specified by Servicer, to the last Digital Asset Wallet associated with your account. You are solely responsible for providing and ensuring the correctness of such Digital Asset Wallet address to and with Servicer within the timeframe specified by Servicer, and we may attempt to return funds to such Digital Asset Wallet. We are not responsible for verifying the Digital Asset Wallet address (including whether it is operative or able to receive the Supported Stablecoins). We may attempt via commercially reasonable methods to return Supported Stablecoins received at a deactivated Digital Asset Payment Address to the originator, but we have no liability should we fail to do so.
A Digital Asset Payment Address that is inactive for eighteen (18) months may be considered dormant. Each state has varying laws as to when Digital Assets in a Digital Asset Payment Address are subject to escheatment, and Bank may be required to send any remaining Digital Assets in the Digital Asset Payment Address to the state of your last known address or otherwise dispose of such Digital Assets in accordance with Applicable Law. You understand that if the Digital Asset Payment Address is inactive (dormant), we may close or delete the Digital Asset Payment Address. We reserve the right to refuse to return any remaining Digital Asset balance amount less than the equivalent of $1.00. You agree that we are relieved of all responsibility if the Digital Asset Payment Address balance is escheated in accordance with Applicable Law. The Digital Asset Payment Address will become inactive unless you have conducted activity with respect to the Digital Asset Payment Address, such as making a Conversion Request.
5. Scope of Services; Relationship
You may only use the Stablecoin Services the Digital Asset Payment Address as permitted by Applicable Law and the Agreement, and not for any illegal or unlawful transaction, or in a way that would cause your Fiat Account to be used for any illegal or unlawful transaction or in a manner prohibited by the Agreement. You may not use the Stablecoin Services, nor may you cause the Digital Asset Payment Address to be used, for any illegal or unlawful transaction, or in a manner that would violate the terms of the Agreement or this Addendum. The Stablecoin Services and Digital Asset Payment Address may only be used to effectuate transactions and for purposes that would be permitted under the terms of the Agreement if such activity were to occur through your Fiat Account.
You may request Conversions (Fiat-to-Supported Stablecoin or Supported Stablecoin-to-Fiat) through Bank via Servicer, which may be facilitated by Bank and/or one or more third-party service providers acting on your behalf to execute your instructions. Bank does not guarantee execution, timing, or availability of any Conversion. You acknowledge and agree that Bank does not exercise any investment discretion on your behalf or otherwise engage in activities that would evidence a fiduciary relationship.
You acknowledge the Stablecoin Services may not be available in all markets or jurisdictions and may be restricted, suspended, or terminated in Bank’s discretion or as required by a service provider or Applicable Law.
The Bank is the merchant of record in connection with the purchase and sale of Supported Stablecoins used to effectuate a Conversion, unless indicated otherwise prior to the effectuation of the Conversion.
Third parties providing data make no warranties of any kind related to the data provided by our Stablecoin Services, whether express, implied, statutory, or otherwise.
6. Supported Stablecoins; Excluded Protocols and Features
Bank and/or Servicer will publish or make available the then-current list of Applicable Blockchains and Supported Stablecoins and may add, suspend, restrict, or discontinue support for any asset or network in their discretion without liability, including for forks, airdrops, wrapped assets, side chains, or alternative networks.
Unless expressly announced, supplemental or advanced protocol functionalities are excluded from the Digital Asset Services, including staking, protocol governance, smart contracts, metacoins, colored coins, side chains, and other derivative, enhanced, or forked protocols. Attempts to use excluded functionality or unsupported networks may result in loss of assets for which Bank and Servicer have no responsibility or obligation to recover.
Bank and Servicer do not own or control the underlying software protocols governing Supported Stablecoins or any other Digital Assets and assume no responsibility for protocol changes, forks, or other operating changes that may affect availability, value, or functionality. Bank may suspend Stablecoin Services or decline to support resulting assets in its sole discretion.
7. Unsupported Digital Assets; Mistaken Transfers; Returns
You must only send Supported Stablecoins over Applicable Blockchains via the Stablecoin Services. Bank is under no obligation to honor, and will have no liability for, any transaction involving unsupported Digital Assets or networks. Bank and Servicer are not required to investigate, identify, or retrieve unsupported assets.
Blockchain transfers (including Conversions and transfers to the Digital Asset Payment Address or your Digital Asset Wallet) cannot be reversed once broadcast and may remain pending due to network conditions. Once you send Digital Assets to an address, you may lose access to your Digital Assets temporarily or indefinitely; for example, an address may have been entered incorrectly, or an address may belong to an entity that will not return your Digital Assets. Digital Assets mistakenly sent to an address that we do not control may not be recoverable, and neither Bank nor Servicer will be under any obligation to attempt to recover Digital Assets so sent in error.
Bank is not responsible or liable for any erroneous, accidental, or mistaken Digital Asset transfer that you effectuate or request via a Conversion Request. You are solely responsible for ensuring accurate, complete and correct addresses (including for the Digital Asset Wallet and Digital Asset Payment Address), destination tags/memos, payment instructions, network selection, account information and asset compatibility, and losses from errors are your responsibility. We are not responsible for losses arising from your provision of incorrect or incomplete information. You acknowledge and agree that Digital Assets sent to or from the Digital Asset Payment Address from or to a Digital Asset Wallet are not eligible for returns. In some instances, you may request a return through Servicer for funds sent to the Digital Asset Payment Address, but Bank is under no obligation to honor your request. You must follow Servicer’s procedures for requesting a return, including providing the Digital Asset Wallet to which the return should be effectuated. You acknowledge and agree that Bank and Servicer have no responsibility for verifying the correctness or validity of such Digital Asset Wallet and instruct Bank to effectuate such return, if permitted by Bank, to the Digital Asset Wallet according to the information you provide to Servicer.
You agree that you are solely responsible and liable for keeping your Fiat Account and Digital Asset Wallet safe and secure and for maintaining adequate security and control of your login and authentication details; you are responsible for all Stablecoin Services that occur using your Fiat Account and Digital Asset Payment Address, including any Conversion Requests and Conversions that were not authorized by you.
8. Placing a Conversion Request; Instructions; and Finality
You may receive Supported Stablecoins into your associate Digital Asset Payment Address twenty-four (24) hours a day, seven (7) days a week, subject to applicable maintenance windows, suspensions, or interruptions. A Conversion Request for a Supported Stablecoin-to-Fiat Conversion is considered submitted when Supported Stablecoin is received into the Digital Asset Payment Address. You instruct Bank to execute a Supported Stablecoin-to-Fiat Conversion at the market price available to Bank upon submission of such Conversion Request. You understand that Bank may not display the conversion price to you before effectuating a Conversion Request. You acknowledge and agree that Bank is acting upon your instruction in executing such a Conversion Request. The Fiat proceeds of a Supported Stablecoin-to-Fiat Conversion will automatically be deposited into your Fiat Account. If a deposit of funds made to your Fiat Account is rejected, reversed, or otherwise fails for any reason, we reserve the right to recover the equivalent amount from your Fiat Account.
A Conversion Request for a Fiat-to-Supported Stablecoin Conversion is considered submitted when you submit such a Conversion Request through the Servicer app or website as directed by Servicer. You instruct Bank to execute a Fiat-to-Supported Stablecoin Conversion using the funds in your Fiat Account at the market price available to Bank upon submission of such a Conversion Request. You understand that Bank may not display the conversion price to you before effectuating a Conversion Request. You acknowledge and agree that Bank is acting upon your instruction in executing such a Conversion Request. Your Conversion Request must include all the Digital Asset Wallet details to effectuate the transaction, and you must provide the Bank with any additional information required by Bank or Servicer. Once the Conversion Request is submitted by you, and accepted by Bank, Bank will execute a corresponding debit to your Fiat Account and transfer the Supported Stablecoin to the Digital Asset Payment Address and then to the Digital Asset Wallet.
For all Conversion Requests, we will attempt to execute the Conversion Request at the prevailing market price, but you understand and acknowledge that prices may differ materially from other venues and may change rapidly due to market conditions. You understand and agree the conversion price may not always be $1.00:1 Supported Stablecoin. There is no representation that prices equal “fair market value” and slippage may occur.
You acknowledge and agree that Bank and Servicer may rely on instructions that appear valid without further verification
Once you submit a Conversion Request and it is accepted for execution, it is generally final and cannot be canceled, including during periods of high volume, illiquidity, or volatility. If a Conversion fails for any reason, we will make a best efforts attempt to provide an automatic refund to you, minus any applicable fees, unless funds are blocked or held as described in this Addendum.
By providing us with the Digital Asset Wallet to send Supported Stablecoins, or by receiving Supported Stablecoins from a Digital Asset Wallet, you represent and warrant that you either own and control the Digital Asset Wallet or that the Digital Asset Wallet is owned and controlled by a person or entity known to you, and that you are permitted to send or receive funds from such Digital Asset Wallet under the Agreement and this Addendum. Because we do not control the Digital Asset Wallet, there is no way for us to help you if you lose control over your Digital Asset Wallet. It is your responsibility to keep your Digital Asset Wallet safe from both theft and inadvertent loss. As the owner of Digital Assets in your Digital Asset Wallet, you bear all risk of loss of such Digital Assets. Servicer may provide you with the option to save or otherwise link a Digital Asset Wallet address for future transactions, and you represent and warrant that you own and control the Digital Asset Wallet or that the Digital Asset Wallet is owned and controlled by a person or entity known to you and that you are permitted to send or receive funds from under the Agreement and this Addendum each time you use or attempt to use the Stablecoin Services in connection with such Digital Asset Wallet.
You agree that you are solely responsible and liable for providing correct information regarding your Conversion Request and reviewing the Conversion Request for accuracy before you choose to submit. You are solely responsible for any and all transfer initiations that are initiated to or from your Digital Asset Wallet through the Digital Asset Payment Address associated with your Fiat Account and we make no, and hereby disclaim all, representations, warranties, claims and assurances as to any transfer initiations.
The date and time that you initiate instructions to us to buy or sell Supported Stablecoin may differ from the date and/or time when the order is executed and the proceeds from the sale are credited to or the amounts to purchase are debited from your Fiat Account. We reserve the right to refuse to process or to cancel or reverse any transaction, Conversion Request or Conversion in our sole discretion.
9. Fiat Funding and Availability
Conversions funded with Fiat will occur only upon receipt of funds in collected, available form in the Fiat Account and completion of any required checks by Bank, Servicer, or their service providers. Pending or uncleared deposits may delay execution. If your Fiat Account has insufficient funds, or if you reverse a payment, you authorize us, in our sole discretion, either to cancel the transaction or to debit your Fiat Account in any amount necessary to complete the transaction.
10. Execution, Settlement, and Timing
Conversions will be executed subject to network conditions and applicable controls. Supported Stablecoins will generally reach the designated Digital Asset Wallet within minutes following initiation, but timing is not guaranteed and may be delayed for any or no reason, including transaction screening, confirmations, or operational reasons.
Once transactions are broadcast to the blockchain, any such transfer is irreversible and may be outside of our control. Transactions may remain in a pending state until confirmed by the relevant network and are not complete while pending. Bank and its service providers do not control network confirmations and do not guarantee that a transfer will be confirmed. Transactions may also remain in a pending state if they are subject to additional review by Bank or Servicer.
Bank may cancel or refuse to process any pending transaction as required by law, court order, sanctions, or risk controls. The date and time you initiate instructions to effect a Conversion may differ from the date and/or time when the Conversion is executed and when your Fiat Account, Digital Asset Payment Address, or Digital Asset Wallet is debited or credited.
Some Digital Asset transactions may be immediately effective when recorded on a public ledger, which is not necessarily the date or time that you initiated the transaction.
NOTWITHSTANDING ANYTHING TO THE CONTRARY IN THIS AGREEMENT, WE DO NOT GUARANTEE ANY ORDER YOU SUBMIT WILL BE EXECUTED OR EXECUTED AT ANY PARTICULAR TIME AND WE WILL NOT BE RESPONSIBLE WHATSOEVER FOR ANY DELAYS OR FOR ANY ORDERS THAT ARE NOT EXECUTED.
11. Fees, Spread, Network Fees, and Set-Off
You agree that network/miner fees, partner fees, spreads, or other charges may apply to Conversions or transfers. Third-party fees are not controlled by Bank and may vary with network congestion. Your responsibility for third-party fees is described below, which portion is incorporated by reference into this Addendum.
The Bank may charge fees in connection with a Conversion as described in Annex A to this Addendum. Your use of the Stablecoin Services constitutes acceptance of applicable fees in effect at the time. Prices offered may be higher or lower than those available on other platforms or exchanges, and execution prices may differ from “market” prices.
Subject to Applicable Law, Bank (or its service provider where applicable) may exercise a right of set-off against sums it holds for you to satisfy unpaid fees or other overdue amounts related to the Stablecoin Services.
You are responsible for determining what, if any, taxes apply due to your use of the Stablecoin Services, and for reporting and remitting the correct tax to the appropriate tax authority. Bank is not responsible for determining whether taxes apply to you or for collecting, reporting, withholding, or remitting any taxes arising from any Stablecoin Services.
12. Limits, Holds, Declines, and Corrective Actions.
Bank or Servicer may impose or adjust limits, thresholds, volumes, cut-off times, or other usage restrictions at any time, including minimum/maximum conversion amounts, transaction counts, and aggregate values. Minimum and maximum Conversion amounts per transaction (“Minimum Conversion Amount” and “Maximum Conversion Amount,” respectively), as well as the Daily Conversion Limit are listed in Annex B. You acknowledge and agree that Conversion Requests for transactions below the Minimum Conversion Amount will not be accepted. You acknowledge and agree that Conversion Requests for transactions above the Maximum Conversion Amount may not be accepted, except that the Bank may, at its discretion and on a case-by-case basis, elect to accept such a Conversion Request. Bank will only process Conversion Requests in whole cents or Supported Stablecoin equivalents; Conversion Requests involving fractional cents may be truncated down to the nearest whole cent or rejected at our discretion. Bank will continue to hold any fractional residuals or Supported Stablecoins received into the Digital Asset Payment Address in an amount below the Minimum Conversion Amount in the Digital Asset Payment Address but will not be obligated to effect a Conversion with such funds; such funds will not be claimed by Bank or Servicer.
Conversion Requests in excess of your Daily Conversion Limit may be held pending the next available conversion window, accepted, or returned to the originating digital asset address, at the Bank’s sole discretion.
Bank may place holds, decline, reverse, cancel, or correct transactions, or claw back funds or assets, including after crediting, for any reason including to address errors, fraud, AML/sanctions concerns, subpoenas, government orders, chargebacks, other compliance reasons, or because Bank determines that such transaction would pose operational or financial risk to Bank, without obligation to reinstate any transaction at the original price. In addition, Bank may impose a minimum holding period for any Supported Stablecoins that you would like to buy or sell. These minimum holding periods are necessary to enable us to carry out fraud prevention measures, to ensure that the Fiat transfers of any given transaction has settled, and to perform other compliance related functions.
Bank may decline to process, cancel or delay processing any Conversion Request for any reason or no reason, including if: (i) you don’t have enough Fiat or Supported Stablecoins; (ii) you exceed applicable limits; (iii) the request is unclear or Bank requires further information and you do not provide it; (iv) there is a genuine dispute about ownership or entitlement to funds or assets; (v) your access to the Stablecoin Services has been suspended or terminated; (vi) Bank believes the request is unauthorized, fraudulent, or related to criminal activity; (vii) Bank believes making the Conversion would cause us to breach Applicable Law or our agreements with liquidity or payment partners; or (viii) you have breached this Addendum or the Agreement. Unless prohibited by law or for a security reason, Bank will notify you when an instruction hasn’t been followed.
13. Counterparty Identification and Transaction History
Servicer will provide you a confirmation after each Conversion you initiate using the Stablecoin Services, which will be viewable in the Servicer App. The confirmation will include certain information regarding your transaction such as the amount of Supported Stablecoin you sold/purchased, the amount your Fiat Account will be charged for the purchase, the exchange rate, and any applicable fees imposed on the transaction.
You have the right to obtain information regarding the transactions that you have initiated using the Stablecoin Services. You may view your transactional history through the Servicer App.
14. Compliance, Sanctions, and Restricted Locations
You represent and warrant that you are not subject to sanctions and will not access or use the Stablecoin Services from Restricted Locations.
Bank may restrict, suspend, or terminate access, cancel orders, return funds to the origin, or require withdrawals to comply with sanctions or other legal obligations, without liability for resulting losses.
Bank may require identity verification, enhanced due diligence, or additional information at any time and may delay or restrict activity until verification is complete.
15. Unauthorized, Incorrect, or Prohibited Transactions
When a Conversion Request and Conversion occurs, Bank will assume that you authorized such Conversion Request or Conversion, unless you notify us otherwise. You agree that we will not be liable to you for any mistaken or accidental orders placed. If you believe you did not authorize a particular transaction or that a transaction was incorrectly carried out, you must contact us as soon as possible. It is important that you regularly check your Fiat Account and Digital Asset Wallet, and your associated transaction history to ensure you notify us as soon as possible of any unauthorized or incorrect transactions. Reporting an unauthorized transaction does not guarantee Bank will be able to reverse the transaction or reimburse you for the transaction.
16. Custody by Bank, Title
You represent and warrant that Supported Stablecoins received into the Digital Asset Payment Address are free of any liens, encumbrances, or conflicting property claims and that you own outright any Digital Assets sent to the Digital Asset Payment Address. You represent and warrant that you are able to transfer title of any Supported Stablecoins received into the Digital Asset Payment Address free of any encumbrances, and you agree that any Supported Stablecoins purchased by Bank from you are taken free of any conflicting security interests or liens, including any security interests created by off-chain transactions or agreements.
The Digital Assets stored in the Digital Asset Payment Address are segregated from both (a) the property of Bank, and (b) the Digital Assets of other customers of Bank. You acknowledge and agree that Bank does not provide general Digital Asset custody services, that Bank’s custody of your Digital Assets is limited to those in the Digital Asset Payment Address, and that such custody is solely for the limited purpose of Conversion and settlement. You acknowledge and agree that Bank does not maintain Digital Asset balances on your behalf. Bank bears no responsibility for and does not custody Digital Assets in your Digital Asset Wallet. You bear all risks associated with your Digital Asset Wallet and keys.
If Bank engages a service provider that temporarily holds assets to facilitate a Conversion, title remains with you and such assets are held for your benefit pursuant to that provider’s custodial framework and applicable UCC Article 8 treatment, where applicable, and subject to the provider’s terms.
17. Stablecoin-Specific Disclosures
You acknowledge that Supported Stablecoins are issued by third-party issuers (e.g., USDC by Circle) and may be redeemable with the issuer, not Bank. Bank is not the issuer, does not hold reserves, and does not guarantee redemption or value.
Stablecoins may de-peg, face liquidity constraints, or experience issuer policy changes that affect redemption and value. Bank and its service providers may cease support and delist a stablecoin and may require you to withdraw or convert before a delist date.
You may be required to agree to applicable issuer terms as a condition of using or redeeming a stablecoin.
18. Risk Disclosures
As with any asset, the value of Digital Assets, including Supported Stablecoins, can go up or down and there can be a substantial risk that you lose money buying, selling, holding, or investing in Digital Assets, including Supported Stablecoins. You should perform research prior to purchasing Digital Assets, including Supported Stablecoins, and carefully consider whether buying, selling, trading or holding Digital Assets is suitable for you in light of your financial condition.
Supported Stablecoins are not legal tender in the United States, are not deposits or obligations of Bank, are not backed by the U.S. government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protection.
Legislative, judicial or regulatory changes or actions at the State, Federal, or international level may adversely affect use, transfer, exchange, or value of Supported Stablecoins. It is possible that in the future, certain laws, regulations, policies or rules relating to Supported Stablecoins may be implemented, which would directly or indirectly affect or restrict your interaction with Bank and your ability to use, transfer or exchange Supported Stablecoins.
The value, security, functionality, and availability of Supported Stablecoins, depend on underlying networks and protocols that Bank and its service providers do not control, and Supported Stablecoins may be subject to market volatility, including deviations from the intended USD conversion rate, and potential total loss of value. Forks, network changes, congestion, or attacks may affect availability or value, and Bank may suspend or decline to support resulting assets.
Any surety bonds or safeguards maintained by service providers may not be sufficient to cover all customer losses, and Bank provides no private insurance covering theft or loss of Supported Stablecoins.
The nature of Supported Stablecoins may result in an increase risk of fraud, theft, hack or cyber attack.
Bank may provide educational information about Supported Stablecoins or other Digital Assets in order to assist users in learning more about such Digital Assets. Information may include, but is not limited to, blog posts, articles, links to third-party content, news feeds, tutorials, and videos. The information provided through the Stablecoin Services does not constitute investment, tax, legal, or other professional advice. Bank does not recommend, suggest, advise or endorse that you purchase or sell Supported Stablecoins, or make any purchase of any good or service. Before engaging in any Conversion or any other activity, you should consult a qualified professional.
The nature of Supported Stablecoins means that any technological difficulties experienced by Bank may prevent your access to or use of your Supported Stablecoins.
Hardware, software or connections required to interact with a Supported Stablecoin network might fail or succumb to malware, unauthorized access or malicious attacks. Third parties may obtain unauthorized access to the Stablecoin Services, including, but not limited to, your public and private keys. Bank shall not be liable or responsible whatsoever for any communication failures, disruptions, errors, distortions or delays or other potential adverse events or adverse consequences you may experience when using the Stablecoin Services, however caused.
Unknown vulnerabilities in or unanticipated changes to the network protocol may cause losses to you or others. Bank has no control over any cryptocurrency network and shall not be liable or responsible whatsoever for any harm occurring as a result of the inability to reverse a transaction, and any losses in connection therewith due to erroneous or fraudulent actions or other potential adverse events or adverse consequences you may experience.
The value of a Supported Stablecoin may be derived from the continued willingness of market participants to exchange Fiat Currency for Supported Stablecoins, which may result in the potential for permanent and total loss of value of a particular Supported Stablecoin should the market for that Supported Stablecoin be materially adversely impacted, otherwise disappear or declines or collapses for an extended period of time.
The volatility and unpredictability of the price of Supported Stablecoins relative to fiat currency may result in significant losses over a short period of time. In addition, price and liquidity are subject to significant fluctuations that may be unpredictable. The price (which can go up or down and even drop to zero) and liquidity of Supported Stablecoins have been subject to large fluctuations in the past and may be subject to large fluctuations in the future.
19. Availability; Jurisdiction; Precedence
The Stablecoin Services are not offered where prohibited by law. You agree not to use the Stablecoin Services where doing so would be unlawful and to promptly inform Bank upon a change of residency affecting availability.
20. Service Modifications; Suspension; Termination
Bank and Servicer may modify, suspend, or discontinue the Stablecoin Services, including adding or removing Supported Stablecoins, changing limits or fees, or altering operational processes, and will endeavor to provide advance notice of material changes where feasible. Your continued use after changes constitutes acceptance.
21. Amendments
Bank may update this Addendum for reasons including changes to fees, limits, features, service providers, technology, or applicable laws and regulatory standards. Unless otherwise indicated, changes take effect when posted or communicated, and your continued use constitutes acceptance. If you do not accept an amendment, you may discontinue use of the Stablecoin Services as provided in the Agreement.
In some jurisdictions, where required by Applicable Law, Bank may provide advance notice (e.g., at least 30 days) of certain changes to pricing schedules, terms, or policies.
22. Liability; Exclusions; Cap; Indemnity; Force Majeure
The Stablecoin Services are provided “as is” and “as available.” To the maximum extent permitted by law, Bank and its service providers disclaim liability for indirect, incidental, consequential, special, punitive, or exemplary damages; inaccuracies or interruptions in price data; network or third-party failures; and losses arising from protocol changes, forks, or market volatility.
By using the Stablecoin Services, you agree that we do not maintain the Digital Asset Wallet and are not liable for the actions or omissions of any third parties that interact with your credentials or account data in connection with our Stablecoin Services.
Subject to Applicable Law, you agree to indemnify and hold harmless Bank, its affiliates, subsidiaries, directors, managers, members, officers, employees, and other customers, from any and all claims, demands, actions, damages, losses, costs or expenses, including without limitation, reasonable legal fees, arising out of or relating to your or any other person’s use of your Login Credentials or any other credentials you may use to access the Stablecoin Services, Fiat Account or Digital Asset Wallet in connection with: (i) use of the Stablecoin Services; (ii) breach of the Addendum, the Agreement or any other agreement or policy; (iii) false, incomplete, or misleading information relied upon by us to verify your identity and source of funds, where applicable; (iv) violation of any Applicable Law; or (v) violation of any rights of any other person or entity; provided, however, that you shall not indemnify Bank for claims or losses arising out of Bank’s gross negligence or willful misconduct as determined by final order of a court of competent jurisdiction. This indemnity shall apply to your successors and assigns and shall survive any termination or cancellation of this Addendum.
Except as required by Applicable Law, Bank shall not be liable to you or anyone else for any loss caused in whole or part by any inaccuracies or incompleteness, delays, interruptions, errors or omissions, including, but not limited to, those arising from the negligence of Bank or contingencies beyond its control in procuring, compiling, interpreting, computing, reporting, or delivering the Stablecoin Services thereon or the information therein. In no event will Bank be liable to you or anyone else for any decision made or action taken by you in reliance on, or in connection with your use of the Stablecoin Services or the information therein, including any inaccuracies in information provided by you to Bank or Servicer.
IN ADDITION TO ANY LIMITATIONS OF LIABILITY SET FORTH IN THE AGREEMENT, IN NO EVENT SHALL BANK, ITS AFFILIATES AND SERVICE PROVIDERS, OR ANY OF THEIR RESPECTIVE OFFICERS, DIRECTORS, AGENTS, EMPLOYEES OR REPRESENTATIVES, BE LIABLE FOR ANY LOST PROFITS OR ANY SPECIAL, INCIDENTAL, INDIRECT, INTANGIBLE, PUNITIVE OR CONSEQUENTIAL DAMAGES, WHETHER BASED IN CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR OTHERWISE, ARISING OUT OF OR IN CONNECTION WITH THIS ADDENDUM, OR THE AUTHORIZED OR UNAUTHORIZED USE OF THE STABLECOIN SERVICES, EVEN IF BANK HAD BEEN ADVISED OF, KNEW OF, OR SHOULD HAVE KNOWN OF THE POSSIBILITY OF SUCH DAMAGES. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION MAY NOT APPLY TO YOU BASED ON YOUR JURISDICTION OR THE GOVERNING LAW.
UNDER NO CIRCUMSTANCES SHALL WE BE REQUIRED TO DELIVER TO YOU ANY DIGITAL ASSETS AS DAMAGES, OR SHALL YOU BE ENTITLED TO SPECIFIC PERFORMANCE OR ANY OTHER SIMILAR REMEDY. YOU AND WE AGREE THAT ANY CALCULATIONS OF DAMAGES BASED IN ANY WAY ON THE VALUE OF DIGITAL ASSETS SHALL BE BASED ON THE LOWEST VALUE OF THE DIGITAL ASSETS DURING THE PERIOD BETWEEN THE ACCRUAL OF THE CLAIM AND THE AWARD OF DAMAGES.
EXCEPT AS REQUIRED BY APPLICABLE LAW, WE SHALL NOT BE LIABLE FOR ANY DAMAGES CAUSED IN WHOLE OR IN PART BY (I) THE MALFUNCTION, UNEXPECTED FUNCTION OR UNINTENDED FUNCTION OF ANY COMPUTER OR CRYPTOCURRENCY NETWORK, INCLUDING WITHOUT LIMITATION LOSSES ASSOCIATED WITH VIRUSES, NETWORK FORKS, REPLAY ATTACKS, DOUBLE-SPEND ATTACKS, SYBIL ATTACKS, 51% ATTACKS, GOVERNANCE DISPUTES, MINING DIFFICULTY, CHANGES IN CRYPTOGRAPHY OR CONSENSUS RULES, HACKING OR CYBERSECURITY BREACHES; (II) THE CHANGE IN VALUE OF ANY CRYPTOCURRENCY; (III) ANY CHANGE IN LAW, REGULATION OR POLICY, OR (IV) FORCE MAJEURE EVENT (INCLUDING BUT NOT LIMITED TO (A) ACTS OF GOD, NATURE, COURT OR GOVERNMENT; (B) FAILURE OR INTERRUPTION IN PUBLIC OR PRIVATE TELECOMMUNICATION NETWORKS, COMMUNICATION CHANNELS OR INFORMATION SYSTEMS; (C) ACTS OR OMISSIONS OF ACTS OF A PARTY FOR WHOM BANK IS NOT RESPONSIBLE; (D) DELAY, FAILURE, OR INTERRUPTION IN, OR UNAVAILABILITY OF, THIRD PARTY SERVICES AND SITES; (E) STRIKES, LOCK-OUTS, LABOUR DISPUTES, WARS, TERRORIST ACTS AND RIOTS; AND (F) VIRUSES, MALWARES, OTHER MALICIOUS COMPUTER CODES OR THE HACKING OF BANK’S SYSTEMS).
THE LIMITATIONS OF LIABILITY IN THIS SECTION ARE INTENDED TO APPLY WITHOUT REGARD TO WHETHER OTHER PROVISIONS OF THIS ADDENDUM HAVE BEEN BREACHED OR HAVE PROVEN INEFFECTIVE. FOR THE AVOIDANCE OF DOUBT, THE LIMITATIONS OF LIABILITY SET FORTH IN THIS ADDENDUM ARE IN ADDITION TO, AND NOT IN LIEU OF, ANY LIMITATIONS OF LIABILITY SET FORTH IN THE AGREEMENT, ALL OF WHICH SHALL APPLY TO THE STABLECOIN SERVICES AND THIS ADDENDUM. TO THE EXTENT ANY LIMITATION IN THIS ADDENDUM CONFLICTS WITH A LIMITATION IN THE AGREEMENT, THE LIMITATION MORE PROTECTIVE OF BANK SHALL GOVERN.
Any and all of our indemnities and warranties (whether express or implied) are hereby excluded to the fullest extent permitted under law except as set forth in this Addendum. Nothing in this Addendum excludes or limits liability which may not be limited or excluded under Applicable Law.
23. Customer Acknowledgements
By using the Stablecoin Services, you acknowledge and accept the protocol, network, market, and regulatory risks described herein and in any incorporated provider terms and risk disclosures, including the possibility of total loss. You are solely responsible for determining the suitability and legality of your use of the Stablecoin Services in your jurisdiction.
ANNEX A
STABLECOIN SERVICES FEES

ANNEX B
MINIMUM AND MAXIMUM CONVERSION AMOUNTS
