Compliance Policies & Procedures

Effective Date: September 11, 2026

Choice Capital Solutions ("Choice Capital," "we," "our," or "us") is committed to treating every business owner fairly, protecting the information entrusted to us, and complying with the federal and state laws that govern commercial financing. This page summarizes the policies and procedures our team follows in the areas of information security, data privacy, fair lending (ECOA), credit reporting (FCRA), unfair or deceptive practices (UDAP), and telephone and text communications (TCPA).

These policies apply to all Choice Capital employees, officers, contractors, and any third parties acting on our behalf.

1. Information Security

We maintain a written information security program designed to protect the confidentiality, integrity, and availability of the information our applicants and clients provide, including bank statements, tax records, Social Security numbers, and business financial data.

Our safeguards include:

• Access controls: Sensitive information is available only to team members who need it to do their jobs. Access is granted based on role and removed promptly when no longer needed or when an employee leaves.
• Secure systems: Information transmitted through our website is protected with SSL/TLS encryption. We use password protection, multi-factor authentication where available, and up-to-date security software on the systems we use.
• Vendor oversight: We work only with service providers that agree to protect the information they handle for us, and we review their safeguards before sharing data.
• Employee training: Team members receive training on data security, phishing awareness, and proper handling of confidential information.
• Secure disposal: Records are retained only as long as needed for business, legal, or regulatory purposes and are then securely destroyed.
• Incident response: We maintain procedures to identify, contain, and respond to any suspected security incident, including notifying affected individuals and authorities when required by law.

2. Data Privacy

We collect only the information needed to evaluate, provide, and service financing, and we use it for those purposes. We do not sell applicant or client financial information. We share information only with parties necessary to process or service your request (such as funding partners, credit bureaus, identity verification providers, and service vendors), or when required by law.

For full details on what we collect, how we use it, and your rights, please see our Privacy Policy.

3. Equal Credit Opportunity Act (ECOA)

Choice Capital complies with the Equal Credit Opportunity Act and Regulation B. We do not discriminate against any applicant on the basis of race, color, religion, national origin, sex (including sexual orientation and gender identity), marital status, or age (provided the applicant has the capacity to contract); because all or part of the applicant's income derives from any public assistance program; or because the applicant has in good faith exercised any right under the Consumer Credit Protection Act.

Our procedures include:

• Evaluating every application using consistent, business-related criteria.
• Providing notice of our decision, and of the applicant's right to request the reasons for any adverse action, within the time frames required by law.
• Training team members on fair lending requirements and monitoring for consistent treatment of applicants.

The federal agency that administers compliance with this law concerning this creditor is the Federal Trade Commission, Equal Credit Opportunity, Washington, DC 20580.

4. Fair Credit Reporting Act (FCRA)

When evaluating an application, we may obtain consumer credit reports on business owners and guarantors. We do so only with a permissible purpose and with the individual's authorization, as provided in our application.

Our procedures include:

• Obtaining credit reports only for legitimate purposes connected to an application or existing account.
• Keeping credit report information confidential and limiting access to authorized team members.
• Providing any required adverse action notices, including the name and contact information of the credit bureau used and the individual's right to obtain a free copy of their report and dispute inaccurate information.
• Securely disposing of credit report information when it is no longer needed.

5. Unfair or Deceptive Acts or Practices (UDAP)

We are committed to honest, transparent dealings with every business owner. Consistent with the Federal Trade Commission Act and applicable state laws, we do not engage in unfair, deceptive, or abusive acts or practices.

Our procedures include:

• Clearly disclosing the key terms, costs, and fees of any financing offer before an agreement is signed.
• Reviewing advertising and marketing materials so that claims about speed, approval, rates, or terms are accurate and not misleading.
• Never pressuring applicants with false deadlines or misrepresenting who we are or what we offer.
• Handling complaints promptly and fairly, and using feedback to improve our practices.

6. Telephone Consumer Protection Act (TCPA)

We respect your right to control how we contact you. Our calling and texting practices are designed to comply with the Telephone Consumer Protection Act, the Telemarketing Sales Rule, and applicable state laws.

Our procedures include:

• Consent: We obtain appropriate consent before sending marketing text messages or placing marketing calls using automated technology or prerecorded messages. Consent is never a condition of obtaining financing.
• Opt-out: You may stop text messages at any time by replying STOP. You may stop calls or emails by telling our team or emailing us at support@choicecapitalsolutions.com. We honor opt-out requests promptly.
• Do-Not-Call: We maintain an internal do-not-call list and screen marketing calls against the National Do Not Call Registry where required.
• Calling hours: We contact individuals only during permitted hours based on their local time zone.
• Records: We keep records of consent and opt-out requests.

Message and data rates may apply. Mobile information is not shared with third parties or affiliates for their marketing purposes.

7. Oversight and Review

Our management team is responsible for overseeing these policies. We review and update them periodically, and whenever laws or our business practices change. Team members who violate these policies are subject to disciplinary action.

8. Contact Us

If you have questions about these policies, want to request the reasons for a credit decision, wish to opt out of communications, or would like to report a concern, please contact us:

Choice Capital Solutions
Email: support@choicecapitalsolutions.com