Corporate Operator Disclosures

Section I — Purpose, Scope, and Corporate Operator Identity

These disclosures summarize the corporate operator position of Rise Digital Financial Corp ("Rise Digital Financial Corp," "we," or "us") regarding Zivo: Cash Advance and ZivoAdvance™ earned wage access. They are published on Zivo's marketing website for transparency to consumers, regulators, and partners. They supplement and should be read together with the Zivo Terms of Service, Privacy Policy, and all agreements and transaction-specific disclosures presented in the Zivo: Cash Advance mobile application before You confirm an advance.

Rise Digital Financial Corp is the United States corporation that designs, develops, and operates Zivo: Cash Advance, distributed on the Apple App Store under Bundle ID com.risedigital.zivo, through which eligible consumers may access ZivoAdvance™, Rise Digital Financial Corp's earned wage access product. Rise Digital Financial Corp affirmatively states that it is not a bank, not a lender, not a money transmitter within the meaning of Section 560.103, Florida Statutes, and not a deferred presentment provider within the meaning of Section 560.402, Florida Statutes. Rise Digital Financial Corp does not hold a bank charter and is not insured by the FDIC or NCUA.

Section II — Product Operator Model and Principal Transaction Structure

Rise Digital Financial Corp operates as a product operator within the established fintech model. Rise Digital Financial Corp builds and operates the software platform, sets eligibility criteria, advance amounts, fee structures, and repayment terms, manages the consumer relationship, and maintains the product's compliance posture. Rise Digital Financial Corp is the origin of advance funds and the principal in both legs of each ZivoAdvance™ transaction: Rise Digital Financial Corp sends its own operating funds to the consumer on advance and collects repayment owed to itself on repayment.

At no point does Rise Digital Financial Corp receive money from a consumer for the purpose of transmitting that money to a third party, act as an intermediary between a sender and recipient, or hold consumer funds in suspense pending transmission to another party. Regulatory classification turns on Rise Digital Financial Corp's product structure and the consumer's actual repayment path, not on the identity of any particular third-party data vendor.

Section III — Nature of ZivoAdvance™ — Earned Wage Access, Not Credit

ZivoAdvance™ is Earned Wage Access (EWA): a product that allows workers to access wages or income they have already earned before their next scheduled payment date. The consumer is not borrowing money they have not yet earned; the consumer is accessing a portion of the consumer's own earned income early, subject to verification and product rules. ZivoAdvance™ is not a payday loan, personal loan, line of credit, or deferred presentment transaction under Chapter 560, Part IV, Florida Statutes.

Rise Digital Financial Corp does not extend credit within the meaning of the Truth in Lending Act (TILA), Regulation Z (12 C.F.R. Part 1026), or comparable state consumer lending statutes, because ZivoAdvance™ provides access to already-earned income rather than a right to defer payment of borrowed principal on credit terms. This position is consistent with the Consumer Financial Protection Bureau Advisory Opinion published at 90 Fed. Reg. 60070 (December 23, 2025), which confirms that properly structured earned wage access products, including direct-to-consumer models, are not credit within the meaning of TILA and Regulation Z. TILA credit disclosures such as Amount Financed, Finance Charge, and annual percentage rate do not apply to ZivoAdvance™ as currently structured.

Section IV — Product Specifications, Amounts, Fees, and Limits

ZivoAdvance™ offers fixed advance amounts of twenty-five dollars ($25.00), fifty dollars ($50.00), seventy-five dollars ($75.00), one hundred dollars ($100.00), or one hundred fifty dollars ($150.00); the amounts available to a given consumer depend on verification and product rules. Only one outstanding advance may be active at any time per consumer; this limit is system-enforced. Rise Digital Financial Corp charges one service fee per advance (the "Access Fee"). The Access Fee is determined from Rise Digital Financial Corp's published fee schedule at the time of the request based on three factors: the advance amount, the delivery speed the consumer selects (standard or instant), and the number of days between the request and the consumer's next scheduled payday. The Access Fee is a fixed dollar amount, is disclosed before the consumer confirms, and does not change after confirmation. There is no interest, no annual percentage rate, no late fee, and no charge of any kind that accrues or increases if settlement occurs after the scheduled date.

All fees, limits, and pricing applicable to a consumer's account are disclosed in the Zivo: Cash Advance application before the consumer confirms an advance. Marketing on this website does not state Access Fee dollar amounts because the schedule may change over time; any fee quoted by Rise Digital Financial Corp support in response to a consumer inquiry is drawn from the schedule then in effect and is informational only. The controlling fee for any transaction is the one displayed in the application at the time of that transaction. Consumers must review in-app disclosures at the time of each transaction.

Section V — Verification, Open Banking, Open Payroll, and Data Partners

Access depends on verification of earned income, linked bank account status, pay-cycle timing, and other risk factors. Not all applicants qualify. Rise Digital Financial Corp uses open banking and open payroll integrations, principally Plaid for account and income verification and Pinwheel for payroll connectivity, together with such other data partners and suppliers as Rise Digital Financial Corp may engage from time to time, to confirm earned or accrued income and to schedule repayment aligned with the consumer's paycheck and pay cycle.

Third-party providers operate under their own terms and privacy policies when a consumer connects accounts or authorizes data access. Rise Digital Financial Corp does not control third-party system availability, data accuracy, or API capabilities. Verification outcomes, repayment scheduling, and availability of payroll-linked repayment options may depend on employer participation, payroll processor support, banking holidays, and network interruptions. Partner data is used for income and cash-flow verification and paycheck timing, not as a substitute for traditional credit underwriting.

Section VI — Funding, Disbursement, and Repayment Mechanics

Advance funds are typically delivered to the consumer's linked bank account via automated clearing house credit from Rise Digital Financial Corp's operating funds. Advances may be processed through sponsor-bank arrangements, including Bank of America, N.A., where applicable. Repayment is scheduled on a date aligned with the consumer's pay cycle, derived from open banking and open payroll data subject to partner availability. The specific repayment date and total collection amount are disclosed in the application before the consumer confirms the advance.

The primary repayment method is automated clearing house debit from the linked bank account on the scheduled date. Where the consumer elects a supported open payroll repayment option and employer or payroll application programming interfaces permit, repayment may instead be satisfied via employer or payroll-processor settlement on payday. Availability of advances, amounts, and timing are not guaranteed. Service interruptions, bank holidays, verification delays, or account status may affect access to funds.

Section VII — No Credit Underwriting, No Credit Bureau Reporting

Rise Digital Financial Corp does not access consumer credit reports, does not use credit scores, and does not perform traditional credit underwriting in connection with ZivoAdvance™. Verification is income- and cash-flow-based, not creditworthiness-based. Rise Digital Financial Corp does not report ZivoAdvance™ transactions to Equifax, Experian, TransUnion, or any other consumer reporting agency. Credit bureau reporting is expressly prohibited under Rise Digital Financial Corp's Terms of Service.

Section VIII — Non-Recourse Structure and Prohibition on Collections

ZivoAdvance™ is structured on a non-recourse basis. If a consumer does not complete repayment, Rise Digital Financial Corp does not pursue that consumer through debt collection, sale of debt, legal action, wage garnishment, or any third-party enforcement mechanism. Rise Digital Financial Corp absorbs non-repayment risk as a product design feature. Rise Digital Financial Corp's sole remedy for non-repayment is to suspend or withhold future advances, subject to product rules in the application.

This non-recourse structure is material to Rise Digital Financial Corp's position that ZivoAdvance™ is not a loan or credit instrument and is antithetical to check-based deferred presentment models that contemplate recourse when an instrument is dishonored.

Section IX — Florida Chapter 560 — Deferred Presentment Classification

Rise Digital Financial Corp's regulatory position is that ZivoAdvance™ does not constitute a deferred presentment transaction under Section 560.402, Florida Statutes, and that Section 560.125 is not applicable to Rise Digital Financial Corp's ZivoAdvance™ activity as currently structured. Florida's deferred presentment regime governs businesses that exchange currency for a consumer's check and agree to hold that check for a deferment period. Section 560.402(3) defines deferred presentment as providing currency or a payment instrument in exchange for a drawer's check and agreeing to hold the check for a deferment period.

ZivoAdvance™ fails each element of that definition. Rise Digital Financial Corp does not accept, receive, or hold a check from the consumer. No payment instrument is tendered by the consumer to Rise Digital Financial Corp in exchange for the advance. Rise Digital Financial Corp does not agree to hold any instrument for a deferment period, and the Access Fee is not a fee charged for deferring presentment of a check. The consumer is not a drawer in the statutory sense. Rise Digital Financial Corp's conclusion is that a product cannot be a deferred presentment transaction without a check.

Section X — Money Transmission Classification Under Section 560.103

Florida Statute Section 560.103 defines a money transmitter as a person who receives currency or monetary value for the purpose of transmitting that value to another location or person. Money transmission requires acting as an intermediary handling someone else's money and routing it at the sender's direction. In a ZivoAdvance™ transaction, Rise Digital Financial Corp transfers its own funds to the consumer on advance and collects repayment owed to itself on repayment. Rise Digital Financial Corp is the payer on advance and collects its own receivable on repayment. There is no third party whose funds Rise Digital Financial Corp holds or transmits. Rise Digital Financial Corp's analysis is that this principal-in-both-legs structure is not money transmission under Section 560.103.

Section XI — Federal Earned Wage Access Framework — CFPB Advisory Opinion

The CFPB Advisory Opinion published at 90 Fed. Reg. 60070 (December 23, 2025) establishes a federal interpretive framework for earned wage access products. While not binding on states, it is persuasive authority on whether properly structured EWA products resemble credit subject to TILA and Regulation Z. The 2025 Advisory Opinion confirms that covered earned wage access products, including direct-to-consumer models, can be categorically different from consumer lending when they provide access to already-earned wages, do not perform traditional credit risk assessment, prohibit credit bureau reporting, and limit recourse to withholding future advances.

Repayment mechanics may vary by transaction. Where a consumer elects supported open payroll repayment and employer or payroll processor capabilities permit settlement on payday, repayment may follow a payroll-process path. Where that path is unavailable or not selected, repayment more commonly occurs by automated clearing house debit from the linked account on a pay-cycle-aligned schedule. The 2025 Advisory Opinion's relevance to TILA classification may depend on the actual repayment path in use; it does not alter Rise Digital Financial Corp's Chapter 560 analysis, which turns on the absence of a consumer check.

Section XII — Florida Legislative Context and Regulatory Engagement

Earned wage access is a developing product category in Florida. The 2024 and 2025 Florida legislative sessions saw introduction of bills that would have created a purpose-built earned wage access registration framework separate from deferred presentment, money transmission, and consumer lending statutes, including construction language that EWA fees would not be considered interest or finance charges and that compliant EWA providers would not be considered creditors, debt collectors, lenders, or money transmitters under existing Chapter 560 provisions. Those bills did not become law as of the date of these disclosures.

Rise Digital Financial Corp supports enactment of a Florida EWA registration framework and will register under any such law upon enactment. Rise Digital Financial Corp engages constructively with regulators and supervisory authorities on product facts and disclosures, including the Florida Office of Financial Regulation, and responds promptly to inquiries with written submissions explaining product structure and legal classification.

Section XIII — Zivo Is Not a Bank; Neobank Roadmap

Rise Digital Financial Corp does not accept deposits from consumers, does not hold consumer funds in trust or custodial capacity, and does not offer checking, savings, or other deposit accounts through Zivo today. Zivo is not FDIC-insured or NCUA-insured. Features described on this website beyond earned wage access, including deposit accounts, debit cards, instant transfers, direct deposit, savings tools, and budgeting, reflect Rise Digital Financial Corp's product roadmap and are not generally available. Joining a waitlist does not open an account or guarantee access.

Section XIV — No Guarantee; Eligibility; and Limitations of This Notice

Availability of advances, amounts, fees, and timing are not guaranteed. Eligibility is determined at the time of each request based on then-current product rules and verified information. These disclosures do not guarantee that any consumer will qualify for ZivoAdvance™ or for any particular advance amount. Consumers must review all in-app disclosures, fee schedules, and agreements before enrolling or confirming a ZivoAdvance™.

Questions regarding these disclosures may be directed to Rise Digital Financial Corp through the contact information below. For binding legal terms governing use of the Product, see the Zivo Terms of Service. For data handling practices, see the Privacy Policy.