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// Regenerate with scripts/build-legal-content.py when counsel revises copy.
import type {LegalDocument} from './types';
export const regulatoryStatus: LegalDocument = {
"slug": "regulatory-status",
"title": "Regulatory Status Disclosure",
"version": "1.0",
"effectiveDate": "July 7, 2026",
"lastUpdated": "July 7, 2026",
"blocks": [
{
"type": "heading",
"level": 1,
"text": "1. PURPOSE AND SCOPE"
},
{
"type": "p",
"text": "This Regulatory Status Disclosure is intended to explain, in plain English and in an institutional disclosure format, the current role of FlowState in connection with its website, platform, treasury tools, banking partner relationships, business-purpose lending workflows, payment-related services, educational content, and related financial technology services."
},
{
"type": "p",
"text": "This Disclosure is designed to help customers, prospective customers, banking partners, lenders, vendors, regulators, counsel, and other stakeholders understand what FlowState does, what FlowState does not do, and which services may be provided by regulated partner institutions or other third-party providers."
},
{
"type": "p",
"text": "This Disclosure should be read together with FlowState’s Terms of Use, Privacy Policy, Cookie Policy, Financial Services Disclaimer, Risk Disclosure Statement, Security and Data Protection Statement, Banking Partner Disclosure, applicable product agreements, account agreements, loan documents, partner bank disclosures, and any other product-specific documentation."
},
{
"type": "heading",
"level": 1,
"text": "2. KEY REGULATORY STATUS QUESTIONS"
},
{
"type": "p",
"text": "The following table provides a high-level summary of common regulatory status questions. It is not a substitute for the full disclosure below or for applicable product-specific agreements."
},
{
"type": "heading",
"level": 1,
"text": "3. FLOWSTATE AS A TREASURY MANAGEMENT PLATFORM"
},
{
"type": "p",
"text": "FlowState is designed to help business customers organize, evaluate, and manage aspects of their treasury operations. Depending on product availability and customer eligibility, FlowState may provide tools, workflows, dashboards, document collection, onboarding support, partner coordination, and educational resources related to business cash management and liquidity planning."
},
{
"type": "p",
"text": "FlowState’s treasury platform may assist business customers with understanding cash balances, business liquidity, collateral availability, account structure, cash movement workflows, borrowing capacity, and related treasury administration. These tools are intended for business-purpose use and are not intended for personal, family, household, or consumer financial management unless expressly permitted in final product documents."
},
{
"type": "p",
"text": "FlowState’s treasury-related activities may include:"
},
{
"type": "ul",
"items": [
"providing a technology interface for business treasury workflows;",
"collecting and organizing customer documentation;",
"helping customers access partner bank or third-party services;",
"supporting business-purpose liquidity analysis;",
"facilitating communications among customers, partner institutions, lenders, and service providers;",
"providing educational content related to treasury management and liquidity planning;",
"supporting onboarding, identity verification, and due diligence workflows; and",
"providing reporting or administrative tools for business customers."
]
},
{
"type": "p",
"text": "FlowState’s treasury platform does not, by itself, mean that FlowState is a bank, custodian, broker-dealer, registered investment adviser, lender, money transmitter, or other regulated financial institution. The regulatory analysis depends on the exact activity performed, the legal entity performing it, the jurisdiction, and the applicable product documents."
},
{
"type": "heading",
"level": 1,
"text": "4. FLOWSTATE AS A FINANCIAL TECHNOLOGY COMPANY"
},
{
"type": "p",
"text": "FlowState may operate as a financial technology company that provides software, workflows, data collection, communications, account onboarding support, risk and compliance support, and administrative tools in connection with business financial services. A financial technology company may support access to regulated financial services without itself being the regulated provider of every underlying financial product."
},
{
"type": "p",
"text": "For example, a fintech platform may provide the customer interface, application workflow, compliance data collection, account dashboard, customer support, or program administration while a partner bank, lender, custodian, payment processor, or other regulated provider performs the regulated function. The role of each party should be identified in the applicable Product Agreement, Banking Partner Disclosure, account agreement, loan agreement, or other service-specific document."
},
{
"type": "p",
"text": "FlowState may receive compensation for technology services, administrative services, referral services, program services, servicing support, onboarding, account support, or other services, to the extent permitted by applicable law and disclosed where required."
},
{
"type": "heading",
"level": 1,
"text": "5. BANKING STATUS AND PARTNER FINANCIAL INSTITUTIONS"
},
{
"type": "heading",
"level": 2,
"text": "5.1 Is FlowState a Bank?"
},
{
"type": "p",
"text": "Unless and until FlowState expressly states otherwise in final legally approved disclosures, FlowState is not a bank, depository institution, credit union, FDIC-insured institution, trust company, or chartered financial institution. FlowState does not itself accept deposits, maintain deposit accounts, or provide FDIC deposit insurance."
},
{
"type": "p",
"text": "References to banking, treasury, accounts, deposits, cash management, sweep programs, liquidity, or similar terms on FlowState’s website or platform should be understood as references to platform functionality, business treasury workflows, partner financial institution services, or potential product categories, and not as a statement that FlowState itself is a bank."
},
{
"type": "heading",
"level": 2,
"text": "5.2 What Partner Banks Do"
},
{
"type": "p",
"text": "Partner banks or partner financial institutions may provide regulated banking services. Depending on the product, such services may include deposit accounts, account opening, custodial arrangements, payment rails, ACH processing, wire transfers, debit or commercial cards, bank statements, funds availability, account closure decisions, compliance monitoring, and other regulated banking services."
},
{
"type": "p",
"text": "Partner banks are responsible for their own regulatory obligations and may impose eligibility criteria, documentation requirements, fees, transaction limits, account restrictions, account closures, compliance reviews, and other requirements under their own agreements and policies."
},
{
"type": "heading",
"level": 2,
"text": "5.3 FlowState’s Role with Banking Partners"
},
{
"type": "p",
"text": "FlowState may act as a technology provider, program interface, treasury platform, referral source, onboarding coordinator, document collector, customer support provider, or administrative service provider in connection with partner bank services. FlowState may facilitate access to partner financial institution services, but partner institutions remain responsible for the regulated banking functions they perform."
},
{
"type": "p",
"text": "Access to partner bank services may require separate agreements with the applicable bank or financial institution. FlowState does not guarantee approval for any bank account, deposit account, payment service, sweep program, card product, custody arrangement, or other partner service."
},
{
"type": "heading",
"level": 1,
"text": "6. LENDING STATUS, LOAN ORIGINATION, AND LOAN SERVICING"
},
{
"type": "heading",
"level": 2,
"text": "6.1 Is FlowState a Lender?"
},
{
"type": "p",
"text": "FlowState’s lending-related status depends on the final legal structure of each lending product. FlowState may support business-purpose lending workflows by providing technology, application intake, document collection, underwriting support, collateral analysis, referral services, administrative support, or servicing coordination. FlowState may also work with lenders, bank partners, private credit providers, loan servicers, collateral agents, or other third parties."
},
{
"type": "p",
"text": "Unless expressly stated in final product documents, no information on the FlowState website or platform constitutes a commitment to lend, approval of credit, binding loan offer, or guarantee that financing will be available. All loans and credit facilities are subject to underwriting, eligibility, collateral review, documentation, applicable law, lender approval, and executed loan documents."
},
{
"type": "heading",
"level": 2,
"text": "6.2 Who Services My Loan?"
},
{
"type": "p",
"text": "Loan servicing may be performed by the originating lender, a bank partner, FlowState, an affiliate, a licensed servicer, a third-party administrator, a collateral agent, or another service provider, depending on the loan product and loan documents. Servicing responsibilities may include payment processing, statements, notices, customer support, account maintenance, collateral monitoring, default administration, reporting, or communications."
},
{
"type": "p",
"text": "The applicable loan agreement, promissory note, servicing agreement, credit agreement, borrower disclosure, or other product document should identify the party responsible for servicing the loan and explain how borrowers should make payments, submit notices, ask questions, and raise disputes."
},
{
"type": "heading",
"level": 2,
"text": "6.3 Business-Purpose Lending"
},
{
"type": "p",
"text": "FlowState’s lending-related services are intended for business-purpose, commercial, treasury, investment, institutional, or organizational use unless expressly stated otherwise. Business-purpose loans may not include consumer protections that apply to personal, family, or household credit products. Customers should not use FlowState lending-related services for consumer purposes unless FlowState expressly permits such use and applicable legal requirements are satisfied."
},
{
"type": "heading",
"level": 1,
"text": "7. INVESTMENT ADVISER, BROKER-DEALER, AND SECURITIES STATUS"
},
{
"type": "heading",
"level": 2,
"text": "7.1 Is FlowState an Investment Adviser?"
},
{
"type": "p",
"text": "Unless expressly stated otherwise in a written advisory agreement and legally approved disclosure, FlowState does not provide individualized investment advice, does not act as a registered investment adviser, and does not undertake to manage customer investment portfolios. Educational content, treasury commentary, liquidity tools, market commentary, strategy discussions, or general financial information should not be treated as personalized investment advice."
},
{
"type": "p",
"text": "Customers should consult their own investment advisers, legal counsel, tax professionals, accountants, and other advisors before making investment, financing, treasury, or business decisions."
},
{
"type": "heading",
"level": 2,
"text": "7.2 Is FlowState a Broker-Dealer or Placement Agent?"
},
{
"type": "p",
"text": "Unless expressly stated otherwise in final legally approved disclosure documents, FlowState does not act as a broker-dealer, securities placement agent, underwriter, exchange, alternative trading system, or securities marketplace. Nothing on the FlowState website or platform should be interpreted as an offer to sell securities or solicitation of an offer to buy securities unless expressly included in final offering documents approved for that purpose."
},
{
"type": "p",
"text": "Any securities offering, fund interest, note, preferred equity, investment contract, or similar instrument, if offered, will be offered only through appropriate offering documents and only to eligible investors in compliance with applicable law."
},
{
"type": "heading",
"level": 2,
"text": "7.3 Educational Content"
},
{
"type": "p",
"text": "FlowState may publish educational or informational content regarding treasury management, business liquidity, financial operations, banking relationships, credit, collateral, or market conditions. Such content is general in nature and should not be relied upon as legal, tax, accounting, investment, fiduciary, underwriting, or regulatory advice."
},
{
"type": "heading",
"level": 1,
"text": "8. DEPOSITS, CUSTODY, AND FDIC INSURANCE"
},
{
"type": "heading",
"level": 2,
"text": "8.1 Who Holds My Deposits?"
},
{
"type": "p",
"text": "Customer deposits, if offered through the FlowState platform, are expected to be held by partner financial institutions, custodians, or other regulated institutions identified in applicable product documents. FlowState does not itself hold deposits unless expressly authorized by law and expressly stated in final legally approved disclosures."
},
{
"type": "p",
"text": "The institution that holds customer funds may vary by product, customer eligibility, account type, sweep arrangement, jurisdiction, and partner availability. Customers should review the applicable account agreement and partner bank disclosures to understand where funds are held and what terms apply."
},
{
"type": "heading",
"level": 2,
"text": "8.2 Custody and Control of Funds"
},
{
"type": "p",
"text": "Custody of funds or assets may be provided by a bank, trust company, custodian, broker-dealer, qualified custodian, collateral agent, payment processor, or other third party, depending on the product structure. FlowState may provide technology access, dashboards, reporting, instructions, customer support, or administrative coordination, but those functions do not necessarily mean FlowState has custody of customer assets."
},
{
"type": "heading",
"level": 2,
"text": "8.3 FDIC Insurance"
},
{
"type": "p",
"text": "FlowState itself is not an FDIC-insured bank and does not provide FDIC insurance. FDIC insurance, where applicable, may be available only for eligible deposit products held at FDIC-insured depository institutions, subject to FDIC rules, limits, ownership categories, account titling, aggregation rules, program structure, and other conditions."
},
{
"type": "p",
"text": "FDIC insurance does not insure investment products, securities, mutual funds, digital assets, non-deposit products, loan products, business losses, market losses, operational losses, fraud losses, or the performance or obligations of FlowState. Customers should review partner bank disclosures and account documents to understand whether and how FDIC insurance may apply."
},
{
"type": "heading",
"level": 1,
"text": "9. PAYMENT PROCESSING AND MONEY MOVEMENT"
},
{
"type": "p",
"text": "FlowState may support payment-related workflows, including ACH, wire transfer, account funding, account-to-account transfers, settlement instructions, payment instructions, invoice-related workflows, or other money movement activities. Such activities may be processed by partner banks, payment processors, money movement providers, custodians, or other regulated or exempt third parties."
},
{
"type": "p",
"text": "FlowState does not guarantee that any payment, transfer, wire, ACH transaction, or settlement instruction will be accepted, processed, completed, settled, reversed, recalled, or delivered within any specific timeframe. Payment processing may be subject to cut-off times, bank approval, compliance screening, fraud monitoring, account holds, funds availability rules, payment network rules, partner policies, and applicable law."
},
{
"type": "p",
"text": "Customers are responsible for verifying payment instructions, recipient information, account numbers, routing numbers, wire instructions, counterparties, and authorizations before submitting instructions. FlowState is not responsible for losses arising from incorrect instructions, business email compromise, social engineering, fraud, unauthorized internal approvals, or customer-side security failures except to the extent liability cannot be limited under applicable law."
},
{
"type": "heading",
"level": 1,
"text": "10. WHO IS REGULATED AND BY WHOM"
},
{
"type": "p",
"text": "Financial services often involve multiple parties, and each party may be regulated differently based on its role, charter, license, registration, exemption, or activity. The following summary is intended to clarify common roles and should be confirmed against final product documents."
},
{
"type": "heading",
"level": 1,
"text": "11. CUSTOMER RESPONSIBILITIES AND PROFESSIONAL ADVICE"
},
{
"type": "p",
"text": "Customers are responsible for understanding the legal and regulatory consequences of using FlowState, partner bank services, lending services, payment services, investment-related services, or any other financial product. FlowState does not provide legal, tax, accounting, regulatory, investment, fiduciary, or other professional advice unless expressly stated in a separate written agreement and permitted by applicable law."
},
{
"type": "p",
"text": "Customers should consult their own advisors regarding:"
},
{
"type": "ul",
"items": [
"entity authority and corporate approvals;",
"tax treatment of deposits, loans, interest, fees, collateral, or investments;",
"accounting treatment and financial statement classification;",
"business-purpose certifications;",
"pledging of collateral and creditor rights;",
"investment suitability and portfolio implications;",
"privacy, cybersecurity, and data transfer obligations;",
"banking, payments, lending, securities, commodities, and money transmission rules;",
"cross-border activity and international users; and",
"regulatory obligations specific to the customer’s industry."
]
},
{
"type": "heading",
"level": 1,
"text": "12. CHANGES IN REGULATORY STATUS"
},
{
"type": "p",
"text": "FlowState’s regulatory status, product structure, partner relationships, licensing, registrations, exemptions, and service model may change over time. FlowState may add, remove, replace, or modify services, partner financial institutions, lenders, servicers, custodians, payment processors, investment-related providers, or other third-party providers."
},
{
"type": "p",
"text": "If FlowState obtains a license, registration, charter, exemption, bank partnership, lending authority, servicing authority, advisory registration, or other regulatory status, FlowState may update this Disclosure and related product documents. No change should be assumed unless expressly stated in final legally approved disclosures."
},
{
"type": "p",
"text": "Customers should review the most current version of this Disclosure and all applicable product-specific documents before using a FlowState service."
},
{
"type": "heading",
"level": 1,
"text": "13. CONTACT INFORMATION"
},
{
"type": "p",
"text": "Questions, requests, or concerns regarding the Regulatory Status Disclosure may be directed to:"
},
{
"type": "p",
"text": "Flow State Capital LLC\nAttn: Privacy / Legal Department\n383 W Lakeview Rd\nLindon UT 84042\nadmin@flowstatecapital.ai\nflowstatecapital.ai"
}
]
};
|