Policy Statement

It is the policy of Regent Bank, (or “Bank”) to establish guidelines for managing Priyo accounts that become inactive, dormant, or have a zero balance for an extended time under the Banking-as-a-Service (BaaS) framework. It ensures compliance with regulatory requirements and mitigates financial and operational risks associated with such accounts.

1. Definitions

• Inactive Account: A Priyo customer's account with no transactions for 12 months.

• Dormant Account: A Priyo customer’s account with no transactions for 24 months

• Zero Balance Account: A Priyo customer’s account that maintains a zero, $0.00, balance for 60 days with no transactions during the period.

2. Customer Communication & Notifications

• Pre-Dormancy Notification: Priyo’s customers will receive automated reminders before their accounts become dormant. The reminders will be sent monthly beginning 90 days prior to the date of dormancy.

• Dormancy Notice: A final notification will be sent to Priyo’s customer before the account is restricted. The final notice will be sent at least 2 weeks prior to the restriction.

3. Dormant Status & Restrictions

A “Dormant Status” flag may be placed on an account for the following reasons:

1. After the period of inactivity referenced above.

2. Death of a single owner when no Beneficiary is named.

3. Any other reason deemed necessary to protect the assets of the account.

Transaction Restrictions: Dormant accounts will be restricted from withdrawals, deposits, and transfers until reactivation.

4. Processing a Transaction on a Dormant Account

1. Transactions processed must be approved by two (2) officers or designated personnel.

2. The two (2) approving officers must complete and initial a Change Form for a one-day override to allow the transaction to post.

3. Forward the Change Form to Input.

5. Reactivation

• Dormant accounts must have written permission of an account owner to be reactivated.

• Reactivation may occur at the time a customer performs a transaction, with their written authorization on a Change Form.

• If reactivation occurs without a transaction, a Change Form with the account owner’s written permission must be on file.

• The Date of Last Contact field must be updated to reactivate the account.

Note: If transactions are returned or rejected, ensure the status is remains as Inactive or Dormant.

6. Zero Balance Accounts/ Closing

Zero balance accounts will be closed after the 60 days. Accounts with no transactions and a $0.00 balance for 60 days will be automatically closed. Zero balance accounts cannot be reopened after closing.

If the FinTech account disclosures fail to include the required disclosure, notice may be sent to affected account holders 30 days prior to closing.

• Note that exceptions can be made on the number of days prior to closing or sending notice if the use case of the FinTech partner supports the need to extend the time period. For example, use case of seasonal transactions.

7. Statements & Record Retention

• Statements for dormant accounts are produced quarterly.

• Dormant account Signature Cards are segregated from active account files.

• If a dormant account becomes active, its Signature Card is moved back to the open file.

• Retention of dormant signature cards and account records is 7 years after the date of closing.