State Disclaimers

The State Departments governing the provision of money transfer services in their States require the user to be aware of their rights and obligations when they use the service. Accordingly, State regulators require FI Partners to disclose standard information to the users regarding the service and redressal rights. These Disclaimers provide users with information about authorities they can contact in case of any grievance or complaints they may have with the service provided by the FI Partners. In order to achieve this objective, SMP is required to place the following State Disclaimers depending on the State selected by the user.

Content of State Disclaimer

The content of State Disclaimers is different for different events in the platform. The description of the events and the disclaimer to be placed are as follows:

A. Email Notifications:

The State Disclaimers should be published on every transaction related email sent to the user.. All such emails sent to the user must have the State disclaimer of the respective State authority depending on the State selected by the user below the Disclaimer of the FI Partners (described in Section 3). The sample content of the State disclaimers for the respective states are as follows:

Your Error Resolution Rights:

You have a right to dispute errors in your transaction. If you think there is an error, contact us within 180 days at 1-888-702-5656 or [e-mail]. You can also contact us for a written explanation of your rights.

You have 30 minutes to cancel this transaction. To cancel this transaction please call us at 1-888-702-5656 or email us at [e-mail].

Your Cancellation Rights:

You can cancel for a full refund within 30 minutes of payment, unless the funds have been picked up or deposited. For questions or complaints about Golden Money Transfer Inc, contact: [e-mail].

Complaint Resolution:

Golden Money Transfer Inc. is licensed and regulated by <<Name of State Authority>>. If you have complaints please first contact Golden Money Transfer Inc. at 1-888-702-5656 or [e-mail]. If you still have unresolved complaint regarding the company’s money transmission activities conducted at this location, please direct your complaint to:

<<Contact Details of State Authority>>

Consumer Financial Protection Bureau (CFPB):

(855) 411-CFPB (2372) TTY/TDD (855) 729-CFPB (2372)

8:00 AM - 8:00 PM Eastern, Monday - Friday

http://www.consumerfinance.gov

Please refer Annexure C for all Names and Contact Details of respective State Authority.

B. Footer of every page starting from the landing page.

There should be a button named “License and Complaint” from the landing page of the website. This button will redirect the user to a link hosted by Inyo which shows the contact details of all the state authorities for the licensed states of the FI partner. The link that should be added are as:

Note: For mobile applications, the link for the “License and Complaint” section can be placed in the menu bar.

C. KYC Section:

KYC for a user can be handled via widgets or API. There are certain requirements to be fulfilled by the SMP while collecting user KYC. The details are as follows:

1. Placement of State Disclaimer text

The user should be able to view the state disclaimers where they can see the details of the state regulators if they need to file a complaint. The link should be named as “State Disclaimer and Complaint Filing”. The link should show the details of the state regulators as per the state from where the user has registered.

The state disclaimers are present in the footer of the KYC section in a link titled “State Disclaimers and Complaint Filing” the content for the state disclaimers in this section will be as follows:

Golden Money Transfer Inc. is licensed and regulated by <<Office of the state Authority>>. If you have complaints, please first contact Golden Money Transfer Inc. at 1-888-702-5656 or [e-mail] . If you still have unresolved complaint regarding the company's money transmission activity, please direct your complaint to:

Contact detail of the state authority:

<<Contact Details of State Authority>>

Note: The above disclaimers are handled by default in KYC widgets provided by us. In case the SMP uses API for KYC process, they will have to place this link to display state disclaimers in the footer section where the user will fill in their KYC details. The format to show the disclaimer is given above whereas the details can be found in Annexure C.

1. User agreement details for TOS and PP of the FI partner

While submitting the KYC details, users should agree to the TOS and PP of the FI partner.

For SMPs using KYC widgets, the TOS and PP of the FI partners are handled by the KYC widgets. For API clients, the SMPs are required to place the TOS and PP of the FI partners (users need to agree to the TOS and PP before continuing to use the service) in the KYC section.

FI Partners’ Logo and Disclaimer Content:

The format and content of logos and disclaimers of the FI Partners shall be different for websites and mobile apps. SMP is required to display the following logo and disclaimer of the FI Partners depending on the State of Domicile selected by the user in the website.

FI Partners’ Logo and Disclaimer Content for Website:

The logo and disclaimer content for the website shall be as follows:

This service is powered by Golden Money Transfer Inc. Click here for terms of service, privacy policy and licensing information of Golden Money Transfer Inc.

The “Click here” link in all the disclaimers above shall redirect to the Licensing Page of the FI Partners hosted by Inyo. Please us the link provided in the text above.

FI Partners’ Logo and Disclaimer Content for App:

In order to address any UI and UX challenges in mobile app, the requirement shall be published within Inyo API/widgets.

Placement of FI Partners’ Logo and Disclaimer

This section describes the placement of Logo and Disclaimer of the FI Partners on the SMP platform as follows:

In case of website:

The FI Partners disclaimers should appear in the signup section. However, for email notifications sent to the users for their account activities, the logo and disclaimer of the FI Partners should be present. The details required for email contents are covered in later sections of this document.

In case of mobile app:

As mentioned above, placement of logo shall be published within Inyo API/widgets.link provided in the authorization text while creating a new transaction as well.