Evidence Over Promises

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Community & Partnerships

PHOCIS Tech© is built around real operators — not theorists — and our community reflects that.
We collaborate with trusted organizations that strengthen private lending, compliance, security, and veteran leadership.

Our network includes:

• • The Tributary Foundation, led by U.S. Marine Corps S. Sargent Javier Romo, supporting families of fallen service members.
• • American Lending Conference — our annual touchpoint with the country's most serious private credit operators.
• • AAPL (American Association of Private Lenders) — industry standards, best practices, and ongoing education.
• • Wells Fargo Finxera — custody-grade banking infrastructure and secure program management.
• • Koop AI — advanced fraud detection and operational risk scoring.

These partnerships reinforce our commitment to lenders who value tradition, integrity, and clean capital management.

If your organization shares those values, we're open to carefully vetted collaborations.

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Compliance

Compliance isn't a feature — it's the spine of PHOCIS Tech©.
Everything we build respects state trust-fund rules, lender EIN ownership, and the realities of modern audits.

Core Compliance Foundation

• • FDIC-insured Clearing Accounts held under each lender's EIN
• • Wells Fargo custody, with daily balance verification
• • No commingling — each account is a true trust-fund structure
• • Automated audit trails for every balance change, draw, and ledger event
• • Hard separation between lender funds, borrower funds, and operating accounts
• • 24/7 ledger immutability — every action time-stamped and locked
• • KYB / KYC workflows that mirror regulated-bank onboarding
• • Encrypted data vaults using bank-grade security rails
• • Multi-party authorization for draws and disbursements
• • State-by-state trust-fund compliance mapping baked into every new account
• • Workflow isolation preventing human error during disbursements
• • Full ledger reconstruction capability for audits within minutes
• • SOC2-aligned engineering for all internal systems
• • Weekly compliance sweeps automated through Koop AI
• • Dual-signature release logic for high-risk transactions

Transparency Reporting

We publish regular numbers to keep lenders aligned with our movements:

• • Weekly: total AUM on platform
• • Weekly: total interest returned to lenders
• • Weekly: new Clearing Accounts opened
• • Monthly: compliance events, incidents (if any), and resolutions
• • Quarterly: independent third-party audit summaries

You don't have to trust us — you can verify us.

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Media

For press, interviews, partnerships, or public commentary:

Jack will route it directly to our CEO and marketing manager instantly.

Everything PHOCIS Tech© shares publicly is factual, compliance-safe, and aligned with our lenders' best interests.

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About PHOCIS Tech©

PHOCIS Tech© was born in the trenches of private lending — not in a boardroom. We were built by the lenders who grew tired of escrow middlemen, compliance guesswork, and the constant drain of "service fees" that served no one but the institutions. We saw every inefficiency in the lending process, every delay, every unnecessary point of friction. So we built the platform that removes them all.

PHOCIS Tech© is the first Digital Clearing Platform for Direct and Private Lenders. Our mission: replace traditional escrow with insured, lender-controlled Clearing Accounts — powered by Wells Fargo Institutional Custody, covered by FDIC + SIPC, and backed by SOC-2 aligned infrastructure.

We didn't set out to improve the system. We set out to replace it.

Funds remain under the lender's EIN — fully insured, fully compliant, and instantly auditable. No middleman. No delays. No excuses.

Our Mission

Our mission is simple, but it demands precision: give lenders complete financial control, automated compliance protection, and scalable revenue options — all in a framework that's compliant across 50 states. We believe in sovereignty over dependency. Transparency over trust. And control over compromise.

We are not another fintech. We are the clearing rail that makes modern lending possible — fast, insured, and intelligent.

Our Story

PHOCIS Tech© was built by a team of financial engineers, compliance experts, and veterans of the escrow industry — led by a United States Marine who knows that discipline, speed, and integrity aren't just values. They're the only way forward.

When others saw problems, we saw opportunity. Where competitors waited for change, we built it.

Our AI State Compliance Engine™ was the first in the industry — a fully automated, 50-state regulatory logic engine that updates itself daily. Every change in law, every compliance update, instantly reflected in your workflow. No guesswork. No downtime. That engine is paired with $250,000 of audit coverage per lender — a protection layer no other platform in the industry provides.

Our Partnerships

PHOCIS Tech© is proud to partner with Tributary Charity Foundation, an organization dedicated to helping veterans rebuild their lives through organic opportunities, leadership, and community. We don't just talk about impact — we build systems that fund it. Every account opened through PHOCIS contributes to veteran-focused initiatives, because we believe technology should not only create profit but restore purpose.

Our Advantages

• • Zero Fees: No ACH, wire, open, or close fees. Ever.
• • No Billing: We never send invoices or request cards.
• • 48-Hour Onboarding: Initial clearance complete in two days.
• • Three-Click Expansion: Sub-accounts open in under three clicks.
• • Revenue Optionality: Earn from your clearing balances, depending on your configuration.
• • SOC-2 Alignment: Full audit trails, timestamped and export-ready.
• • Military-Grade Security: AES-256 encryption, Wells Fargo custody.

Our Vision for the Future

We're not standing still. PHOCIS Tech© is expanding its clearing rails into new frontiers of decentralized and AI-driven financial infrastructure.

Next up:

• • PHOCIS Coin — our upcoming meme-backed liquidity token, bridging real-world clearing with digital asset yield.
• • Smart Sub-Accounts™ — compliance-aware accounts that deploy in seconds, auto-configured to state and federal regulations.
• • PHOCIS AI+™ — the next generation of our Compliance Bot, providing conversational, real-time guidance with integrated audit verification.

We're not talking about disruption — we're executing it. Every product we launch strengthens one core promise: that control, compliance, and profit should belong to the lender, not the institution.

Our Ethos

We move fast, but never recklessly. We innovate, but never compromise security. We serve lenders, but we never forget service — because PHOCIS was built on the values of those who serve.

We believe in earning trust, not asking for it.

We believe in technology that protects as much as it performs.

And above all, we believe that compliance can be your competitive edge, not your cost center.

Join the Revolution

You can talk about change — or you can help build it.

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Leadership

Nate — Founder & CEO, PHOCIS Tech©

Nate didn't grow up around privilege. He grew up around persistence.

His story begins the hard way — with a tough upbringing that demanded grit before success was even in the picture. Sports became his first battlefield: football, track, wrestling. The lessons were the same everywhere — when it hurts, push harder. When it breaks, rebuild stronger. Those early years forged the discipline that would later define both his leadership and the DNA of PHOCIS Tech©.

Then came the United States Marine Corps, where every day was a test of endurance and precision. The Corps taught him that leadership is earned through action, not titles — that you move first, eat last, and own every outcome. Those values — accountability, clarity, and relentless drive — became the foundation for everything that came next.

From Bootcamp to Beverly Hills

After the Marines, Nate entered the mortgage world — starting as an assistant at CS Financial in Beverly Hills, California, one of the most competitive and fast-paced lending institutions in the country. It was there he had his first look at the high-performance world of elite mortgage originators.

Until that point, Nate had never met anyone who made $100,000 in a single month. Watching these titans bulldoze loans down a conveyor belt of assistants and processors — turning precision and teamwork into profitability — was mesmerizing. The entire floor moved like a machine built on ambition (and ego).

He had a front-row seat to one of the most inspiring transformations in post-crash finance — Jeff Seabold's leadership turning a 15-person brokerage floor into the foundation of what would become Banc of California, a full-scale banking institution born from the ashes of 2008. That environment showed Nate what elite performance looked like — speed, trust, and execution under pressure.

The Climb and the Creation

Nate rose through the ranks, grinding his way up the corporate ladder. By his early 30s, he had transitioned from originator to developer — building his first single-family residence (SFR) in Hancock Park, Los Angeles, where he and his family lived for more than a decade. Over the next six years, Nate developed and sold seven SFR properties, mastering the rhythm of finance, construction, and deal flow.

Then the world stopped.

When COVID hit, building paused — but Nate didn't. Instead, he pivoted again. Locked down at home, he dove headfirst into coding. Late nights turned into early mornings filled with logic trees, Python scripts, and the growing realization that the next great shift in lending wouldn't come from Wall Street — it would come from FinTech.

Coding gave him the language. Lending gave him the problem.
Together, they became the blueprint for PHOCIS Tech©.

Building PHOCIS: The Battle for Control

When the first partner banks failed to meet the standard, Nate refused to compromise. He went bigger. That's when Wells Fargo Institutional Custody entered the picture — a move that required a massive institutional commitment, a personal guarantee from Nate himself, and total alignment with SOC-2 security and FDIC + SIPC protections.

It was the high-risk, high-accountability move that only a Marine-turned-founder would take — and it paid off.

By October 2025, lenders began circling. By November, the first 10 organic lenders were onboarded, each seeing what the rest of the market had missed — a compliance-first clearing system that gives control back to the lender.

From there, it's been pure forward motion.

The Mission: Give Control Back to the People Who Earn It

PHOCIS Tech© was never built for the megabanks. It was built for the small lender running a 3-to-5-person shop — the kind of business that keeps local processors employed, builds real community relationships, and refuses to hand its future over to an algorithm.

That's the difference. PHOCIS doesn't replace people — it protects them.

It gives smaller lending teams the same firepower and compliance protection as national institutions, without the bureaucracy, fees, or red tape.

Every part of this platform was engineered to honor the people who built the lending industry — the independent brokers, processors, and originators who never got credit for holding the system together.

Through PHOCIS, Nate's journey comes full circle: from a Marine with a mission, to a broker watching legends in Beverly Hills, to a developer, a coder, and finally, the founder of a platform designed to give back to the community that made it all possible.

PHOCIS Tech© is more than a company — it's a declaration:
Control belongs to the lender.

We don't change the way you lend. We change the way you earn.

And we never forget who we're building it for.

Built to Lead. Built to Last. Built by Marines.
We're Monetizing a Revolution.

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Comprehensive Privacy Policy

Effective Date: April 2025

1. Introduction

PHOCIS Tech© ("Company," "we," "our," or "us") is committed to safeguarding the privacy and security of your non-public personal information. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our services or access our platform. It applies to current and former customers, users accessing the Service on behalf of a business, and visitors of www.phocistech.com.

By accessing the Service, you consent to the practices described herein. This policy is constructed in accordance with U.S. federal and state privacy regulations, including but not limited to: GDPR, CCPA, GLBA, FIPA, and the California Shine the Light law. PHOCIS Tech© maintains the right to alter this policy and update compliance language at any time to align with evolving technologies, regulations, or operational standards. We may notify users via email, in-platform notices, or website updates.

2. Definitions

• • Account: A unique record allowing access to PHOCIS Tech© services, which may include user-specific credentials, access levels, transaction logs, and system interaction data.
• • Consumer: A natural person who interacts with the platform for personal or household purposes, as defined under CCPA.
• • Data Controller: PHOCIS Tech© determines the purpose and means of processing personal data under GDPR.
• • Device: Any hardware/software (e.g., mobile, desktop, tablet, kiosk) used to access the Service.
• • Personal Data: Identifiable information such as name, contact data, account numbers, and biometric data.
• • Service: The PHOCIS Tech© website, mobile apps, APIs, portals, and proprietary systems.
• • Usage Data: Automatically collected data such as browser type, device info, interaction timestamps, and diagnostics.

3. Personal Information Collected

PHOCIS Tech© collects data from users, affiliated institutions, and automated systems during registration, onboarding, service use, or third-party integrations.

Examples of Data We Collect:

• • Identifiers: Name, DOB, government-issued ID (license, passport).
• • Contact: Address, email, phone, emergency contact.
• • Transactional: Bank details, wire logs, ACH records, cash flow.
• • Employment: Job title, employer, income verification.
• • Sensitive: SSN, biometrics, authentication data.
• • Behavioral: Heatmaps, clickstream, user interaction trends.

4. Data Collection Methods

Information may be collected via:

• • Online forms & applications
• • Uploaded documentation
• • Financial integrations
• • Support tickets
• • Cookies & tracking scripts
• • Session monitoring & screen recording

Third-party providers must meet PHOCIS Tech©'s privacy and security standards.

5. Cookies & Tracking Technologies

PHOCIS Tech© uses cookies, pixels, and tracking tools to:

• • Maintain session stability
• • Authenticate users
• • Detect fraud/bot activity
• • Improve navigation and platform UX
• • Analyze user behavior

Tracking is anonymized unless tied to a logged-in session. Users can adjust settings via their browser.

6. Use of Information

PHOCIS Tech© uses your data to:

• • Perform AML/KYC onboarding
• • Enable secure account access & fund movement
• • Meet legal/compliance reporting obligations
• • Prevent fraud
• • Optimize the platform via analytics
• • Provide support & updates
• • Develop new features & services
• • Monitor and respond to security threats

AI and ML tools are used to detect anomalies, guide security alerts, and protect user data.

7. Disclosure of Information

PHOCIS Tech© does not sell or lease personal data. We may disclose information only when necessary, such as to:

• • Regulators (SEC, FINRA, OFAC, FDIC)
• • Legal entities under subpoena or court order
• • Contracted service providers (under strict privacy terms)
• • Auditors and compliance reviewers
• • Data analytics vendors (anonymized use only)

8. International Data Transfer

While PHOCIS Tech© operates in the U.S., some data may be processed internationally under:

• • Standard Contractual Clauses (SCCs)
• • U.S.-EU Privacy Shield (legacy)
• • Approved cross-border agreements

9. Data Security Measures

PHOCIS Tech© employs robust protection standards:

• • AES-256 encryption (in transit + at rest)
• • SOC 2 Type II certified systems
• • Zero Trust access validation
• • Regular 3rd-party penetration testing
• • MFA on all access portals
• • EDR systems and tamper-proof audit logs
• • A defined Incident Response Plan (IRP)

10. Data Retention & Storage

We retain data in line with U.S. financial law:

• • Customer Data: ≥ 7 years post account closure
• • Communications: Indefinitely
• • Transaction Records: Immutable for 7+ years
• • Backups: Rotated & encrypted based on internal policy

Expired records are destroyed or anonymized per NIST 800-88 standards.

11. Customer Rights

Users may:

• • Request a copy of stored data (Access)
• • Request corrections (Rectification)
• • Limit data use (Restrict Processing)
• • Object to AI-based decisions
• • Transfer data to another platform
• • File complaints via support@phocistech.com

Requests can be submitted through our site's privacy section.

12. GDPR-Specific Disclosures

PHOCIS Tech© processes EU/EEA data under:

• • Consent
• • Contractual necessity
• • Legal obligation
• • Legitimate interest

Users can withdraw consent at any time, pending compliance requirements.

13. CCPA-Specific Disclosures

California residents may:

• • Request disclosures of data from the past 12 months
• • Request deletion (except when required by law)
• • Exercise non-discrimination rights in pricing or access

Submit CCPA requests via our Data Access Portal or by calling 877.679.6879.

14. Minors & Children's Privacy

PHOCIS Tech© does not permit access by users under 18. We do not knowingly collect data from minors. Any such data will be deleted immediately.

15. Policy Updates

This Privacy Policy may be updated to reflect changes in law or operations. Updates will be communicated via:

• • Our website
• • Email (to registered users)
• • In-platform notifications

16. Contact Information

For privacy questions or rights requests:

PHOCIS Tech© Compliance Department
📧 support@phocistech.com
📞 877.679.6879
🌐 www.phocistech.com

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Terms & Conditions

Effective Date: April 2025

1. Acceptance & Interpretation

By accessing or using the PHOCIS Tech© platform, website, services, portal, or applications (collectively referred to as the "Platform"), you agree to be legally bound by the terms and conditions set forth herein (the "Terms"). If you do not accept these Terms in full, you may not access or use the Platform. These Terms constitute a binding agreement between you (the "User") and PHOCIS Tech© (the "Company").

PHOCIS Tech© reserves the right to modify or update these Terms at any time without notice. Continued use of the Platform after any changes constitutes acceptance of the new Terms.

"You" or "User" means any individual or entity accessing the Platform. "Company" means PHOCIS Tech©, a Delaware entity.

2. Definitions

For the purposes of this Agreement:

• • "Account": A unique profile created by the User to access services on the Platform.
• • "Affiliate": An entity directly or indirectly controlling, controlled by, or under common control with PHOCIS Tech©.
• • "Content": Any and all information, data, text, software, photographs, graphics, video, messages, tags, or other materials that appear on or are distributed through the Platform.
• • "Device": Any device used by a User to access the Platform, including but not limited to desktop computers, tablets, or smartphones.
• • "Products": All services, including Clearing Accounts, platform access, integrations, and tools, offered to Users by PHOCIS Tech©.
• • "Service": The complete offering of PHOCIS Tech© including digital services, web applications, support infrastructure, and banking integrations.
• • "User Content": All data, uploads, documents, posts, and submissions provided by the User.

3. Regulatory Compliance & Security

PHOCIS Tech© is committed to full compliance with United States financial laws and regulations, including those related to Anti-Money Laundering (AML), Know Your Customer (KYC), Office of Foreign Assets Control (OFAC), and the U.S. Treasury.

All Users must complete full onboarding and verification procedures. Submissions of IRS W-9 forms are required before any revenue-sharing disbursements.

Platform Security Includes:

• • SOC 2 Type II Compliance
• • AES-256 Encryption Standards
• • OAuth 2.0 Secure Login
• • Multi-Factor Authentication (MFA)
• • FDIC-insured banking partners via integrated clearing structure

Users understand and accept that the Company is not liable for breaches caused by external third parties or situations beyond its control.

4. Account Registration, Credentials & User Obligations

Users must register for an account and provide truthful, current, and complete information. It is the User's responsibility to maintain the confidentiality of their credentials.

Any unauthorized use of credentials must be reported to the Company immediately. The User is solely responsible for all activity under their account.

Failure to adhere to accurate registration and credential practices may result in account termination, restriction, or legal action.

5. Acceptable Use Policy

PHOCIS Tech© provides its services for lawful and compliant uses only. Prohibited uses include:

• • Engaging in fraud or financial crime
• • Circumventing the platform, integrations, or clearing structure
• • Uploading or distributing malware or other malicious code
• • Manipulating transactional data, wire activity, or sub-accounts
• • Conducting business in restricted or sanctioned jurisdictions
• • Using the platform for non-commercial or exploitative behavior

Violation of this section may lead to immediate suspension, permanent account restriction, legal recourse, and notification to federal regulatory authorities.

6. Digital Consent, Electronic Signatures & Delivery

By using this Platform, you consent to:

• • The use of electronic signatures
• • The receipt of notices, terms, and legal communications digitally
• • All agreements, disclosures, and documents being provided in digital format

You waive any defense of invalidity based on electronic transmission or execution.

7. Intellectual Property Rights

All elements of the Platform—including software, code, content, visual design, process flows, documentation, and platform functionality—are protected by applicable intellectual property laws and are the exclusive property of PHOCIS Tech© or its licensors.

Users may not modify, reproduce, transmit, publish, create derivative works from, reverse engineer, or exploit any part of the Platform.

Use of PHOCIS Tech© logos, brand assets, or proprietary code without written permission is strictly prohibited.

8. User Content & Submissions

You retain ownership of content you upload but grant PHOCIS Tech© an irrevocable, worldwide, royalty-free, perpetual license to use, store, distribute, display, and reproduce the content in connection with platform operation.

You represent that your content:

• • Is not obscene, defamatory, deceptive, or illegal
• • Does not infringe upon any third-party rights
• • Does not include protected information or trade secrets without authorization

PHOCIS Tech© reserves the right to remove or restrict content that violates these standards.

9. Third-Party Services & Affiliates

PHOCIS Tech© partners with third-party institutions for fund custody, bank integration, and backend processing.

We are not responsible for:

• • Downtime of third-party APIs
• • Errors made by affiliate banks
• • Delays caused by government holidays or batch settlements
• • Links to or from non-affiliated websites

Users must comply with any third-party terms of use embedded within the Platform's services.

10. Transactional Security & Processing Disclosures

All funds movement is conducted via PHOCIS Tech©'s integrated clearing architecture. Certain ACH and wire processes are subject to schedule limitations, banking cutoffs, and institutional protocols.

PHOCIS Tech© does not control delays caused by intermediary banks, nor does it guarantee settlement within user-defined timeframes.

11. No Guarantee of Returns & Risk Statement

PHOCIS Tech© is not a bank, investment adviser, or licensed fiduciary. Services are not guaranteed to generate returns.

Clearing Accounts accrue yield based on market conditions and U.S. Treasury performance. Historic yield data does not ensure future results.

12. Limitation of Liability

Under no circumstances will PHOCIS Tech© be held liable for:

• • Indirect, incidental, or consequential damages
• • Losses resulting from system errors, outages, or force majeure
• • Damages exceeding $100 or the amount paid by the User in the 12 months prior to claim

13. Indemnification

You agree to indemnify, defend, and hold harmless PHOCIS Tech©, its founders, partners, officers, affiliates, and employees from any claim, liability, or loss arising from your breach of these Terms, misuse of the Platform, or infringement of intellectual property.

14. Governing Law & Arbitration

These Terms are governed by the laws of the State of California. Any disputes will be resolved via binding arbitration in Los Angeles County through the American Arbitration Association (AAA).

Class action waivers apply. Users agree to individual resolution unless local law prohibits it.

15. International Users

This Platform is controlled from the United States. International Users are solely responsible for compliance with local laws.

PHOCIS Tech© does not allow onboarding from the European Economic Area.

16. Termination, Suspension & Non-Circumvention

PHOCIS Tech© may suspend or terminate access without notice for breach of these Terms.

Users are strictly prohibited from engaging directly with any platform partner or affiliate introduced via PHOCIS Tech© in an attempt to bypass the platform, clearing fees, or account structure.

Violations may result in immediate termination and legal action.

17. Updates & Notification

PHOCIS Tech© reserves the right to update, modify, or amend these Terms without notice. It is your responsibility to review these Terms regularly.

18. Contact

Questions or concerns? Please reach out to: support@phocistech.com

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SMS Messaging Policy & User Consent

Effective Date: November 01, 2025

1. Purpose of this Policy

This SMS Messaging Policy explains how PHOCIS Capital Inc., doing business as PHOCIS Tech©, communicates with users via text message (SMS and MMS) and how users may provide or withdraw consent. This Policy applies to all phone numbers collected through our website, applications, and platform-related services.

2. How We Use SMS Messaging

PHOCIS Tech© may send SMS or MMS messages to users who have provided their mobile numbers and explicitly opted in. Messages may include:

• • Account verifications, security alerts, or system notifications
• • Transaction confirmations or compliance notices
• • Product or service updates and optional marketing offers

Message frequency varies but generally does not exceed four (4) messages per month for marketing communications. Transactional and security alerts may occur as needed.

3. Consent to Receive Text Messages

By entering your phone number on a PHOCIS Tech© form or during platform registration and checking the consent box, you agree to receive recurring text messages at the number you provided.

Consent is not a condition of purchasing or using PHOCIS Tech© services.

You may still use the platform even if you do not opt in to receive messages. Standard message and data rates may apply depending on your mobile plan. Wireless carriers are not liable for delayed or undelivered messages.

4. Opt-Out Instructions

You may revoke consent or unsubscribe at any time:

• • Reply STOP to any PHOCIS Tech© text message to cancel future messages
• • Contact support@phocis.tech to request removal
• • Call 877-679-6879 to speak with support

You'll receive one final confirmation: "PHOCIS Tech©: You're unsubscribed and will no longer receive messages. Reply HELP for assistance or email support@phocis.tech."

5. Help and Support

For assistance with SMS communications, reply HELP to any message or contact:

📧 support@phocis.tech
📞 877-679-6879

6. Data Protection

Phone numbers and related messaging data are stored securely and handled in accordance with our Privacy Policy. We do not sell, rent, or share consent or opt-in data with third parties for marketing purposes.

Opt-in and opt-out records are retained for a minimum of two (2) years for compliance with telecommunications and regulatory requirements.

7. Important Notice

8. Contact Information

PHOCIS Capital Inc. (d/b/a PHOCIS Tech©)

🌐 https://phocistech.com
📧 support@phocis.tech
📞 877-679-6879