Effective August 16, 2026 · Published at protocolwealthllc.com/terms
What this document is
These General Terms and Conditions are the operating and legal terms of Protocol Wealth's advisory engagements. They are incorporated by reference into each signed Client Advisory Agreement and, together with that signed form, make up the whole agreement between Protocol Wealth and the Client.
The signed form carries what is specific to one engagement: who the Client is, which services are INCLUDED, what authority is granted, the negotiated fees, termination, assignment, and governing law. This document carries what applies to every engagement. Terms are not repeated across the two documents, so the two cannot drift apart or contradict each other.
This document was previously published as the Master Advisory Terms at protocolwealthllc.com/legal/master-advisory-terms. It was renamed and moved to protocolwealthllc.com/terms on August 15, 2026; the former address redirects here.
This is more than a rename. The predecessor document carried three firm-level clauses — confidentiality, basis of advice, and notice — while stating that it held the operating and legal terms not repeated in the signed agreement. It did not. This version sets those terms out: custody, brokerage, valuation, reporting, client responsibilities, cybersecurity, conflicts, proxy voting, ERISA, succession, and the service-specific terms. A client who signed under the predecessor should read this document rather than assume it restates what they saw.
Precedence and non-waiver
- On any conflict between a signed Client Advisory Agreement and these General Terms and Conditions, the signed Agreement controls.
- On any conflict with a mandatory provision of the Investment Advisers Act of 1940, the Act controls over both documents — including Section 215 (15 U.S.C. 80b-15). Nothing in these Terms waives, or requires any Client to waive, compliance with the Advisers Act or any rule or order under it, or any right of action under federal or state law.
- Only a service marked INCLUDED in the signed Agreement is active. A service marked PENDING ACTIVATION does not authorize trading or fees.
How these terms change
Protocol Wealth will notify the Client of any material change to these Terms. Because the Client may terminate at any time without penalty under the signed Agreement, the Client is never bound to terms they have not chosen to continue under.
Each published version of these Terms is retained, so the terms in effect on any past date can be identified. Protocol Wealth's published document versions are listed at protocolwealthllc.com/archive/disclosures.
Changing the terms of a signed Agreement is different, and requires the Client's written or legally effective electronic agreement.
Disclosures are not terms
Protocol Wealth's Privacy Policy, Form ADV Part 2A and Form CRS, subprocessor list, and risk and service disclosures are disclosures, not terms of the Agreement. They describe the firm's current practices, are updated from time to time, and the version published at any date is the version then in effect. They are published at protocolwealthllc.com/privacy, protocolwealthllc.com/disclosures, protocolwealthllc.com/subprocessors, and on the SEC's adviser-information site under CRD #335298.
Core terms
These apply to every engagement.
1. Appointment and Fiduciary Standard
The Client hereby appoints Protocol Wealth as its investment adviser for the services marked INCLUDED in Exhibit A (Elected Services) of the signed Client Advisory Agreement. Protocol Wealth accepts this appointment and will provide the specified services. In fulfilling these services, Protocol Wealth shall act as a fiduciary and in a manner it reasonably believes to be in the best interest of the Client.
2. Scope of Advisory Services
The specific services the Client is engaging Protocol Wealth for are designated by the Client in Exhibit A (Elected Services) of the signed Client Advisory Agreement and are detailed further in the service-specific terms in this document. Ongoing investment management services will generally include:
(1) Assessment of the Client's financial situation, investment objectives, time horizon, and risk tolerance.
(2) Development of a tailored investment policy statement and asset allocation strategy.
(3) Identification and selection of appropriate investments, including but not limited to, stocks, bonds, mutual funds, and exchange-traded funds (ETFs).
(4) Ongoing portfolio monitoring and periodic reviews to ensure alignment with the Client's objectives.
(5) Recommendations for account rebalancing as needed due to market drift or changes in the Client's circumstances.
(6) Provision of regular performance reports, available online and/or in paper format.
(7) Coordination with the independent custodian to facilitate back-office support, including trade execution and statement generation.
3. Basis of Advice (Public Information Only; No MNPI)
The Client acknowledges that Protocol Wealth obtains information from a wide range of publicly available sources. Protocol Wealth does not possess, nor does it claim to have, sources of inside or private information. The recommendations developed by Protocol Wealth are based on the professional judgment of Protocol Wealth. Protocol Wealth cannot guarantee the results of its recommendations. Advice related to digital assets relies exclusively on publicly available information, onchain data, disclosures from decentralized finance protocols, and other non-confidential sources. Protocol Wealth does not use or depend on material non-public information to advise on digital assets.
4. Other Fees and Expenses
The Client acknowledges that they may incur additional charges imposed by third parties. These charges are separate from Protocol Wealth's advisory fee and may include, but are not limited to: brokerage commissions, transaction fees, custodial fees, internal management fees and expense ratios of investment products, and blockchain network fees ("gas fees").
5. Receipt of Form ADV Part 2A, Form CRS, and Privacy Policy
The Client acknowledges receipt of Protocol Wealth's Form ADV Part 2A, Privacy Policy, and Form CRS, provided before or at the time of signing this Agreement, and also available at: Form ADV Part 2A and Form CRS (SEC Investment Adviser Public Disclosure — adviserinfo.sec.gov/firm/summary/335298); Privacy Policy and Legal Disclosures (protocolwealthllc.com/disclosures).
6. Client Information
The management of the Account is based on the financial information the Client provides in the Client Profile, the advisory scope recorded in Exhibit A (Custody / Advisory Scope Covered) of the signed Client Advisory Agreement, and the Investment Policy Statement where one applies. The Client is responsible for promptly notifying Protocol Wealth in writing of any material changes to their financial situation or investment objectives.
7. Confidentiality (AML / CIP Data)
All information and documentation obtained through Protocol Wealth's AML and CIP processes will be treated as confidential in accordance with Protocol Wealth's Privacy Policy, except where disclosure is required to comply with applicable laws, regulations, or legal proceedings.
8. True and Accurate Information; Client Representation and Indemnity
The Client represents and warrants that all information the Client provides to Protocol Wealth — in the client-specific scope recorded in the signed Client Advisory Agreement, in any onboarding questionnaire, and throughout the engagement — is true, accurate, and complete in all material respects, and the Client agrees to keep it current by promptly notifying Protocol Wealth in writing of any material change. Protocol Wealth is entitled to rely on that information without independent verification in providing its services. The Client acknowledges that Protocol Wealth's advice, suitability determinations, planning, and reporting depend on the accuracy and completeness of the information the Client provides, and that inaccurate, incomplete, or outdated information can cause the services to be unsuitable or incorrect. To the fullest extent permitted by law, the Client agrees to hold Protocol Wealth harmless from, and to indemnify it against, losses, claims, and expenses arising out of the Client's provision of inaccurate or incomplete information or the Client's failure to update it. Nothing in this Section limits Protocol Wealth's liability for its own negligence or breach of fiduciary duty, nor waives, or requires the Client to waive, any non-waivable right the Client has under the Investment Advisers Act of 1940 or other applicable law.
9. Administration of Accounts
To implement the agreed-upon investment strategy, it may be necessary to open additional accounts for the Client. The Client hereby authorizes Protocol Wealth to initiate the opening of such related accounts, subject to the Client providing all necessary approvals and signatures required by the account custodian.
10. Custody of Assets
The Client shall at all times retain beneficial ownership and control over the assets under management. For the purposes of this agreement, the term "Client" shall be understood to include any legal entity, account structure, or fiduciary arrangement designated by the Client to hold assets. Assets shall be held in an account titled in a manner that reflects the Client's legal ownership or authorized control. Such titling may include, but is not limited to:
(1) Individual accounts in the Client's name;
(2) Joint accounts where the Client is a co-owner (e.g., Joint Tenants with Rights of Survivorship, Tenants in Common);
(3) Trust where the Client serves as grantor, trustee, beneficiary, or authorized representative;
(4) Corporate, partnership, or limited liability company accounts where the Client has ownership interest, managerial authority, or authorized signatory authority;
(5) Retirement accounts, pension plans, or other tax-advantaged accounts held for the Client's benefit;
(6) Estate accounts where the Client serves as executor, administrator, or authorized representative;
(7) Custodial accounts where the Client serves as custodian for a minor or incapacitated person;
(8) Foundation, endowment, or charitable organization accounts where the Client has authorized control;
(9) Government entity accounts where the Client has authorized signatory authority; or
(10) Any other account structure where the Client has legal authority to direct investment decisions.
The custody method will depend on the nature of the asset:
(1) Securities and Traditional Assets. All securities and other traditional assets must be held in an account at a qualified independent custodian ("Custodian"). Protocol Wealth is authorized to instruct the Custodian to carry out transactions for the Client. Subject to and without limiting Protocol Wealth's fiduciary duty to select and monitor the Custodian with reasonable care, Protocol Wealth is not liable for the independent acts or omissions of the Custodian that are beyond Protocol Wealth's reasonable control.
(2) Digital and Non-Security Assets. The Client understands and agrees that custody of Digital Assets involves unique and significant risks. While some Digital Assets may be held with a specialized Digital Asset Qualified Custodian ("QC") such as Anchorage Digital or BitGo, many onchain activities (e.g., interacting with decentralized finance or "DeFi" protocols, staking, or lending) require transferring assets to platforms or smart contracts that are not Qualified Custodians. This includes Digital Assets held in a wallet the Client owns and controls, in which the Client is the sole signer and Protocol Wealth holds no credential that can move those assets. The Client explicitly acknowledges that assets held outside of a Qualified Custodian are not protected under the SEC's Custody Rule, are not safeguarded by the Securities Investor Protection Corporation (SIPC), and may not be segregated from the assets of the platform or protocol operator. This increases the risk of total and permanent loss due to platform insolvency, hacking, fraud, smart contract failure, or operational issues. Protocol Wealth acts as a fiduciary in selecting and monitoring custodians and platforms, and nothing in this Agreement shall be construed to waive or limit any duty or liability Protocol Wealth may have under the Investment Advisers Act of 1940 or applicable state law. Protocol Wealth selects and monitors the qualified custodians, the wallet technology providers it uses, and related providers consistent with that fiduciary duty and conducts ongoing due diligence on them. Subject to and without limiting the foregoing fiduciary obligations, Protocol Wealth is not liable for losses arising solely from the independent acts, insolvency, breach, or malfunction of a third-party custodian, platform, smart contract, or blockchain protocol that are beyond Protocol Wealth's reasonable control; this allocation of third-party risk does not reduce Protocol Wealth's duty to select and monitor such providers with reasonable care.
11. Verification of Beneficial Ownership (BSA / Corporate Transparency Act)
Notwithstanding the form of ownership or account title, Protocol Wealth is required by federal law (including the Bank Secrecy Act and the Corporate Transparency Act) to identify and verify the identity of the ultimate beneficial owner(s) of all assets.
The Client agrees to provide, or cause any representative entity (such as a trust, business entity, or representing attorney) to provide, all documentation required by Protocol Wealth to satisfy its legal and regulatory obligations. This includes disclosing the identity of all natural persons who ultimately own or control the assets. Failure to provide satisfactory documentation shall be grounds for Protocol Wealth to decline to open an account or to terminate this Agreement and liquidate the account. All information provided for this purpose will be protected under Protocol Wealth's privacy policy, but is subject to lawful requests from regulators and law enforcement.
12. Know Your Customer and Anti-Money Laundering Compliance
To comply with federal laws, including the Bank Secrecy Act and the USA PATRIOT Act, and to protect the integrity of the financial system, Protocol Wealth has established a comprehensive Anti-Money Laundering (AML) program and Customer Identification Program (CIP). As a condition of this Agreement, the Client agrees to the following:
(1) Initial and Ongoing Verification. The Client agrees to promptly provide all information and documentation Protocol Wealth requests to verify the identity of the Client and any beneficial owners. This may include, but is not limited to: (a) Full legal name, date of birth, physical address, and a U.S. Taxpayer Identification Number (TIN); (b) A copy of a valid government-issued photo ID (e.g., passport or driver's license); (c) Information regarding the nature and purpose of the Account, including the Client's occupation, source of wealth, and the origin of funds (for both fiat currency and digital assets) to be deposited.
(2) Digital Asset Due Diligence. The Client understands that transactions involving digital assets, particularly those originating from self-custodied wallets or decentralized platforms, may require enhanced due diligence. The Client agrees to provide information concerning the history and source of such assets upon request.
(3) Future Methods of Verification. The Client acknowledges that identity verification technology is evolving. Protocol Wealth may, at its discretion and where permissible by regulation, utilize or accept privacy-preserving verification methods, such as cryptographically secured zero-knowledge (ZK) attestations or other verifiable onchain credentials, to supplement or support its identity verification processes.
(4) Ongoing Cooperation and Updates. The Client agrees to promptly notify Protocol Wealth of any changes to the information provided and to cooperate with any periodic or transaction-based requests for updated information throughout the course of the relationship.
13. Foreign Client Representations and Compliance (OFAC / FATCA / CRS)
If the Client is a non-U.S. person or entity, the Client represents and warrants that they are not subject to restrictions under U.S. export control laws, sanctions administered by the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC"), or other similar sanctions laws. The Client agrees to provide any certifications, tax forms, or documentation reasonably requested by Protocol Wealth to comply with applicable tax reporting laws, including the Foreign Account Tax Compliance Act ("FATCA"). To the extent Protocol Wealth, or a custodian or other financial institution servicing the Account, has reporting obligations with respect to the Account under the OECD Common Reporting Standard ("CRS") as implemented by an applicable jurisdiction, the Client agrees to provide the self-certifications, tax forms, and documentation reasonably requested to satisfy those obligations. The Client is responsible for determining its own tax reporting obligations; Protocol Wealth does not provide tax or legal advice. Additionally, Client further agrees that this Agreement, and all services provided under it, shall be governed by the laws of the United States and the State of Colorado, regardless of the Client's place of residence, incorporation, or business operations.
14. Brokerage and Trade Execution; Best Execution; Aggregation
Protocol Wealth is authorized to select the broker-dealer and/or custodian for executing transactions. In seeking best execution, Protocol Wealth may use broker-dealers outside of the Client's primary Custodian. The Client understands that the Custodian or executing broker-dealer may charge transaction fees, which will be disclosed on trade confirmations and/or account statements. When Protocol Wealth deems the purchase or sale of a security to be advantageous for multiple clients, it may, at its discretion, aggregate these orders to seek a more favorable price or lower brokerage commissions. In such cases, securities will be allocated among participating client accounts in a fair and equitable manner.
15. Trading Authorization
Where the signed Client Advisory Agreement marks a service as discretionary, the Client grants Protocol Wealth discretionary trading authority over the assets in the covered Account(s) (the "Managed Account(s)") — decisions to buy, sell, hold, or otherwise transact in securities, cash, and other investments — exercised at Protocol Wealth's discretion and without consulting the Client before each transaction. Discretion extends only to services marked INCLUDED and marked discretionary in that Agreement.
Discretion is trading authority, not transfer authority, and it does not extend to moving assets out of the Client's control. For assets held in the Client's self-custody wallet, the Client is the sole signer: Protocol Wealth holds no credential that can move those assets, no server-side transaction signer exists, and Protocol Wealth's root-quorum membership in the Client's wallet organization is zero. Protocol Wealth may propose, prepare, and recommend a transaction, and may approve it within the policy limits the Client has configured, but the Client authorizes it. Protocol Wealth cannot transfer the Client's digital assets to itself or to any third party, and does not have authority to do so. While discretion is fully granted, the Client may provide a written request to be notified prior to a significant change in asset allocation, which Protocol Wealth will accommodate as a courtesy without limiting its authority to act. Additionally, Protocol Wealth may provide non-discretionary advice on assets held away by the Client ("Held-Away Assets"), for which the Client retains all responsibility for custody, trade execution, and outcomes.
16. Account Valuation
Protocol Wealth will calculate the value of Account assets in good faith for reporting and billing purposes. The valuation method generally uses closing prices for listed securities and data from recognized third-party price feeds, major exchanges, or custodian-provided valuations for other investments, including digital assets. The Client acknowledges that pricing for digital and illiquid assets can be complex and variable. Protocol Wealth relies on these external data sources and is not responsible for their accuracy or timeliness. The valuations used by Protocol Wealth are estimates and may differ from the official statements provided by the Custodian.
17. Reports
The Client's official account statements and trade confirmations are generated and delivered by the independent Custodian and serve as the definitive record for the Account. As a convenience, Protocol Wealth may periodically issue additional or supplemental reports, which are not guaranteed for accuracy and should be compared against the official Custodian statements. For Digital Assets managed onchain, reporting may involve directing the Client to third-party data aggregators (e.g., Zapper, DeBank), for which Protocol Wealth assumes no responsibility for accuracy or availability. The Client is responsible for carefully reviewing and reconciling all information from the Custodian, Protocol Wealth, and any onchain data sources, and for promptly reporting any discrepancies.
18. Consent to Electronic Delivery
The Client authorizes Protocol Wealth to deliver all required regulatory notices, disclosures, and all other Protocol Wealth correspondence via email. The Client has the right to withdraw their consent to electronic delivery without any fee. The Client acknowledges that communications relating to digital assets, DeFi activities, protocol governance, staking rewards, airdrops, or blockchain events may only be delivered electronically via email or through the secure client portal.
E-SIGN mechanics and the Client's rights (the Client acknowledges each of the following): (a) Right to paper; revocation. The Client may obtain a paper copy of any electronically delivered document at no charge, and may withdraw this consent or update the delivery email at any time, without any fee, by written notice to Protocol Wealth; a withdrawal takes effect within a reasonable time after Protocol Wealth is able to act on it and applies going forward. (b) Review-or-deemed-accepted window. A document is delivered when sent to the Client's designated email or made available in the secure client portal with notice; the Client should review each communication promptly, and a document is deemed received if the Client does not object within the review period stated in the communication or, if none is stated, within a reasonable period. Deemed receipt establishes delivery only. It is not acceptance of any amended term: changing the terms of a signed Client Advisory Agreement requires the Client's written or legally effective electronic agreement, and silence is never that. (c) Hardware and software requirements. To receive and retain electronic communications the Client needs a device with internet access, a current web browser, an active email account able to receive messages from Protocol Wealth, and the ability to open and save PDF documents; the Client confirms current access to these. (d) Network-security acknowledgment. The Client acknowledges that email and internet delivery are not perfectly secure, that Protocol Wealth is not responsible for the security of the Client's own devices, email account, or network, and that the Client is responsible for the confidentiality and security of the delivery email account and portal credentials (see the Cybersecurity — Client Responsibilities section).
I affirmatively consent to and authorize Protocol Wealth to deliver all communications to me electronically. I understand that this consent will apply to all documents required by law to be provided to me and that this authorization will remain in effect until I revoke it.
19. Notice
Any notice or other communication required or permitted under the Agreement is considered given when delivered in person or sent by email, U.S. mail, or overnight courier, with postage prepaid. Notices to Protocol Wealth should be sent to the address below. Notices to the Client are sent to the email address the Client provided, unless the Client instructs Protocol Wealth in writing to use an alternate address.
Protocol Wealth, LLC — 201 Milwaukee Street, Suite 200, Denver, Colorado 80206. Telephone: 720-383-4550. Email: [email protected].
20. Use of Artificial Intelligence
Protocol Wealth uses artificial-intelligence ("AI") tools under a co-intelligence approach that combines human adviser judgment with AI under human oversight. AI supports research, analysis, portfolio monitoring, document preparation, and internal operations; it does not replace the Client's adviser, does not make autonomous investment decisions, and does not operate outside supervision. No AI system makes a fiduciary decision or delivers advice to the Client without human validation; every material AI-assisted output is reviewed and approved by a human adviser before it reaches the Client or informs a recommendation.
Protocol Wealth governs this use through written policies and periodic review, immutable audit logging of AI-assisted interactions, and monitoring for bias and other advice red-flags. Protocol Wealth applies safeguards designed to protect the Client's nonpublic personal information: its policy requires de-identification of client data before AI processing where feasible, and independent technical controls block the transmission of identifying data to AI providers. Protocol Wealth's AI providers operate under agreements that exclude the Client's data from model training and, where offered, provide zero data retention.
AI outputs can contain errors or omissions; human review is the control Protocol Wealth relies on to address this. Protocol Wealth does not overstate the role or capability of AI in its services and will update this disclosure before any material change to how it uses AI.
The specific risks of AI-assisted advice that human oversight is designed to mitigate include, without limitation: (1) reliance on assumptions or omitted context a model does not surface; (2) reliance on outdated Client information the model was not updated with; (3) bias in training data or algorithms that can skew an output; (4) fabricated or inaccurate outputs ("hallucinations"); (5) tool or service outages that affect availability; and (6) loss of context across long or multi-step interactions. This enumerated list of AI risks corresponds to the disclosure Protocol Wealth makes in Form ADV Part 2A, Item 8 (methods of analysis). Protocol Wealth's governance of AI use, including permitted and prohibited uses and the safeguards summarized above, is set out in its AI Acceptable Use Policy, published at protocolwealthllc.com/legal/ai-acceptable-use.
21. Client's Responsibilities
The success of the advisory relationship is a shared responsibility. The Client agrees to:
(1) Provide Complete and Accurate Information.
(2) Communicate Material Changes in their financial or personal situation.
(3) Impose Investment Restrictions in writing. The Client is responsible for informing Protocol Wealth in writing of any specific and reasonable investment restrictions they wish to place on the management of the Account.
(4) Review Account Information from both Protocol Wealth and the custodian. The Client agrees to carefully review all account statements, trade confirmations, and performance reports provided by both Protocol Wealth and the independent custodian. The Client is responsible for promptly reporting any discrepancies or questions to Protocol Wealth.
(5) Maintain Cybersecurity for their personal devices and accounts, as detailed in the following section.
22. Cybersecurity — Client Responsibilities
The Client acknowledges that safeguarding their digital security is a critical part of protecting their financial assets. The Client understands that failure to adhere to these cybersecurity best practices can significantly increase the risk of unauthorized access and potential financial loss. While Protocol Wealth maintains its own cybersecurity protocols, the Client agrees to take responsibility for securing their personal devices, accounts, and information by adhering to the following best practices. A comprehensive guide with additional information is available from Protocol Wealth upon request.
(1) Secure Account Access. Creating strong, unique passwords for each financial account, utilizing a reputable password manager, and enabling multi-factor authentication (MFA) wherever possible. The Client agrees to never share their login credentials with anyone, including Protocol Wealth staff.
(2) Device and Software Integrity. Regularly update operating systems, applications (especially web browsers), and anti-virus/anti-malware software on all personal computers and mobile devices. The Client agrees to secure their devices with a passcode, PIN, or biometric lock (e.g., Face ID, fingerprint).
(3) Safe Charging Practices. Avoid using public USB charging stations (e.g., in airports, cafes, or hotels) due to the risk of "juice jacking" malware. Instead, the Client should charge devices using their own AC power adapters plugged into an electrical outlet or by using a portable battery pack (power bank) without data transfer capabilities.
(4) Secure Network Usage. Avoid accessing financial accounts or transmitting sensitive information while connected to public or untrusted Wi-Fi networks. A secure, private network (such as a home network) or a trusted cellular data connection is strongly recommended.
(5) Vigilance Against Phishing and Fraud. Treat all unsolicited emails, text messages, and phone calls with extreme suspicion. The Client agrees to independently verify any unusual requests for personal information or urgent actions by contacting the financial institution through official, known channels (e.g., a phone number on the institution's website or the back of a card), not by using links or phone numbers provided in suspicious communications.
(6) Regular Account Monitoring. Promptly reviewing account statements, trade confirmations, and transaction histories to identify and report any unauthorized or suspicious activity to both Protocol Wealth and the appropriate financial institution immediately.
(7) Nothing in this Agreement limits Protocol Wealth's liability for its own negligence or breach of fiduciary duty, nor waives or requires the Client to waive any non-waivable right the Client has under the Investment Advisers Act of 1940 or other applicable law. Subject to and without limiting the foregoing, the Client agrees that Protocol Wealth shall not be held liable for financial losses caused solely by the Client's failure to adhere to these cybersecurity best practices, such as the compromise of the Client's email account or the sharing of login credentials.
23. Non-Exclusive Relationship; Conflicts of Interest
The Client acknowledges and agrees that Protocol Wealth may manage investments, give advice, or take actions for other clients, for Protocol Wealth's accounts, or for accounts of parties related to Protocol Wealth. This may involve providing advice or taking actions different from what Protocol Wealth does for the Client. Protocol Wealth is not required to buy, sell, or recommend any security or investment for the Client that Protocol Wealth may buy, sell, or recommend for other clients, Protocol Wealth's accounts, or accounts of related persons. Conflicts might occur in how investment opportunities are allocated among accounts that Protocol Wealth manages. Protocol Wealth will aim to allocate opportunities fairly and in the best interests of all involved accounts, but there is no guarantee that any particular opportunity will be allocated in a specific way. If Protocol Wealth acquires material, non-public information about a security or issuer that it cannot lawfully use or disclose, Protocol Wealth is not obligated to share or use that information for the Client's benefit. The Client understands that Protocol Wealth may recommend third-party custodians, trading platforms, or service providers, including those related to digital asset custody or management. Protocol Wealth makes no promises or warranties about the performance, security, or compliance of any third-party providers.
24. Risk (No Guarantee)
Protocol Wealth cannot guarantee the future performance of the Account or promise that investment decisions will be successful. The investment decisions Protocol Wealth makes for the Client are subject to various market, currency, economic, political, and business risks, and may not yield a profit. In managing the Account, Protocol Wealth will not consider any other securities, cash, or other investments the Client owns unless the Client has instructed Protocol Wealth to do so.
25. Limitations and Disclosure of Other Professional Services; No Tax or Legal Advice
(1) Scope of Services. The services provided herein are limited to the duties for the services marked INCLUDED in Exhibit A (Elected Services) of the signed Client Advisory Agreement. Comprehensive financial planning is a separate and distinct service available only where that service is marked INCLUDED in Exhibit A (Elected Services) of the signed Client Advisory Agreement.
(2) No Tax or Legal Advice. Protocol Wealth does not provide tax, accounting, or legal advice and does not prepare tax returns or legal documents (such as wills or trusts). Nothing in this Agreement or in the Services constitutes tax or legal advice. The Client is responsible for all tax consequences of transactions in the Account and should consult a qualified attorney and/or tax professional regarding their specific situation; upon the Client's request, Protocol Wealth will reasonably coordinate with the Client's attorney and/or accountant.
(3) No Legal Proceedings. Protocol Wealth will not advise the Client or act for the Client in any legal proceedings, including bankruptcies or class actions, involving securities held for the Account.
(4) Referrals to Affiliated Professionals and Conflicts of Interest. Protocol Wealth personnel may have relationships with separate firms that provide other professional services ("Affiliated Firms"). If Protocol Wealth refers a Client to an Affiliated Firm, this creates a material conflict of interest. Protocol Wealth will deliver a separate written disclosure detailing the relationship. The Client is under no obligation to use any Affiliated Firm.
26. Proxy Voting and Digital-Asset Governance
The Client retains exclusive responsibility for all proxy voting and digital asset governance decisions. The specific policies are set out in the service-specific terms in this document.
27. ERISA Accounts
If the Account is maintained on behalf of a plan subject to the Employee Retirement Income Security Act of 1974 ("ERISA") or similar government regulation, Protocol Wealth acknowledges that certain services it may provide could constitute investment advice to a retirement plan for compensation. As a result, Protocol Wealth may be considered a "fiduciary" as defined under Section 3(21)(A)(ii) of the Employee Retirement Income Security Act of 1974 ("ERISA"). Protocol Wealth will act in a manner consistent with fiduciary requirements under ERISA if, based on the facts and circumstances, these services make Protocol Wealth a fiduciary as a matter of law. The parties agree that Protocol Wealth, unless expressly specified otherwise in this Agreement:
(1) has no responsibility and will not: (a) exercise any discretionary authority or control over the management of the Client's retirement plan; (b) exercise any authority or control over the management or disposition of plan assets; or (c) have any discretionary authority or responsibility in administering the plan or interpreting its documents;
(2) is not an "investment manager" as defined in Section 3(38) of ERISA and does not have the authority to manage, acquire, or dispose of plan assets; and
(3) is not the "Administrator" of the Client's retirement plan as defined in ERISA.
The Client agrees to maintain ERISA fidelity bonding for the Account as required by law and to include Protocol Wealth and, as applicable, Protocol Wealth personnel within the coverage of such bond to the extent required.
The Client affirms that retaining Protocol Wealth and any instructions given regarding the Account are consistent with applicable plan and trust documents and agrees to provide Protocol Wealth with copies of such governing documents upon request. The individual signing this Agreement on the Client's behalf acknowledges status as a "named fiduciary" with respect to the control and management of the assets held in the Account and agrees to notify Protocol Wealth promptly of any change in the identity of such fiduciary. The Client further recognizes that the Account represents only a portion of the plan's assets and that Protocol Wealth has no responsibility for ensuring the plan's overall compliance with ERISA, the Internal Revenue Code, or other applicable laws or governing documents, except to the limited extent of Protocol Wealth's services with respect to the Account as described in this Agreement.
If the Client's Account is ERISA-covered and involves digital assets, the Client acknowledges that Protocol Wealth's fiduciary responsibilities are limited to traditional investments unless otherwise agreed in writing. Digital-asset holdings may require separate oversight, custodial arrangements, and additional risk disclosures (see the digital-asset risk disclosures published at protocolwealthllc.com/disclosures).
28. Client Death or Disability (incl. Digital-Asset Succession)
The Client's death or legal incapacity will not automatically terminate this Agreement. Upon receiving written notice and satisfactory proof of such an event, Protocol Wealth will act as follows:
(1) Authorized Representative. If the Client has a legally appointed representative (such as an agent under a power of attorney, a trustee, an executor, or a court-appointed conservator), Protocol Wealth will follow their instructions upon receiving official documentation confirming their authority.
(2) No Designated Representative. In the absence of an authorized representative, the account will be governed by the applicable state's estate and succession laws. Protocol Wealth will place a temporary restriction on the account to safeguard the assets and await formal legal instruction, such as Letters Testamentary or a court order.
(3) Digital Asset Succession. The Client understands and agrees that the policies and procedures for succession depend on how and where the digital assets are held:
(a) Assets Managed by Protocol Wealth. At a Qualified Custodian (e.g., Anchorage Digital, BitGo): For assets held directly at a Qualified Custodian, succession and recovery are governed exclusively by the policies and procedures of that specific institution. The Client's authorized fiduciary or heir will be required to engage directly with the custodian and satisfy their specific legal and documentation requirements (such as providing death certificates, letters testamentary, or court orders). Protocol Wealth will assist in coordinating this process but is not responsible for the custodian's policies or their successful execution. In a Client-Owned Self-Custody Wallet: Protocol Wealth holds no key material for that wallet and cannot recover it. Where the wallet platform provides an assisted-recovery process, Protocol Wealth may only co-approve a recovery that the Client, or the Client's authorized fiduciary or heir, initiates — it cannot originate one.
(b) Client's Self-Custodied Assets. The Client is solely and exclusively responsible for the succession and recovery of any digital assets held outside of Protocol Wealth's management, including assets in personal hardware wallets, software wallets, or on other platforms. Protocol Wealth has no ability or responsibility to assist in recovering these assets. The Client is strongly advised to maintain a comprehensive personal digital estate plan to prevent the permanent loss of all self-custodied assets.
29. Amendment
Changing the terms of a signed Client Advisory Agreement requires the Client's written or legally effective electronic agreement. Protocol Wealth may update these General Terms and Conditions as described under "How these terms change" above.
30. Entire Agreement; Non-Waiver of Advisers Act Rights; Validity
Entire Agreement. This Agreement represents Protocol Wealth's entire understanding regarding the matters specified herein. No other agreements, covenants, representations, or warranties, express or implied, oral or written, have been made by any party to any other party concerning the subject matter of this Agreement.
Non-Waiver of Advisers Act Rights. Nothing in this Agreement shall be construed to waive, limit, or cause the Client to waive compliance with any provision of the Investment Advisers Act of 1940 or any rule or order thereunder, or any right of action the Client may have under federal or state law. Consistent with Section 215 of the Advisers Act, any condition, stipulation, or provision purporting to bind the Client to waive compliance with the Advisers Act or any rule or order thereunder is void.
Validity. If any part of this Agreement is found to be invalid or unenforceable, it does not affect the validity or enforceability of the remainder of this Agreement.
Service-specific terms
These apply only where the corresponding service is marked INCLUDED in the signed Agreement.
A. Financial planning (non-discretionary)
Scope of Planning Services (Phase I Plan; Phase II Monitoring)
Protocol Wealth will provide comprehensive, ongoing financial planning and investment advice on a strictly non-discretionary basis. "Non-discretionary" means Protocol Wealth will not place trades, open or close accounts, move funds, or otherwise implement recommendations without the Client's explicit prior authorization. The Client remains solely responsible for deciding whether and how to implement any recommendation and for executing all transactions. This service is intended for clients who self-manage some or all of their assets, including "held-away" accounts (for example, workplace retirement plans or brokerage accounts not managed by Protocol Wealth), as well as for clients receiving investment management who desire a holistic financial plan. Services are delivered in two phases: (i) Phase I, Initial Financial Plan Development, culminating in a written plan and implementation checklist delivered directly via email, or through the RightCapital platform or other similar online platforms; and (ii) Phase II, Ongoing Monitoring and Advisory, consisting of periodic review, updates, and advisory support to help the Client implement and maintain the plan over time. Protocol Wealth's advice relies on information the Client provides and on data Protocol Wealth is authorized to access. Protocol Wealth does not provide legal or tax advice; any tax or estate strategies will be coordinated with the Client's attorney and/or CPA as appropriate.
Phase I: Initial Financial Plan Development. (1) Discovery and Goal Setting: Conduct in-depth meetings to understand the Client's financial situation, risk tolerance, values, and long-term objectives, and to define measurable planning priorities and assumptions. (2) Data Aggregation: Securely collect and organize relevant financial data, including assets, liabilities, income, expenses, insurance policies, tax documents, and estate plans. Where available, Protocol Wealth may use third-party data connections authorized by the Client to facilitate ongoing updates. (3) Analysis and Strategy Formulation: Perform a comprehensive analysis of the Client's financial position relative to goals across Retirement Planning, Investment Portfolio Analysis, Cash Flow and Debt Management, Risk Management and Insurance Review, Education Planning, Estate Planning Review, and Tax Planning Strategies, and develop specific, non-discretionary recommendations. (4) Plan Presentation: Deliver a written financial plan directly via email, or through the RightCapital platform or other similar online platforms, including an executive summary, detailed analyses, and an actionable implementation checklist that assigns responsibilities and target timelines.
Phase II: Ongoing Monitoring and Advisory. (1) Implementation Guidance: Provide ongoing support and clarification as the Client implements recommendations. For held-away accounts, Protocol Wealth will provide non-discretionary, account-specific guidance; the Client is responsible for executing any transactions or elections. (2) Regular Progress Meetings: Conduct scheduled review meetings, typically semi-annually or annually (and more frequently as mutually agreed), to assess progress toward goals, update assumptions for material life events, and adapt recommendations to current market and legislative conditions. (3) Proactive Monitoring: Monitor the Client's planning inputs and the plan within the chosen online platform or similar method and provide proactive outreach regarding relevant changes in tax law, planning strategies, or other opportunities reasonably likely to affect the plan. Monitoring does not include continuous account surveillance or discretionary trade execution. (4) Plan and Portfolio Updates: Refresh projections, target savings rates, and allocation recommendations as new information becomes available or the Client's goals change. (5) Direct Access: Provide the Client with ongoing access to the advisory team during normal business hours for planning questions within the scope of this engagement.
Planning Technology Suite
Service includes client access to RightCapital or similar online platform for financial modeling and portfolio analysis, and Monarch Money or similar tools for cash flow management and expense tracking.
Non-Discretionary Nature; Client Implementation Responsibility
The success of the financial planning process is a shared responsibility. The Client agrees to: (1) Provide complete and accurate information regarding their financial situation, goals, and relevant documents in a timely manner; (2) Notify Protocol Wealth of any material changes to their financial or personal circumstances (e.g., change in employment, marital status, or significant inheritance); and (3) Acknowledge that the Client is solely responsible for the implementation of any and all recommendations provided under this non-discretionary service.
Limitations. (1) Non-Discretionary Service. All services provided under this section are advisory in nature. Protocol Wealth has no authority to execute transactions or implement recommendations on the Client's behalf. (2) No Legal or Tax Advice; Document Preparation. Protocol Wealth does not provide legal or tax advice, nor does it prepare legal (e.g., wills, trusts) or tax documents. Protocol Wealth will coordinate with the Client's chosen attorneys and accountants at their direction.
Scope Limitation — No Ongoing Supervision, Monitoring, or Reporting (Non-Discretionary)
Except for the Phase II monitoring expressly described above and only to the extent elected, the planning services are point-in-time and non-discretionary: Protocol Wealth has no ongoing duty to supervise, continuously monitor, or report on the Client's accounts, held-away assets, or investments, and no obligation to update the plan, issue account statements or performance reports, or alert the Client to market or account developments, absent a separate written engagement or the elected Phase II monitoring. The Client is responsible for implementing, maintaining, and monitoring the plan and for the custody, execution, and outcomes of any account the Client self-manages. This scope limitation does not reduce the fiduciary duty of care Protocol Wealth owes with respect to the advice it does render.
Planning fees
(1) For Stand-Alone Planning Clients. For Clients engaging Protocol Wealth solely for the services described in this section, the fee is the fixed planning fee stated in Exhibit A (Fee Schedule) of the signed Client Advisory Agreement, billed as Exhibit A provides.
(2) For Integrated Wealth Management Clients. For Clients whose signed Client Advisory Agreement marks an investment-management service as INCLUDED, the Financial Planning Services described herein may be included on a complimentary basis if the Client's assets under management (AUM) meet a minimum threshold specified by the Adviser.
B. Traditional asset management
Grant of Discretionary Authority
For this section, "Traditional Assets" means marketable securities held at a qualified custodian, such as equities, exchange-traded funds, mutual funds, and investment-grade fixed income; it excludes digital assets, private funds, annuities, insurance products, real estate, collectibles, and other non-marketable or held-away assets unless expressly agreed upon in writing.
Client grants Protocol Wealth ongoing discretionary authority to manage Traditional Assets in the Account(s), including the authority to buy, sell, and exchange securities; determine target and tactical asset allocations; and select or remove securities and funds, all without prior consultation on each transaction. Protocol Wealth may also deduct advisory fees from the Account(s) as authorized in this Agreement. Protocol Wealth will develop and implement an investment strategy designed to align with the Client's objectives and risk profile as established in the client-specific scope recorded in the signed Client Advisory Agreement and the Investment Policy Statement (IPS). Services include Investment Strategy Development, Portfolio Construction, Ongoing Management, a Rebalancing Policy, and Performance Reporting, as further described below.
Investment Policy Statement; Client-Imposed Restrictions
Investment Strategy Development. Creation and periodic refinement of a tailored IPS that outlines the Client's objectives, time horizon, liquidity needs, constraints, and risk tolerance, and identifies any reasonable investment restrictions approved by Protocol Wealth. Portfolio Construction: Selection of an appropriate asset allocation and the underlying securities and/or funds (which may include individual stocks, bonds, ETFs, and mutual funds) to implement the IPS, with due consideration of costs, taxes, and trading efficiency. Ongoing Management: Ongoing monitoring of the portfolio and discretionary adjustments Protocol Wealth deems appropriate in response to market conditions, taxable events, product changes, or changes in the Client's circumstances communicated to Protocol Wealth.
Client Investment Restrictions. The Client reserves the right to impose reasonable restrictions on investment activities. Any specific prohibitions, preferences, or constraints will be mutually agreed upon and formally documented in the Investment Policy Statement (IPS), which will govern all investment decisions for the portfolio.
Rebalancing and Allocation Bands
Portfolios will be reviewed regularly and rebalanced as needed to adhere to the target asset allocation defined in the IPS. Unless otherwise specified in the IPS, Protocol Wealth generally rebalances when asset class weights breach tolerance bands of approximately 20% of their target weight (e.g., a 10% target rebalanced near 8% or 12%) or on at least an annual basis, taking into account trading costs and tax considerations.
Performance Reporting
Protocol Wealth will provide periodic performance reporting, typically quarterly, which should be reviewed alongside and reconciled to the official account statements and tax documents provided by the Custodian. Performance reports are for informational purposes and may use selected benchmarks reasonably aligned with the portfolio's asset mix; benchmarks are unmanaged and for comparison only.
Brokerage and Custody of Assets
All Client assets under this section shall be held in the Client's name at a qualified independent custodian (e.g., Altruist or Schwab) (the Custodian). The Custodian is responsible for trade settlement, safekeeping, and the issuance of official account statements and tax forms. Other than the limited custody that arises where the Client has authorized direct deduction of advisory fees, Protocol Wealth does not maintain custody of Client assets. The Client authorizes Protocol Wealth to issue trade instructions to the Custodian and to deduct advisory fees as disclosed in this Agreement. Protocol Wealth may, when it reasonably believes it is in the Client's best interest, execute transactions through or "trade away" to another broker, which may result in additional commissions or fees as described in Protocol Wealth's Form ADV.
Options Trading
Options strategies will be used only if explicitly authorized by the Client, approved by the Custodian for the relevant account, and deemed suitable by Protocol Wealth. The Client acknowledges receipt of the "Characteristics and Risks of Standardized Options" (ODD) (the current OCC booklet, delivered separately before any options activity). Unless otherwise agreed in writing, Protocol Wealth restricts options activity to conservative, income-generating, or hedging strategies (e.g., covered calls or cash-secured puts) and will not employ uncovered or speculative strategies. Options trading may require margin or specific collateral; margin amplifies gains and losses and could lead to losing more than the amount invested. The Client remains responsible for any margin agreements with the Custodian and for understanding the risks and costs associated with options and margin. This section applies only to standardized, exchange-traded options on traditional securities; for Digital Asset derivatives, see section E (Options strategies) below.
Proxy Voting and Corporate Actions
The Client retains exclusive responsibility for all proxy voting decisions related to securities held in the Account(s). Protocol Wealth will not vote proxies on the Client's behalf. Protocol Wealth may, upon request, provide general information regarding proxy matters as an accommodation. The Client is responsible for responding to corporate actions, class action claims, and reorganization decisions; Protocol Wealth may provide information or assistance upon request but does not undertake to monitor or act on such matters.
Trading and Allocation Practices; Best Execution
Protocol Wealth may aggregate orders for multiple clients when it believes aggregation is likely to result in an overall economic benefit and will allocate aggregated trades in a fair and equitable manner over time consistent with Protocol Wealth's trade allocation policies. Protocol Wealth seeks best execution, considering total cost or proceeds, execution quality, and other factors. Trade errors, if any, will be handled in accordance with Protocol Wealth's trade error policy, with the objective that the Client will be made whole and not bear losses caused by Protocol Wealth's error.
Taxes and Coordination with Advisors
Protocol Wealth's services do not include preparing tax returns or providing legal or tax advice. Protocol Wealth may consider tax implications in making investment decisions (for example, loss harvesting, asset location, or gain realization), but the Client remains responsible for all tax consequences of transactions. The Client should consult with their tax advisor; upon the Client's request, Protocol Wealth will reasonably coordinate with the Client's CPA or attorney.
Client Responsibilities; No Guarantee
The Client agrees to provide complete and accurate information and notify Protocol Wealth promptly of material changes to circumstances, goals, or constraints. Protocol Wealth's management relies on the information the Client provides, and data feeds authorized by the Client. The Client should carefully review Custodian statements and promptly advise Protocol Wealth of any discrepancies.
No Guarantee. Investment recommendations and results are subject to market risk, including loss of principal. Past performance does not guarantee future results. Targets, forecasts, or forward-looking statements are based on assumptions and are not guarantees of future performance.
C. Digital-asset management
Definitions
For purposes of this section: "Digital Assets" means cryptographically secured fungible or non-fungible tokens recorded on a distributed ledger (including, for example, Bitcoin, Ether, and ERC-20 tokens), but excludes any asset Protocol Wealth designates as unsupported. "Qualified Custodian" means a custodian that meets applicable regulatory standards for safeguarding client assets. "MPC Wallet" means a non-custodial, multi-party computation wallet solution with policy-based controls. "OTC Derivatives" means bilateral, over-the-counter financial contracts, including but not limited to options, perpetuals, and swaps, where the underlying asset is a Digital Asset and the contract is not cleared through a central clearinghouse. "ECP" means an "Eligible Contract Participant" as defined in Section 1a(18) of the Commodity Exchange Act.
Grant of Discretionary Authority — Digital Assets
The Client grants Protocol Wealth ongoing discretionary authority to manage Digital Assets within the Account(s), including the authority to buy, sell, exchange, and otherwise transact in supported Digital Assets; to participate in onchain activities as described below; and to transfer assets among Client-approved venues and accounts, all without prior consultation for each transaction, subject to the controls and limitations in this section and the Client's written restrictions. This transfer authority does not extend to the Client's self-custody wallet, from which Protocol Wealth cannot move assets: the Client is the sole signer, and Protocol Wealth may prepare and recommend a transfer but the Client authorizes and signs it. Protocol Wealth will manage the Account(s) to align with the Client's objectives and risk profile as established in the client-specific scope recorded in the signed Client Advisory Agreement and any applicable investment policy.
Portfolio Management. Discretionary buying, selling, exchanging, and holding of Digital Assets on supported trading venues or through the Custodian, considering liquidity, venue quality, slippage, spreads, and costs.
On-Chain Activity (Staking, DeFi, Liquidity Provision)
Discretionary participation in onchain activities that Protocol Wealth deems reasonably appropriate and operationally supportable, which may include staking (custodial or native), delegated staking, re-staking, protocol-native lending/borrowing, providing liquidity, and interacting with decentralized protocols (DeFi). Protocol Wealth will evaluate material smart-contract, counterparty, slashing, validator, bridge, and protocol risks; however, the Client acknowledges such risks cannot be eliminated.
Asset Transfers
Transfers among Client-approved Qualified Custodians and MPC Wallets to implement strategy, rebalance, fund onchain activity, or manage operational risk. Transfers will be limited to whitelisted addresses and subject to wallet policy controls.
Custody Framework
(1) Custodians and Wallets. Protocol Wealth will utilize a combination of Qualified Custodians (e.g., Anchorage Digital, BitGo) and Client-owned self-custody wallets, as authorized by the Client. Other than the limited custody that arises where the Client has authorized direct deduction of advisory fees, Protocol Wealth does not maintain custody of Digital Assets, and Protocol Wealth does not have unilateral control of private keys. The Custodian is responsible for safekeeping, settlement, and the issuance of official statements for custodied assets.
(2) Security and Key Management. The Client authorizes Protocol Wealth to assist in configuring wallet policy controls (such as approval requirements, whitelists, and velocity limits) within the Client's wallet and to support access to any key-backup or recovery service the Client elects, which is established in the Client's name with the recovery material delivered to the Client and not to Protocol Wealth. Protocol Wealth does not guarantee the performance, security, or availability of any third-party provider and is not liable for losses caused by third-party failures or the Client's failure to protect credentials, devices, or recovery materials.
(3) Authorizations. Transaction authorization thresholds and approval workflows for MPC Wallets will be documented in writing. Protocol Wealth does not effect transfers from the Client's self-custody wallet; the Client authorizes and signs each transfer.
Client Investment Restrictions
The Client may impose reasonable written restrictions (for example, prohibitions on specific assets, chains, protocols, leverage, or derivatives). Protocol Wealth must accept any restriction in writing before it becomes effective. Restrictions may cause the portfolio to deviate from targets, increase costs or taxes, limit participation in onchain opportunities, or materially impact performance.
Options, Leverage, and Derivatives
Unless expressly authorized in writing by the Client, approved by the Custodian or venue, and determined suitable by Protocol Wealth, Protocol Wealth will not employ margin, leverage, perpetuals, futures, options, or other derivatives referencing Digital Assets. Furthermore, unless OTC Derivatives is marked INCLUDED in Exhibit A (Elected Services) of the signed Client Advisory Agreement and the Client's eligible-contract-participant status has been verified, Protocol Wealth is strictly prohibited from employing margin, leverage, or derivatives in the management of Digital Assets. Any unauthorized use of these instruments shall be considered a violation of this Agreement.
Valuation, Reporting, and Benchmarks
(1) Valuation. Portfolio values for Digital Assets will be based on pricing sources Protocol Wealth reasonably selects (for example, the Custodian's marks, consolidated vendor pricing, or venue mid-prices). Prices may vary across venues, may be unavailable during outages, and are subject to rapid change.
(2) Reporting. Protocol Wealth will provide periodic performance reporting (typically quarterly) for information purposes. The Client should review Protocol Wealth's reports alongside and reconcile them to official custodian statements for custodied assets and to MPC Wallet transaction records.
(3) Benchmarks. If used, benchmarks are unmanaged and provided solely for comparison; they may not reflect onchain activity or illiquidity.
Rewards, Fees, and Network Costs
(1) Rewards. Staking rewards, airdropped tokens, fee rebates, and protocol incentives attributable to the Account(s) will accrue to the Client, net of any fees, slashing penalties, validator commissions, custodian charges, or network fees, unless otherwise agreed in writing.
(2) Network Fees. Network fees (gas), custodian fees, and reasonable third-party charges are borne by the Client and are paid from the account or wallet in which the transaction occurs. Where assets are in the Client's self-custody wallet, those fees are paid from that wallet when the Client authorizes the transaction. High network congestion may result in elevated fees or delayed execution.
Forks, Airdrops, and Protocol Events
In the event of a network fork, token migration, re-denomination, airdrop, chain reorganization, or similar event, Protocol Wealth will exercise reasonable discretion regarding whether and how to support, claim, or dispose of resulting assets, considering security, legality, custody support, and operational feasibility. Protocol Wealth is not required to support assets or chains it deems unsupported or impracticable. Unclaimed assets may expire or become worthless.
Trading, Venues, and Best Execution
Digital Asset trading may occur through custodial brokers, OTC counterparties, or on-venue DEX/CEX platforms. "Best execution" is assessed holistically, considering price, liquidity, fees, slippage, settlement risk, and operational risk; venue outages and fragmentation may impair execution quality. Protocol Wealth may aggregate orders when appropriate and will allocate fills fairly over time consistent with its allocation policies. Trade errors, if any, will be handled under Protocol Wealth's trade error policy with the objective that the Client will be made whole for losses caused by Protocol Wealth's error.
Compliance; Sanctions; Travel Rule
Protocol Wealth and its service providers may be required to collect, verify, and share Client and transaction information to comply with anti-money laundering (AML), counter-terrorist financing (CTF), sanctions screening (e.g., OFAC), and "Travel Rule" requirements. If Protocol Wealth or a service provider reasonably believes a transaction may violate applicable law or policy, execution may be delayed, blocked, or refused without liability to Protocol Wealth.
Taxes and Coordination with Advisors
Protocol Wealth may consider tax implications (for example, gain/loss realization, lot selection) but does not prepare tax returns or provide tax or legal advice. The Client is responsible for all tax consequences and for consulting their tax advisor. Upon request, Protocol Wealth will reasonably coordinate with the Client's CPA or attorney.
Acknowledgment of Risk
The Client acknowledges that Digital Assets and onchain activities involve unique, substantial, and speculative risks, including but not limited to smart-contract exploits; validator/slashing risk; bridge, oracle, and protocol failures; exchange and counterparty risk; hacking, theft, or loss of private keys; chain halts or reorganizations; regulatory changes; extreme volatility; illiquidity; and loss of principal. By selecting this service, the Client confirms they have received, read, and understood the Digital Asset Risk Disclosures in the digital-asset risk disclosures published at protocolwealthllc.com/disclosures.
Digital Asset Governance and Estate Planning
(1) Governance. The Client retains sole responsibility for voting or otherwise exercising any governance rights associated with Digital Assets. Protocol Wealth will not exercise governance rights on the Client's behalf but may provide non-binding information upon request.
(2) Estate Planning. The Client is solely responsible for establishing and maintaining an effective succession plan so fiduciaries can access necessary credentials and recovery materials. Protocol Wealth cannot recover assets if credentials, seeds, or recovery shares are lost or inaccessible.
Client Responsibilities; Service Availability; No Guarantee
The Client agrees to safeguard credentials and devices; maintain current contact information; promptly notify Protocol Wealth of material changes to circumstances, constraints, or authorized wallets; and review custodian statements and wallet activity for accuracy. Protocol Wealth's services rely on information the Client provides and on third-party data feeds authorized by the Client.
Service Availability. Access to custodians, wallets, protocols, or networks may be limited or unavailable due to maintenance, congestion, or outages, which may delay transactions, valuation, or reporting. Protocol Wealth is not responsible for losses or delays attributable to such third-party or network events.
No Guarantee. Targets, forecasts, yield rates, and forward-looking statements are based on assumptions and are not guarantees of future results. Participation in staking, lending, liquidity provision, or other onchain activities may result in the loss of principal and rewards, including through slashing, smart-contract failure, or market movement.
D. Qualified custody
Qualified Custodian Appointment
All securities and other traditional assets must be held in an account at a qualified independent custodian ("Custodian"), such as Altruist or Schwab, titled in the Client's name. For Digital Assets held in qualified custody, Protocol Wealth will utilize Qualified Custodians (e.g., Anchorage Digital, BitGo) as authorized by the Client. Other than the limited custody that arises where the Client has authorized direct deduction of advisory fees, Protocol Wealth does not maintain custody of Client assets, and Protocol Wealth does not have unilateral control of private keys. Protocol Wealth is authorized to instruct the Custodian to carry out transactions for the Client. Subject to and without limiting Protocol Wealth's fiduciary duty to select and monitor the Custodian with reasonable care, Protocol Wealth is not liable for the independent acts or omissions of the Custodian that are beyond Protocol Wealth's reasonable control.
Custodial Account Control and Reporting
The Custodian is responsible for trade settlement, safekeeping, and the issuance of official account statements and tax forms, which serve as the definitive record for the Account. The Client authorizes Protocol Wealth to issue trade instructions to the Custodian and to deduct advisory fees as disclosed in this Agreement. The Client should review Protocol Wealth's reports alongside and reconcile them to the official custodian statements, and promptly advise Protocol Wealth of any discrepancies.
Digital-Asset Qualified-Custody Risk
The Client understands and agrees that custody of Digital Assets involves unique and significant risks. While some Digital Assets may be held with a specialized Digital Asset Qualified Custodian ("QC") such as Anchorage Digital or BitGo, Protocol Wealth does not guarantee the performance, security, or availability of any third-party custodian and is not liable for losses caused by the failure, breach, or malfunction of any third-party QC. For assets held directly at a Qualified Custodian, succession and recovery are governed exclusively by the policies and procedures of that specific institution.
E. Options strategies
Options Trading Authorization
Trading in options, futures, and options on futures, including those related to digital assets ("Derivatives Products"), is highly speculative and carries significant risk. It is suitable only for financially experienced clients who have a high-risk tolerance and are prepared to accept substantial losses, which could exceed their initial investment. The client might lose more than the amount invested. By marking Listed Options or OTC Derivatives as INCLUDED in Exhibit A (Elected Services) of the signed Client Advisory Agreement, the Client represents that they have completed the "Investment Experience" section of the Client Profile, affirm a high tolerance for risk suitable for Derivatives Products, and are prepared for the possibility of significant financial loss. All trading in Derivatives Products will be conducted on a Discretionary or Non-Discretionary basis as recorded in Exhibit A (Per-Client Election Summary) of the signed Client Advisory Agreement.
Receipt of Options Disclosure Document (ODD)
The Client acknowledges they have been provided with and are encouraged to read the official "Characteristics and Risks of Standardized Options" disclosure document (the "ODD") from the Options Clearing Corporation (available at theocc.com/company-information/documents-and-archives/options-disclosure-document), as well as any similar risk disclosures for futures trading. The Client has read and understands the summary of key risks outlined in the OCC 'Characteristics and Risks of Standardized Options' booklet, including the risk of magnified losses (leverage), total loss of premium, unlimited loss on uncovered positions, time decay (theta), futures and margin risk, and the amplified risks of crypto derivatives.
Conservative-Strategy Default
Unless otherwise agreed in writing, Protocol Wealth restricts options activity to conservative, income-generating, or hedging strategies (e.g., covered calls or cash-secured puts) and will not employ uncovered or speculative strategies. Options strategies will be used only if explicitly authorized by the Client, approved by the Custodian for the relevant account, and deemed suitable by Protocol Wealth. Options trading may require margin or specific collateral; margin amplifies gains and losses and could lead to losing more than the amount invested. The Client remains responsible for any margin agreements with the Custodian.
OTC Derivatives Election — ECP Gating
Protocol Wealth manages Over-the-Counter ("OTC") derivatives — including crypto-linked options, swaps, and borrow/lend, via third-party platforms such as FalconX — only where OTC Derivatives is marked INCLUDED in Exhibit A (Elected Services) of the signed Client Advisory Agreement, the applicable strategy schedule and provider approvals are in place, and the Client's eligible-contract-participant status has been verified. Acknowledging a risk disclosure is not an election and does not authorize the service. Where the service is active, the Client owes the associated management fee (Managed Options Strategies fee schedule, the fee table in Exhibit A (Fee Schedule) of the signed Client Advisory Agreement).
Agency Relationship: The Client acknowledges that they have executed or will execute a separate agreement with the platform provider (e.g., FalconX) as the Direct Counterparty. Protocol Wealth acts solely as the Client's Agent and Investment Advisor with limited power of attorney to execute trades. Protocol Wealth is not a party to the contract between the Client and the platform and does not guarantee the performance of the platform or the counterparty.
Eligible Contract Participant (ECP) Status: The Client represents and warrants that they are an Eligible Contract Participant as defined in Section 1a(18) of the Commodity Exchange Act, and agrees to notify Protocol Wealth immediately if they no longer meet ECP financial thresholds. Unless OTC Derivatives is marked INCLUDED in Exhibit A (Elected Services) of the signed Client Advisory Agreement and the Client's eligible-contract-participant status has been verified, Protocol Wealth is strictly prohibited from employing margin, leverage, or derivatives in the management of Digital Assets.
Counterparty and Credit Risk: Unlike exchange-traded options, OTC derivatives are not guaranteed by a clearinghouse (e.g., OCC). The Client is exposed to the credit risk of the platform (FalconX or its affiliates). If the platform becomes insolvent, the Client may lose all collateral and unrealized gains. Assets held for crypto derivatives, even in a tri-party custodial account, are generally not protected by SIPC. Protocol Wealth's fiduciary duty applies to the strategy and execution of these trades, but Protocol Wealth does not guarantee the solvency of the Custodian or the Swap Dealer.
Protocol Wealth, LLC is an investment adviser registered with the U.S. Securities and Exchange Commission. Registration does not imply a certain level of skill or training. Investing involves risk, including possible loss of principal.
Protocol Wealth, LLC — General Terms and Conditions, effective August 16, 2026.