Complaint Policy

Overview

Sprouter takes customer complaints seriously. This Complaint Policy explains how to file a complaint, the timelines we operate against, the special procedures that apply to suspected errors on Sprouter Finance accounts under Regulation E, and the external regulators you may contact if you are not satisfied with how Sprouter has handled your complaint.

Filing a complaint with Sprouter does not waive any of your rights under federal or state law, and does not require you to wait before contacting an external regulator.

How to File a Complaint

You can submit a complaint through any of the channels below. To help us resolve your complaint as quickly as possible, please include:

• Your full name and the email or username on your Sprouter account.
• A clear description of the issue, including the date(s) it occurred.
• Any relevant transaction IDs, event IDs, screenshots, or other supporting documentation.
• The outcome you are seeking.
• The best way to reach you for follow-up.

Channels

• Email: support@getsprouter.com — please include "Complaint" in the subject line.
• Phone: 612-695-6849
• Postal mail: Sprouter LLC, Attn: Complaints, 3104 East Camelback Road #852, Phoenix, AZ 85016
• In-app: the Help & Support section of the Sprouter app routes complaints to the same review queue.

Acknowledgment & Resolution Timelines

• Acknowledgment: Sprouter will acknowledge receipt of every written complaint within 2 business days of receiving it.
• Initial review: A Tier 2 specialist or higher will review the complaint and either resolve it or assign it for further investigation.
• Target resolution: Sprouter aims to resolve general complaints within 10 business days of receipt. If a complaint requires more time — for example because it involves a third-party banking partner, processor, or external regulator — Sprouter will provide a written status update before the 10-business-day target lapses and will continue to provide updates at least every 10 business days until the matter is closed.
• Written outcome: Sprouter will provide a written response describing the outcome of the review and the reasoning behind it.

Different and stricter timelines apply to suspected electronic-fund-transfer errors under Regulation E, described below.

Reg E — EFT Error Resolution

If a complaint relates to a suspected error on an electronic fund transfer (EFT) involving your Sprouter Finance account — for example, an unauthorized transaction, an incorrect amount, a missing transaction, or a computational error on a statement — additional consumer-protection rules apply under the Electronic Fund Transfer Act and Regulation E (12 C.F.R. § 1005.11).

Notice Window

You must notify Sprouter of a suspected EFT error no later than 60 days after the statement on which the suspected error first appeared was made available to you. Notice may be given orally or in writing, and Sprouter may request that you confirm an oral notice in writing within 10 business days.

10-Business-Day Investigation

After receiving notice of a suspected error, Sprouter (working with our banking partners) will investigate and determine whether an error occurred within 10 business days. Sprouter will report the results of the investigation to you within 3 business days after completing the investigation. If an error is confirmed, Sprouter will correct the error, including crediting any interest where applicable, within 1 business day of determining that an error occurred.

45-Day Extended Investigation & Provisional Credit

If Sprouter is unable to complete the investigation within 10 business days, the investigation may be extended up to 45 calendar days from the date Sprouter received notice of the suspected error. If Sprouter elects to take longer than 10 business days, Sprouter will provisionally credit your account in the amount of the suspected error (including interest where applicable) within 10 business days of receiving the notice, so that you have use of the funds during the investigation.

90-Day Window for New Accounts, Foreign-Initiated, and Point-of-Sale Transfers

For errors involving (a) transactions on a Sprouter Finance account opened within the last 30 days, (b) transactions initiated outside the United States, or (c) point-of-sale debit-card transactions, the investigation period may be extended to 90 calendar days, and the provisional-credit deadline may be extended to 20 business days, all consistent with Regulation E.

If No Error Is Found

If Sprouter determines that no error occurred, Sprouter will provide you with a written explanation within 3 business days after completing the investigation. You may request copies of the documents that Sprouter relied on in reaching its determination, and Sprouter will provide them. If a provisional credit was issued, Sprouter will give you at least 5 business days' notice before debiting the provisional-credit amount from your account.

Appeals & Management Review

If you are not satisfied with Sprouter's response to your complaint, you may request a formal appeal by replying to the written outcome and asking for management review. Appeals are escalated to Tier 3 (see the Customer Services Policy), which includes a member of Sprouter's leadership and, where appropriate, our compliance counsel.

• Appeals are acknowledged within 2 business days of receipt.
• Tier 3 review concludes with a final written response within 15 business days of the appeal being received, unless the matter requires additional time, in which case Sprouter will provide an interim status update.
• The Tier 3 written response describes the outcome of the appeal, the reasoning, and any further options available to you, including the external regulator contacts listed below.

External Regulators

You always have the right to contact an external regulator at any time, including before, during, or after Sprouter's internal complaint process. Sprouter will not retaliate against any customer who files a complaint with a regulator.

Federal

• Consumer Financial Protection Bureau (CFPB)
  Online: consumerfinance.gov/complaint
  Phone: 1-855-411-2372 (toll free)
  Mail: Consumer Financial Protection Bureau, P.O. Box 27170, Washington, DC 20038

State

You may also contact your state Attorney General or your state banking / financial-services regulator. Contact information is available from the National Association of Attorneys General directory and the Conference of State Bank Supervisors. State-specific contacts for Texas and New York are listed in the next section.

Money Transmission Licensing

Money-transmission services on Sprouter Finance accounts are provided by Priority, directly or through its subsidiary Finxera, Inc. (NMLS #1168701). Finxera's state-by-state money-transmitter licensing details are published at finxera.com/licensing and prioritycommerce.com/licensing.

State-Specific Disclosures

Texas Residents

If you are a Texas resident and have a complaint, you should first contact Sprouter using the channels in this policy. If Sprouter has not been able to resolve your complaint after 60 days, you may also file a complaint with the Texas Department of Banking, which licenses Finxera, Inc., as a money transmitter in Texas:

New York Residents

If you are a New York resident, you may file a complaint with the New York State Department of Financial Services:

Customers in other states may contact their state Attorney General or state banking regulator. Sprouter and our banking partners hold the licenses required to operate in your state; please contact us if you would like a copy of the licensing details applicable to your jurisdiction.

Recordkeeping

Sprouter retains records of every complaint — including the original complaint, supporting documentation, internal investigation notes, and the written outcome — for at least five (5) years from the date the complaint is closed, consistent with applicable financial-services recordkeeping requirements. Records are stored on secure systems and are made available to regulators on request.

Updates to This Policy

We may update this policy from time to time. Material changes will be communicated by email or in-product notice and reflected in the "Last Updated" date at the top of this page. Continued use of the Application after the effective date of any change constitutes your acceptance of the updated policy.

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