Alto Custodian Account Agreement

Custodian Account Agreement

Updated: November 14, 2025

b. I understand and agree the Administrator and Custodian may release information about me to others as permitted above or in the Administrator’s or Custodian’s Privacy Policy, or as I, a Financial Advisor or a representative I have authorized in writing, may direct, or otherwise to the extent the Administrator or Custodian is required by law or other regulatory authority. c. I further understand the Internal Revenue Service does not require my consent to any provision of this document other than the certification required to avoid backup withholding.

a. Until such time as I change or revoke the designation, I hereby instruct the Administrator and Custodian to follow the investment directions which I provide, or a Financial Advisor provides to Administrator in investing and reinvesting the principal and interest for the above-referenced Account or other custodial account for which Administrator serves as record keeper. Instructions must be in writing, and written direction shall be construed so as to include electronic signature. Administrator has the right to refuse to fund or process investments that are not administratively feasible and/or would place an undue financial or administrative burden on the Administrator.

b. The account is established for the exclusive benefit of the Account Holder or his/her beneficiaries. In taking action based on this authorization Custodian and Administrator may act solely on the written instruction, designation or representation of the Account Holder or a Financial Advisor. I understand that, to the extent the Administrator enables me to grant access or control of my Account to third parties (including but not limited to a Financial Advisor or other representative), such access or control may be conditioned upon the execution by me and such third parties of such further instruments, documents or terms of service as the Administrator may require. I expressly certify that I take complete responsibility for the funding of my Account, the investments made by and for my Account, and the securities, instrument(s) or property purchased, traded or held in my Account. I agree to indemnify and hold harmless Custodian and Administrator, and their respective agents or assigns, for any and all claims, actions, proceedings, damages, judgments, liabilities, costs, and expenses, including attorneys’ fees arising from or in connection with this Agreement. Custodian and/or Administrator may deduct from the Account any amounts to which they are entitled to reimbursement under the foregoing hold harmless provision. Custodian and Administrator have no responsibility or fiduciary role whatsoever related to or in connection with the Account in taking any action related to any purchase, sale or exchange instructed by the Account Holder or the Account Holder’s agents, representatives or attorneys-in-fact, including but not limited to suitability of any investment or transaction, compliance with any state or federal law or regulation, income or expense to the Account, or preservation of Account capital or income.

c. In executing transfers, it is understood and agreed that I will not hold Custodian and/or Administrator liable or responsible for anything done or omitted in the administration, custody or investments of the Account or any other account of mine prior to the date they shall complete their respective acceptance as successor Custodian and Administrator and shall be in possession of all of the assets transferred, nor shall they have any duty or responsibility to inquire into or take any action with respect to any acts performed by any prior or other custodian or administrator.

d. While requesting distributions from an account that may be reported on Form 1099-R, the Administrator may establish controls and limitations on account holder requests to withdraw funds from a newly established individual retirement account for a period of sixty (60) days upon account creation. The Administrator may decline to process any distribution made within the first 60 days of account creation, except for any request to revoke an account within the first seven (7) days of establishing an account pursuant to Treasury Rule 1.408-6(d)(4)(ii)(A)(2) and sections 8.03 of Form 5305-A and 9.03 of Form 5305-RA, as the case may be. Administrator will not make any attempt to notify the account holder of the expiration of the 60-day period, and account holder shall ensure that any distribution request made after such expiration is initiated in a manner that suits its needs.

a. I acknowledge that I have received, reviewed, understand, and agree to the Administrator’s posted fee schedule. I agree to be bound by those pricing and payment terms and conditions as are currently in effect and as they may be amended from time to time.

b. I agree to pay, and I authorize the payment of Administrator’s and Custodian’s service fees and charges (“Fees”) at the rates and intervals and upon the terms and conditions set forth in the fee schedule made available to me or to a Financial Advisor by the Administrator (including as posted on its website), and to pay for any extraordinary services or requests not included. Administrator’s Fees may include, without limitation, annual, monthly or per-transaction fees, payable in fixed amounts, in tiered amounts or percentage rates based on account or transaction sizes, or from fees charged by third party Investment Providers (as defined below). Fees are payable in full in advance (unless otherwise expressly provided in the terms and conditions), or in connection with executing Account Holder instructions and performing services and are non-refundable. I understand that annual and other billing periods may run from the date I first register for the applicable service or calendar periods in Administrator’s discretion. Undirected cash in the Account shall be placed by the Custodian in FDIC-insured banks. I agree the Administrator and Custodian may utilize the principal amount of undirected cash in the Account or liquidate Account assets to pay Account fees if the credit card or other acceptable form of payment provided by me or a Financial Advisor is or becomes invalid and another valid means of payment is not provided promptly upon request. If any payment is not received by the Administrator within 15 days after it becomes due, then upon five days’ notice to the email address associated with my account, without prejudice to any other rights they may have, Administrator and Custodian may close the Account. Administrator and Custodian shall bear no responsibility for any adverse tax consequences or other liabilities or obligations resulting from the performance of their duties or exercise of their rights, including, without limitation, from any liquidation or distribution of assets in the Account resulting from nonpayment of fees. Administrator reserves the right to sell any past due receivables to a collection and credit reporting agency.

c. Administrator reserves the right to set account minimum balance requirements at its sole discretion.

d. Administrator further reserves the right to modify Fees and charge any additional fee after giving Account Holder and/or Financial Advisor reasonable notice. All changes to the fee schedule will be posted at the Administrator’s website at www.AltoIRA.com or within the fee schedule posted within the AltoIRA platform. I acknowledge and agree this fee disclosure is part of my Agreement with the Administrator.

I understand and agree that the Administrator and Custodian do not recommend any investments, even if their affiliates licensed to do so may make such recommendations, and I remain solely responsible for the selection and execution of any investment I direct, or a Financial Advisor directs the Administrator and Custodian to make for the benefit of my Account. Without limiting the generality of the foregoing, Administrator and Custodian shall not be required to negotiate a compensation arrangement with any Investment Provider that produces a best execution price for the Account. I waive any and all conflicts of interest the Administrator or Custodian may have or that may arise in connection with any such compensation, service or other arrangements between the Administrator or Custodian or their affiliates and any Investment Providers.

b. Cash maintained by the Administrator and Custodian are held in pooled accounts at one or more banks insured by the FDIC. FDIC pass-through insurance protects funds held on behalf of an account holder against the risk of loss should an FDIC-insured bank(s) where funds are held fail.

c. Crypto assets, virtual currency, cryptocurrency, or other digital assets are not insured by the FDIC, may lose value, are not deposits or other obligations of the Bank, or Pinnacle Bank and are not guaranteed by the Bank or Pinnacle Bank. Virtual Currency is not legal tender, is not backed by the government, and accounts and value balances are not subject to Securities Investor Protection Corporation protections. All funds transferred to Coinbase, Inc. (Coinbase) in connection with an account holder’s CryptoIRA account and held in cash at Coinbase may be maintained at one or more banks insured by the FDIC, at which Coinbase may deposit customer funds. As of May 2023, Coinbase may deposit customer funds with one of the following institutions: (i) JPMorgan Chase; (ii) Cross River Bank; and (iii) Pathward (previously known as MetaBank). Should cash transferred to Coinbase exceed applicable $250,000 insurance deposit limits, then Coinbase may sweep excess deposits to JPMorgan and State Street U.S. government money market funds (tickets OGVXX and GVMXX). Click here for more information regarding Coinbase’s cash management practices. Administrator and Custodian may, from time to time, transfer undirected cash held at Coinbase to and from an omnibus custodial account for the benefit of AltoIRA accounts maintained by the Administrator and Custodian, and held at a bank referenced under Section 13(a) herein.

b. I understand that the FAA governs this Arbitration Provision, which evidences a transaction involving interstate commerce.

c. I understand that, as used in this Arbitration Provision, the terms Custodian and Administrator include their (i) directors, officers, members, managers, employees, or agents in their capacity as such or otherwise and (ii) their successors and assigns. Each of the entities and/or individuals listed in this paragraph can enforce the Arbitration Provision.

d. I agree that, upon the request of any party, whether made before or after the institution of any legal proceeding, all claims and disputes of every type and matter, past present or future, which may arise between the Account Holder and the Custodian or between the Account Holder and the Administrator shall be submitted to individual, final and binding arbitration. I understand this Arbitration Provision is intended to be interpreted as broadly as the FAA allows and includes, but is not limited to, claims based on any legal theory whatsoever, including negligence, breach of contract, tort, fraud, misrepresentation, trespass, the common law, or any statute, regulation, or ordinance. I further agree that any and all disputes relating to the interpretation, applicability, enforceability, scope, waiver or formation of this Agreement, including but not limited to any contention that all or any part of this Agreement is void or voidable, is an issue to be decided by the panel of arbitrators. I understand that this Arbitration Provision shall govern any disputes involving Account Holder and the Custodian or between the Account Holder and the Administrator, as the case may be, notwithstanding any provisions, including and without limitation venue or arbitration provisions, contained in any agreement signed by Custodian in its custodial capacity.

e. Class Action Waiver: I understand that if I elect to arbitrate a claim that I may not participate in a class action in court or in class-wide arbitration, either as a plaintiff, defendant or class member. I understand that I may not act as a private attorney general in court or in arbitration and that claims asserted by me may not be joined or consolidated with claims brought by any other person. Further, I understand that the arbitrator(s) shall have no power or authority to conduct a class-wide arbitration, private attorney general arbitration or multiple-party arbitration. I understand that in the event a final judicial determination is made that the Class Action Waiver is unenforceable and that a class, mass, or representative action may proceed notwithstanding the existence of this Agreement, the Arbitrator is nevertheless without authority to preside over a class, mass, or representative action, and any such action must be brought in a court of competent jurisdiction—not in arbitration, but the portion of the Class Action Waiver that is enforceable shall be enforced in arbitration.

f. Mutuality: I understand that any restriction I have under this Arbitration Provision applies equally to limit the rights of the Custodian and Administrator to pursue the same claims, including but not limited to the Class Action Waiver,

g. Arbitration Rejection: If I do not want this Arbitration Provision to apply, I understand that I may reject it by mailing a written rejection notice which gives my name and account number and contains a statement that I reject the Arbitration Provision of this Agreement. The rejection notice must be sent by me to: Alto Trust Co., Capitol View Block E, 500 11th Avenue North, Suite 790, Nashville TN 37203. I understand that a rejection notice is only effective if it is signed by me, and it is received within 30 calendar days after the date I was first provided with this Agreement and written notice providing me with a right to reject this Arbitration Provision. My rejection of this Arbitration Provision will not affect any other provision of this Agreement or my ability to obtain other services from the Custodian and/or Administrator.

h. Small Claims Court Option: Notwithstanding the foregoing, I understand that I have the right to file an individual action in small claims court if it is within the jurisdiction of the small claims court and remains in that court. I understand that the Custodian and Administrator in such a small claims court action may not elect to have the claim resolved by binding arbitration. However, I understand that if such action is removed to federal court or transferred to a court of general jurisdiction that the defendant shall retain the right to have the dispute submitted to binding arbitration.

i. Judicial Review: I agree that judicial review shall be governed by the FAA. The decision of the Arbitrator may be entered and enforced as a final judgment in any court of competent jurisdiction.

j. Sanctions: I agree that to the extent allowed by applicable law, the arbitrator(s), may award either party its reasonable attorneys’ fees and costs upon a finding that a claim was frivolous or brought for purposes of harassment.

k. Pre-Arbitration Notice: I understand that any party who intends to file a demand for arbitration must first send to the other, by certified mail, return receipt requested, a written Notice of Dispute. I understand I must send my notice of dispute to Alto Trust Co., Capitol View Block E, 500 11th Avenue North, Suite 790, Nashville TN 37203, and that any Notice of Dispute sent to me may be sent to the last known address I have provided to the Custodian or Administrator. The Notice of Dispute shall contain: (1) my name, address, and phone number, (2) describe the nature of my claim and a short factual statement supporting the claim, (3) state the specific relief sought, and (4) be signed in writing by the party seeking arbitration (i.e., either by me personally, or a representative of the Custodian or Administrator). I understand that if I am the one demanding arbitration and I have retained an attorney, that my Notice of Dispute must also include my signed statement authorizing the Custodian and Administrator to disclose my confidential records to my attorney if necessary to resolve my claim. After the Notice of Dispute is received, I agree that any party has thirty (30) days to research the issues contained in the Notice of Dispute and attempt to engage in informal settlement negotiations with the party that submitted the Notice of Dispute.

i. Commencing Arbitration: I understand that an arbitration proceeding may not be commenced unless the arbitration claimant has complied with the PRE-ARBITRATION NOTICE requirement, above. To commence arbitration, I understand that a claimant shall file a Demand for Arbitration with the American Arbitration Association (“AAA”) and must send a copy of the Demand for Arbitration to the other party by certified mail, return receipt requested. I understand that I shall send a Demand for Arbitration to the Custodian or Administrator at 500 11th Avenue North, Suite 790, Nashville TN 37203 and that any Demand for Arbitration send to me may be sent to the last known address I have provided to the Custodian or Administrator. I understand the AAA’s address is: American Arbitration Association, Case Filing Services, 1101 Laurel Oak Road, Suite 100, Voorhees, NJ 08043. The AAA’s current address and/or email address also may be found on its web site at www.adr.org. I understand that demands for Arbitration may not be accepted by the AAA unless it includes my name, address, phone number and written signature, as well as a short statement of the claim and the specific relief that is being sought. I understand that if I have failed to comply with the PRE-ARBITRATION NOTICE and the requirements for the Demand for Arbitration that the AAA will be without authority to open a matter and commence arbitration until these requirements are satisfied.

m. Arbitration Administrator and Rules: I understand that the arbitration will be administered by the AAA and conducted in accordance with the AAA’s Consumer Arbitration Rules (“AAA Rules”) in effect at the time the arbitration commences; however, if there is a conflict between the AAA Rules and this Agreement, this Agreement shall govern. The AAA Rules are available at www.adr.org, by calling the AAA at 1-800-778-7879 or its then current telephone number as provided on its web site, or by sending a written request to: American Arbitration Association, 1101 Laurel Oak Road, Suite 100, Voorhees, NJ 08043. Any arbitration proceeding shall be conducted by a panel of three arbitrators selected pursuant to the AAA rules unless the parties agree otherwise. I understand that if the AAA cannot or will not serve and the parties are unable to select an arbitration administrator by mutual consent, a court will select the arbitration administrator. Upon selection the arbitration administrator will appoint the arbitrator(s) in accordance with the arbitration administrator’s rules; however, the arbitrator(s) must be a retired or former judge or a lawyer with at least ten (10) years of experience.

n. Remedies: I understand that, subject to the CLASS ACTION WAIVER, the arbitrator(s) may award any party any remedy to which that party is entitled under applicable law (including without limitation legal, equitable, and injunctive relief), but such remedies shall be limited to those that would be available to a party in his/her/its individual capacity in a court of law for the claims presented to and decided by the arbitrator(s).

o. Location and Costs: I understand that any arbitration hearing must take place at a location reasonably convenient to me and that the location will be decided by the arbitrator(s). I understand that the parties will follow applicable law and the AAA Rules applicable to filing fees and administration fees. I understand that Custodian and Administrator will pay any and all fees of the arbitration administrator and/or the arbitrator if the applicable law or rules requires them to if they must bear such fees in order for this Arbitration Provision to be enforced.

p. Compelling Arbitration: I agree that if a party is required to enforce this arbitration agreement against the other party and/or to compel the other party to arbitration pursuant to this agreement, the party shall recover from the other party reasonable attorneys’ fees, costs and expenses so incurred. Arbitration shall be final and binding upon the parties.