Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) Policy

Last modified: March 8th, 2026.

PURPOSE

The purpose of this Policy is to ensure that Shift Connect Global dba Pay From Away (“Pay From Away”) complies with the federal prohibition on unfair, deceptive, or abusive acts or practices found in Title X of the Dodd-Frank Act. This Policy is designed to prevent unfair, deceptive, or abusive acts or practices (“UDAAP”) in connection with Pay From Away’s consumer-facing payment and related financial services.

SCOPE

This Policy applies to all Pay From Away employees, contractors, and third-party service providers. This Policy governs all of Pay From Away’s activities in connection with consumer financial products and services, including advertising and marketing, website content, customer onboarding, payment processing, account or transaction access through the website, servicing, support, and collections-related activities, where applicable.

STATEMENT OF POLICY

Pay From Away is committed to treating consumers fairly, providing clear and complete communications regarding its products and services, and responding to consumer concerns promptly and courteously. Pay From Away will not tolerate unfair, deceptive, or abusive acts or practices in any part of its business, whether conducted directly or through a third-party service provider.

OVERSIGHT AND IMPLEMENTATION OF POLICY

Senior Management is responsible for oversight of this Policy and for ensuring appropriate implementation across the organization.

The compliance function, together with applicable operational, support, risk, and management personnel, will conduct compliance monitoring and reviews on at least an annual basis to help ensure that all employees and applicable third-party service providers comply with this Policy and to identify any weaknesses that need to be addressed to minimize and prevent UDAAP risk. Senior Management will be informed of any deficiencies identified through compliance monitoring that require corrective action.

DEFINITIONS

Unfair

The standard for unfairness under the Dodd-Frank Act is that an act or practice is unfair when:

1. It causes or is likely to cause substantial injury to consumers;
2. The injury is not reasonably avoidable by consumers; and
3. The injury is not outweighed by countervailing benefits to consumers or to competition.

Likely to cause substantial injury

An act or practice is unfair if it causes or is likely to cause substantial injury to consumers. Substantial injury usually involves monetary harm. Monetary harm includes, for example, costs, fees, losses, delays, or other financial consequences incurred by consumers as a result of an unfair practice. An act or practice that causes a small amount of harm to a large number of consumers may also be deemed to cause substantial injury. Forgone monetary benefits or denial of access to products or services may also cause substantial injury.

Actual injury is not required in every case. A significant risk of concrete harm may also be sufficient. However, trivial or merely speculative harms are typically insufficient for a finding of substantial injury. Emotional impact and other subjective harms ordinarily will not alone amount to substantial injury, though in some circumstances they may contribute to it.

Injury not reasonably avoidable

An act or practice is unfair if it causes or is likely to cause a substantial injury that is not reasonably avoidable by consumers. Consumers cannot reasonably avoid injury if the act or practice interferes with their ability to make informed decisions or to take action to avoid injury.

If material information about a product or service, such as pricing, timing, fees, limitations, or eligibility requirements, is withheld, obscured, changed after the consumer has committed, or presented in a confusing or misleading way, the consumer may not be able to reasonably avoid the injury. Consumers also cannot reasonably avoid injury if they are coerced into purchasing unwanted products or services, or if a transaction occurs without their knowledge or consent.

A key question is not whether a consumer could theoretically have made a better choice, but whether the act or practice hindered the consumer’s decision-making or ability to avoid harm in a practical and reasonable way.

Injury not outweighed by countervailing benefits to consumers or competition

An act or practice is unfair if the injury it causes is not outweighed by any offsetting consumer or competitive benefits. Such benefits may include lower prices, increased access, or other efficiencies. In assessing whether an act or practice is unfair, consideration may also be given to the costs of measures that would prevent the injury.

Public policy, as established by statute, regulation, judicial decision, or agency determination, may be considered along with all other evidence in determining whether an act or practice is unfair. However, public policy alone may not serve as the primary basis for determining that an act or practice is unfair.

Deceptive

A representation, omission, act, or practice is deceptive when:

1. It misleads or is likely to mislead the consumer;
2. The consumer’s interpretation is reasonable under the circumstances; and
3. The misleading representation, omission, act, or practice is material.

Representation likely to mislead

An act or practice is deceptive if there is a representation, omission, act, or practice that misleads or is likely to mislead the consumer. Deception is not limited to situations in which a consumer has already been misled. An act or practice may be deceptive if it is likely to mislead consumers.

It is necessary to evaluate a statement, representation, or omission in the context of the entire advertisement, webpage, transaction flow, account experience, communication, or course of dealing to determine whether the overall net impression is misleading or deceptive. A representation may be express or implied, and may be written, oral, digital, visual, or operational in nature. If material information is necessary to prevent a consumer from being misled, omitting that information may be deceptive.

Written disclosures may be insufficient to correct a misleading statement or representation, particularly where the consumer is directed away from qualifying information or where key limitations are hidden in fine print, buried in links, or presented after the consumer has already made a decision. Likewise, subsequent truthful disclosures may not cure an earlier misleading impression.

Acts or practices that may be deceptive include:

• Making misleading cost, timing, payment, exchange rate, or price claims;
• Offering to provide a product or service that is not in fact available as described;
• Using bait-and-switch techniques;
• Omitting material limitations, conditions, risks, or eligibility requirements from an offer;
• Failing to provide the promised services; or
• Presenting website flows, prompts, or communications that create a misleading overall impression.

The Federal Trade Commission “four Ps” test may assist in evaluating whether a representation, omission, act, or practice is likely to mislead:

• Is the statement prominent enough for the consumer to notice?
• Is the information presented in an easy-to-understand format that does not contradict other information and at a time when the consumer’s attention is not distracted elsewhere?
• Is the placement of the information in a location where consumers can be expected to look or hear?
• Is the information in close proximity to the claim it qualifies?

Reasonable consumer

An act or practice is deceptive if it would be misleading from the perspective of a reasonable consumer. In determining whether an act or practice is misleading, Pay From Away will consider whether the consumer’s interpretation of or reaction to the representation, omission, act, or practice is reasonable under the circumstances.

When representations or marketing practices target a specific audience, the communication must be reviewed from the point of view of a reasonable member of that audience.

A representation may be deceptive even if not all consumers would interpret it in the same way, so long as a significant minority of reasonable consumers is likely to be misled. Exaggerated claims or puffery, however, are not deceptive if they would not be taken seriously by a reasonable consumer.

Material

An act or practice is deceptive if the representation or omission is material. A representation, omission, act, or practice is material if it is likely to affect a consumer’s choice of, or conduct regarding, the product or service. Information important to consumers is material.

In general, information about central characteristics of a product or service, such as costs, fees, benefits, restrictions, timing, exchange rates, availability, refundability, cancellation rights, eligibility, or limitations, is presumed to be material. Express claims made with respect to a financial product or service are presumed material. Omissions may also be presumed material when Pay From Away knew or should have known that the consumer needed the omitted information to evaluate the product or service.

Abusive

An abusive act or practice:

1. Materially interferes with the ability of a consumer to understand a term or condition of a consumer financial product or service; or
2. Takes unreasonable advantage of:

• A lack of understanding on the part of the consumer of the material risks, costs, or conditions of the product or service;
• The inability of the consumer to protect their interests in selecting or using a consumer financial product or service; or
• The reasonable reliance by the consumer on a covered person to act in the interests of the consumer.

An abusive act or practice does not need to cause substantial injury to establish liability. An abusive act or practice also may be unfair or deceptive.

Material Interference

An act or omission is abusive if it materially interferes with a consumer’s ability to understand a term or condition of a consumer financial product or service. Material interference may include acts or omissions that obscure, withhold, de-emphasize, render confusing, or hide information relevant to the consumer’s ability to understand terms and conditions.

Examples include:

• Buried disclosures, including fine print, dense legal wording, jargon, or poorly timed disclosures;
• Physical or procedural interference, such as hiding or withholding notices;
• Digital interference, such as website, user interface, or user experience designs that make terms and conditions materially less accessible or salient;
• Multiple click-throughs, pop-ups, confusing prompts, misleading defaults, or dark patterns; and
• Overshadowing, where prominent content interferes with the comprehension of important qualifying information.

Unreasonable Advantage

An act or practice is abusive when an entity takes unreasonable advantage of particular circumstances, even if the condition was not created by the entity.

Gaps in understanding. A lack of understanding on the part of the consumer of the material risks, costs, or conditions of the product or service may include:

• The consequences or likelihood of failed, delayed, returned, or rejected payments;
• Monetary charges as well as non-monetary costs such as lost time, inconvenience, inability to access funds, or reputational harm;
• The timing of payment processing, remittance, holding periods, or delivery of funds;
• The conditions under which fees may be assessed; and
• The difference between Pay From Away’s services and those of a bank or other financial institution.

Unequal bargaining power. The inability of the consumer to protect their interests in selecting or using a consumer financial product or service may include:

• Monetary and non-monetary interests, including privacy or reputational interests;
• Time spent trying to obtain customer support assistance;
• Lack of practical alternatives once a payment has been initiated or scheduled;
• Use of standard-form agreements where contractual provisions are not subject to negotiation; and
• High transaction costs to exit a relationship or reverse a transaction.

Reasonable reliance. The reasonable reliance by the consumer on Pay From Away to act in the consumer’s interest may include circumstances where Pay From Away communicates or implies that it will guide the consumer, help the consumer select among options, protect the consumer from avoidable harm, or otherwise act in the consumer’s best interest.

STANDARDS

Marketing and Disclosures

Pay From Away requires that all marketing materials, website content, customer agreements, transaction flows, support communications, statements, and other disclosures meet the following requirements:

• All representations are factually based;
• All materials describe clearly, prominently, and accurately the costs, benefits, risks, timing, availability, and other material terms of the products or services being offered;
• All materials clearly describe related products or services being offered either as an option or as required to obtain certain terms;
• All material limitations or conditions on the terms or availability of products and services are disclosed clearly and prominently;
• The consumer’s attention is drawn to key terms, including limitations and conditions necessary to make an informed decision;
• All fees, penalties, and other charges that may be imposed, and the reason for those charges, are clearly and prominently disclosed;
• Contracts clearly inform consumers of provisions that permit changes in terms and conditions;
• Materials communicate costs, benefits, availability, and other terms in language that can be understood by the intended audience;
• Materials do not misrepresent costs, conditions, limitations, or other terms either affirmatively or by omission;
• Pay From Away avoids advertising terms that are generally not available to the typical targeted consumer;
• Materials and advertising do not improperly target or exclude consumers on a discriminatory basis, including through digital advertising; and
• Pay From Away must clearly identify itself in consumer-facing materials and must not create the misleading impression that it is a bank where it is not.

Availability of Terms or Services

Pay From Away must ensure that any product or service consumers receive is consistent with the disclosures provided to them. Pay From Away requires the following:

• Consumers are reasonably able to obtain the products and services as represented;
• Products and services are offered in a manner that prevents discrimination;
• Consumers receive the specific product or service they request, or any substitute or modified offering is clearly explained;
• Counteroffers, substitutions, or revised terms clearly, prominently, and accurately explain the difference between the original product or service requested and the one being offered;
• Actual practices are consistent with stated policies, procedures, website disclosures, and customer-facing agreements; and
• Timing, fees, delivery expectations, and availability of funds are described accurately and consistently.

Servicing and Support

Pay From Away must ensure that its employees and third-party service providers do the following in connection with servicing, support, and consumer account or transaction access:

• Refrain from engaging in practices that lead to differential treatment or disproportionately adverse impacts on a discriminatory basis;
• Effectively respond to consumers’ calls, emails, and support requests;
• Represent fees, charges, timing, and transaction status in a manner that is not misleading;
• Process, post, reconcile, and communicate consumer payments in a timely and accurate manner;
• Apply payments in a manner consistent with disclosed practices;
• Charge consumers only for products and services to which they have specifically agreed;
• Make available timely notices, transaction histories, statements, or status information electronically through https://www.payfromaway.io/ where applicable;
• Avoid making any statements about timing, delivery, refunds, payment status, or service outcomes that are incomplete, misleading, or confusing; and
• Provide support in a manner that allows consumers a reasonable opportunity to understand and address issues affecting their transactions.

Collections

To the extent collection activities are conducted, Pay From Away must ensure that such activities comply with applicable law, including the Fair Debt Collection Practices Act where applicable, and are conducted in a manner that prevents abusive, deceptive, or unfair practices.

Pay From Away requires that its employees and third-party service providers do the following:

• Refrain from engaging in collections practices that lead to differential treatment or disproportionately adverse impacts on a discriminatory basis;
• Clearly indicate the purpose of the communication where required;
• Avoid disclosing the existence of a consumer’s debt or obligation except as permitted by law;
• Refrain from making repeated telephone calls, or calls at inappropriate times, that may annoy, abuse, or harass any person; and
• Ensure that any representations about balances, obligations, deadlines, consequences, or settlement options are accurate and not misleading.

PROHIBITED ACTS OR PRACTICES

Pay From Away will continuously assess its activities to ensure that it is not engaging in any unfair, deceptive, or abusive acts or practices in connection with the products and services it offers consumers. Without limiting that obligation, Pay From Away prohibits the following:

• Failing to clearly identify Pay From Away and the nature of its role in a transaction;
• Misrepresenting or obscuring whether Pay From Away is acting as a platform, processor, remittance provider, or other service provider;
• Misrepresenting that Pay From Away is a bank if it is not;
• Using high-pressure, aggressive, manipulative, or coercive tactics to market or sell products or services;
• Relying primarily on hidden, back-end, penalty, or surprise fees rather than transparent upfront pricing;
• Offering a product or service with features, terms, or conditions presented in a way that may materially increase the difficulty of consumer understanding;
• Offering a product or service that is not actually available as described;
• Failing to disclose material limitations, restrictions, timing considerations, eligibility requirements, or conditions;
• Failing to disclose material relationships with third-party service providers where disclosure is needed to avoid misleading consumers;
• Misrepresenting ancillary products or services as required when they are optional;
• Imposing fees, penalties, or other costs on a consumer for seeking information about their account, transaction, or payment status except where clearly disclosed and legally permissible;
• Targeting a product to particular populations without appropriate tailoring of marketing, disclosures, website content, and other materials to support consumer understanding;
• Improperly giving inferior terms to one demographic as compared to another on a discriminatory basis;
• Improperly offering or providing more favorable access, products, or services to one demographic as compared to another on a discriminatory basis;
• Improperly treating consumers of certain demographics worse or providing extra assistance or exceptions in a discriminatory manner;
• Engaging in targeted advertising, targeting logic, or marketing segmentation in a discriminatory way;
• Using decision-making processes in eligibility determinations, onboarding, pricing, servicing, support, or collections that result in discrimination;
• Failing to evaluate and make necessary adjustments and corrections to prevent discrimination;
• Offering, inducing a consumer to accept, or steering a consumer toward an inferior product or service, or one with abusive terms or features, for the benefit of Pay From Away, an employee, or a third-party service provider;
• Misrepresenting that a product or service is endorsed, guaranteed, or recommended by a federal or state government agency or other authority; and
• Using website or app design practices, including dark patterns, that materially interfere with consumer understanding or choice.

COMPLIANCE

Pay From Away will conduct compliance monitoring on at least an annual basis to help ensure that employees and relevant third-party service providers comply with this Policy and the UDAAP prohibition. The results of this monitoring will be compiled into reports for review by Senior Management and other responsible personnel.

Monitoring

Pay From Away will monitor all relevant aspects of its activities in connection with consumer financial products and services. Key areas of focus include consumer interactions, website content and flows, support communications, disclosures, complaints, third-party oversight, and product or service changes.

Interactions with Consumers

Pay From Away will monitor the activities of its employees, support personnel, marketing personnel, and third-party service providers to help ensure they do not engage in unfair, deceptive, or abusive acts or practices with respect to consumer interactions.

In connection with this, Pay From Away will periodically review the following:

• Training programs to ensure that employees and third parties who market, promote, support, or service products receive adequate UDAAP-related training;
• Scripts, templates, FAQs, support responses, and other consumer communications to ensure that clear and accurate statements are provided and no misrepresentations or misleading statements are made;
• Recordings or other records of customer service or sales communications, where applicable;
• Compensation arrangements with employees and third-party service providers, as well as performance criteria, to ensure they do not create unintended incentives to engage in UDAAPs; and
• Consumer complaints received directly or indirectly, along with associated tracking and reports, to ensure complaints are addressed in a timely manner and to identify trends, deficiencies, or potential UDAAP concerns.

Marketing and Disclosures

Pay From Away will monitor the activities of its employees and third-party service providers to help ensure they do not engage in unfair, deceptive, or abusive acts or practices with respect to marketing, advertising, website content, onboarding, and disclosures.

In connection with this, Pay From Away will periodically review a sample of the following:

• Solicitations and promotional materials;
• Website pages, landing pages, sign-up flows, and social media content;
• Marketing scripts and disclosures for new products, services, and features;
• Consumer-facing agreements, disclosures, transaction confirmations, receipts, and notices;
• Support content, FAQs, and template communications;
• Statements, transaction histories, or equivalent consumer-facing records made available through the website; and
• Any collection notices or related communications, where applicable.

Products and Services

Pay From Away will periodically evaluate its existing products and services, along with their features, terms, conditions, disclosures, and operational practices, for substantive compliance with this Policy.

New or modified products, services, website flows, or material features must be evaluated to help ensure they comply with this Policy and do not pose unacceptable UDAAP risk. In particular, Pay From Away may assess UDAAP risk associated with a product, feature, communication, or process by:

• Conducting a legal and compliance analysis of whether an act or practice could be unfair, deceptive, or abusive;
• Performing relevant market or industry research regarding the product or service, or similar offerings;
• Assessing regulatory guidance, enforcement developments, complaints, or similar issues relating to the product or service; and
• Reviewing the end-to-end consumer experience, including user interface, disclosure timing, customer support impact, and likely consumer understanding.

Third-Party Service Providers

Pay From Away will implement and maintain effective risk and supervisory controls to select, manage, and oversee third-party service providers.

In connection with this, Pay From Away may conduct periodic reviews or audits to determine whether third parties are complying with Pay From Away’s expectations and applicable legal requirements. These reviews may include:

• Initial and ongoing training;
• Performance reviews or audits;
• Discipline policies and records of disciplinary action, where applicable;
• Third-party agreements and contractual performance standards;
• Compensation programs or incentives, where relevant; and
• Third-party policies, procedures, scripts, materials, and consumer interaction practices.

Reporting

On at least an annual basis, responsible compliance or management personnel will prepare reports of compliance monitoring results for review by Senior Management. These reports will identify any weaknesses or deficiencies that may require corrective action, disciplinary action, enhancements to controls, or changes to this Policy.

Record Retention

Pay From Away will retain evidence of compliance with this Policy for a period of at least three (3) years, unless a longer retention period is required by law, contract, complaint handling needs, litigation hold, or another internal policy.

RELATIONSHIP TO OTHER LAWS

An unfair, deceptive, or abusive act or practice may also violate other federal, state, provincial, or local laws, depending on the facts and circumstances. For example, an act or practice involving misleading disclosures, discriminatory treatment, or unlawful collection activity may also violate other consumer protection, anti-discrimination, privacy, payments, or financial services laws.

Conversely, a transaction or practice that is in technical compliance with one law may nevertheless violate the prohibition against UDAAP. Compliance with one disclosure or regulatory requirement does not insulate Pay From Away from liability if the overall communication, transaction flow, service practice, or consumer experience is misleading, unfair, or abusive.