Platform Terms of Service & EFT Disclosure

Important Summary: Turn Financial is a financial technology company, not a bank. Deposit accounts and banking services are provided by our partner financial institutions (including Veridian Credit Union, Member NCUA/FDIC). Savings circles on Turn are 0% non-lending personal capital pooling arrangements where members receive 100% of their savings principal back without debt or interest.

1. Introduction & Acceptance of Terms

Welcome to Turn Financial, Inc. ("Turn Financial", "Turn", "we", "us", or "our"). These Platform Terms of Service ("Terms") govern your access to and use of our financial technology platform, including our conversational assistant Turn Butler, our mobile and web applications, our telephony and SMS lines, and our community savings circle management software (collectively, the "Platform" or "Services").

By registering for an account, accessing our applications, submitting your mobile phone number, joining or organizing a savings circle, communicating with Turn Butler via voice or text, or utilizing any Turn Financial service, you agree to be bound by these Terms and our incorporated policies:

If you do not agree to these Terms, you may not access or use the Platform.

2. Non-Bank Financial Technology Platform & FBO Account Custody

Turn Financial provides software, accounting, and communication tools. Turn Financial is not a bank or depository institution. Banking services, stored value accounts, and debit card issuance are facilitated through our licensed depository institution partners:

Custodial Trust Accounts (FBO): All customer funds loaded into personal Turn Wallets, community circle pot vaults, and reserve buffers are held in custodial omnibus trust accounts (For the Benefit Of – "FBO") at our partner financial institution, Veridian Credit Union (and/or designated partner banks), which is an NCUA/FDIC-insured institution.
Pass-Through Deposit Insurance: Funds held in the custodial FBO account qualify for pass-through deposit insurance up to the standard statutory limit of $250,000.00 per individual member, subject to applicable regulatory recordkeeping rules.
Card Issuance: Turn Visa Debit Cards (virtual and physical) are issued by our licensed partner financial institution pursuant to a license from Visa U.S.A. Inc.

3. Community Savings Circles (Susu, Pardna, Tanda) & 0% Non-Lending Invariant

Turn Financial digitizes, coordinates, and automates traditional rotating savings and credit associations (ROSCAs), known globally as Susu, Pardna, Tanda, Sòl, Chit Funds, or Hui:

0% Interest & Personal Capital Preservation (IRC § 61): Circles on Turn are mutual personal capital pooling arrangements. They are strictly non-lending, zero-interest transactions. When a member receives their lump-sum payout hand, it represents the exact return of member-contributed principal. Turn Financial does not extend consumer credit, charge interest rates, or offer loans.
Choice A Clean Pot Guarantee: The scheduled recipient receives a 100% full face-value payout (e.g., $1,000.00 on a 10-person $100/round circle). Zero platform deductions are taken from member savings principal.
Rotating Seniority & Payout Schedule: Participants in rotating circles agree to contribute their scheduled dues on time and receive their scheduled payout hand on their designated rotation date.
Peer Trust Foundation: Members form circles with people they already know and trust (family, lifelong friends, faith communities, coworkers). Turn provides automated ledger accounting and cryptographic settlement, but does not operate an anonymous public lending marketplace.

4. 57% Reinvestment, Referral & Organizer Cash Back Program

Turn Financial modernizes community finance by returning approximately ~57% of platform software fees directly back to members and community leaders:

Organizer Cash Back (1.50% / 150 bps): Verified members who host, create, and coordinate savings circles earn ongoing 1.50% Organizer Cash Back on the gross pot for their community stewardship.
Referral Cash Back (0.50% / 50 bps): Every verified member who invites peers earns 0.50% ongoing Referral Cash Back on all circle dues contributed by people they personally invite for as long as those circles remain active.
Tax Classification as Non-Taxable Price Reductions (IRS Rev. Rul. 76-96 & 84-41): Under longstanding IRS revenue rulings, customer incentives, fee offsets, and Cash Back rebates earned in connection with consumer software services are legally classified as non-taxable reductions in purchase price. Cash Back applied toward platform fees or dues does not constitute taxable gross income.
Single-Tier Invariant (Strictly Non-MLM): Turn Financial is strictly not a multi-level marketing (MLM) program. Members earn Cash Back only on people they personally invite. There are zero multi-tiered commission overrides.

5. Turn Wallet, Stored Value & Zero-Overdraft Invariant

Pre-Funded Execution Only: Turn Financial enforces a zero-overdraft ledger rule. Outbound transfers, circle contributions, and card purchases will only execute if you have sufficient available funds. Turn never charges overdraft fees, non-sufficient fund (NSF) fees, or late penalties.
Stored Value Ceilings (31 CFR § 1010.100): In compliance with federal anti-money laundering regulations, unverified accounts are subject to stored value limits of $2,000.00. Balances exceeding this limit require completion of Tier-1 identity verification (CIP).

6. Regulation E Electronic Fund Transfer Disclosures (12 CFR § 1005.18)

Your rights and protections regarding electronic fund transfers (EFTs) are governed by federal Regulation E:

Electronic Statements: You may inspect your complete transaction history, fees, running balances, and Regulation E disclosures anytime in your account dashboard.
Error Resolution Notice: If you believe your statement or transaction receipt is incorrect, or if you need more information about a transfer:
1. Notify us promptly by emailing support@turn.financial or contacting Member Care.
2. We must hear from you no later than sixty (60) days after the date the electronic statement or transaction receipt was made available.
3. Provide your name, contact details, transaction details, and explain clearly why you believe there is an error.
4. We will investigate and determine whether an error occurred within 10 business days (20 business days for new accounts) and will correct any error promptly.

7. Electronic Communications Agreement (E-SIGN Act)

By using Turn Financial or providing your phone number, you consent to receive all disclosures, notices, statements, and communications electronically pursuant to the Electronic Signatures in Global and National Commerce Act (E-SIGN Act). Communications may be delivered via SMS text message, automated voice telephone call, mobile push notification, or email.

8. Text Messaging & Telephony Integration

By providing your mobile phone number on our website or within our applications, you expressly agree to our SMS & Voice Messaging Terms of Service. You acknowledge that message and data rates may apply, message frequency varies, and that you may opt out of marketing or informational text messages at any time by replying STOP. Consent to text messages is never a condition of purchase.

9. Prohibited Activities

You agree not to use the Platform for money laundering, terrorist financing, fraud, identity theft, unauthorized automated scraping, tampering with our double-entry ledger, or violating any local, state, or federal laws.

10. Disclaimer of Warranties & Limitation of Liability

THE PLATFORM IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED. TO THE MAXIMUM EXTENT PERMITTED BY LAW, TURN FINANCIAL DISCLAIMS ALL WARRANTIES, INCLUDING MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. IN NO EVENT SHALL TURN FINANCIAL BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, OR CONSEQUENTIAL DAMAGES.

11. Dispute Resolution, Binding Individual Arbitration & Class Action Waiver

PLEASE READ THIS SECTION CAREFULLY. IT CONTAINS A BINDING INDIVIDUAL ARBITRATION AGREEMENT AND CLASS ACTION WAIVER.

Informal Resolution: You agree to first contact support@turn.financial and attempt to resolve any dispute informally for at least thirty (30) days.
Binding Arbitration: Any unresolved dispute arising out of these Terms shall be resolved exclusively through binding individual arbitration administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules.
Class Action Waiver: YOU AND TURN FINANCIAL AGREE THAT DISPUTES MAY ONLY BE BROUGHT IN AN INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY CLASS, COLLECTIVE, OR REPRESENTATIVE PROCEEDING.

12. Governing Law & Contact

These Terms are governed by the laws of the State of Delaware, without regard to conflicts of law principles.

Turn Financial, Inc.
Member Care & Compliance: support@turn.financial