Electronic Fund Transfer Disclosure (Regulation E)

This disclosure describes your rights and responsibilities regarding electronic fund transfers (EFTs) to and from your deposit account at OMB Bank held in connection with the Easy Impound Program. This disclosure is provided to you in accordance with the Electronic Fund Transfer Act (15 U.S.C. § 1693 et seq.) and Regulation E (12 C.F.R. Part 1005) of the Consumer Financial Protection Bureau. Please read this disclosure carefully and retain it for your records.

Your banking relationship is with OMB Bank (“Bank”), a state-chartered financial institution and member of the Federal Reserve System, Member FDIC. Easy Impound (a trade name of ON-Time Prop Pay LLC) serves as the program manager and technology provider. Treasury Prime, Inc. serves as a ledger and technology services provider to the Bank. Neither Easy Impound nor Treasury Prime is a bank or holds your deposits.

1. Types of electronic fund transfers

The following types of electronic fund transfers may be initiated to or from your Account:

a. ACH Debit Transfers (Deposits). You may authorize recurring ACH debit transfers from your designated external bank account (“Linked Bank Account”) to fund your Program Account. Transfers are initiated at the frequency and in the amounts established by the Program schedule for your property tax and insurance obligations.

b. ACH Credit Transfers (Disbursements). The Bank will initiate ACH credit transfers from your Account to pay your property taxes to the applicable taxing authority and your property insurance premiums to the applicable insurance carrier, in accordance with the Program schedule. These disbursements are processed in advance of the applicable delinquency date; see Section 4.d below for important information on the deadline to request cancellation of a scheduled disbursement.

c. ACH Credit Transfers (Withdrawals/Refunds). You may request a withdrawal of your Program Funds at any time. Upon your request, an ACH credit transfer will be initiated from your Account to your Linked Bank Account. Withdrawals are generally processed within seven (7) to fourteen (14) business days.

Transfers you can initiate. You cannot initiate ATM transactions, debit card transactions, point-of-sale purchases, wire transfers, check writing, or person-to-person payment transfers from your Account. Your Account is a special-purpose deposit account used exclusively for property tax and insurance payment activity under the Program. The Bank initiates tax and insurance disbursements from your Account by ACH, wire, or check, depending on the payment methods accepted by the applicable taxing authority or insurance carrier.

2. Fees for electronic fund transfers

• ACH Debit (Deposit from Linked Bank Account): no fee.
• ACH Credit (Tax / Insurance Disbursement): no fee.
• ACH Credit (Withdrawal to Linked Bank Account): no fee.
• Returned ACH Item: up to $5.00 per item.

The Bank reserves the right to change fees upon thirty (30) days’ prior written notice. Fees described above are Bank fees only. Technology fees charged by Easy Impound for access to the Easy Impound platform are separate and are governed by the Easy Impound Terms of Service. Technology fees are never deducted from your Program Funds.

3. Documentation of transfers

a. Periodic Statements. You will receive periodic account statements at least quarterly (or monthly if there is electronic fund transfer activity in a given month). Statements will be made available electronically through the Easy Impound platform and will include the amount, date, and type of each electronic fund transfer, as well as your Account balance.

b. Transaction Confirmations. You may receive electronic notifications confirming individual transactions (deposits, disbursements, and withdrawals) through the Easy Impound platform, email, or other electronic means you have consented to receive.

c. Preauthorized Credits. If you have arranged to have a preauthorized deposit (ACH credit) made to your Account, you can verify whether the deposit has been made by logging into the Easy Impound platform or by contacting Easy Impound customer support or the Bank.

4. Preauthorized transfers

a. Right to Stop Payment. If you have authorized recurring ACH debit transfers from your Linked Bank Account, you have the right to stop any of these payments. To stop a payment, you must notify us orally or in writing at least three (3) business days before the scheduled transfer date. If you call, we may require you to confirm your stop-payment request in writing within fourteen (14) days. If we do not receive written confirmation within fourteen (14) days after your oral notification, we may honor subsequent preauthorized transfers.

b. Notice of Varying Amounts. If preauthorized ACH debit transfers from your Linked Bank Account may vary in amount, you will be notified at least ten (10) days before each transfer of the amount and date of the transfer. You may choose instead to receive notice only when the transfer would differ by more than an agreed-upon amount from the previous transfer, or when the amount would fall outside an agreed-upon range.

c. Liability for Failure to Stop Payment. If you timely order us to stop a preauthorized transfer and provide us with sufficient information to identify the transfer, and we fail to do so, we may be liable for your losses or damages.

d. Cancellation of Tax or Insurance Disbursements. Property tax and insurance disbursements are processed and released in advance of the applicable delinquency date so that payment reaches the taxing authority or insurance carrier on time. Because of this processing time, you cannot cancel a scheduled tax or insurance disbursement within fourteen (14) calendar days before the applicable tax or insurance delinquency date, as the payment will already have been disbursed to the taxing authority or insurance carrier. To request cancellation of a scheduled tax or insurance disbursement, you must notify us at least fourteen (14) calendar days before the applicable tax or insurance delinquency date. Cancellation requests received after this deadline cannot be honored, and once a disbursement has been sent it cannot be recalled or reversed.

For properties in states that distinguish between a tax due date and a tax delinquency date, all deadlines in this Section are measured from the delinquency date.

5. Error resolution procedures — your rights

PLEASE READ THIS SECTION CAREFULLY. IT DESCRIBES YOUR RIGHTS AND OUR OBLIGATIONS UNDER FEDERAL LAW.

In Case of Errors or Questions About Your Electronic Transfers. Contact us as soon as possible if you think your statement or receipt is wrong, or if you need more information about a transfer listed on the statement or receipt. We must hear from you no later than sixty (60) days after we sent you the FIRST statement on which the problem or error appeared. When you contact us:

• Tell us your name and Account number.
• Describe the error or the transfer you are unsure about, and explain as clearly as you can why you believe it is an error or why you need more information.
• Tell us the dollar amount of the suspected error.

How to Contact Us: by telephone at (417) 869-9000; by mail at OMB Bank, 3570 S National Ave, Springfield, MO 65807; or through the Easy Impound platform at support@easyimpound.com. If you tell us orally, we may require that you send us your complaint or question in writing within ten (10) business days.

What We Will Do After We Receive Your Notice. We will tell you the results of our investigation within ten (10) business days after we hear from you, and will correct any error promptly. If we need more time, however, we may take up to forty-five (45) calendar days to investigate your complaint or question. If we decide to do this, we will provisionally credit your Account within ten (10) business days for the amount you think is in error, so that you will have use of the money during the time it takes us to complete our investigation. If we ask you to put your complaint or question in writing and we do not receive it within ten (10) business days, we may not provisionally credit your Account.

For new Accounts: for errors involving a new Account (within the first thirty (30) days after the first deposit is made), we may take up to twenty (20) business days to provisionally credit your Account, and up to ninety (90) calendar days to complete our investigation.

We will tell you the results within three (3) business days after completing our investigation. If we determine that no error occurred, we will send you a written explanation. You may ask for copies of the documents that we used in our investigation.

6. Your liability for unauthorized transfers

Tell us AT ONCE if you believe an unauthorized electronic fund transfer has been made from your Account, or if you believe your Account credentials have been compromised. Contacting us immediately is the best way to protect yourself from possible losses.

Your Account does not use a card, PIN, or other access device. If an unauthorized electronic fund transfer appears on a periodic statement, you must notify us within sixty (60) days after we sent you the FIRST statement on which the unauthorized transfer appeared. If you do not notify us within that period, you may not get back any money you lost after the sixty (60) days if we can prove that we could have stopped someone from taking the money had you told us in time.

If a good reason (such as a long trip or a hospital stay) kept you from telling us, we will extend the time periods.

7. Our liability for failure to complete transfers

If we do not complete a transfer to or from your Account on time or in the correct amount according to our agreement with you, we will be liable for your losses or damages. However, there are some exceptions. We will NOT be liable, for instance:

• If, through no fault of ours, you do not have enough money in your Account to make the transfer.
• If the electronic transfer system or the Ledger Provider system was not working properly and you knew about the malfunction when you started the transfer.
• If circumstances beyond our control (such as fire, flood, power failure, equipment or system malfunction, or other force majeure event) prevent the transfer, despite reasonable precautions that we have taken.
• If your Linked Bank Account has been closed, frozen, or subject to legal process.
• If you have not provided us with correct, complete, or current Account or Linked Bank Account information.
• If there are other exceptions stated in our agreement with you.

8. Confidentiality

We will disclose information to third parties about your Account or the transfers you make only: (a) where it is necessary for completing a transfer; (b) in order to verify the existence and condition of your Account for a third party, such as a credit bureau or merchant; (c) in order to comply with government agency or court orders; (d) as described in our Privacy Policy; or (e) if you give us your written permission.

9. Business days

Our business days are Monday through Friday, excluding federal holidays. Transfers requested on a non-business day will be processed on the next business day.

10. Additional provisions

a. Governing Law. This Disclosure and the electronic fund transfer services described herein are governed by the Electronic Fund Transfer Act, Regulation E, and, to the extent not preempted by federal law, the laws of the State of Missouri.

b. Amendments. We may amend this Disclosure at any time. We will provide you with at least twenty-one (21) days’ prior written notice of any change that would result in increased fees, increased liability for you, fewer types of available electronic fund transfers, or stricter limitations on the frequency or dollar amount of transfers.

c. Relationship to Account Agreement. This Disclosure is incorporated into and made a part of the Deposit Account Agreement between you and the Bank. In the event of a conflict between this Disclosure and the Account Agreement regarding electronic fund transfer rights and obligations, this Disclosure shall control to the extent required by federal law.

d. Program Manager and Ledger Provider. Easy Impound, as program manager, may assist in communicating error resolution notices and transfer requests between you and the Bank. Treasury Prime, Inc., as ledger provider, facilitates transaction processing on behalf of the Bank. Your rights under this Disclosure are against the Bank, regardless of which party you initially contact. Notifying Easy Impound of an error or unauthorized transfer constitutes notice to the Bank for purposes of the timeframes described in this Disclosure.

Contact information

If you have questions about electronic fund transfers, errors, unauthorized transfers, or wish to stop a preauthorized transfer, please contact: OMB Bank, 3570 S National Ave, Springfield, MO 65807, phone (417) 869-9000; or Easy Impound Customer Support, support@easyimpound.com, phone (307) 249-4185, www.easyimpound.com.

Acknowledgment. By opening an Account, selecting “I Agree,” or using electronic fund transfer services in connection with the Easy Impound Program, you acknowledge that you have received, read, and understood this Electronic Fund Transfer Disclosure (Regulation E Disclosure).

Electronic acceptance. If you accept this Disclosure electronically, the Easy Impound platform records your name, the date and time of acceptance, and the IP address associated with your acceptance. That record constitutes your signature.