E-SIGN and Electronic Communications Policy and Procedures

Introduction

Glep Payments LLC (“Glep”) uses electronic records and electronic signatures to support efficient client onboarding, disclosures, and communications. This policy establishes procedures to ensure Glep’s electronic signature and consent practices comply with applicable law and meet bank partner expectations.

Policy Statement

Glep will obtain and document valid consent before delivering disclosures and communications electronically. Glep will maintain records and audit trails sufficient to demonstrate compliance, validate consent, and support record retention and examination readiness.

Scope

1. This policy applies to all employees, contractors, and third-party vendors involved
   1. Client onboarding
   2. Account opening workflows
   3. Disclosure delivery
   4. Electronic communications
2. Electronic signature and acceptance of agreements

Definitions

1. Electronic Signature: An electronic sound, symbol, or process attached to or logically associated with a record and executed or adopted by a person with intent to sign.
2. Electronic Consent (eConsent): Affirmative consent to receive electronic disclosures and communications and transact electronically.
3. Electronic Records: Disclosures, agreements, policies, notices, and communications provided electronically.

Consent Requirements (eConsent)

1. Before delivering required disclosures electronically, Glep will ensure:
   1. Clients receive clear disclosure that they are consenting to electronic delivery of required documents
   2. Clients provide affirmative consent (e.g., checkbox + “I Agree” action)
   3. Consent is logged with timestamp and record versioning
   4. If a client does not consent to electronic delivery, Glep may restrict access to features that require electronic delivery.

Required Disclosures & Document Delivery

1. Glep will ensure that all required disclosures, agreements, and notices delivered electronically:
   1. are presented in a format the client can access and retain
   2. are available for download or recordkeeping when applicable
   3. are delivered via approved methods (platform link, email delivery, or secure portal)

Hardware and Software Requirements

Glep will provide notice of minimum system requirements for accessing electronic records (e.g., internet access, modern browser, ability to view PDFs when applicable). If requirements materially change, Glep will provide notice consistent with operational procedures.

Withdrawal of Consent

Clients may request to withdraw consent for electronic communications by contacting Glep Compliance at the official compliance address. Glep will document the withdrawal request and evaluate whether continued use of the platform is feasible without electronic delivery.

Record Retention and Audit Trail

1. Glep will retain electronic consent and signature evidence in a manner that supports audit readiness, including:
   1. Consent language version
   2. Timestamp
   3. User identifier
   4. IP address or device/session information (where available)
   5. Executed agreement records
2. Records will be stored consistent with Glep’s record retention standards and maintained in an accessible format.

Vendor Oversight

1. If Glep uses third-party systems for electronic signature or electronic document delivery, those vendors must:
   1. meet Glep’s third-party risk management standards
   2. support audit logging and record retention
   3. provide contractual safeguards and security controls

Training and Monitoring

Relevant teams (Compliance, Operations, Sales, Customer Support) will receive training on eConsent workflows and appropriate handling of client communication requests. Compliance will periodically test that electronic consent is captured and retained properly.