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TRACE CAPITAL SYSTEMS
LEGAL DISCLOSURE

Terms of Use

EFFECTIVE DATE: MARCH 1, 2026 · LAST UPDATED: MARCH 1, 2026

Please read these Terms of Use carefully before using our website or services. These terms constitute a legally binding agreement between you and Trace Capital Systems.

SECTION 1 — ACCEPTANCE OF TERMS

By accessing or using the Trace Capital Systems website (tracecapitalsystems.com) and any services offered therein, you agree to be bound by these Terms of Use. If you do not agree to these terms, do not use this website or submit any forms.

These Terms of Use apply to all visitors, users, and clients who access or use our services, including the Forensic Trace Intake Form, the Client Portal, and any related communications.

SECTION 2 — NATURE OF SERVICES

Trace Capital Systems is a forensic recovery firm and PTIN-registered practitioner entity. Our services are strictly limited to:

• Forensic identification of unapplied capital positions (TC76X markers) on the Federal Tax Ledger.

• Identification of OBBBA-related ledger offsets (TC-846).

• Preparation and submission of IRS Form 8821 (Tax Information Authorization) for read-only ledger access.

• Reconciliation of dormant payroll tax credits including but not limited to WOTC, H-2B, and Veteran Hiring programs.

IMPORTANT: Trace Capital Systems does not operate as a Certified Public Accounting (CPA) firm, law firm, or investment advisor. Nothing on this website constitutes tax advice, legal counsel, or fiduciary guidance. Clients are strongly encouraged to consult a licensed CPA or tax attorney regarding their specific tax obligations.

SECTION 3 — ELIGIBILITY

To use our services, you must:

• Be an authorized signatory (Corporate Officer, Partner, Member-Manager, or equivalent) of the legal entity on whose behalf you are submitting information.

• Have the authority to authorize a Tax Information Authorization (Form 8821) on behalf of the business entity.

• Be at least 18 years of age.

• Provide accurate, complete, and truthful information in all intake forms and communications.

By submitting the Forensic Trace Intake Form, you represent and warrant that you meet all eligibility requirements above.

SECTION 4 — AUTHORIZATION & FORM 8821

By submitting the Forensic Trace Intake Form and executing the DocuSign e-signature process, you are authorizing Trace Capital Systems, as a PTIN-holding practitioner entity, to file IRS Form 8821 (Tax Information Authorization) on behalf of your business entity.

This authorization is read-only and does not grant Trace Capital Systems the ability to make changes to your tax filings, represent you before the IRS in a fiduciary capacity, or access any accounts beyond the scope of ledger reconciliation.

You may revoke this authorization at any time by submitting Form 8821 directly to the IRS with the revocation box checked, or by submitting a written revocation to Trace Capital Systems at rogers@tracecapitalsystems.com.

SECTION 5 — IDENTITY VERIFICATION

To satisfy IRS identity authentication requirements for remote PTIN practitioners (NIST IAL2 standard), all signatories are required to complete an identity verification process via DocuSign, which may include government-issued photo ID upload, liveness detection, and knowledge-based authentication.

By proceeding, you consent to this identity verification process. The resulting Certificate of Completion is retained as part of our compliance record and is not shared with third parties except as required by law.

SECTION 6 — FEES & CONTINGENCY MODEL

Trace Capital Systems operates on a contingency-based fee structure. Fees are only earned upon successful identification and recovery of dormant capital on behalf of the client.

• Phase 1 — Forensic Trace Activation: $150 (non-refundable processing fee)

• Phase 2 — Admin Liquidation Filing: $450

• Phase 3 — Final Recovery Fee: 20% of confirmed recovered funds

All fee structures are outlined in the separate Engagement Agreement provided to each client. By engaging our services, you agree to the fee schedule as stated in your Engagement Agreement.

SECTION 7 — ACCURACY OF INFORMATION

You agree to provide accurate, complete, and truthful information in all forms and communications with Trace Capital Systems. Providing false or misleading information, including but not limited to incorrect EINs, unauthorized signatories, or fabricated payroll data, may constitute fraud and could result in:

• Immediate termination of services.

• Referral to appropriate law enforcement agencies.

• Civil liability for damages incurred by Trace Capital Systems.

Trace Capital Systems is not liable for errors or delays caused by inaccurate information provided by the client.

SECTION 8 — INTELLECTUAL PROPERTY

All content on this website, including but not limited to text, graphics, logos, the "Trace Protocol™" methodology, and software, is the exclusive property of Trace Capital Systems and is protected by applicable intellectual property laws.

You may not reproduce, distribute, modify, or create derivative works from any content on this website without express written permission from Trace Capital Systems.

SECTION 9 — LIMITATION OF LIABILITY

To the maximum extent permitted by applicable law, Trace Capital Systems shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising from your use of this website or our services, including but not limited to:

• IRS determinations, audits, or enforcement actions unrelated to our specific services.

• Outcomes of tax filings prepared by the client or third-party advisors.

• Delays caused by IRS processing times, government shutdowns, or regulatory changes.

• Any unauthorized access to your data resulting from circumstances beyond our reasonable control.

Our total liability to you for any claims arising from these Terms shall not exceed the fees paid by you to Trace Capital Systems in the 12 months preceding the claim.

SECTION 10 — GOVERNING LAW & DISPUTE RESOLUTION

These Terms of Use shall be governed by and construed in accordance with the laws of the State of Nevada, without regard to its conflict of law provisions.

Any disputes arising from these Terms or your use of our services shall first be submitted to good-faith mediation. If mediation fails, disputes shall be resolved by binding arbitration in Clark County, Nevada, under the rules of the American Arbitration Association.

You waive any right to participate in a class action lawsuit or class-wide arbitration against Trace Capital Systems.

SECTION 11 — CHANGES TO THESE TERMS

Trace Capital Systems reserves the right to modify these Terms of Use at any time. Changes will be posted on this page with an updated effective date. Your continued use of our website or services after any changes constitutes acceptance of the revised terms.

It is your responsibility to review these Terms periodically for updates.

SECTION 12 — CONTACT

For questions regarding these Terms of Use, contact us at:

Trace Capital Systems

Attn: Legal & Compliance

rogers@tracecapitalsystems.com

725.234.1388

Ms. Rogers, Director of Client Relations

© 2026 TRACE CAPITAL SYSTEMS · ALL RIGHTS RESERVED · PTIN REGISTERED PRACTITIONER ENTITY

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