PAYPAL BALANCE TERMS AND CONDITIONS

Last updated on May 20, 2024

About Your PayPal Balance Account

Please note that these PayPal Balance Terms and Conditions apply to accounts currently
or previously named PayPal Cash and PayPal Cash Plus. All references to “PayPal Balance
account” or “Balance Account” shall be deemed to include PayPal Cash and PayPal Cash
Plus accounts, as applicable.

These terms and conditions are between you and PayPal, Inc. and govern your use of your PayPal
Balance account and the PayPal services related to that account. The terms “PayPal Balance account”
or “Balance Account” in these terms and conditions will be used to refer to a PayPal Balance account
and shall include any account currently or previously known as a PayPal Cash account or a PayPal
Cash Plus account, as applicable.

These terms and conditions apply to U.S. Balance Accounts only. You must be an individual and
resident of the United States or one of its territories and at least 18 years old, or the age of majority
in your state of residence to open a U.S. Balance Account and use the PayPal services.

By opening and using a Balance Account, you agree to comply with all aspects of these terms and
conditions and any upcoming changes described on the Policy Updates page at the time you accept
these terms and conditions (which changes will apply to you on the indicated effective dates). These
terms and conditions include an agreement to resolve disputes by arbitration on an individual
basis. You also agree to comply with the following:

PayPal Account User Agreement

Acceptable Use Policy

Electronic Communications Delivery Policy (E-Sign Disclosure and Consent)

Please read carefully all of these terms and conditions, the terms of the above policies, and each of
the other terms and agreements that apply to you.

We may revise these terms and conditions and any of the other terms, agreements, or policies from
time to time. The revised version will be effective at the time we post it, unless otherwise noted. If
our changes reduce your rights or increase your responsibilities, we will provide notice of such
changes in accordance with the terms of the user agreement.
 Notice will include posting information about the changes on our Policy Updates page. If you
accepted these terms and conditions prior to us posting notice of the changes on our Policy
Updates page, then such notice will be provided at least 21 days before the applicable effective
date.

By continuing to use our services after any changes to these terms and conditions, you agree to abide
and be bound by those changes. If you do not agree with any changes to these terms and conditions,
you may close your Balance Account.

Opening a Balance Account

If you open a Balance Account you will be able to hold a balance, and use balance to send and receive
money, purchase things online using mobile devices or in stores, and make payments, among other
benefits. You can only open a Balance Account if you have a PayPal personal account (or “personal
account”) in good standing, and you can only use your Balance Account by accessing it through your
personal account. We will automatically link your Balance Account to your personal account.

Your login credentials for your personal account act as the credentials to access your Balance
Account.

Before you can open a Balance Account, we must verify or have previously verified the required
identifying information that you provide to us.

The required identifying information is: name, physical address, date of birth and taxpayer
identification number.

You are responsible for maintaining adequate security and control of any and all IDs, passwords,
personal identification numbers, or any other codes that you use to access your Balance Account and
the PayPal services. You must keep your mailing address, email address and other contact
information current in your PayPal profile.

Closing Your Balance Account

You can close your Balance Account without closing your personal account but you cannot close your
personal account without closing your Balance Account. Closing a personal account will result in
PayPal automatically closing your Balance Account. You can terminate your relationship with us at
any time without cost, but you will remain liable for all obligations related to your Balance Account
and personal account even after those accounts are closed. You must withdraw or transfer any funds
held in a Balance Account before closing the Balance Account.

In certain cases, you may not close your Balance Account, including:
 To evade an investigation.

If you have a pending transaction using your Balance Account as the payment method or an open
dispute or claim related to your Balance Account.

If your Balance Account has a negative balance.

If your Balance Account is subject to a hold or limitation.

Available Features of Balance Accounts

As described in more detail below, here are some of the things you can do with a Balance Account:

Receive money;

Hold money;

Convert money from one currency to another;

Withdraw money from your Balance Account to a debit card or bank account linked to your
personal account;

Transfer money for purchases of goods and services;

Send “personal
personal transactions
transactions” to and request personal transactions from friends and family;

Buy, sell, and hold certain cryptocurrencies if eligible;

Make in-store purchases using a PayPal-branded debit card linked to your Balance Account;

Withdraw money at ATMs using a PayPal-branded debit card;

Transfer money to and withdraw money from PayPal Savings;

Set up Direct Deposit of funds into your Balance Account;

Add cash into your Balance Account at several retail stores throughout the U.S.; and

Transfer proceeds from checks into your Balance Account using our remote check capture feature.

Receiving Funds into Your Balance Account

You may transfer money into your Balance Account from any bank account linked to your personal
account by requesting an electronic transfer from your bank account. You can also add funds from a
linked Visa or Mastercard Debit Card. There are daily, weekly, and monthly limits on the amounts you
can transfer to your Balance Account. Please refer to the How do I add money to my PayPal
balance from my bank? PayPal Help Center page for more information.
Money sent by someone else to your personal account will automatically be placed in your Balance
Account.

To receive money in a currency your Balance Account is not currently configured to accept, it may be
necessary to create a balance in your Balance Account in that currency or convert the money into
another currency. Certain currencies can only be received by converting the money into another
currency that PayPal allows you to hold. If the money is converted, PayPal’s transaction exchange
rate (including our currency conversion spread
spread) will be used.

You can add funds into your Balance Account at retail stores in amounts from $20.00 to $500.00 per
transaction. There are daily and monthly limits on the amounts you can add and daily, weekly, and
monthly limits on the number of times you can add money. Please refer to the What is PayPal add
Cash at Stores and how do I use it? PayPal Help Center page for more information. You can
also add funds into your Balance Account using the remote check capture feature where that feature
is available. Remote check capture is not available if you have a negative balance in your Balance
Account and may not be available in all locations. Please refer to the PayPal Help Center Cash a
Check page for more information and details on availability and other restrictions. If any fees are
charged for adding cash at stores and remote check capture transactions, they can be found in
the PayPal Balance Long Form Disclosure
Disclosure.

When you open a PayPal Balance account with PayPal, we may also provide you with a The Bancorp
Bank, N.A. (“Bancorp”) issued account number and routing number that you can use to set up Direct
Deposit into your Balance Account or to use your Balance Account as a payment method for goods
and services through a direct debit payment transaction that you initiate via a third-party
merchant’s website or mobile application. Otherwise, you can separately receive a Bancorp issued
account and routing number by enrolling in Direct Deposit or by opening a PayPal branded debit card.

You may arrange to have all or part of your paycheck or any federal or state government benefit or
payment (e.g., Federal tax refunds or Social Security payment) transferred directly into your Balance
Account by your employer or government payer, as applicable, by using the Direct Deposit feature.

To enroll, you will need to provide your employer or the government payer, as applicable, with the
account and routing numbers found in the Direct Deposit section available in the PayPal app or in the
“Account” section of settings after logging in on our website. Your employer or government payer may
also ask you to fill out their own direct deposit form. We do not charge any fees to set up or maintain
Direct Deposit.

We may offer early access to Direct Deposit funds to eligible customers. Direct Deposit and the earlier
availability of funds are subject to the timing of the payer’s funding. Funds transferred via Direct
Deposit generally will be available on the day the funds are applied to your account. Because we do
not receive funds via Direct Deposit instantly, there will be some delay between the payment being
initiated by the payer and the payment arriving at PayPal. For example, Direct Deposit of funds may
be delayed for several days in the event of a federal or bank holiday. You may review your periodic
statements or transaction history on [Link] or contact us at PayPal Customer Service to
verify that each Direct Deposit has been received. Funds added to your account via Direct Deposit,
including funds added using an account and routing number issued by Bancorp, are transferred to
and held by one or more banks insured by the Federal Deposit Insurance Corporation (FDIC) that we
choose in our discretion (“Program
Program Banks
Banks”) where they are eligible for FDIC pass-through insurance.
We reserve the right to accept, reject, or limit transfers via Direct Deposit in our sole discretion. If
you wish to cancel Direct Deposits, you must contact the payer directly.

To assist in the prevention of fraud, you represent the following:

For Direct Deposit of a tax refund

the name and Social Security Number associated with each refund payment will match the
name and Social Security Number associated with your PayPal account; and

involving a joint tax return, the name of the first person listed in the tax return and their
Social Security Number associated with the refund payment will match the name and Social
Security Number associated with the PayPal account holder.

For Direct Deposit of other federal payments, the name and Social Security Number associated
with each payment will match the name and Social Security Number associated with your PayPal
account.

Holding Funds in Your Balance Account

Unless otherwise expressly stated, all references to “funds” in these terms and conditions mean
money denominated in sovereign currency and not cryptocurrency or any other form of asset.

Any funds in your Balance Account represent unsecured claims against PayPal, unless you have
opened a PayPal Debit Mastercard® account (“PayPal Debit Card”), have enrolled in Direct Deposit, or
have bought or received cryptocurrency. In that case, PayPal places the U.S. dollar funds held in your
Balance Account in one or more Program Banks
Banks, as explained below in the paragraphs regarding
pass-through deposit insurance provided by the FDIC.

If your Balance Account is not eligible for FDIC pass-through insurance, PayPal combines your
Balance Account balance with the balances of other Balance Account holders and invests those funds
in liquid investments in accordance with state money transmitter laws. You will not receive any
interest or other return on the funds held with PayPal. PayPal owns the interest or other earnings on
these investments. However, the claim against PayPal represented by funds held in your Balance
Account is not secured by these investments and you do not have any ownership interest (either legal
or beneficial) in these investments. These pooled amounts are held apart from PayPal’s corporate
funds, and PayPal will neither use these funds for its operating expenses or any other corporate
purposes nor will it voluntarily make these funds available to its creditors in the event of bankruptcy.

If your Balance Account is eligible for FDIC pass-through insurance, PayPal will hold these funds as
your agent and custodian, and you will be the ultimate beneficial owner of the funds. PayPal will
deposit your funds into one or more custodial accounts we maintain for the benefit of eligible Balance
Account holders at one or more Program Banks. PayPal customer funds in these custodial accounts
are eligible for pass-through FDIC insurance coverage. Subject to the limitations set forth below, this
means that if a bank holding the custodial account in which your funds are deposited fails, you should
be eligible to be insured by the FDIC up to the standard maximum deposit insurance amount
(currently $250,000). Note that the FDIC insurance maximum applies to the aggregate of all funds
that you have on deposit in all accounts you have with the same bank in a particular FDIC ownership
category. For example, if you have a Balance Account and a Venmo account that are both held in your
individual capacity and you qualify for pass-through FDIC insurance in both accounts, any balances
you maintain in those accounts will be aggregated for purposes of FDIC limits to the extent we place
those funds in the same bank. If the total balances you have at any bank exceeds FDIC insurance
limits, the amount in excess of those limits could be lost if the bank fails. FDIC pass-through
insurance does not protect you against the failure of PayPal.

When we provide immediate or early credit of funds sent to your Balance Account, there might be a
delay between the time that funds are credited and when we actually transfer those funds to one of
the custodial accounts. That amount might not be eligible for FDIC pass-through insurance in your
name during this period, but we will still hold the funds as your agent and custodian in investments
authorized by our state regulators. FDIC pass-through insurance coverage is contingent upon our
maintaining accurate records and on both us and the Program Bank in which the funds are deposited
otherwise complying with requirements in FDIC regulations. The determinations of whether these
requirements have been satisfied and whether you are eligible for FDIC pass-through insurance
coverage will be made by the FDIC at the time that a Program Bank holding a custodial account fails.
You will not receive any interest or other return on funds held in these custodial accounts and you
agree that any earnings on funds in a custodial account belong to PayPal, and PayPal may be
compensated for placing your funds in a custodial account.

Your eligibility for FDIC pass-through insurance only applies to U.S. dollar funds held in your eligible
Balance Account balance and placed by PayPal in a Program Bank on your behalf. It does not apply to
funds held in any non-U.S. dollar currencies, nor does it apply to any amounts held in
cryptocurrencies.
Your Balance Account balance may be held in currencies other than U.S. dollars. You are responsible
for all risks associated with maintaining multiple currencies in a Balance Account. You may not
manage multiple currencies for speculative trading purposes, conversion arbitrage, conversion
options, or any other activity that PayPal determines is primarily for the purpose of gaining or
making money based on currency conversion rates. PayPal may hold, cancel, or reverse any
transaction we determine to violate this policy.

You can also use your Balance Account to hold or receive certain cryptocurrencies if eligible.
Cryptocurrency eligibility and other specific terms and conditions can be found in the PayPal
Cryptocurrencies Terms and Conditions
Conditions.

Withdrawing Money from a Balance Account

If you have money in a Balance Account, you may withdraw it by:

Transferring it via a standard transfer to an eligible debit card or a bank account linked to your
personal account for free,

Transferring it via an Instant Transfer to an eligible debit card or bank account linked to your
personal account, subject to the fees applicable to such transfers that can be found on the PayPal
Balance Long Form Disclosure and that will be disclosed to you in advance each time you
initiate such a withdrawal,

Transferring it to PayPal Savings, or

Requesting a check from us.

In addition, if you have a Balance Account, you may withdraw funds from an ATM using your PayPal-
branded debit card subject to the fees that may apply to such withdrawals that can be found on
the PayPal Balance Long Form Disclosure
Disclosure. You may also use your PayPal-branded debit card to
withdraw funds from a bank teller at a participating bank branch or other financial institution. For
more information on withdrawing money from your Balance Account, please refer to the How do I
get money out of my PayPal account? PayPal Help Center page
page..

If you have enrolled in Direct Deposit, we may offer you the ability to use your Balance Account as a
payment method for goods and services through a direct debit payment transaction that you initiate
via a third-party merchant’s website or mobile application. Direct debit payment transactions are
considered electronic fund transfers, and your Balance Account is debited on a one-time or recurring
basis as you instruct using your Bancorp account and routing number used for your Direct Deposits.
There are daily limits on the amount and number of direct debit payment transactions and limits on
the amount you can transfer per transaction. Please refer to the What is Direct Debit? PayPal
Help Center page for more information. As part of a direct debit payment transaction, you may be
required to provide various consents and agree to the terms and conditions presented by the
merchant. Management of any scheduled payments, including cancellation, can be done through the
merchant’s website or mobile application. You may also contact PayPal Customer Service at least
3 Business Days prior to any scheduled recurring transfer to enable a stop payment.

For any scheduled recurring transfer, if you order us to stop one of these payments 3 Business
Days or more before the transfer is scheduled, and we do not do so, we will be liable for your losses
or damages. If these regular payments may vary in amount, you have the right to advance notice of
the amount and date of the transfer from the merchant at least 10 days before the transfer is made.
If the merchant provides the option, you may choose instead to get this notice only when the
payment would differ by more than a certain amount from the previous payment, or when the
amount would fall outside certain limits that you set.

To protect us and our users from loss, we may delay a withdrawal, in certain situations, including if
we need to confirm that you have authorized the withdrawal or if other payments to your Balance
Account have been subject to a reversal (for example, as a result of a chargeback, bank reversal or
dispute by a buyer). If we place a limitation on your personal account, a payment is subject to a
hold, or your Balance Account or an associated account has a negative balance in any currency while a
withdrawal from your Balance Account is pending, you will have to reinitiate the withdrawal once the
limitation or hold has been lifted, or negative balance is fully paid.

We may set limits on your withdrawals.

We don’t charge a fee to make a standard transfer of funds from your Balance Account to an eligible
debit card or your bank using your personal account. If your debit card or bank account linked to your
personal account is eligible to receive Instant Transfer withdrawals from your Balance Account, you
will be provided the option to use it when you transfer money out of your account, subject to the
fees applicable to such transfers that can be found on the PayPal Balance Long Form
Disclosure and that will be disclosed to you in advance each time you initiate such a transfer.

When you withdraw funds in your Balance Account from an ATM using a PayPal-branded debit card,
you may be charged a fee by the owner of the ATM and an additional fee per the terms of your
Cardholder Agreement that can be found on the Legal Agreements page. Other withdrawal limits
also apply to the use of your PayPal-branded debit card. Please refer to the applicable Cardholder
Agreement for details that can be found on the Legal Agreements page.

If you request a paper check from us, you must cash it within 180 days of the date of issuance, or we
will return the funds to your Balance Account. We will not send a check to a post office box, and we
will only send a check to an address once we have confirmed that it belongs to you.
Authorization to Charge Your Balance Account
General authorization to charge your Balance Account

By opening a Balance Account, you authorize PayPal to charge your Balance Account (a) whenever
you choose your Balance Account as the payment method to send money or purchase something
using PayPal, (b) when you withdraw money from your Balance Account, (c) in connection with any
errors, claims, or disputes, and (d) for amounts you owe to PayPal.

Authorization of specific transactions

Each time you send money using your Balance Account as the funding source, you authorize PayPal to
charge your Balance Account for the amount you are sending and any applicable fees.

Each time you use PayPal to purchase something from a seller or make a donation using the balance
in your Balance Account, you authorize PayPal to charge your Balance Account for the amount
specified during the checkout process and any applicable fees. If the amount of your transaction
changes after checkout, you authorize PayPal to charge your Balance Account for the revised amount
(for example, if the amount increases because you add another product or service (e.g., expedited
delivery), the amount decreases, or is split because a portion of your order is canceled or delayed).

If your Balance Account cannot be charged, you authorize PayPal to charge the backup payment
method or other payment method linked to your personal account, pursuant to the hierarchy listed
in the User Agreement section on Payment Method Used for My Transaction (Automatic
Payments)
Payments).

If you request a transfer from your bank account to your Balance Account using PayPal, you authorize
PayPal to debit the selected bank account for the amount you are transferring and any applicable
fees and to debit or credit the linked bank account in connection with any errors, claims, or disputes.
You authorize PayPal to re-present this transfer from your bank account up to two (2) times if the
initial transfer is rejected by your bank for any reason. Adding money to your Balance Account while a
re-presentment is pending does not stop the original transfer from being re-presented by us to your
bank. If you request a withdrawal from your Balance Account, you authorize PayPal to debit your
Balance Account for the amount you are withdrawing and any applicable fees and to send those funds
to the destination you have designated.

When you request to transfer funds from your PayPal Savings account to your PayPal Balance
account, or from your PayPal Balance account to your PayPal Savings account, you authorize us to
debit the source account and credit the destination account in the amount you designate and for
applicable fees, if any, and in connection with any errors, claims, or disputes.

Revoking your authorization

You can revoke our authority to charge your Balance Account with respect to future transactions by
closing your Balance Account as described in the section Closing Your Balance Account
Account. Among
other things, you cannot close your Balance Account if you have a pending transaction using your
Balance Account as the payment method or an open dispute or claim related to your Balance
Account. You will remain liable for all obligations related to your Balance Account even after your
Balance Account is closed, and you authorize us to debit or credit a backup payment method in
connection with an error, dispute, or claim with respect to a transaction initiated prior to the time
that your Balance Account was closed.

Currency Conversion
How we convert currency

PayPal will always perform the conversion for transactions where your Balance Account is the funding
source for a transaction using your personal account. When PayPal converts currency, it will be
completed at the transaction exchange rate we set for the relevant currency exchange. The
transaction exchange rate is adjusted regularly and includes a currency conversion spread applied
and retained by us on a base exchange rate to form the rate applicable to your conversion. The base
exchange rate is based on rates within the wholesale currency markets on the conversion day or the
prior Business Day
Day; or, if required by law or regulation, set at the relevant government reference
rate(s).

For some uses of your Balance Account, PayPal may determine currency conversion is necessary. The
applicable currency conversion spread can be found on our Fees page under the heading Currency
Conversions
Conversions.

Fee Information and Regulatory Disclosures

You can find a list of all fees for the Balance Account on the PayPal Balance Long Form
Disclosure
Disclosure.

Account Statements and Requesting Account Records

You have the right to receive an account statement showing your Balance Account activity. You may
view your Balance Account statement by logging into your personal account. Balance Account holders
will receive two statements: one showing all transactions in their personal account and an additional
statement showing only transactions involving their Balance Account.

Sending Money and Buying

Sending Money to a Friend or Family Member
You can use your Balance Account as the funding source to send money to a friend's or family
member’s eligible PayPal account using the send money feature in your linked personal account. You
can also send money to a friend or family member even if they don’t have an eligible PayPal account
at the time you send them money, using their email address or mobile number in any currency that
PayPal supports, and you can choose your Balance Account as the payment method you want to use.
If the person to whom you are sending money does not have an eligible PayPal account, they can
claim it by opening an eligible PayPal account. If they don’t open an eligible PayPal account to claim
it, it will be refunded to you.

We may, at our discretion, impose limits on the amount of money you can send, including money you
send for purchases.

When you send money to a friend or family member who has an eligible PayPal account one of two
things may happen: they may accept or decline the money. If you use your linked Balance Account as
the funding source and they decline to accept the money, the money (including any fees you were
charged) will be refunded to your Balance Account.

The fees applicable to sending money to an eligible PayPal account can be found on the PayPal
Balance Long Form Disclosure and will be disclosed to you in advance each time you initiate a
transaction to send money to a friend or family member. If you convert money in your Balance
Account balance from one currency to another before sending money, PayPal’s transaction exchange
rate (including our currency conversion spread
spread) will be used.

Sending Money to or Receiving Money From PayPal Savings

PayPal Savings will be linked to your PayPal account. Additional information about PayPal Savings
can be found in the PayPal User Agreement
Agreement.

Transfers from your PayPal Savings to your PayPal balance will generally be available in your Balance
Account immediately upon transfer from your PayPal Savings even though we do not receive funds
transferred from your PayPal Savings instantly. For example, funds transferred from your PayPal
Savings to your Balance Account may be delayed for several days in the event of a federal or bank
holiday. If PayPal does not receive the funds from your PayPal Savings account, PayPal reserves the
right in its sole discretion to remove from your Balance Account the amount of funds for which
PayPal provided early access, but did not receive from the bank that provides your PayPal Savings
account.

Buying Something From, or Returning Something to, a

Seller Who Accepts PayPal Using Your Balance Account
You can purchase something from a seller who accepts PayPal, in any currency that the seller accepts
and that PayPal supports, using the balance in your Balance Account linked to your personal account.
This includes, for example:

Purchasing something at an online retailer’s website and selecting PayPal balance as your payment
method at checkout.

Sending money to a seller for goods or services and selecting PayPal balance as your payment
method.

Using your personal account and selecting PayPal balance as your payment method to purchase
something at a seller’s physical store.

When you purchase something from a seller who accepts PayPal you don’t pay a fee to PayPal. If
PayPal performs a currency conversion
conversion, PayPal’s transaction exchange rate (including
our currency conversion spread
spread) will be used.

Payment review
When PayPal identifies a potentially high-risk transaction, we review the transaction more closely
before allowing it to proceed. When this happens, PayPal will place a hold on the transaction and
notify the seller to delay shipping of the item. As a buyer, this may delay your receipt of the item you
purchased. If we clear the transaction, we will notify the seller and direct them to ship the item. If we
don’t clear the transaction, we will cancel it and return the funds to you, unless we are legally
required to take other action.

Refunds
When you purchase something from a seller online using your Balance Account linked to your personal
account as the funding source and the transaction is ultimately refunded, the money will be refunded
to your Balance Account. When you purchase something from a seller online using your bank account
linked to your personal account as the funding source and the transaction is ultimately refunded, we
will attempt to refund the money to your bank account. If we are unable to do so, we will refund the
money to your Balance Account. For purchases you make in a seller’s store location that you paid for
using your personal account and the transaction is ultimately refunded, the money will be refunded
to your Balance Account regardless of the funding source linked to the personal account you
designated to use for the purchase.

If PayPal performed a currency conversion for your transaction, and a refund is issued:

Within 1 day of the date of the original payment, PayPal’s transaction exchange rate used at the
time of the original payment will apply.
 Beyond 1 day of the date of the original payment, PayPal’s transaction exchange rate on the date
of the refund will apply.

Money will be refunded in the currency you paid; or if we are unable to refund in the currency you
paid, in your primary holding currency; or we are unable to refund in your primary holding currency,
then in U.S. dollars.

Restricted Activities and Holds

Restricted Activities
In connection with your use of our websites, your Balance Account, the PayPal services, or in the
course of your interactions with PayPal, other PayPal customers, or third parties, you must not:

Breach these terms and conditions, the PayPal Account User Agreement for your personal
account, the PayPal Acceptable Use Policy
Policy, the Commercial Entity Agreements (if they
apply to you), or any other agreement between you and PayPal;

Violate any law, statute, ordinance, or regulation (for example, those governing financial services,
consumer protections, unfair competition, anti-discrimination or false advertising);

Infringe PayPal’s or any third party’s copyright, patent, trademark, trade secret or other
intellectual property rights, or rights of publicity or privacy;

Sell counterfeit goods;

Act in a manner that is defamatory, trade libelous, threatening or harassing;

Provide false, inaccurate or misleading information;

Send or receive what we reasonably believe to be potentially fraudulent funds;

Refuse to cooperate in an investigation or provide confirmation of your identity or any

information you provide to us;

Attempt to double dip during the course of a dispute by receiving or attempting to receive funds
from both PayPal and the seller, bank or debit card issuer for the same transaction;

Control an account that is linked to another account that has engaged in any of these restricted
activities;

Conduct your business or use the PayPal services in a manner that results in or may result in;

complaints;
 requests by buyers (either filed with us or card issuers) to invalidate payments made to you;

fees, fines, penalties or other liability or losses to PayPal, other PayPal customers, third
parties or you;

Allow your Balance Account to have a negative balance;

Access the PayPal services from a country that is not included on PayPal’s permitted countries
list
list;

Take any action that imposes an unreasonable or disproportionately large load on our websites,
software, systems (including any networks and servers used to provide any of the PayPal services)
operated by us or on our behalf or the PayPal services;

Facilitate any viruses, trojan horses, malware, worms or other computer programming routines
that attempts to or may damage, disrupt, corrupt, misuse, detrimentally interfere with,
surreptitiously intercept or expropriate, or gain unauthorized access to any system, data,
information or PayPal services;

Use an anonymizing proxy; use any robot, spider, other automatic device, or manual process to
monitor or copy our websites without our prior written permission; or use any device, software or
routine to bypass our robot exclusion headers;

Interfere or disrupt or attempt to interfere with or disrupt our websites, software, systems
(including any networks and servers used to provide any of the PayPal services) operated by us or
on our behalf, any of the PayPal services or other users’ use of any of the PayPal services;

Take any action that may cause us to lose any of the services from our Internet service providers,
payment processors, or other suppliers or service providers;

Circumvent any PayPal policy or determinations about your Balance Account such as temporary or
indefinite suspensions or other account holds, limitations or restrictions, including, but not
limited to, engaging in the following actions: attempting to open new or additional PayPal
account(s) when your Balance Account has a negative PayPal balance or has been restricted,
suspended or otherwise limited; opening new or additional PayPal accounts using information that
is not your own (e.g. name, address, email address, etc.); or using someone else’s PayPal account;
or

Harass and/or threaten our employees, agents, or other users.

Actions We May Take if You Engage in Any Restricted

Activities
If we believe that you’ve engaged in any of these activities, we may take a number of actions to
protect PayPal, its customers and others at any time in our sole discretion. The actions we make take
include, but are not limited to, the following:

Limit your Balance Account, and/or close or suspend your Balance Account, immediately and
without penalty to us;

Refuse to provide the PayPal services to you in the future;

Limit your access to our websites, software, systems (including any networks and servers used to
provide any of the PayPal services) operated by us or on our behalf, your Balance Account or any
of the PayPal services, including limiting your ability to pay or send money with your Balance
Account, restricting your ability to send money or make withdrawals;

Hold your Balance Account balance for up to 180 days if reasonably needed to protect against the
risk of liability or if you have violated our Acceptable Use Policy
Policy;

Contact buyers who have purchased goods or services from you using PayPal, your bank, other
impacted third parties or law enforcement about your actions;

Update inaccurate information you provided us;

Take legal action against you;

If you’ve violated our Acceptable Use Policy

Policy, then you’re also responsible for damages to PayPal
caused by your violation of this policy; or

If you are a seller and you violate the Acceptable Use Policy, then in addition to being subject to
the above actions you will be liable to PayPal for the amount of PayPal’s damages caused by your
violation of the Acceptable Use Policy. PayPal may deduct such damages directly from any existing
balance in any PayPal account you control.

If we close your Balance Account or terminate your use of the PayPal services for any reason, we’ll
provide you with notice of our actions and make any unrestricted funds held in your Balance Account
available for withdrawal.

You are responsible for all reversals, chargebacks, claims, fees, fines, penalties and other liability
incurred by PayPal, any PayPal customer, or a third party caused by or arising out of your breach of
these terms and conditions, and/or your use of the PayPal services.

Holds and Limitations

What are holds and limitations
Under certain circumstances, in order to protect PayPal and the security and integrity of the network
of buyers and sellers that use the PayPal services, PayPal may take account-level or transaction-level
actions. Unless otherwise noted, if we take any of the actions described here, we’ll provide you with
notice of our actions, but we retain the sole discretion to take these actions. To request information
in connection with an account limitation, hold or reserve, you should visit the Resolution Center or
follow the instructions in our email notice with respect to the limitation or hold. Account holds or
limitations may impact your ability to move funds to or from your PayPal Savings account until the
hold or limitation on your PayPal account is lifted.

Our decision about holds and limitations may be based on confidential criteria that are essential to
our management of risk and the protection of PayPal, our customers and/or service providers. We
may use proprietary fraud and risk modeling when assessing the risk associated with your PayPal
account. In addition, we may be restricted by regulation or a governmental authority from disclosing
certain information to you about such decisions. You agree that we have no obligation to disclose the
details of our risk management or security procedures to you.

Holds
A hold is an action that PayPal may take under certain circumstances either at the transaction level
or the account level. When PayPal places a temporary hold on a payment, the money is not available
to either the sender or the recipient. PayPal reviews many factors before placing a hold on a
payment, including: account tenure, transaction activity, past customer disputes, and overall
customer satisfaction.

Holds based on PayPal’s risk decisions

We may place a hold on payments sent to your Balance Account if, in our sole discretion, we believe
that there may be a high level of risk associated with you, your Balance Account, your
personal account, or your transactions or that placing such a hold is necessary to comply with state
or federal regulatory requirements. We make decisions about whether to place a payment hold based
on a number of factors, including information available to us from both internal sources and third
parties. When we place a hold on a payment, the funds will appear in your Balance Account with an
indication that they are unavailable or pending. We’ll notify you, either through your Balance Account
or directly by phone or email, whenever we place a hold.

Risk-based holds generally remain in place for up to 21 days from the date the payment was received
into your Balance Account. We may release the hold earlier under certain circumstances, but any
earlier release is at our sole discretion. The hold may last longer than 21 days and can be in effect up
to 180 days.
Account Limitations
Limitations are implemented to help protect PayPal, buyers and sellers when we notice restricted
activities
activities, an increased financial risk, or activity that appears to us as unusual or suspicious.
Limitations also help us collect information necessary for keeping your Balance Account open.

There are several reasons why your account could be limited, including:

If we suspect someone could be using your Balance Account without your knowledge, we’ll limit it
for your protection and look into the fraudulent activity.

If your bank lets us know that there have been unauthorized transfers between your Balance
Account and your bank account.

In order to comply with applicable law.

If we believe in our sole discretion that you have breached these terms and conditions or violated
the Acceptable Use Policy
Policy.

Seller performance indicating your PayPal account is high risk. Examples include: indications of
poor selling performance because you’ve received an unusually high number of claims and
chargebacks, selling an entirely new or high-cost product type, or if your typical sales volume
increases rapidly.

Unless a permanent limitation is placed on your account, you will need to resolve any issues with your
Balance Account and personal account before a limitation can be removed. Normally, this is done
after you provide us with the information we request. However, if we reasonably believe a risk still
exists after you have provided us that information, we may take action to protect PayPal, our users,
a third party, or you from reversals, fees, fines, penalties, legal and/or regulatory risks and any other
liability.

Court Orders, Regulatory Requirements or Other Legal

Process
If we are notified of a court order or other legal process (including garnishment or any equivalent
process) affecting you, or if we otherwise believe we are required to do so in order to comply with
applicable law or regulatory requirements, we may be required to take certain actions, including
holding payments to/from your Balance Account, placing a limitation on your Balance Account, or
releasing your funds. We will decide, in our sole discretion, which action is required of us. Unless the
court order, applicable law, regulatory requirement or other legal process requires otherwise, we will
notify you of these actions. We do not have an obligation to contest or appeal any court order or legal
process involving you or your Balance Account. When we implement a hold or limitation as a result of
a court order, applicable law, regulatory requirement or other legal process, the hold or limitation
may remain in place longer than 180 days.

Liability for Unauthorized Transactions and Other Errors

Protection from Unauthorized Transactions
To protect yourself from unauthorized activity in your Balance Account, you should regularly log into
your personal account and review your Balance Account statements. PayPal will notify you of each
transaction by sending an email to your primary email address on file. You should review these
transaction notifications to ensure that each transaction was authorized and accurately completed.

PayPal will protect you from unauthorized activity in your Balance Account. When this protection
applies, PayPal will cover you for the full amount of the unauthorized activity as long as you
cooperate with us and follow the procedures described below.

Additional rules and procedures for addressing an unauthorized transaction apply in cases involving
cryptocurrencies. You can find the additional rules and procedures in the Liability for Unauthorized
Transactions and Errors section of the PayPal Cryptocurrencies Terms and Conditions
Conditions.

What is an Unauthorized Transaction

An “Unauthorized Transaction” occurs when money is sent from your Balance Account that you did
not authorize and that did not benefit you. For example, if someone steals or fraudulently obtains
your password, uses the password to access funds in your Balance Account, and sends a payment
using those funds, an Unauthorized Transaction has occurred.

What is not considered an Unauthorized Transaction

It is NOT an Unauthorized Transaction if you grant authority to someone to use your Balance Account
(by giving them your login information) and they exceed the authority you gave them. You are
responsible for transactions made in this situation unless you have previously notified PayPal that
you no longer authorize transfers by that individual.

Reporting an Unauthorized Transaction

If you believe your PayPal login information has been lost or stolen, please contact PayPal
customer service immediately or call: (888) 221-1161 or write: PayPal, Attn: Error Resolution
Department, P.O. Box 45950, Omaha, NE 68145-0950.

Tell us AT ONCE if you believe that an electronic fund transfer has been made without your
permission using your login information or by other means. You could lose all the money in your
Balance Account. If you tell us within 60 days after we provide you your Balance Account and
personal account statements showing transfers you did not make, you will be eligible for 100%
protection for Unauthorized Transactions.

Also, if your Balance Account statement shows transfers that you did not make, including those made
with your PayPal login information or by other means, tell us at once. If you do not tell us within 60
days after we provided the statement to you, you may not get back any money you lost after the 60
days if we can prove that we could have stopped someone from taking the money if you had told us
in time. If a good reason (such as a long trip or a hospital stay) kept you from telling us, we may
extend the time periods.

Error Resolution
What is an Error
An “Error” means the following:

When money is either incorrectly taken from your Balance Account or incorrectly placed into your
Balance Account, or when a transaction is incorrectly recorded in your Balance Account.

You send a payment and the incorrect amount is debited from your Balance Account.

An incorrect amount is credited to your Balance Account.

A transaction is missing from or not properly identified in your Balance Account statement.

We make a computational or mathematical error related to your Balance Account.

You request receipt or periodic statement documents that PayPal is required to provide to you.

You request information concerning preauthorized (recurring) transfers to your Balance Account
that PayPal is required to provide to you.

You request additional information or clarification concerning a transfer to or from your Balance
Account, including a request you make to determine whether an error has occurred.

You inquire about the status of a pending transfer to or from your Balance Account.

You request documentation or other information, unless the request is for a duplicate copy for tax
or other record-keeping purposes.

What is not considered an Error

The following are NOT considered Errors:
 If you give someone access to your Balance Account (by giving them your login information) and
they use your Balance Account without your knowledge or permission. You are responsible for
transactions made in this situation.

Invalidation and reversal of a payment as a result of the actions described under Refunds,
Reversals and Chargebacks
Chargebacks.

Routine inquiries about the balance in your Balance Account.

Requests for duplicate documentation or other information for tax or other recordkeeping
purposes.

In case of Errors or questions about your electronic transfers

Telephone us at (888) 221-1161, contact us through the PayPal Resolution Center
Center; or write us at
PayPal, Attn: Error Resolution Department, P.O. Box 45950, Omaha, NE 68145-0950.

Notify us as soon as you can, 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
60 days after we sent the FIRST statement on which the problem or error appeared.

Tell us your name and account number (if any).

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.

If you tell us orally, we may require that you send us your complaint or question in writing within
10 Business Days
Days.

We will determine whether an error occurred within 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 45 days to
investigate your complaint or question. If we decide to do this, we will credit your Balance Account
within 10 Business Days for the amount you think is in error, so that you will have the 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 10 Business Days
Days, we may not credit your
Balance Account.

For errors involving new Balance Accounts, point-of-sale transactions, or foreign-initiated

transactions, we may take up to 90 days to investigate your complaint or question. For new Balance
Accounts, we may take up to 20 Business Days to credit your Balance Account for the amount you
think is in error.
We will tell you the results within 3 Business
Business Days
Days after completing our investigation. If we decide
that there was no error, we will send you a written explanation. You may ask for copies of the
documents that we used in our investigation.

Processing Errors
We will rectify any processing error that we discover. If the error results in:

You receiving less than the correct amount to which you were entitled, then we will credit your
Balance Account for the difference between what you should have received and what you actually
received.

You receiving more than the correct amount to which you were entitled, then we will debit your
Balance Account for the difference between what you actually received and what you should have
received.

Our not completing a transaction on time or in the correct amount, then we will be responsible to
you for your losses or damages directly caused by this failure, unless:

through no fault of ours, you did not have enough available funds to complete the
transaction;

our system was not working properly and you knew about the breakdown when you started
the transaction; or

the error was due to extraordinary circumstances outside our control (such as fire, flood or
loss of Internet connection), despite our reasonable precautions.

Processing errors are not:

Delays that result from PayPal applying holds

holds or
or limitations
limitations.

Delays based on a payment

payment review
review.

Your errors in making a transaction (for example, mistyping an amount of money that you are
sending).

Remittance Transfer Errors

What
What is
is aa Remittance
Remittance Transfer
Transfer
You may be protected for certain errors when you send money outside the U.S. using a Balance
Account. A “Remittance Transfer” is a transaction that meets the following criteria:

The payment is sent from a Balance Account that is used primarily for personal, family or
household purposes,

The payment is made for personal, family or household purposes,

The payment is made using the send money feature through your personal account,

The payment amount equals or exceeds $15 U.S. dollars (excluding fees charged to you) or the
foreign currency equivalent calculated using exchange rates in effect at the time of the
transaction, and

The recipient received the payment in a PayPal account outside of the U.S.

Payments that you make at a merchant website or location by selecting PayPal as a payment option
are not “Remittance Transfers.”

What
What qualifies
qualifies as
as aa Remittance
Remittance Transfer
Transfer Error
Error
A “Remittance Transfer Error” occurs if:

You paid an incorrect amount to send the Remittance Transfer. For example, you were charged
more than the total shown on the remittance transfer receipt you received (unless the total shown
on the receipt was an estimate, and the difference results from application of the actual exchange
rate, fees, and taxes).

PayPal made a computational or bookkeeping error, such as a miscalculation of the amount the
recipient received.

The amount stated in the remittance transfer receipt was not made available to the recipient,
unless:

we stated in the remittance transfer receipt that we used estimates and the difference in the
amount received and the amount stated in the remittance transfer receipt results from
application of the actual exchange rate, fees, and taxes, or

the problem was caused by extraordinary circumstances outside our control.

Funds were available to the recipient later than the date of availability that was disclosed to you
on the remittance transfer receipt or were not delivered, unless:
 extraordinary circumstances outside our control caused the delay, and we could not
reasonably anticipate those circumstances,

delays resulted from fraud screenings, or were caused by requirements of the Office of
Foreign Assets Controls or similar requirements, or

you (or someone assisting you) made the transfer with fraudulent intent.

You request documentation or information concerning the Remittance Transfer, such as

information required to determine if a Remittance Transfer Error occurred.

What
What is
is not
not considered
considered aa Remittance
Remittance Transfer
Transfer Error
Error
The following are NOT considered Remittance Transfer Errors:

An inquiry about the status of a Remittance Transfer, except where the funds from the transfer
were not made available to a designated recipient by the disclosed date of availability,

A request for information for tax or other recordkeeping purposes,

A change requested by the designated recipient, or

A change in the amount or type of currency received by the designated recipient from the amount
or type of currency stated in the disclosure provided you, if we relied on information provided by
you in making the disclosure.

What
What to
to do
do if
if you
you think
think there
there has
has been
been aa Remittance
Remittance Transfer
Transfer Error
Error or
or
problem
problem
If you think there has been a Remittance Transfer Error or problem with your Remittance Transfer:

Call us at: (888) 221-1161.

Write us at: PayPal, Attn: Error Resolution Department, P.O. Box 45950, Omaha, NE 68145-0950.

Log in to your personal account at [Link] and go to the Resolution

Resolution Center
Center and dispute a
transaction.

You must contact us within 180 days of the date we promised to you that funds would be made
available to the recipient. When you do, please tell us:

Your name, address and telephone number,

The error or problem with the transfer, and why you believe it is an error or problem,
 The name of the person receiving the funds, and if you know it, his or her telephone number or
address,

The dollar amount of the transfer, and

The confirmation code or number of the transaction.

We will determine whether an error occurred within 90 days after you contact us and we will correct
any error promptly. We will tell you the results within 3 Business
Business Days
Days after completing our
investigation. If we decide that there was no error, we will send you a written explanation. You may
ask for copies of any documents we used in our investigation.

Other Legal Terms

Communications Between You and Us
If you provide us your mobile phone number, you agree that PayPal and its affiliates may contact you
at that number using autodialed or prerecorded message calls or text messages to: (i) service your
PayPal branded accounts, (ii) investigate or prevent fraud, or (iii) collect a debt. We will not use
autodialed or prerecorded message calls or texts to contact you for marketing purposes unless we
receive your prior express written consent. We may share your mobile phone number with service
providers with whom we contract to assist us with the activities listed above, but we will not share
your mobile phone number with third parties for their own purposes without your consent. You do
not have to agree to receive autodialed or prerecorded message calls or texts to your mobile phone
number in order to use and enjoy the products and services offered by PayPal. You can decline to
receive autodialed or prerecorded message calls or texts to your mobile phone number by updating
your preferences in your PayPal account settings at [Link]
[Link], by contacting customer
customer
support
support, by calling us at 1-844-629-9108, or by replying STOP to a message. The frequency of
messages may vary, and standard telephone minute and text charges may apply. Neither we nor your
phone carriers are liable for delayed or undelivered messages.

PayPal may communicate with you about your Balance Account and the PayPal services electronically
as described in our Electronic
Electronic Communications
Communications Delivery
Delivery Policy
Policy. You will be considered to have
received a communication from us, if it’s delivered electronically, 24 hours after the time we post it
to our website or email it to you. You will be considered to have received a communication from us, if
it’s delivered by mail, 3 Business
Business Days
Days after we send it.

Unless you’re communicating with us about a matter where we’ve specified another notice address
(for example, our Liability
Liability for
for Unauthorized
Unauthorized Transactions
Transactions and
and Other
Other Errors
Errors process), written
notices to PayPal must be sent by postal mail to: PayPal, Inc., Attention: Legal Department, 2211
North First Street, San Jose, California 95131.
Annual Report 2024 for Calendar Year 2023 | U.S. Office of Government Ethics; 5 C.F.R. part 2634 | Form Approved: OMB No. (3209-0001) (Updated Nov. 2021)

Executive Branch Personnel

Public Financial Disclosure Report (OGE Form 278e)

Filer's Information
Acosta Garcia, Alma N

Special Assistant to the President and House Legislative Affairs Liaison, White House - Biden-Harris Administration

Report Year: 2024

Other Federal Government Positions Held During the Preceding 12 Months:

None

Electronic Signature - I certify that the statements I have made in this form are true, complete and correct to the best of my knowledge.

/s/ Acosta Garcia, Alma N [electronically signed on 04/16/2024 by Acosta Garcia, Alma N in [Link]]

Agency Ethics Official's Opinion - On the basis of information contained in this report, I conclude that the filer is in compliance with applicable laws and regulations (subject to
any comments below).
/s/ Chung, Christie, Certifying Official [electronically signed on 05/15/2024 by Chung, Christie in [Link]]

Other review conducted by

/s/ Chung, Christie, Ethics Official [electronically signed on 05/15/2024 by Chung, Christie in [Link]]

U.S. Office of Government Ethics Certification

Acosta Garcia, Alma N - Page 1

Data Revised 05/15/2024

Acosta Garcia, Alma N - Page 2

1. Filer's Positions Held Outside United States Government

None

2. Filer's Employment Assets & Income and Retirement Accounts

None

3. Filer's Employment Agreements and Arrangements

None

4. Filer's Sources of Compensation Exceeding $5,000 in a Year

(N/A) - Not required for this type of report

5. Spouse's Employment Assets & Income and Retirement Accounts

# DESCRIPTION EIF VALUE INCOME TYPE INCOME
AMOUNT

1 Traditional IRA No

1.1 Fidelity Advisor New Insights Fund Class A Yes $1,001 - $15,000 None (or less
Shares (FNIAX) than $201)

Acosta Garcia, Alma N - Page 3

6. Other Assets and Income
# DESCRIPTION EIF VALUE INCOME TYPE INCOME
AMOUNT

1 Residential RENTAL PROPERTY #1, N/A $500,001 - Rent or Royalties $50,001 -

Washington, DC $1,000,000 $100,000

2 Residential RENTAL PROPERTY #2, N/A $1,000,001 - Rent or Royalties $50,001 -

Washington DC $5,000,000 $100,000

3 Residential RENTAL PROPERTY #3, N/A $1,000,001 - Rent or Royalties $50,001 -

Washington, DC $5,000,000 $100,000

4 Midland National Life Insurance Company, N/A $250,001 - None (or less
whole life policy #1 $500,000 than $201)

5 Midland National Life Insurance Company, N/A $250,001 - None (or less
whole life policy #2 $500,000 than $201)

6 U.S. bank #1 (cash) N/A $15,001 - None (or less

$50,000 than $201)

7 iShares Core Dividend Growth ETF (DGRO) Yes $1,001 - $15,000 $201 - $1,000

8 Artisan Developing World Fund Advisor Class Yes $1,001 - $15,000 None (or less
Shares (APDYX) than $201)

9 Artisan International Value Fund Advisor Class Yes $1,001 - $15,000 $201 - $1,000
Shares (APDKX)

10 iShares Core S&P Small-Cap ETF (IJR) Yes $1,001 - $15,000 $1,001 - $2,500

11 iShares Core S&P 500 ETF (IVV) Yes $1,001 - $15,000 $201 - $1,000

12 MFS Global Real Estate Fund Class I Shares Yes $1,001 - $15,000 None (or less
(MGLIX) than $201)

13 JOHCM International Select Fund Class I Yes $1,001 - $15,000 None (or less
Shares (JOHIX) than $201)

14 Neuberger Berman Large Cap Value Fund Yes $1,001 - $15,000 None (or less
Institutional Class (NBPIX) than $201)

Acosta Garcia, Alma N - Page 4

# DESCRIPTION EIF VALUE INCOME TYPE INCOME
AMOUNT

15 Principal MidCap Value Fund I Institutional Yes $1,001 - $15,000 None (or less
Class Shares (PVMIX) than $201)

16 T Rowe Price International Discovery Fund Yes $1,001 - $15,000 None (or less
(PRIDX) than $201)

17 MFS Mid Cap Growth Fund Class I Shares Yes $1,001 - $15,000 None (or less
(OTCIX) than $201)

18 Invesco S&P 500 Quality ETF (SPHQ) Yes $1,001 - $15,000 None (or less
than $201)

19 SPDR Portfolio S&P 500 High Dividend ETF Yes $1,001 - $15,000 None (or less
(SPYD) than $201)

20 SPDR Portfolio S&P 500 Growth ETF (SPYG) Yes $1,001 - $15,000 $201 - $1,000

21 TIAA-CREF International Equity Index Fund Yes $1,001 - $15,000 None (or less
Advisor Class Shares (TCIHX) than $201)

22 Residential Property #4 Washington DC N/A $1,000,001 - Rent or Royalties $100,001 -

$5,000,000 $1,000,000

23 Residential Property Rental Property #5, Port N/A $250,001 - Rent or Royalties None (or less
Tobacco, MD $500,000 than $201)

24 US credit union (cash) N/A $1,001 - $15,000 None (or less

than $201)

25 Vanguard Total Stock Market Index Fund Yes $1,001 - $15,000 None (or less
Admiral (VTSAX) than $201)

26 US bank #1 (cash) N/A $1,001 - $15,000 None (or less

than $201)

27 US bank #2 (cash) N/A $1,001 - $15,000 None (or less

than $201)

7. Transactions

Acosta Garcia, Alma N - Page 5

None

8. Liabilities
# CREDITOR NAME TYPE AMOUNT YEAR RATE TERM
INCURRED

1 FLAGSTAR BANK Mortgage $250,001 - 2016 3.625 30 years

(investment/rent $500,000
al property)

2 Roundpoint Mortgage Servicing Mortgage $500,001 - 2017 3.75 30 years

(investment/rent $1,000,000
al property)

3 PENNYMAC LOAN SERVICES Mortgage $500,001 - 2019 3.625 30 years

(investment/rent $1,000,000
al property)

4 PNC BANK HOME EQUITY $100,001 - 2020 4.09 30 years

LOAN $250,000

5 Small Business Administration Government loan $50,001 - 2021 3.75 30 years

$100,000

6 Wells Fargo Credit Card $15,001 - 2023 0% revolving

$50,000

7 Roundpoint Mortgage Servicing Mortgage $500,001 - 2022 2.75 30 years

(investment/rent $1,000,000
al property)

8 Mr. Cooper Mortgage $250,001 - 2023 7.49 30 years

(investment/rent $500,000
al property)

9 Well Fargo #2 Credit Card $15,001 - 2023 0 revolving

$50,000

10 Bank of America Credit Card $10,001 - 2023 0 revolving

$15,000

Acosta Garcia, Alma N - Page 6

# CREDITOR NAME TYPE AMOUNT YEAR RATE TERM
INCURRED

11 Bank of America #2 Credit Card $15,001 - 2023 0 revolving

$50,000

9. Gifts and Travel Reimbursements

None

Endnotes

Acosta Garcia, Alma N - Page 7

Summary of Contents

1. Filer's Positions Held Outside United States Government

Part 1 discloses positions that the filer held at any time during the reporting period (excluding positions with the United States Government). Positions are reportable even if the
filer did not receive compensation.

This section does not include the following: (1) positions with religious, social, fraternal, or political organizations; (2) positions solely of an honorary nature; (3) positions held as
part of the filer's official duties with the United States Government; (4) mere membership in an organization; and (5) passive investment interests as a limited partner or non-
managing member of a limited liability company.

2. Filer's Employment Assets & Income and Retirement Accounts

Part 2 discloses the following:

● Sources of earned and other non-investment income of the filer totaling more than $200 during the reporting period (e.g., salary, fees, partnership share, honoraria,
scholarships, and prizes)
● Assets related to the filer's business, employment, or other income-generating activities (1) that ended the reporting period with a value greater than $1,000 or (2) from
which more than $200 in income was received during the reporting period (e.g., equity in business or partnership, stock options, retirement plans/accounts and their
underlying holdings as appropriate, deferred compensation, and intellectual property, such as book deals and patents)

This section does not include assets or income from United States Government employment or assets that were acquired separately from the filer's business, employment, or
other income-generating activities (e.g., assets purchased through a brokerage account). Note: The type of income is not required if the amount of income is $0 - $200 or if the
asset qualifies as an excepted investment fund (EIF).

3. Filer's Employment Agreements and Arrangements

Part 3 discloses agreements or arrangements that the filer had during the reporting period with an employer or former employer (except the United States Government), such as
the following:

● Future employment
● Leave of absence
● Continuing payments from an employer, including severance and payments not yet received for previous work (excluding ordinary salary from a current employer)
● Continuing participation in an employee welfare, retirement, or other benefit plan, such as pensions or a deferred compensation plan
● Retention or disposition of employer-awarded equity, sharing in profits or carried interests (e.g., vested and unvested stock options, restricted stock, future share of a
company's profits, etc.)

Acosta Garcia, Alma N - Page 8

4. Filer's Sources of Compensation Exceeding $5,000 in a Year

Part 4 discloses sources (except the United States Government) that paid more than $5,000 in a calendar year for the filer's services during any year of the reporting period.

The filer discloses payments both from employers and from any clients to whom the filer personally provided services. The filer discloses a source even if the source made its
payment to the filer's employer and not to the filer. The filer does not disclose a client's payment to the filer's employer if the filer did not provide the services for which the client
is paying.

5. Spouse's Employment Assets & Income and Retirement Accounts

Part 5 discloses the following:

● Sources of earned income (excluding honoraria) for the filer's spouse totaling more than $1,000 during the reporting period (e.g., salary, consulting fees, and partnership
share)
● Sources of honoraria for the filer's spouse greater than $200 during the reporting period
● Assets related to the filer's spouse's employment, business activities, other income-generating activities (1) that ended the reporting period with a value greater than $1,000
or (2) from which more than $200 in income was received during the reporting period (e.g., equity in business or partnership, stock options, retirement plans/accounts and
their underlying holdings as appropriate, deferred compensation, and intellectual property, such as book deals and patents)

This section does not include assets or income from United States Government employment or assets that were acquired separately from the filer's spouse's business,
employment, or other income-generating activities (e.g., assets purchased through a brokerage account). Note: The type of income is not required if the amount of income is $0
- $200 or if the asset qualifies as an excepted investment fund (EIF). Amounts of income are not required for a spouse's earned income (excluding honoraria).

6. Other Assets and Income

Part 6 discloses each asset, not already reported, (1) that ended the reporting period with a value greater than $1,000 or (2) from which more than $200 in investment income
was received during the reporting period. For purposes of the value and income thresholds, the filer aggregates the filer's interests with those of the filer's spouse and dependent
children.

This section does not include the following types of assets: (1) a personal residence (unless it was rented out during the reporting period); (2) income or retirement benefits
associated with United States Government employment (e.g., Thrift Savings Plan); and (3) cash accounts (e.g., checking, savings, money market accounts) at a single financial
institution with a value of $5,000 or less (unless more than $200 in income was received). Additional exceptions apply. Note: The type of income is not required if the amount of
income is $0 - $200 or if the asset qualifies as an excepted investment fund (EIF).

Acosta Garcia, Alma N - Page 9

7. Transactions

Part 7 discloses purchases, sales, or exchanges of real property or securities in excess of $1,000 made on behalf of the filer, the filer's spouse or dependent child during the
reporting period.

This section does not include transactions that concern the following: (1) a personal residence, unless rented out; (2) cash accounts (e.g., checking, savings, CDs, money
market accounts) and money market mutual funds; (3) Treasury bills, bonds, and notes; and (4) holdings within a federal Thrift Savings Plan account. Additional exceptions
apply.

8. Liabilities

Part 8 discloses liabilities over $10,000 that the filer, the filer's spouse or dependent child owed at any time during the reporting period.

This section does not include the following types of liabilities: (1) mortgages on a personal residence, unless rented out (limitations apply for PAS filers); (2) loans secured by a
personal motor vehicle, household furniture, or appliances, unless the loan exceeds the item's purchase price; and (3) revolving charge accounts, such as credit card balances,
if the outstanding liability did not exceed $10,000 at the end of the reporting period. Additional exceptions apply.

9. Gifts and Travel Reimbursements

This section discloses:

● Gifts totaling more than $480 that the filer, the filer's spouse, and dependent children received from any one source during the reporting period.
● Travel reimbursements totaling more than $480 that the filer, the filer's spouse, and dependent children received from any one source during the reporting period.

For purposes of this section, the filer need not aggregate any gift or travel reimbursement with a value of $192 or less. Regardless of the value, this section does not include the
following items: (1) anything received from relatives; (2) anything received from the United States Government or from the District of Columbia, state, or local governments; (3)
bequests and other forms of inheritance; (4) gifts and travel reimbursements given to the filer's agency in connection with the filer's official travel; (5) gifts of hospitality (food,
lodging, entertainment) at the donor's residence or personal premises; and (6) anything received by the filer's spouse or dependent children totally independent of their
relationship to the filer. Additional exceptions apply.

Acosta Garcia, Alma N - Page 10

Privacy Act Statement

Title I of the Ethics in Government Act of 1978, as amended (the Act), 5 U.S.C. § 13101 et seq., as amended by the Representative Louise McIntosh Slaughter Stop Trading on
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This collection of information is estimated to take an average of ten hours per response, including time for reviewing the instructions, gathering the data needed, and completing
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Acosta Garcia, Alma N - Page 11

IMPORTANT DISCLOSURES
Investing in securities involves a risk of loss. Past performance is never a guarantee of future returns. Investing
in foreign stock markets involves additional risks, such as the risk of currency fluctuations. The following
constitutes the general views of Fisher Investments and should not be regarded as personalized investment
advice or a reflection of the performance of Fisher Investments or its clients. Nothing herein is intended to be
a recommendation or a forecast of market conditions. Rather, it is intended to illustrate a point. Current and
future markets may differ significantly from those illustrated herein. Not all past forecasts were, nor future
forecasts may be, as accurate as those predicted herein.
CONTENTS
INTRODUCTION 1
INVESTMENT ACCOUNT TYPES 5
MAIN TYPES OF INVESTMENT OPTIONS 9
EQUITIES 9
FIXED INCOME 13
FUNDS 20
CURRENCIES 27
DERIVATIVES 30
INTRODUCTION
How should you invest your hard-earned savings? It might be the most important question you ask
about your retirement. The financial services industry is rife with recommendations, yet few investors
fully understand what investment vehicles are available to them—the opportunities, the risks and how
suitable each one may be based on their unique goals. Those in the financial services industry—financial
advisors, brokers, etc.—often use jargon to steer you toward investments that benefit them or their
business. Few explain how certain investments work and why some options might be more appropriate
for your situation than others.

That’s why we put together this guide. At Fisher Investments, as a fiduciary, we are committed to
investor education and believe an informed investor is a better investor. We’ll introduce a variety of
the most common investment vehicles and detail the risks and opportunities of each. For a deeper
discussion of investments’ pros and cons, and how they may help you achieve a comfortable retirement,
we recommend contacting Fisher Investments to learn more.

1
 INVESTMENT
ACCOUNT TYPES
INVESTMENT ACCOUNT TYPES
Before we dive into investment choices, it’s important to understand the different account types you can
utilize. This is because the type of account you use can help determine whether a certain investment type
is appropriate for your situation and goals. The main account types are:

• Taxable: These include individual and joint accounts, corporate accounts and certain types of
trusts. The tax on gains and income varies depending on the account type and the account owner’s
tax bracket.

• Tax Deferred: Common types include traditional 401(k)s and Individual Retirement Accounts
(IRAs).

• Tax Exempt: These range from Roth 401(k)s and Roth IRAs, which allow for tax-free growth, to
529 Savings Plans, that allow for tax-free withdrawals for qualified education expenses.

Below is a breakdown of common types of accounts and the associated tax treatment of contributions
and withdrawals. We recommend consulting a tax advisor to create a plan that fits your individual
circumstance.

RETIREMENT ACCOUNTS’ TAX TREATMENT

CONTRIBUTIONS WITHDRAWALS
Pre-Tax After-Tax Tax-Free? Taxable?
Traditional 401(k) or 403(b) yes yes1 no yes4
Roth 401(k) or 403(b) no yes yes4,5 no
Traditional IRA yes2 yes3 no yes4
SEP IRA yes yes no yes4
ROTH IRA no yes yes4,5 no
1
Employer plan dependent.
2
Full deductibility of a contribution is dependent on income limits and whether an individual is covered by an employee-sponsored plan.
3
Higher earners will not receive a tax deduction for IRA contributions .
4
Early-withdrawal penalties generally apply before age 59.5, with some exceptions.
5
Earnings can be withdrawn tax-free only after account is open 5 years or in case of disability or death

While this isn’t an exhaustive list of account types, it can help you consider how certain investments may
be more suitable for some account types than others.

5
 MAIN TYPES
OF INVESTMENT
OPTIONS
EQUITIES
An equity investment represents partial ownership of a business or other entity. There are two main
types of equity investments: common stock and preferred stock. While both are technically equity,
these securities are very different. When investors refer to the “stock market” or “stocks,” it’s usually in
reference to common stocks. Preferred stocks have characteristics similar to fixed income. The common
stock market is much bigger and investors exchange shares more frequently. Additionally, common
stock provides higher capital appreciation potential, gives owners voting rights and allows investors to
participate in a company’s future profits—characteristics not typical of preferred stocks.

Because stocks offer a share in the future profitability of a company, which is theoretically unlimited, the
potential upside is equally unlimited. This is among the reasons why stocks have offered superior returns
over the long run. However, investing in stocks comes with risks and is also subject to loss for a variety
of reasons. Investors can even face total loss if a company goes bankrupt. In this section, we explore
common stocks in more detail.

WHAT’S THE BENEFIT OF OWNING STOCKS?

Historically, stocks have offered superior long-term growth relative to other asset classes. This is the
primary reason we believe stocks should comprise a sizeable portion of an investing account when you
need long-term growth. Stocks are also highly liquid—meaning you can easily buy and sell them. Other
asset classes, like real estate, can be more difficult to sell quickly—which may require owners to seek
alternative sources of financing or even offer price discounts if they need to get cash quickly.

WHAT ARE THE RISKS OF OWNING STOCKS?

High Short-Term Volatility

Stocks, like all investments, have risks. For starters, stocks have relatively high short-term volatility. Even
day-to-day swings can be dramatic—gaining or losing significant value. For example, the 1987 stock
market crash known as “Black Monday” saw the S&P 500 lose about 20% of its value on a single day.
This was the worst single-day performance recorded in modern market history—and an outlier—but
stock markets regularly see changes of greater than one percent. That’s why, in our view, a long-term
approach is required for investing in stocks. Stock market crashes have generally been followed by
periods of even greater recovery.

9
Concentration

For most long-term investors, a properly diversified strategy is a prudent approach. Investing in a single
company—or even just a handful of companies—can increase the risk of losing a substantial portion of
your investment. There are countless examples of companies that have gone bankrupt over the years. In
the event of a bankruptcy, stockholders are the last to get paid. So even if there’s any money left after all
the debt gets paid, it usually amounts to very little. Whether it’s blatant fraud (e.g., Enron) or simply a
company failing to adapt (e.g., Sears), having too much of your nest egg in one stock can be dangerous.

Even investing in narrow parts of the market can amplify volatility. Consider the FAANG stocks—
Facebook (now Meta), Amazon, Apple, Netflix and Google (Alphabet)—that have been popular in
recent years. If investors only put their money into these stocks, they would have seen tremendous
returns coming into 2022, based on the performance of those companies over the prior decade.
However, many of these stocks fell materially more than the market in the 2022 bear market.

Some investors want their portfolio to align with their beliefs and choose to refrain from investing in
certain parts of the market like “sin stocks” (e.g., tobacco, alcohol, defense, etc.). Others have personal,
religious or moral reasons to avoid areas like energy or certain financials. There’s nothing wrong with
wanting a portfolio to reflect your preferences, but being too restrictive can limit your ability to diversify.

10 800-568-5082
FISHER INVESTMENTS’ VIEW ON STOCKS
We believe stocks are an essential asset class for investors requiring long-term capital growth. Despite
stocks’ high short-term volatility, we believe their superior historical average returns make stocks one
of the best investment vehicles for long-term wealth accumulation. Throughout this guide, we will
illustrate how stocks have performed over long periods relative to other asset classes.

12%

10.3%
10%
9.2%

8%

6.0% 5.9%
6% 5.6%
5.1%

4.1%
4%
2.9%

2%

0%
Domestic Non - US US AAA Gold, in Natl. Assoc. of US 10 - year US Muni Inflation,
Stocks, Stocks, Corp Bonds, USD Realtors, Treasury Bonds, US CPI
S&P 500 MSCI EAFE >20 - year (Jan 1974 – Median (Jan 1926 – >10 - year (Jan 1926 –
(Jan 1926 – (Jan 1971 – maturity Dec 2021) Price of Single Dec 2021) maturity Dec 2021)
Dec 2021) Dec 2021) (Jan 1926 – Family Home (Jan 1926 –
Dec 2021) (Feb 1968 – Dec 2021)
Dec 2021)

Source: Global Financial Data, FactSet, as of 2/18/2022.

One of the most frequent questions we field from investors is “When is the right time to invest in the
market?” Unfortunately, market timing is nearly impossible and even the greatest investors in the world
can have incorrect market forecasts. That’s why we believe long-term investors should refrain from
making short-term decisions. Investors who wait for clarity before investing in the stock market can
miss out on returns, which can be damaging to their long-term success. As Exhibit 2 shows, time in the
market tends to be more important than market timing.

11
EXHIBIT 2: IT’S TIME IN THE MARKET, NOT TIMING THE MARKET,
THAT’S IMPORTANT
What if You Missed the Best Days?

YOUR CUMULATIVE
RETURN DROPPED TO RETURN DROPPED TO
10 of the 9,130 trading days (0.11%) 1,350% 7.94%
20 of the 9,130 trading days (0.22%) 751% 6.31%
30 of the 9,130 trading days (0.33%) 438% 4.93%
40 of the 9,130 trading days (0.44%) 256% 3.69%
50 of the 9,130 trading days (0.55%) 142% 2.56%

Value of $500,000 Invested in 1988

Value of $500,000 Invested in 1988

$18,000,000
$15,971,761
$16,000,000

$14,000,000

$12,000,000

$10,000,000

$8,000,000 $7,251,088

$6,000,000
$4,255,796
$4,000,000
$2,689,755
$1,779,433
$2,000,000 $1,208,950

$0
Fully Invested Missing Best Missing Best Missing Best Missing Best Missing Best
10 Up-Days 20 Up-Days 30 Up-Days 40 Up-Days 50 Up-Days

Source: FactSet, as of 2/3/2023. Daily S&P 500 Total Return Index from 1/1/1988 – 12/30/2022.

12 800-568-5082
FIXED INCOME
Fixed income securities offer investors a fixed interest payment on a regular schedule. The most common
type of fixed income security is bonds, which are loans from investors to a company or government
entity in return for a fixed interest payment and a promise to repay the loan when it comes due (or
“matures”). Because fixed income securities offer a fixed interest payment with less direct exposure to the
earnings or losses of a company, potential returns are limited, relative to stocks. However, bond holders
are compensated for lower return potential in two ways. First, the interest payments are effectively
assured as long as the issuer remains solvent. Second, in the event of a bankruptcy and liquidation, bond
holders are paid back ahead of equity investors.

Despite these potential benefits, bond holders still face a variety of risks. For example, if a bond pays
annual interest of 4% but a new issuer offers a bond paying 6%, the 4% bond may lose principal value
as investors sell it in favor of the bond paying 6%. This can happen in inflationary periods, which are
often accompanied by higher interest rates. Another potential risk is insolvency. A corporation may issue
a bond in 2025 with plans to pay regular interest for the next 30 years, but if it goes bankrupt before
2055, investors may lose both future interest payments and their principal. In this section, we explore the
different types of fixed income securities and how their characteristics generally differ from one another.

Fixed Income: Bonds

WHAT ARE BONDS?
If an entity, like the US government or a corporation, needs to borrow money to pay for things, it may
issue bonds. Investors purchase these bonds—lending the entity cash—in exchange for a promise to get
repaid at a future point in time known as the “maturity date.” With most types of bonds, investors are
entitled to semi-annual interest payments (the “coupon rate” or “yield”) to compensate them for lending
cash, much like a bank charges interest on a mortgage.

Similar to most listed stocks, bonds operate in an auction market. However, most bond issuances are
priced exactly the same. For example, Treasury bonds are usually priced in $1,000 denominations while
municipal bonds are often priced in multiples of $5,000. Therefore, the auction market in this case
dictates the interest rate an issuer needs to pay, not the price.

13
The interest rate varies depending on a variety of factors, including:

Maturity dates: How far into the future the bond matures. In many circumstances,
longer maturities carry higher interest rates than shorter maturities to compensate
investors for the longer duration.

Creditworthiness of the issuer: Investors require higher interest payments from

issuers at greater risk of default (i.e., failing to make an interest payment). Credit ratings
agencies (e.g., S&P, Moody’s, Fitch) attempt to delineate between the risk different
issuers represent, but their methodology is an imperfect science.

This auction process occurs on the primary market—where transactions happen between an entity and
investors. Once the the initial auction concludes, investors are able to buy and sell on the secondary
market—where transactions can happen between investors or other market makers.

WHY INVEST IN BONDS?

Lower Short-Term Volatility

Bond prices change inversely to interest rates, meaning prices go down when interest rates rise and
vice versa. Because interest rates don’t tend to move dramatically over short periods, the value of bonds
usually stays relatively steady. This could help provide a hedge against the volatility of other assets, like
stocks.

Priority Repayment in Bankruptcy

In the event the bond issuer enters bankruptcy, bondholders must be paid before stockholders. In this
way, bonds may be less risky than stocks.

WHAT ARE COMMON TYPES OF BONDS?

Government Bonds

The most common form of US government bonds is known as “Treasury” debt, or “Treasuries.”
Investors often perceive Treasuries as less risky than other kinds of debt, so they tend to have lower
yields. Treasuries are auctioned off on a regular basis with varying maturity dates—usually between 1
month and 30 years. The interest rate fluctuates based on a variety of factors, including the supply and
demand at each auction.

14 800-568-5082
Here are some other common types of government bonds:

• Municipal bonds are debt issued by state and local entities. The interest on these bonds is usually
paid free of federal income tax and potentially state and local taxes, depending on the bond and your
circumstance. Because municipal bonds aren’t taxed federally, they usually have lower interest rates
than Treasuries. They also could be more risky because state and local governments aren’t as solvent
as the federal government.

• iBonds have gotten a lot of attention amid higher inflation periods. The interest rate changes twice
a year and adjusts to the Consumer Price Index (CPI) plus a fixed rate set by the government. Unlike
other bonds, investors don’t receive interest payments. Instead, the bonds increase by the percentage
value of the semi-annually calculated rate. Investors are only able to purchase $10,000 per year per
person. Investors are prohibited from redeeming within one year of purchase. A penalty of three
months’ interest is taken if redeemed within five years.

• Treasury Inflation-Protected Securities or TIPS are bonds issued by the federal government
that can also offer protection against inflation. TIPS have a fixed interest rate determined by an
auction. However, the principal—the original cost of the bond—goes up with inflation and down
with deflation. As a result, the payments you receive also fluctuate. The US Treasury limits purchases
to $10 million when bought directly from the government at auction, but investors can exceed that
limit by purchasing TIPS on the secondary market.

Corporate Bonds

Corporate bonds are debt issued by companies. These bonds tend to have higher yields than government
debt because the perceived risk of default is higher.

High-Yield Bonds

Sometimes known as “junk bonds,” these generally have the lowest credit ratings. Companies usually get
low ratings because they have a higher risk of default, whether that’s due to already-high debt loads or
a material change in their business operations. These bonds tend to offer the highest yield compared to
government and corporate bonds.

15
WHAT ARE THE RISKS ASSOCIATED WITH BONDS?
Interest Rate Risk

The value of your bonds can decline if interest rates rise.

Default Risk

Even though bond holders get paid sooner than stock holders, they can still absorb heavy losses if a
company defaults on its loan obligations.

Credit Risk

Some debt is inherently more risky. One way the market assesses comparative risk is by looking at
“credit spreads”—the interest rate difference between what two issuers pay on debt with comparable
terms. A classic example is contrasting what the US government pays on a 30-year bond with what a US
corporation pays on a bond over the same period. As previously mentioned, corporate debt is generally
perceived as riskier than government-issued debt, so corporate debt yields tend to be higher. Like interest
rates, this credit spread can fluctuate. Spreads can widen in periods of distress, which hurts the value of
the bond if you hold the riskier asset.

Liquidity Risk

While bonds are generally a highly liquid asset class, specific individual bonds can be more difficult
to trade because there is a smaller secondary market for them. Bond funds offer investors more
diversification and liquidity over individual issuances, which can help mitigate this risk.

Prepayment Risk

If debt gets paid off earlier than the original maturity date, it can put investors into the unexpected
situation of having to find a replacement investment for those funds. If this happens, investors are repaid
their principal in full, but forfeit future interest payments. Investors may be adversely impacted if the
prevailing interest rate environment is lower than when the pre-paid debt was originally issued.

Opportunity Cost

Bonds have lower long-term return potential than stocks. If your portfolio requires higher long-term
growth, then bonds can you leave you short-handed. Your asset allocation should be derived from a
thorough examination of your goals, cash-flow needs and investment time horizon.

16 800-568-5082
FISHER INVESTMENTS’ VIEW ON BONDS
We believe bonds can play a crucial role in an investor’s portfolio—depending on their investing goals
and needs. Primarily, we see bonds as a useful method of dampening stock market volatility. In some
circumstances, having a higher allocation to bonds may be a prudent strategy. For example, investors
who are drawing a higher percentage of funds from their investments or those who are prone to
emotional decision-making amid stock market swings may need a healthy portion of their portfolio in
bonds. Conversely, an investor who doesn’t rely on their portfolio for many day-to-day expenses or is
simply looking to leave assets to heirs may not require any bond exposure.

While investing in bonds can limit short-term volatility, bonds have also historically had lower returns
relative to stocks. As Exhibit 3 shows, corporate bonds have had better returns than government and
municipal bonds over time—but all are materially lower than stock returns.

-
12%

10.3%
10%
9.2%

8%

6.0% 5.9%
6% 5.6%
5.1%

4.1%
4%
2.9%

2%

0%
Domestic Non - US US AAA Gold, in Natl. Assoc. of US 10 - year US Muni Inflation,
Stocks, Stocks, Corp Bonds, USD Realtors, Treasury Bonds, US CPI
S&P 500 MSCI EAFE >20 - year (Jan 1974 – Median (Jan 1926 – >10 - year (Jan 1926 –
(Jan 1926 – (Jan 1971 – maturity Dec 2021) Price of Single Dec 2021) maturity Dec 2021)
Dec 2021) Dec 2021) (Jan 1926 – Family Home (Jan 1926 –
Dec 2021) (Feb 1968 – Dec 2021)
Dec 2021)

Source: Global Financial Data, FactSet, as of 2/18/2022.

17
Fixed Income: Money Market Funds and CDs
WHAT ARE MONEY MARKET FUNDS?
Money market funds invest in short-term securities—usually with maturities of less than one year—that
generally provide a higher return than savings accounts. The types of securities and maturities vary from
fund to fund, but money market funds usually carry very little risk of default.

WHAT ARE CERTIFICATES OF DEPOSIT?

Certificates of Deposits are slightly different from money market instruments because they can have
terms that last longer than one year. A CD “locks up” your cash for a specific period of time and pays
interest to the purchaser. The interest rate is usually quoted in annual terms. So, for example, if you
bought a 6-month CD that pays 1%, your actual interest earned would be 0.5%. Depending on the CD
and financial institution offering it, there are usually penalties for withdrawing your money prior to
maturity.

WHY USE MONEY MARKET FUNDS OR CDs?

Investors should use these instruments when they are looking for very short-term returns. For example,
pretend you know you are going to need $20,000 for a home renovation project in three months. You
can get slightly better returns than what you would get in a savings account by purchasing a three-month
CD, and you don’t have to take the risk your cash will fall in value.

18 800-568-5082
WHAT ARE THE RISKS OF MONEY MARKET FUNDS OR CDs?
There aren’t as many explicit risks associated with these instruments, which is why returns are so low
relative to other types of investments. While money market funds aren’t technically insured against loss
by the FDIC, the risk of default is very low. However, it’s important to read the fine print, as the fees for
money market funds can eat into your return.

The implicit risks are much higher. It’s smart to keep anywhere from three months, to a couple years’
worth of expenses in cash/cash equivalents, depending on your comfort level. But having larger sums
tied up in low-return investments can leave your cash subject to the insidious impacts of inflation. If
your money isn’t keeping up with inflation, your purchasing power is declining.

FISHER INVESTMENTS’ VIEW ON MONEY MARKET FUNDS AND CDs

CD and money market fund returns are paltry when compared to other asset classes. As such, we
don’t believe they are very useful as investment vehicles. In our opinion, these instruments are most
appropriate when you are preparing for a known expense within a short, pre-defined period.

19
FUNDS
Funds are investment products that pool investor money together for a specific purpose. There are many
types of funds that invest in a variety of asset classes, take different management approaches and have
varying fee structures. Funds are usually a good option for investors with smaller amounts to invest
because they can offer needed diversification—and management in some cases—without having to
purchase a lot of different securities. However, those services come at a cost that can affect the return,
and these investments can typically be traded easily, which allow them to be used for purposes other
than those for which they may have been intended. In this section, we explore the main different types
of funds, how they compare and what investors should use them for.

Funds: Mutual Funds

WHAT ARE MUTUAL FUNDS?
Mutual funds are pooled investment vehicles with professional fund management. Investors purchase
shares of the fund and that money is aggregated and invested in the fund strategy. Funds can range
across asset classes. Regulations usually require the underlying strategy to align with the name of the
mutual fund. For example, you can’t have a mutual fund named “US Large Cap”—where one would
expect investments in large US corporations—and then have the assets invested in foreign bonds.
Mutual funds aren’t traded intraday. So investors will receive the closing price at the end of the trading
day for any redeemed shares.

Here are a few types of common mutual funds:

• Stock mutual funds invest in certain-sized companies, sectors, geographies, styles, etc.

• Bond mutual funds invest in different types of debt, including corporate, government, high yield,
municipal, etc.

• Balanced funds usually invest in a mix of stocks or bonds.

• Index funds attempt to track a specific underlying index (S&P 500, Dow Jones, etc.)

• Specialty funds may invest in other asset classes, like real estate and commodities or have a specific
mandate like socially responsible investing.

• Fund-of-funds is a fund that invests in a collection of mutual funds.

20 800-568-5082
CLOSED VS. OPEN FUNDS
There are two main types of mutual funds—closed ended and open ended. Closed-ended funds issue a
limited number of shares whereas open-ended funds can issue and retire shares as dictated by investor
demand.

A term commonly associated with mutual funds is net asset value (NAV). The NAV reflects the
aggregate value of the underlying investments. For example, if the value of the underlying stocks in an
equity mutual fund rises by 1% in a day, the NAV rises by 1%. However, mutual fund prices don’t always
reflect the NAV. Particularly in the case of closed-ended funds (finite shares), the price of the fund can
deviate from the NAV. If demand for a fund is high, it can trade at a premium to NAV, and if there is
very low demand, it can trade at a discount.

Be careful, though: Past performance does not indicate future results. Investors might justify paying a
premium for a high-performing fund, but the reasons for good performance may change as the market
changes. Similarly, an underperforming fund may not stay underperforming forever.

WHAT ARE THE BENEFITS OF MUTUAL FUNDS?

Mutual funds are a great way for investors to achieve diversification. Most investors are introduced to
mutual funds through employer-sponsored retirement plans like 401(k)s. Depending on the company,
employees may only have a handful of investing options to choose from, and these are usually mutual
funds. They are best utilized for smaller investment sums where diversification through individual
securities isn’t possible or is too expensive.

WHAT ARE THE DRAWBACKS OF USING MUTUAL FUNDS?

Mutual funds can have a number of drawbacks investors should know about:

High costs: While fees have come down over time, mutual funds are generally still
expensive relative to other options out there, such as exchange-traded funds (ETFs),
which we discuss in the next section.

Layered fees: Mutual funds often have various fees meant to incentivize money
managers to recommend proprietary funds. Sometimes this results in an upfront fee
for investment, penalties for not holding the fund for a minimum period of time and
commissions paid to brokers to cover sales advertising (12b-1 fees). It’s important to read
the fine print to understand what the total costs are.

21
 Over-diversification: Some investors take the approach of investing in a variety of
mutual funds. While this can make sense from an asset allocation perspective, an
investor can also become too diversified. For example, equity mutual funds sometimes
invest in thousands of companies. Imagine having multiple funds like that in your
portfolio. Even investing $100,000 in multiple funds with thousands of companies
dramatically reduces the impact a single company can have on overall returns.

No cohesive strategy: Mutual fund managers don’t work together. You can have one
mutual fund manager who dislikes a certain company and decides to sell, while another
manager may be buying that same company.

Funds: Exchange-Traded Funds (ETFs)

WHAT ARE ETFs?
Exchange-traded funds are pooled investment vehicles with similarities to mutual funds, but they can
be traded intraday, like stocks. ETFs started as a passive tool to track an underlying index such as the
S&P 500 or the Nasdaq Composite. ETF adoption has since grown dramatically and there is now a
wider range of options—including actively managed ETFs and ETFs that track a variety of asset classes
from stocks and bonds to cryptocurrencies. Like mutual funds, actively managed ETFs typically carry
a higher cost of management relative to passively managed ETFs. However, ETF fees are still typically
lower than those of mutual funds.

WHAT ARE THE BENEFITS OF ETFs?

ETFs give investors diversified investment exposure, typically at a lower cost than mutual funds, making
them attractive vehicles for long-term investors. For example, building out an individual bond portfolio
can be difficult as individual bonds don’t have as much liquidity as individual stocks do. So using a bond
ETF, which trades intraday, can improve liquidity.

22 800-568-5082
WHAT ARE THE RISKS OF ETFs?
While fees are typically lower than mutual funds, ETFs carry many of the same risks such as the
potential for over-diversification and lack of a cohesive strategy when multiple ETFs are used in
conjunction with one another. The ETF market has also evolved, and there are some ETFs that provide
risky positioning. For example, some ETFs offer leveraged returns that can provide double or even triple
the returns—and losses—of an underlying index. Unsuspecting investors may not be aware of the risks
these investments pose or the volatility associated with them. As always, it’s important to understand
what you are investing in and what risks could affect your investment.

FISHER INVESTMENTS’ VIEW ON MUTUAL FUNDS AND ETF s

Mutual funds and ETFs have an important purpose in the investing world, providing diversification
for portfolios of any size. However, we believe high net worth investors can build a well-diversified,
more efficient portfolio using individual stocks. By doing so, investors can avoid over-diversifying
their portfolios, streamline their approach and have more transparency on their strategy and fees.
Additionally, while many of these types of funds are designed to be held long term, some investors trade
them actively. Several independent research reports suggest investors who commonly switch between
strategies tend to underperform markets. Exhibit 4 illustrates one such study, conducted by DALBAR.
This study expands beyond just mutual funds and ETFs, but shows the pitfalls an investor can face when
regularly making short-term-focused investment decisions. We see investors do this with funds all too
often.

23
 -
Hypothetical Growth of $1 Million Invested 25 Years, 12/31/1996 – 12/31/2021

$11,000,000
$10,254,368
$10,000,000

$9,000,000

$8,000,000

$7,000,000
$6,086,837
$6,000,000

$5,000,000

$4,000,000
$3,064,524
$3,000,000

$2,000,000
$1,321,154
$1,000,000

$0
US Equities Average Equity US Bonds Average Bond
Fund Investors Fund Investors

Equities Bonds

Source: DALBAR, as of 4/5/2022. Quantitive Analysis of Investor Behavior based on an initial investment if $1 million, US
stocks and bonds are represented by the S&P 500 and Barclays US Aggregate Treasury Bond Index, respectively, 12/31/1996
– 12/31/2021. Indexes do not take into account the fees and expenses associated with investing, and individuals cannot invest
directly in any index. Average stock investor and average bond investor returns calculated as the change in assets after excluding
sales, redemptions and exchanges. This method of calculation captures realized and gains, dividends, interest, trading costs, sales
charges, fees and other applicable costs.

We do believe ETFs, in particular, can be part of a tailored portfolio, and Fisher Investments uses
ETFs for several purposes for clients. For example, we believe bond ETFs are very useful in providing
diversification and, perhaps more importantly, liquidity in an asset class where you can’t always
obtain these qualities easily. Additionally, ETFs can be used for smaller account sizes or as temporary
replacements when tax-loss harvesting—selling securities at a loss to capture the future tax benefit and
potentially reinvesting in what was originally sold as regulations allow. Overall, these instruments can
be useful tools in an investor’s toolkit, but we think high net worth investors should weigh the risks of
solely relying on them relative to a more strategic approach.

24 800-568-5082
Funds: Real Estate Investment Trusts (REITs)
WHAT ARE REITs?
While not technically a type of fund, Real Estate Investment Trusts pool investor assets together,
allowing them to get diversified exposure to a variety of real estate assets. Most types of REITs are traded
on public exchanges, similar to other types of funds, but some are private and come with additional
liquidity risks. To qualify as a REIT, an entity must meet a number of regulatory requirements. A few of
these requirements include:

• REITs must invest at least 75% of their assets into real estate.

• REITs must derive at least 75% of their gross income from rents from real property, interest on
mortgages financing real property or sales of real estate.

• REITs must distribute at least 90% of their taxable income in the form of shareholder dividends.

REITs can invest in a number of different types of real estate assets, ranging from housing and
commercial property to industrial and data centers. Some of the largest publicly traded REITs in the
world own cell phone towers. It’s particularly important for investors to understand these nuances if they
decide to invest in REITs because returns will vary depending on what is happening in the individual
markets the REIT is investing in.

WHAT ARE SOME OF THE BENEFITS OF REITs?

The main benefit of REITs is that they allow investors to get diversified exposure to real estate without
the cost and liquidity issues of investing in real property. Additionally, investors can get exposure to
types of real estate they may not be able to otherwise. For example, most individual investors can’t afford
to buy an office building or a warehouse, but they can invest in one through a REIT.

REITs also tend to have higher dividend yields than the average stock. This is partially because dividends
from REITs avoid “double taxation.” Because REITs are required to distribute almost all of their taxable
income, they typically pay very little in income tax. Compare this to a dividend from a regular company.
The company has to pay taxes on its earnings and then decides to pay dividends from the leftover cash.
Investors then also have to pay taxes on the dividends they receive. While we would caution against only
looking at dividends when considering an investment, the higher dividend may be attractive to income-
seeking investors.

25
WHAT ARE SOME RISKS OF REITs?
Historically, REITs have been sensitive to changes in interest rates. When rates increase, it tends to
negatively impact REIT prices. Additionally, an investor usually needs to do quite a bit of research on
the REIT to understand the underlying assets it holds. There can be large differences in performance
between types of REITs. Cell phone tower REITs behave very differently than data center REITs, for
example. Real estate also represents a small portion of the global stock universe. Considering many
retirees already count their home as one of their biggest assets, investing in REITs can lead to an over-
concentration in real estate trends.

FISHER INVESTMENTS’ VIEW ON REITs

REITs make up a small portion of the overall equity market, but can be appropriate investments
depending on your outlook on the economy, the industry the REIT operates in and the interest rate
environment, among other factors. Like any investment, we recommend evaluating your selection of
a REIT carefully. REITs come in many different forms and have a wide variety of fees and areas of
expertise. Some REITs are also known as “non-traded REITs,” which lack liquidity and can sometimes
trap an investor’s funds for lengthy periods while the REIT attempts to sell its assets—the underlying
real estate—before allowing fund withdrawals. If a REIT is publicly traded and in a broad benchmark
like the S&P 500, this represents lower liquidity risk.

26 800-568-5082
CURRENCIES
Unlike an appreciating asset like an equity—which represents ownership of a company and entitles
investors to a share of the company’s current and future profits—currencies fluctuate solely on supply
and demand relative to each other. The technicalities of what can cause supply and demand changes for
currencies are highly complex—and wide-ranging, depending on the currency in question.

In today’s world, you can break currency investing into two different types: fiat and digital. Fiat
currencies simply represent the currencies many are familiar with—the US dollar, the British pound, the
Japanese yen, etc.—while digital currencies are typically cryptocurrencies or tokens. In this section, we
explore both and detail what we think you should know when it comes to investing in currencies.

Currencies: Fiat Currencies

HOW DO YOU INVEST IN FIAT CURRENCIES?
Investors can purchase currencies on foreign exchange markets (“forex”), but, similar to commodities,
individual investors are much more likely to get exposure via investment products like mutual funds
or ETFs. Currency markets are traded 24 hours a day and enable the exchange of different countries’
currencies.

WHAT ARE THE BENEFITS OF CURRENCY TRADING?

Depending on your circumstances, there can be some benefits to trading currencies. For example, if
you spend a significant amount of time outside the country, it can make sense to maintain assets in
corresponding currencies. By maintaining multiple currency accounts, you can better mitigate short-
term swings that might affect your spending power. Multinational companies trade currencies regularly
to cover their expenses in the countries where they operate.

WHAT ARE SOME RISKS OF CURRENCY INVESTMENTS?

Using currencies as an investment is a highly speculative practice. Similar to commodities, currency
prices are impacted by difficult-to-predict supply and demand patterns and tend to ebb and flow relative
to one another over long periods of time. So in order to profit from investing in currencies, you have to
have impeccable timing—a nearly impossible feat.

27
FISHER INVESTMENTS’ VIEW ON FIAT CURRENCIES
We believe the optimal strategy for many investors is to maintain a globally diversified portfolio. Being
globally diversified means having exposure to companies that report their profits in different currencies.
Therefore, the value of the dollar relative to other global currencies can sometimes affect the value of
non-USD investments. However, we don’t think investors should seek direct currency exposure as an
effective long-term investment vehicle. Our research suggests that major currencies tend to ebb and flow
relative to one another—not appreciate over time like other asset classes.

Currencies: Cryptocurrencies and Non-fungible

Tokens (NFTs)
WHAT ARE CRYPTOCURRENCIES AND NFTs?
Cryptocurrencies and non-fungible tokens are both digital assets that have gained popularity in
recent years. Proponents of digital assets see them as having similar, if not more, value than physical
alternatives. In the case of cryptocurrencies, there are thousands of “coins” or “tokens” but the biggest
by market capitalization are Bitcoin and Ethereum. NFTs represent ownership of digital assets. This can
be as simple as owning a digital image or as complex as owning a virtual piece of property in a virtual
program.

WHAT ARE THE BENEFITS OF CRYPTOCURRENCIES AND NFTs?

Some see digital assets as tools to replace physical assets altogether. Others see digital assets as good
investments because a small fraction of these assets have experienced tremendous growth. We remain
skeptics for a variety of reasons including overall low adoption rate, substantial price volatility,
unregulated nature, black market affiliation and difficulty to value.

28 800-568-5082
WHAT ARE THE RISKS OF CRYPTOCURRENCIES AND NFTs?
There are many risks associated with digital assets and we would caution long-term investors to limit
their exposure. In addition to the extreme price volatility digital assets experience, it remains unclear
how something like cryptocurrency could (or would be allowed to) replace a traditional or “fiat”
currency like the dollar. Naturally, proponents would judge our skepticism harshly. But there are too
many unknowns to make us comfortable recommending in something with such variability. There is
no intrinsic value, cash-flow stream to predict or industry to analyze. The price is primarily driven by
speculation—dictated by what the next person is willing to pay.

FISHER INVESTMENTS’ VIEW ON CRYPTOCURRENCIES AND NFTs

As mentioned above, we don’t believe these assets should be a central part of any well-diversified
investment plan. These assets are in their infancy—something proponents of them would have you
believe is a reason to close your eyes and buy. But doing so comes with extraordinary risk and volatility.
Some investors are barely able to stomach the short-term volatility of the stock market. But when
compared to Bitcoin—the largest and most-traded cryptocurrency—stock volatility looks sanguine.
Exhibit 5 shows the number of days the S&P 500 and Bitcoin experience declines of 5% or more. We
simply believe this much volatility isn’t suitable for most investors.

5 500
$80K
14,000 MSCI World Total Return Index Bitcoin Close Price
MSCI World -5%+ Down Day $70K Bitcoin -5%+ Down Day
13,000
MSCI World -5% or more: $60K Bitcoin -5% or more:
12,000
4 days 158 days
$50K
11,000

$40K
10,000

9,000 $30K

8,000 $20K

7,000 $10K

6,000 $0K
2017 2018 2019 2020 2021 2022 2017 2018 2019 2020 2021 2022

Source: CoinMarketCap, FactSet, as of 3/24/2022. Bitcoin close price, MSCI World Gross Total Return Index, daily,
1/1/2017 – 3/23/2022. Presented in US dollars.

29
DERIVATIVES
Derivatives are financial contracts that derive their value from an underlying asset such as an individual
security, a fund or a broad index. Investors typically purchase derivatives to either hedge their exposure
to an underlying asset or to speculate on price movements. These assets are complex and should only be
purchased by investors with a high degree of knowledge about how they work and the associated risks.
While there are many different types of derivatives, we will explore the two most common ones investors
are interested in—options and futures—in this section.

Derivatives: Options
WHAT ARE OPTIONS AND HOW DO YOU INVEST IN THEM?
Options are contracts that trade as their own separate securities with specific terms, notably a “strike
price” and an expiration date. The “option” gives the buyer the choice to take action—either to buy or
sell—on an underlying security at a specific price (i.e., the “strike price”) prior to the expiration date. The
two main types of options are:

• Call options: Calls give the buyer the right, but not obligation, to buy an underlying asset at the
strike price. Investors usually purchase call options when they believe the price of the underlying
asset will rise above the strike price. In order to make an intrinsic profit, the underlying asset must
rise past the strike price enough to cover the cost of purchasing the option contract.

• Put options: Puts give the buyer the right, but not obligation, to sell the underlying asset at the
strike price. Investors usually purchase put options when they believe the price of the underlying
asset will fall below the strike price. In order to make an intrinsic profit, the underlying asset must
fall past the strike price enough to cover the cost of purchasing the option contract.

30 800-568-5082
WHY DO INVESTORS USE OPTIONS AND WHAT ARE THE RISKS?
Investors who purchase options usually do so either to hedge their exposure to an underlying asset—
buying a put option to protect against a potential price decline in a company they own shares in, for
example—or to speculate on near-term price trends. The most the option buyer can lose is the amount
they paid for the contract, which limits the downside risk relative to sellers.

Investors who choose to sell options usually do so because they do not expect the price of the underlying
asset to move beyond the strike price—leaving the option to expire worthless when it hits the expiration
date. If that happens, the seller’s profit is equal to that of the price of the option contract. However, if the
asset moves beyond the strike price—referred to as being “in the money”—then the seller must deliver
the underlying asset in the amount agreed to in the contract. For the sellers of call options in particular,
the potential loss is theoretically unlimited.

Derivatives: Futures
WHAT ARE FUTURES?
Like other types of derivatives, futures are a contract between two parties. Futures are a standardized
agreement to buy or sell an underlying asset at a predetermined price at a specified time in the future.
Futures can cover anything from individual stocks to commodities such as oil, gold, corn and more. As
opposed to options that can expire worthless, futures contracts oblige an exchange of the underlying
asset agreed to in the contract. However, an investor doesn’t pay a separate price for the contract aside
from potential brokerage, exchange or trading fees.

WHY DO INVESTORS USE FUTURES?

Similar to options, futures contracts can help hedge exposure to an underlying asset or speculate on price
movements. Companies with heavy commodity exposure often use futures markets to hedge against the
possibility of a large price swing dramatically impacting their profits. For example, an airline that uses
futures to hedge the price of jet fuel. Or a farmer who uses futures to hedge the price of their crops.

Investors may use futures to hedge against a decline in their portfolio, assuming they are able to
accurately forecast such a period. They can also use futures to speculate on the price movement of
underlying assets, which can add to their returns. However, their returns will suffer if incorrect.

31
WHAT ARE THE RISKS WITH FUTURES?
The main risk of futures contracts is being wrong. Investors can sustain heavy losses if the price of the
underlying asset dramatically deviates from the price agreed to in the contract. Futures contracts are
priced on a daily basis and may subject one party to a margin call—a broker requirement to either
deposit more money or sell assets in an investor’s account—if the price moves far enough away from the
agreed price. Margin calls can force investors to take losses in periods of extreme market volatility.

FISHER INVESTMENTS’ VIEW ON OPTIONS AND FUTURES

Options and futures can be useful tools for investors in certain situations, but they are inherently short-
term focused and come with risks. Most individual investors don’t have the know-how to effectively
and safely use options and futures widely in their portfolios. Even the most seasoned professionals don’t
know how markets will behave in the short term—though many claim they do, few have a verifiable
long-term track record of being consistently correct. When it comes to stock market forecasting, for
example, even the best are wrong 30–40% of the time.

While hedging against decline may sound appealing—particularly in the midst of market volatility—it
can also lower your near-term returns and the compounding effect of returns over time. As Exhibit
6 shows, daily market movements have historically been a coin flip as to whether they are positive or
negative. Even stretching out to one-year periods, there historically has been a reasonably high chance
of being wrong. As we discussed earlier, limiting market exposure can have a detrimental impact on an
investor’s long-term returns.

32 800-568-5082
EXHIBIT 6: FREQUENCY OF POSITIVE AND NEGATIVE STOCK RETURNS

PERIOD FREQUENCY OF FREQUENCY OF

SINCE 1928 POSITIVE RETURNS NEGATIVE RETURNS
Daily* 53% 47%
Calendar Month 63% 37%
Calendar Quarter 69% 31%
Calendar Year 74% 26%
Rolling 1 Year 75% 25%
Rolling 5 Year 88% 12%
Rolling 10 Year 94% 6%
Rolling 20 Year 100% 0%
Rolling 25 Year 100% 0%

Source: Global Financial Data, Inc. as of 6/6/2022.

*Daily return data begins on 1/3/1928, and are based on price appreciation only; all other data begins 1/31/1926 and reflects
total return.

In our view, derivatives should only be employed in an investment strategy when there is a high degree
of confidence in what the near-term future holds. At Fisher Investments, we seek to identify periods of
sustained market declines. If successful, it’s possible we would employ the use of options and/or futures
as part of a strategy to limit the decline of investor portfolios. However, we believe it is too risky to do
this with large portions of portfolios and would simply seek a portfolio that mirrors cash-like returns.
Investors don’t need to avoid short-term market declines to reach their goals. Derivatives can be a
tempting tool to ease the pain of market volatility, but participating fully in long-term market returns is
more important.

IN CONCLUSION
Investors today have more ways to invest their money than ever before, but, as you can see, not all
options are created equal. We believe an investor’s portfolio strategy should reflect their unique goals,
cash-flow needs and investment time horizon. No two situations are exactly alike, and you deserve to
have your portfolio tailored to your needs. If you’d like to have a conversation about how we can help
you achieve your investment goals, please contact us.

33
FISHER INVESTMENTS CAN HELP YOU MANAGE RISK AND BUILD
A MORE SECURE FINANCIAL FUTURE
Our full-service approach means you’re supported at every step of your financial journey.

PLANNING
Fisher Investments can help you craft an appropriate investment strategy built around your cash-flow needs and
investment goals and objectives. Your strategy should guide all your investment decisions. The market isn’t intuitive—
in fact, many times prudent investing involves doing the opposite of what feels “right.” This is why having a sound
investment strategy—and an adviser who can help you stay disciplined—can help you achieve your longer-term goals.

PORTFOLIO MANAGEMENT
We create a personalized portfolio tailored to your unique situation: your financial goals, wants, needs, health, family
and lifestyle. Led by our founder, Ken Fisher, our Investment Policy Committee—the primary decision-makers for your
portfolio—has 150+ combined years of industry experience.

CLIENT SERVICE
Fisher Investments offers a level of client service that we believe is rare in our industry. Our objective is to help you reach
your goals and keep you informed and comfortable along the way. A big part of this is making sure you understand your
strategy and stick to it. Investing involves emotions, and we seek to help our clients stay disciplined, whether the market
is up or down. Each client has a direct point of contact, called an Investment Counselor. Your Investment Counselor:

• Helps you understand what’s going on in your account and why

• Reviews your investment goals and objectives regularly
• Handles your day-to-day needs quickly and smoothly

START THE CONVERSATION TODAY

A second set of eyes on your financial plan is always a good idea. If you want an experienced financial professional
to review your portfolio and financial goals, we urge you to call us at 800-568-5082 for a complimentary
evaluation.* We can help you create a retirement investing strategy to generate the income you need and achieve
your long-term goals. We look forward to hearing from you.

*For qualified investors with $500,000 or more in investable assets.

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transaction. There are daily and monthly limits on the amounts you can add and daily, weekly, and
monthly limits on the number of times you can add money. Please refer to the What is PayPal add
Cash at Stores and how do I use it? PayPal Help Center page for more information. You can
also add funds into your Balance Account using the remote check capture feature where that feature
is available. Remote check capture is not available if you have a negative balance in your Balance
Account and may not be available in all locations. Please refer to the PayPal Help Center Cash a
Check page for more information and details on availability and other restrictions. If any fees are
charged for adding cash at stores and remote check capture transactions, they can be found in
the PayPal Balance Long Form Disclosure
Disclosure.

When you open a PayPal Balance account with PayPal, we may also provide you with a The Bancorp
Bank, N.A. (“Bancorp”) issued account number and routing number that you can use to set up Direct
Deposit into your Balance Account or to use your Balance Account as a payment method for goods
and services through a direct debit payment transaction that you initiate via a third-party
merchant’s website or mobile application. Otherwise, you can separately receive a Bancorp issued
account and routing number by enrolling in Direct Deposit or by opening a PayPal branded debit card.

You may arrange to have all or part of your paycheck or any federal or state government benefit or
payment (e.g., Federal tax refunds or Social Security payment) transferred directly into your Balance
Account by your employer or government payer, as applicable, by using the Direct Deposit feature.

To enroll, you will need to provide your employer or the government payer, as applicable, with the
account and routing numbers found in the Direct Deposit section available in the PayPal app or in the
“Account” section of settings after logging in on our website. Your employer or government payer may
also ask you to fill out their own direct deposit form. We do not charge any fees to set up or maintain
Direct Deposit.

We may offer early access to Direct Deposit funds to eligible customers. Direct Deposit and the earlier
availability of funds are subject to the timing of the payer’s funding. Funds transferred via Direct
Deposit generally will be available on the day the funds are applied to your account. Because we do
not receive funds via Direct Deposit instantly, there will be some delay between the payment being
initiated by the payer and the payment arriving at PayPal. For example, Direct Deposit of funds may
be delayed for several days in the event of a federal or bank holiday. You may review your periodic
statements or transaction history on [Link] or contact us at PayPal Customer Service to
verify that each Direct Deposit has been received. Funds added to your account via Direct Deposit,
including funds added using an account and routing number issued by Bancorp, are transferred to
and held by one or more banks insured by the Federal Deposit Insurance Corporation (FDIC) that we
choose in our discretion (“Program
Program Banks
Banks”) where they are eligible for FDIC pass-through insurance.
We reserve the right to accept, reject, or limit transfers via Direct Deposit in our sole discretion. If
you wish to cancel Direct Deposits, you must contact the payer directly.

To assist in the prevention of fraud, you represent the following:

For Direct Deposit of a tax refund

the name and Social Security Number associated with each refund payment will match the
name and Social Security Number associated with your PayPal account; and

involving a joint tax return, the name of the first person listed in the tax return and their
Social Security Number associated with the refund payment will match the name and Social
Security Number associated with the PayPal account holder.

For Direct Deposit of other federal payments, the name and Social Security Number associated
with each payment will match the name and Social Security Number associated with your PayPal
account.

Holding Funds in Your Balance Account

Unless otherwise expressly stated, all references to “funds” in these terms and conditions mean
money denominated in sovereign currency and not cryptocurrency or any other form of asset.

Any funds in your Balance Account represent unsecured claims against PayPal, unless you have
opened a PayPal Debit Mastercard® account (“PayPal Debit Card”), have enrolled in Direct Deposit, or
have bought or received cryptocurrency. In that case, PayPal places the U.S. dollar funds held in your
Balance Account in one or more Program Banks
Banks, as explained below in the paragraphs regarding
pass-through deposit insurance provided by the FDIC.

If your Balance Account is not eligible for FDIC pass-through insurance, PayPal combines your
Balance Account balance with the balances of other Balance Account holders and invests those funds
in liquid investments in accordance with state money transmitter laws. You will not receive any
interest or other return on the funds held with PayPal. PayPal owns the interest or other earnings on
these investments. However, the claim against PayPal represented by funds held in your Balance
Account is not secured by these investments and you do not have any ownership interest (either legal
or beneficial) in these investments. These pooled amounts are held apart from PayPal’s corporate
funds, and PayPal will neither use these funds for its operating expenses or any other corporate
purposes nor will it voluntarily make these funds available to its creditors in the event of bankruptcy.

If your Balance Account is eligible for FDIC pass-through insurance, PayPal will hold these funds as
your agent and custodian, and you will be the ultimate beneficial owner of the funds. PayPal will
deposit your funds into one or more custodial accounts we maintain for the benefit of eligible Balance
Account holders at one or more Program Banks. PayPal customer funds in these custodial accounts
are eligible for pass-through FDIC insurance coverage. Subject to the limitations set forth below, this
means that if a bank holding the custodial account in which your funds are deposited fails, you should
be eligible to be insured by the FDIC up to the standard maximum deposit insurance amount
(currently $250,000). Note that the FDIC insurance maximum applies to the aggregate of all funds
that you have on deposit in all accounts you have with the same bank in a particular FDIC ownership
category. For example, if you have a Balance Account and a Venmo account that are both held in your
individual capacity and you qualify for pass-through FDIC insurance in both accounts, any balances
you maintain in those accounts will be aggregated for purposes of FDIC limits to the extent we place
those funds in the same bank. If the total balances you have at any bank exceeds FDIC insurance
limits, the amount in excess of those limits could be lost if the bank fails. FDIC pass-through
insurance does not protect you against the failure of PayPal.

When we provide immediate or early credit of funds sent to your Balance Account, there might be a
delay between the time that funds are credited and when we actually transfer those funds to one of
the custodial accounts. That amount might not be eligible for FDIC pass-through insurance in your
name during this period, but we will still hold the funds as your agent and custodian in investments
authorized by our state regulators. FDIC pass-through insurance coverage is contingent upon our
maintaining accurate records and on both us and the Program Bank in which the funds are deposited
otherwise complying with requirements in FDIC regulations. The determinations of whether these
requirements have been satisfied and whether you are eligible for FDIC pass-through insurance
coverage will be made by the FDIC at the time that a Program Bank holding a custodial account fails.
You will not receive any interest or other return on funds held in these custodial accounts and you
agree that any earnings on funds in a custodial account belong to PayPal, and PayPal may be
compensated for placing your funds in a custodial account.

Your eligibility for FDIC pass-through insurance only applies to U.S. dollar funds held in your eligible
Balance Account balance and placed by PayPal in a Program Bank on your behalf. It does not apply to
funds held in any non-U.S. dollar currencies, nor does it apply to any amounts held in
cryptocurrencies.
Your Balance Account balance may be held in currencies other than U.S. dollars. You are responsible
for all risks associated with maintaining multiple currencies in a Balance Account. You may not
manage multiple currencies for speculative trading purposes, conversion arbitrage, conversion
options, or any other activity that PayPal determines is primarily for the purpose of gaining or
making money based on currency conversion rates. PayPal may hold, cancel, or reverse any
transaction we determine to violate this policy.

You can also use your Balance Account to hold or receive certain cryptocurrencies if eligible.
Cryptocurrency eligibility and other specific terms and conditions can be found in the PayPal
Cryptocurrencies Terms and Conditions
Conditions.

Withdrawing Money from a Balance Account

If you have money in a Balance Account, you may withdraw it by:

Transferring it via a standard transfer to an eligible debit card or a bank account linked to your
personal account for free,

Transferring it via an Instant Transfer to an eligible debit card or bank account linked to your
personal account, subject to the fees applicable to such transfers that can be found on the PayPal
Balance Long Form Disclosure and that will be disclosed to you in advance each time you
initiate such a withdrawal,

Transferring it to PayPal Savings, or

Requesting a check from us.

In addition, if you have a Balance Account, you may withdraw funds from an ATM using your PayPal-
branded debit card subject to the fees that may apply to such withdrawals that can be found on
the PayPal Balance Long Form Disclosure
Disclosure. You may also use your PayPal-branded debit card to
withdraw funds from a bank teller at a participating bank branch or other financial institution. For
more information on withdrawing money from your Balance Account, please refer to the How do I
get money out of my PayPal account? PayPal Help Center page
page..

If you have enrolled in Direct Deposit, we may offer you the ability to use your Balance Account as a
payment method for goods and services through a direct debit payment transaction that you initiate
via a third-party merchant’s website or mobile application. Direct debit payment transactions are
considered electronic fund transfers, and your Balance Account is debited on a one-time or recurring
basis as you instruct using your Bancorp account and routing number used for your Direct Deposits.
There are daily limits on the amount and number of direct debit payment transactions and limits on
the amount you can transfer per transaction. Please refer to the What is Direct Debit? PayPal
Help Center page for more information. As part of a direct debit payment transaction, you may be
required to provide various consents and agree to the terms and conditions presented by the
merchant. Management of any scheduled payments, including cancellation, can be done through the
merchant’s website or mobile application. You may also contact PayPal Customer Service at least
3 Business Days prior to any scheduled recurring transfer to enable a stop payment.

For any scheduled recurring transfer, if you order us to stop one of these payments 3 Business
Days or more before the transfer is scheduled, and we do not do so, we will be liable for your losses
or damages. If these regular payments may vary in amount, you have the right to advance notice of
the amount and date of the transfer from the merchant at least 10 days before the transfer is made.
If the merchant provides the option, you may choose instead to get this notice only when the
payment would differ by more than a certain amount from the previous payment, or when the
amount would fall outside certain limits that you set.

To protect us and our users from loss, we may delay a withdrawal, in certain situations, including if
we need to confirm that you have authorized the withdrawal or if other payments to your Balance
Account have been subject to a reversal (for example, as a result of a chargeback, bank reversal or
dispute by a buyer). If we place a limitation on your personal account, a payment is subject to a
hold, or your Balance Account or an associated account has a negative balance in any currency while a
withdrawal from your Balance Account is pending, you will have to reinitiate the withdrawal once the
limitation or hold has been lifted, or negative balance is fully paid.

We may set limits on your withdrawals.

We don’t charge a fee to make a standard transfer of funds from your Balance Account to an eligible
debit card or your bank using your personal account. If your debit card or bank account linked to your
personal account is eligible to receive Instant Transfer withdrawals from your Balance Account, you
will be provided the option to use it when you transfer money out of your account, subject to the
fees applicable to such transfers that can be found on the PayPal Balance Long Form
Disclosure and that will be disclosed to you in advance each time you initiate such a transfer.

When you withdraw funds in your Balance Account from an ATM using a PayPal-branded debit card,
you may be charged a fee by the owner of the ATM and an additional fee per the terms of your
Cardholder Agreement that can be found on the Legal Agreements page. Other withdrawal limits
also apply to the use of your PayPal-branded debit card. Please refer to the applicable Cardholder
Agreement for details that can be found on the Legal Agreements page.

If you request a paper check from us, you must cash it within 180 days of the date of issuance, or we
will return the funds to your Balance Account. We will not send a check to a post office box, and we
will only send a check to an address once we have confirmed that it belongs to you.
Authorization to Charge Your Balance Account
General authorization to charge your Balance Account

By opening a Balance Account, you authorize PayPal to charge your Balance Account (a) whenever
you choose your Balance Account as the payment method to send money or purchase something
using PayPal, (b) when you withdraw money from your Balance Account, (c) in connection with any
errors, claims, or disputes, and (d) for amounts you owe to PayPal.

Authorization of specific transactions

Each time you send money using your Balance Account as the funding source, you authorize PayPal to
charge your Balance Account for the amount you are sending and any applicable fees.

Each time you use PayPal to purchase something from a seller or make a donation using the balance
in your Balance Account, you authorize PayPal to charge your Balance Account for the amount
specified during the checkout process and any applicable fees. If the amount of your transaction
changes after checkout, you authorize PayPal to charge your Balance Account for the revised amount
(for example, if the amount increases because you add another product or service (e.g., expedited
delivery), the amount decreases, or is split because a portion of your order is canceled or delayed).

If your Balance Account cannot be charged, you authorize PayPal to charge the backup payment
method or other payment method linked to your personal account, pursuant to the hierarchy listed
in the User Agreement section on Payment Method Used for My Transaction (Automatic
Payments)
Payments).

If you request a transfer from your bank account to your Balance Account using PayPal, you authorize
PayPal to debit the selected bank account for the amount you are transferring and any applicable
fees and to debit or credit the linked bank account in connection with any errors, claims, or disputes.
You authorize PayPal to re-present this transfer from your bank account up to two (2) times if the
initial transfer is rejected by your bank for any reason. Adding money to your Balance Account while a
re-presentment is pending does not stop the original transfer from being re-presented by us to your
bank. If you request a withdrawal from your Balance Account, you authorize PayPal to debit your
Balance Account for the amount you are withdrawing and any applicable fees and to send those funds
to the destination you have designated.

When you request to transfer funds from your PayPal Savings account to your PayPal Balance
account, or from your PayPal Balance account to your PayPal Savings account, you authorize us to
debit the source account and credit the destination account in the amount you designate and for
applicable fees, if any, and in connection with any errors, claims, or disputes.

Revoking your authorization

You can revoke our authority to charge your Balance Account with respect to future transactions by
closing your Balance Account as described in the section Closing Your Balance Account
Account. Among
other things, you cannot close your Balance Account if you have a pending transaction using your
Balance Account as the payment method or an open dispute or claim related to your Balance
Account. You will remain liable for all obligations related to your Balance Account even after your
Balance Account is closed, and you authorize us to debit or credit a backup payment method in
connection with an error, dispute, or claim with respect to a transaction initiated prior to the time
that your Balance Account was closed.

Currency Conversion
How we convert currency

PayPal will always perform the conversion for transactions where your Balance Account is the funding
source for a transaction using your personal account. When PayPal converts currency, it will be
completed at the transaction exchange rate we set for the relevant currency exchange. The
transaction exchange rate is adjusted regularly and includes a currency conversion spread applied
and retained by us on a base exchange rate to form the rate applicable to your conversion. The base
exchange rate is based on rates within the wholesale currency markets on the conversion day or the
prior Business Day
Day; or, if required by law or regulation, set at the relevant government reference
rate(s).

For some uses of your Balance Account, PayPal may determine currency conversion is necessary. The
applicable currency conversion spread can be found on our Fees page under the heading Currency
Conversions
Conversions.

Fee Information and Regulatory Disclosures

You can find a list of all fees for the Balance Account on the PayPal Balance Long Form
Disclosure
Disclosure.

Account Statements and Requesting Account Records

You have the right to receive an account statement showing your Balance Account activity. You may
view your Balance Account statement by logging into your personal account. Balance Account holders
will receive two statements: one showing all transactions in their personal account and an additional
statement showing only transactions involving their Balance Account.

Sending Money and Buying

Sending Money to a Friend or Family Member
You can use your Balance Account as the funding source to send money to a friend's or family
member’s eligible PayPal account using the send money feature in your linked personal account. You
can also send money to a friend or family member even if they don’t have an eligible PayPal account
at the time you send them money, using their email address or mobile number in any currency that
PayPal supports, and you can choose your Balance Account as the payment method you want to use.
If the person to whom you are sending money does not have an eligible PayPal account, they can
claim it by opening an eligible PayPal account. If they don’t open an eligible PayPal account to claim
it, it will be refunded to you.

We may, at our discretion, impose limits on the amount of money you can send, including money you
send for purchases.

When you send money to a friend or family member who has an eligible PayPal account one of two
things may happen: they may accept or decline the money. If you use your linked Balance Account as
the funding source and they decline to accept the money, the money (including any fees you were
charged) will be refunded to your Balance Account.

The fees applicable to sending money to an eligible PayPal account can be found on the PayPal
Balance Long Form Disclosure and will be disclosed to you in advance each time you initiate a
transaction to send money to a friend or family member. If you convert money in your Balance
Account balance from one currency to another before sending money, PayPal’s transaction exchange
rate (including our currency conversion spread
spread) will be used.

Sending Money to or Receiving Money From PayPal Savings

PayPal Savings will be linked to your PayPal account. Additional information about PayPal Savings
can be found in the PayPal User Agreement
Agreement.

Transfers from your PayPal Savings to your PayPal balance will generally be available in your Balance
Account immediately upon transfer from your PayPal Savings even though we do not receive funds
transferred from your PayPal Savings instantly. For example, funds transferred from your PayPal
Savings to your Balance Account may be delayed for several days in the event of a federal or bank
holiday. If PayPal does not receive the funds from your PayPal Savings account, PayPal reserves the
right in its sole discretion to remove from your Balance Account the amount of funds for which
PayPal provided early access, but did not receive from the bank that provides your PayPal Savings
account.

Buying Something From, or Returning Something to, a

Seller Who Accepts PayPal Using Your Balance Account
You can purchase something from a seller who accepts PayPal, in any currency that the seller accepts
and that PayPal supports, using the balance in your Balance Account linked to your personal account.
This includes, for example:

Purchasing something at an online retailer’s website and selecting PayPal balance as your payment
method at checkout.

Sending money to a seller for goods or services and selecting PayPal balance as your payment
method.

Using your personal account and selecting PayPal balance as your payment method to purchase
something at a seller’s physical store.

When you purchase something from a seller who accepts PayPal you don’t pay a fee to PayPal. If
PayPal performs a currency conversion
conversion, PayPal’s transaction exchange rate (including
our currency conversion spread
spread) will be used.

Payment review
When PayPal identifies a potentially high-risk transaction, we review the transaction more closely
before allowing it to proceed. When this happens, PayPal will place a hold on the transaction and
notify the seller to delay shipping of the item. As a buyer, this may delay your receipt of the item you
purchased. If we clear the transaction, we will notify the seller and direct them to ship the item. If we
don’t clear the transaction, we will cancel it and return the funds to you, unless we are legally
required to take other action.

Refunds
When you purchase something from a seller online using your Balance Account linked to your personal
account as the funding source and the transaction is ultimately refunded, the money will be refunded
to your Balance Account. When you purchase something from a seller online using your bank account
linked to your personal account as the funding source and the transaction is ultimately refunded, we
will attempt to refund the money to your bank account. If we are unable to do so, we will refund the
money to your Balance Account. For purchases you make in a seller’s store location that you paid for
using your personal account and the transaction is ultimately refunded, the money will be refunded
to your Balance Account regardless of the funding source linked to the personal account you
designated to use for the purchase.

If PayPal performed a currency conversion for your transaction, and a refund is issued:

Within 1 day of the date of the original payment, PayPal’s transaction exchange rate used at the
time of the original payment will apply.
 Beyond 1 day of the date of the original payment, PayPal’s transaction exchange rate on the date
of the refund will apply.

Money will be refunded in the currency you paid; or if we are unable to refund in the currency you
paid, in your primary holding currency; or we are unable to refund in your primary holding currency,
then in U.S. dollars.

Restricted Activities and Holds

Restricted Activities
In connection with your use of our websites, your Balance Account, the PayPal services, or in the
course of your interactions with PayPal, other PayPal customers, or third parties, you must not:

Breach these terms and conditions, the PayPal Account User Agreement for your personal
account, the PayPal Acceptable Use Policy
Policy, the Commercial Entity Agreements (if they
apply to you), or any other agreement between you and PayPal;

Violate any law, statute, ordinance, or regulation (for example, those governing financial services,
consumer protections, unfair competition, anti-discrimination or false advertising);

Infringe PayPal’s or any third party’s copyright, patent, trademark, trade secret or other
intellectual property rights, or rights of publicity or privacy;

Sell counterfeit goods;

Act in a manner that is defamatory, trade libelous, threatening or harassing;

Provide false, inaccurate or misleading information;

Send or receive what we reasonably believe to be potentially fraudulent funds;

Refuse to cooperate in an investigation or provide confirmation of your identity or any

information you provide to us;

Attempt to double dip during the course of a dispute by receiving or attempting to receive funds
from both PayPal and the seller, bank or debit card issuer for the same transaction;

Control an account that is linked to another account that has engaged in any of these restricted
activities;

Conduct your business or use the PayPal services in a manner that results in or may result in;

complaints;
 requests by buyers (either filed with us or card issuers) to invalidate payments made to you;

fees, fines, penalties or other liability or losses to PayPal, other PayPal customers, third
parties or you;

Allow your Balance Account to have a negative balance;

Access the PayPal services from a country that is not included on PayPal’s permitted countries
list
list;

Take any action that imposes an unreasonable or disproportionately large load on our websites,
software, systems (including any networks and servers used to provide any of the PayPal services)
operated by us or on our behalf or the PayPal services;

Facilitate any viruses, trojan horses, malware, worms or other computer programming routines
that attempts to or may damage, disrupt, corrupt, misuse, detrimentally interfere with,
surreptitiously intercept or expropriate, or gain unauthorized access to any system, data,
information or PayPal services;

Use an anonymizing proxy; use any robot, spider, other automatic device, or manual process to
monitor or copy our websites without our prior written permission; or use any device, software or
routine to bypass our robot exclusion headers;

Interfere or disrupt or attempt to interfere with or disrupt our websites, software, systems
(including any networks and servers used to provide any of the PayPal services) operated by us or
on our behalf, any of the PayPal services or other users’ use of any of the PayPal services;

Take any action that may cause us to lose any of the services from our Internet service providers,
payment processors, or other suppliers or service providers;

Circumvent any PayPal policy or determinations about your Balance Account such as temporary or
indefinite suspensions or other account holds, limitations or restrictions, including, but not
limited to, engaging in the following actions: attempting to open new or additional PayPal
account(s) when your Balance Account has a negative PayPal balance or has been restricted,
suspended or otherwise limited; opening new or additional PayPal accounts using information that
is not your own (e.g. name, address, email address, etc.); or using someone else’s PayPal account;
or

Harass and/or threaten our employees, agents, or other users.

Actions We May Take if You Engage in Any Restricted

Activities
If we believe that you’ve engaged in any of these activities, we may take a number of actions to
protect PayPal, its customers and others at any time in our sole discretion. The actions we make take
include, but are not limited to, the following:

Limit your Balance Account, and/or close or suspend your Balance Account, immediately and
without penalty to us;

Refuse to provide the PayPal services to you in the future;

Limit your access to our websites, software, systems (including any networks and servers used to
provide any of the PayPal services) operated by us or on our behalf, your Balance Account or any
of the PayPal services, including limiting your ability to pay or send money with your Balance
Account, restricting your ability to send money or make withdrawals;

Hold your Balance Account balance for up to 180 days if reasonably needed to protect against the
risk of liability or if you have violated our Acceptable Use Policy
Policy;

Contact buyers who have purchased goods or services from you using PayPal, your bank, other
impacted third parties or law enforcement about your actions;

Update inaccurate information you provided us;

Take legal action against you;

If you’ve violated our Acceptable Use Policy

Policy, then you’re also responsible for damages to PayPal
caused by your violation of this policy; or

If you are a seller and you violate the Acceptable Use Policy, then in addition to being subject to
the above actions you will be liable to PayPal for the amount of PayPal’s damages caused by your
violation of the Acceptable Use Policy. PayPal may deduct such damages directly from any existing
balance in any PayPal account you control.

If we close your Balance Account or terminate your use of the PayPal services for any reason, we’ll
provide you with notice of our actions and make any unrestricted funds held in your Balance Account
available for withdrawal.

You are responsible for all reversals, chargebacks, claims, fees, fines, penalties and other liability
incurred by PayPal, any PayPal customer, or a third party caused by or arising out of your breach of
these terms and conditions, and/or your use of the PayPal services.

Holds and Limitations

What are holds and limitations
Under certain circumstances, in order to protect PayPal and the security and integrity of the network
of buyers and sellers that use the PayPal services, PayPal may take account-level or transaction-level
actions. Unless otherwise noted, if we take any of the actions described here, we’ll provide you with
notice of our actions, but we retain the sole discretion to take these actions. To request information
in connection with an account limitation, hold or reserve, you should visit the Resolution Center or
follow the instructions in our email notice with respect to the limitation or hold. Account holds or
limitations may impact your ability to move funds to or from your PayPal Savings account until the
hold or limitation on your PayPal account is lifted.

Our decision about holds and limitations may be based on confidential criteria that are essential to
our management of risk and the protection of PayPal, our customers and/or service providers. We
may use proprietary fraud and risk modeling when assessing the risk associated with your PayPal
account. In addition, we may be restricted by regulation or a governmental authority from disclosing
certain information to you about such decisions. You agree that we have no obligation to disclose the
details of our risk management or security procedures to you.

Holds
A hold is an action that PayPal may take under certain circumstances either at the transaction level
or the account level. When PayPal places a temporary hold on a payment, the money is not available
to either the sender or the recipient. PayPal reviews many factors before placing a hold on a
payment, including: account tenure, transaction activity, past customer disputes, and overall
customer satisfaction.

Holds based on PayPal’s risk decisions

We may place a hold on payments sent to your Balance Account if, in our sole discretion, we believe
that there may be a high level of risk associated with you, your Balance Account, your
personal account, or your transactions or that placing such a hold is necessary to comply with state
or federal regulatory requirements. We make decisions about whether to place a payment hold based
on a number of factors, including information available to us from both internal sources and third
parties. When we place a hold on a payment, the funds will appear in your Balance Account with an
indication that they are unavailable or pending. We’ll notify you, either through your Balance Account
or directly by phone or email, whenever we place a hold.

Risk-based holds generally remain in place for up to 21 days from the date the payment was received
into your Balance Account. We may release the hold earlier under certain circumstances, but any
earlier release is at our sole discretion. The hold may last longer than 21 days and can be in effect up
to 180 days.
Account Limitations
Limitations are implemented to help protect PayPal, buyers and sellers when we notice restricted
activities
activities, an increased financial risk, or activity that appears to us as unusual or suspicious.
Limitations also help us collect information necessary for keeping your Balance Account open.

There are several reasons why your account could be limited, including:

If we suspect someone could be using your Balance Account without your knowledge, we’ll limit it
for your protection and look into the fraudulent activity.

If your bank lets us know that there have been unauthorized transfers between your Balance
Account and your bank account.

In order to comply with applicable law.

If we believe in our sole discretion that you have breached these terms and conditions or violated
the Acceptable Use Policy
Policy.

Seller performance indicating your PayPal account is high risk. Examples include: indications of
poor selling performance because you’ve received an unusually high number of claims and
chargebacks, selling an entirely new or high-cost product type, or if your typical sales volume
increases rapidly.

Unless a permanent limitation is placed on your account, you will need to resolve any issues with your
Balance Account and personal account before a limitation can be removed. Normally, this is done
after you provide us with the information we request. However, if we reasonably believe a risk still
exists after you have provided us that information, we may take action to protect PayPal, our users,
a third party, or you from reversals, fees, fines, penalties, legal and/or regulatory risks and any other
liability.

Court Orders, Regulatory Requirements or Other Legal

Process
If we are notified of a court order or other legal process (including garnishment or any equivalent
process) affecting you, or if we otherwise believe we are required to do so in order to comply with
applicable law or regulatory requirements, we may be required to take certain actions, including
holding payments to/from your Balance Account, placing a limitation on your Balance Account, or
releasing your funds. We will decide, in our sole discretion, which action is required of us. Unless the
court order, applicable law, regulatory requirement or other legal process requires otherwise, we will
notify you of these actions. We do not have an obligation to contest or appeal any court order or legal
process involving you or your Balance Account. When we implement a hold or limitation as a result of
a court order, applicable law, regulatory requirement or other legal process, the hold or limitation
may remain in place longer than 180 days.

Liability for Unauthorized Transactions and Other Errors

Protection from Unauthorized Transactions
To protect yourself from unauthorized activity in your Balance Account, you should regularly log into
your personal account and review your Balance Account statements. PayPal will notify you of each
transaction by sending an email to your primary email address on file. You should review these
transaction notifications to ensure that each transaction was authorized and accurately completed.

PayPal will protect you from unauthorized activity in your Balance Account. When this protection
applies, PayPal will cover you for the full amount of the unauthorized activity as long as you
cooperate with us and follow the procedures described below.

Additional rules and procedures for addressing an unauthorized transaction apply in cases involving
cryptocurrencies. You can find the additional rules and procedures in the Liability for Unauthorized
Transactions and Errors section of the PayPal Cryptocurrencies Terms and Conditions
Conditions.

What is an Unauthorized Transaction

An “Unauthorized Transaction” occurs when money is sent from your Balance Account that you did
not authorize and that did not benefit you. For example, if someone steals or fraudulently obtains
your password, uses the password to access funds in your Balance Account, and sends a payment
using those funds, an Unauthorized Transaction has occurred.

What is not considered an Unauthorized Transaction

It is NOT an Unauthorized Transaction if you grant authority to someone to use your Balance Account
(by giving them your login information) and they exceed the authority you gave them. You are
responsible for transactions made in this situation unless you have previously notified PayPal that
you no longer authorize transfers by that individual.

Reporting an Unauthorized Transaction

If you believe your PayPal login information has been lost or stolen, please contact PayPal
customer service immediately or call: (888) 221-1161 or write: PayPal, Attn: Error Resolution
Department, P.O. Box 45950, Omaha, NE 68145-0950.

Tell us AT ONCE if you believe that an electronic fund transfer has been made without your
permission using your login information or by other means. You could lose all the money in your
Balance Account. If you tell us within 60 days after we provide you your Balance Account and
personal account statements showing transfers you did not make, you will be eligible for 100%
protection for Unauthorized Transactions.

Also, if your Balance Account statement shows transfers that you did not make, including those made
with your PayPal login information or by other means, tell us at once. If you do not tell us within 60
days after we provided the statement to you, you may not get back any money you lost after the 60
days if we can prove that we could have stopped someone from taking the money if you had told us
in time. If a good reason (such as a long trip or a hospital stay) kept you from telling us, we may
extend the time periods.

Error Resolution
What is an Error
An “Error” means the following:

When money is either incorrectly taken from your Balance Account or incorrectly placed into your
Balance Account, or when a transaction is incorrectly recorded in your Balance Account.

You send a payment and the incorrect amount is debited from your Balance Account.

An incorrect amount is credited to your Balance Account.

A transaction is missing from or not properly identified in your Balance Account statement.

We make a computational or mathematical error related to your Balance Account.

You request receipt or periodic statement documents that PayPal is required to provide to you.

You request information concerning preauthorized (recurring) transfers to your Balance Account
that PayPal is required to provide to you.

You request additional information or clarification concerning a transfer to or from your Balance
Account, including a request you make to determine whether an error has occurred.

You inquire about the status of a pending transfer to or from your Balance Account.

You request documentation or other information, unless the request is for a duplicate copy for tax
or other record-keeping purposes.

What is not considered an Error

The following are NOT considered Errors:
 If you give someone access to your Balance Account (by giving them your login information) and
they use your Balance Account without your knowledge or permission. You are responsible for
transactions made in this situation.

Invalidation and reversal of a payment as a result of the actions described under Refunds,
Reversals and Chargebacks
Chargebacks.

Routine inquiries about the balance in your Balance Account.

Requests for duplicate documentation or other information for tax or other recordkeeping
purposes.

In case of Errors or questions about your electronic transfers

Telephone us at (888) 221-1161, contact us through the PayPal Resolution Center
Center; or write us at
PayPal, Attn: Error Resolution Department, P.O. Box 45950, Omaha, NE 68145-0950.

Notify us as soon as you can, 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
60 days after we sent the FIRST statement on which the problem or error appeared.

Tell us your name and account number (if any).

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.

If you tell us orally, we may require that you send us your complaint or question in writing within
10 Business Days
Days.

We will determine whether an error occurred within 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 45 days to
investigate your complaint or question. If we decide to do this, we will credit your Balance Account
within 10 Business Days for the amount you think is in error, so that you will have the 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 10 Business Days
Days, we may not credit your
Balance Account.

For errors involving new Balance Accounts, point-of-sale transactions, or foreign-initiated

transactions, we may take up to 90 days to investigate your complaint or question. For new Balance
Accounts, we may take up to 20 Business Days to credit your Balance Account for the amount you
think is in error.
We will tell you the results within 3 Business
Business Days
Days after completing our investigation. If we decide
that there was no error, we will send you a written explanation. You may ask for copies of the
documents that we used in our investigation.

Processing Errors
We will rectify any processing error that we discover. If the error results in:

You receiving less than the correct amount to which you were entitled, then we will credit your
Balance Account for the difference between what you should have received and what you actually
received.

You receiving more than the correct amount to which you were entitled, then we will debit your
Balance Account for the difference between what you actually received and what you should have
received.

Our not completing a transaction on time or in the correct amount, then we will be responsible to
you for your losses or damages directly caused by this failure, unless:

through no fault of ours, you did not have enough available funds to complete the
transaction;

our system was not working properly and you knew about the breakdown when you started
the transaction; or

the error was due to extraordinary circumstances outside our control (such as fire, flood or
loss of Internet connection), despite our reasonable precautions.

Processing errors are not:

Delays that result from PayPal applying holds

holds or
or limitations
limitations.

Delays based on a payment

payment review
review.

Your errors in making a transaction (for example, mistyping an amount of money that you are
sending).

Remittance Transfer Errors

What
What is
is aa Remittance
Remittance Transfer
Transfer
You may be protected for certain errors when you send money outside the U.S. using a Balance
Account. A “Remittance Transfer” is a transaction that meets the following criteria:

The payment is sent from a Balance Account that is used primarily for personal, family or
household purposes,

The payment is made for personal, family or household purposes,

The payment is made using the send money feature through your personal account,

The payment amount equals or exceeds $15 U.S. dollars (excluding fees charged to you) or the
foreign currency equivalent calculated using exchange rates in effect at the time of the
transaction, and

The recipient received the payment in a PayPal account outside of the U.S.

Payments that you make at a merchant website or location by selecting PayPal as a payment option
are not “Remittance Transfers.”

What
What qualifies
qualifies as
as aa Remittance
Remittance Transfer
Transfer Error
Error
A “Remittance Transfer Error” occurs if:

You paid an incorrect amount to send the Remittance Transfer. For example, you were charged
more than the total shown on the remittance transfer receipt you received (unless the total shown
on the receipt was an estimate, and the difference results from application of the actual exchange
rate, fees, and taxes).

PayPal made a computational or bookkeeping error, such as a miscalculation of the amount the
recipient received.

The amount stated in the remittance transfer receipt was not made available to the recipient,
unless:

we stated in the remittance transfer receipt that we used estimates and the difference in the
amount received and the amount stated in the remittance transfer receipt results from
application of the actual exchange rate, fees, and taxes, or

the problem was caused by extraordinary circumstances outside our control.

Funds were available to the recipient later than the date of availability that was disclosed to you
on the remittance transfer receipt or were not delivered, unless:
 extraordinary circumstances outside our control caused the delay, and we could not
reasonably anticipate those circumstances,

delays resulted from fraud screenings, or were caused by requirements of the Office of
Foreign Assets Controls or similar requirements, or

you (or someone assisting you) made the transfer with fraudulent intent.

You request documentation or information concerning the Remittance Transfer, such as

information required to determine if a Remittance Transfer Error occurred.

What
What is
is not
not considered
considered aa Remittance
Remittance Transfer
Transfer Error
Error
The following are NOT considered Remittance Transfer Errors:

An inquiry about the status of a Remittance Transfer, except where the funds from the transfer
were not made available to a designated recipient by the disclosed date of availability,

A request for information for tax or other recordkeeping purposes,

A change requested by the designated recipient, or

A change in the amount or type of currency received by the designated recipient from the amount
or type of currency stated in the disclosure provided you, if we relied on information provided by
you in making the disclosure.

What
What to
to do
do if
if you
you think
think there
there has
has been
been aa Remittance
Remittance Transfer
Transfer Error
Error or
or
problem
problem
If you think there has been a Remittance Transfer Error or problem with your Remittance Transfer:

Call us at: (888) 221-1161.

Write us at: PayPal, Attn: Error Resolution Department, P.O. Box 45950, Omaha, NE 68145-0950.

Log in to your personal account at [Link] and go to the Resolution

Resolution Center
Center and dispute a
transaction.

You must contact us within 180 days of the date we promised to you that funds would be made
available to the recipient. When you do, please tell us:

Your name, address and telephone number,

The error or problem with the transfer, and why you believe it is an error or problem,
 The name of the person receiving the funds, and if you know it, his or her telephone number or
address,

The dollar amount of the transfer, and

The confirmation code or number of the transaction.

We will determine whether an error occurred within 90 days after you contact us and we will correct
any error promptly. We will tell you the results within 3 Business
Business Days
Days after completing our
investigation. If we decide that there was no error, we will send you a written explanation. You may
ask for copies of any documents we used in our investigation.

Other Legal Terms

Communications Between You and Us
If you provide us your mobile phone number, you agree that PayPal and its affiliates may contact you
at that number using autodialed or prerecorded message calls or text messages to: (i) service your
PayPal branded accounts, (ii) investigate or prevent fraud, or (iii) collect a debt. We will not use
autodialed or prerecorded message calls or texts to contact you for marketing purposes unless we
receive your prior express written consent. We may share your mobile phone number with service
providers with whom we contract to assist us with the activities listed above, but we will not share
your mobile phone number with third parties for their own purposes without your consent. You do
not have to agree to receive autodialed or prerecorded message calls or texts to your mobile phone
number in order to use and enjoy the products and services offered by PayPal. You can decline to
receive autodialed or prerecorded message calls or texts to your mobile phone number by updating
your preferences in your PayPal account settings at [Link]
[Link], by contacting customer
customer
support
support, by calling us at 1-844-629-9108, or by replying STOP to a message. The frequency of
messages may vary, and standard telephone minute and text charges may apply. Neither we nor your
phone carriers are liable for delayed or undelivered messages.

PayPal may communicate with you about your Balance Account and the PayPal services electronically
as described in our Electronic
Electronic Communications
Communications Delivery
Delivery Policy
Policy. You will be considered to have
received a communication from us, if it’s delivered electronically, 24 hours after the time we post it
to our website or email it to you. You will be considered to have received a communication from us, if
it’s delivered by mail, 3 Business
Business Days
Days after we send it.

Unless you’re communicating with us about a matter where we’ve specified another notice address
(for example, our Liability
Liability for
for Unauthorized
Unauthorized Transactions
Transactions and
and Other
Other Errors
Errors process), written
notices to PayPal must be sent by postal mail to: PayPal, Inc., Attention: Legal Department, 2211
North First Street, San Jose, California 95131.
You understand and agree that, to the extent permitted by law, PayPal may, without further notice
or warning, monitor or record telephone conversations you or anyone acting on your behalf has with
PayPal or its agents for quality control and training purposes or for our own protection. You
acknowledge and understand that while your communications with PayPal may be overheard,
monitored, or recorded not all telephone lines or calls may be recorded by PayPal, and PayPal does
not guarantee that recordings of any particular telephone calls will be retained or retrievable.

PayPal’s Rights
PayPal
PayPal suspension
suspension and
and termination
termination rights
rights
PayPal, in its sole discretion, reserves the right to suspend or terminate these terms and conditions,
access to or use of its websites, software, systems (including any networks and servers used to
provide any of the PayPal services) operated by us or on our behalf or some or all of the PayPal
services for any reason and at any time upon notice to you and, upon termination of these terms and
conditions, the payment to you of any unrestricted funds held in your Balance Account.

Security
Security interest
interest
As security for the performance of your obligations under these terms and conditions, you grant to
PayPal a lien on, and security interest in and to, funds held in your Balance Account.

Amounts
Amounts owed
owed to
to PayPal
PayPal
If the balance in your Balance Account becomes negative for any reason, that negative balance
represents an amount that you owe to PayPal. PayPal may deduct these amounts from funds that are
added to your Balance Account later, either by you or from payments you receive. If you have more
than one PayPal account, we may set off a negative balance in one PayPal account against a PayPal
balance in your other PayPal account(s), including a Balance Account. If you continue using your
Balance Account when it has a negative balance, you authorize PayPal to combine the negative
balance with any debit or transaction sent from your personal account when that combination is
disclosed to you in advance of initiating the debit or transaction.

If you hold funds in a Balance Account in multiple currencies, and the balance for one of the
currencies becomes negative for any reason, PayPal may set off the negative balance by using funds
you maintain in a different currency. If you have a negative balance in non-U.S. dollars for a period of
21 days or longer, PayPal will convert this negative balance to U.S. dollars. In either case, a currency
currency
conversion
conversion will be necessary, and PayPal’s transaction exchange rate (including our currency
currency
conversion
conversion spread
spread) will be used.

In addition to the above, if you have a past due amount owed to us or our affiliates, PayPal may debit
your Balance Account to pay any amounts that are past due. This includes amounts owed by using
our various products such as Venmo, Xoom or Braintree.

Insolvency
Insolvency proceedings
proceedings
If any proceeding by or against you is commenced under any provision of the United States
Bankruptcy Code, as amended, or under any other bankruptcy or insolvency law, we’ll be entitled to
recover all reasonable costs or expenses (including reasonable legal fees and expenses) incurred in
connection with the enforcement of these terms and conditions.

Assumption
Assumption of
of rights
rights
If PayPal invalidates and reverses a payment that you made to a recipient (either at your initiative or
otherwise), you agree that PayPal assumes your rights against the recipient and third parties related
to the payment and may pursue those rights directly or on your behalf, in PayPal’s discretion.

No
No waiver
waiver
Our failure to act with respect to a breach of any of your obligations under these terms and
conditions by you or others does not waive our right to act with respect to subsequent or similar
breaches.

Indemnification and Limitation of Liability

In this section, we use the term “PayPal” to refer to PayPal, Inc., our parent PayPal Holdings, Inc., and
our affiliates, and each of their respective directors, officers, employees, agents, joint venturers,
service providers and suppliers. Our affiliates include each entity that we control, we are controlled
by or we are under common control with.

Indemnification
Indemnification
You
You must
must indemnify
indemnify PayPal
PayPal for
for actions
actions related
related to
to your
your Balance
Balance Account
Account and
and your
your use
use of
of
the
the PayPal
PayPal services.
services. You agree to defend, indemnify and hold PayPal harmless from any claim or
demand (including reasonable legal fees) made or incurred by any third party due to or arising out of
your breach of these terms and conditions, your improper use of the PayPal services, your violation
of any law or the rights of a third party and/or the actions or inactions of any third party to whom
you grant permissions to use your Balance Account or access our websites, software, systems
(including any networks and servers used to provide any of the PayPal services) operated by us or on
our behalf, or any of the PayPal services on your behalf.

Limitation
Limitation of
of liability
liability
PayPal’s
PayPal’s liability
liability is
is limited
limited with
with respect
respect to
to your
your Balance
Balance Account
Account and
and your
your use
use of
of the
the
PayPal
PayPal services.
services. In no event shall PayPal be liable for lost profits or any special, incidental or
consequential damages (including without limitation damages for loss of data or loss of business)
arising out of or in connection with our websites, software, systems (including any networks and
servers used to provide any of the PayPal services) operated by us or on our behalf, any of the PayPal
services, or these terms and conditions (however arising, including negligence), unless and to the
extent prohibited by law.

Our liability to you or any third parties in any circumstance is limited to the actual amount of direct
damages. In addition, to the extent permitted by applicable law, PayPal is not liable, and you agree
not to hold PayPal responsible, for any damages or losses (including, but not limited to, loss of
money, goodwill, or reputation, profits, or other intangible losses or any special, indirect, or
consequential damages) resulting directly or indirectly from: (1) your use of, or your inability to use,
our websites, software, systems (including any networks and servers used to provide any of the
PayPal services) operated by us or on our behalf, or any of the PayPal services; (2) delays or
disruptions in our websites, software, systems (including any networks and servers used to provide
any of the PayPal services) operated by us or on our behalf and any of the PayPal services; (3)
viruses or other malicious software obtained by accessing our websites, software, systems (including
any networks and servers used to provide any of the PayPal services) operated by us or on our behalf
or any of the PayPal services or any website or service linked to our websites, software or any of the
PayPal services; (4) glitches, bugs, errors, or inaccuracies of any kind in our websites, software,
systems (including any networks and servers used to provide any of the PayPal services) operated by
us or on our behalf or any of the PayPal services or in the information and graphics obtained from
them; (5) the content, actions, or inactions of third parties; (6) a suspension or other action taken
with respect to your Balance Account; or (7) your need to modify your practices, content, or
behavior, or your loss of or inability to do business, as a result of changes to these terms and
conditions or PayPal’s policies.

Disclaimer of Warranty and Release

No
No warranty
warranty
The
The PayPal
PayPal services
services are
are provided
provided “as-is”
“as-is” and
and without
without any
any representation
representation or
or warranty,
warranty,
whether
whether express,
express, implied
implied or
or statutory.
statutory. PayPal
PayPal specifically
specifically disclaims
disclaims any
any implied
implied
warranties
warranties of
of title,
title, merchantability,
merchantability, fitness
fitness for
for aa particular
particular purpose
purpose and
and non-
non-
infringement.
infringement.

PayPal does not have any control over the products or services provided by sellers who accept PayPal
as a payment method, and PayPal cannot ensure that a buyer or a seller you are dealing with will
actually complete the transaction or is authorized to do so. PayPal does not guarantee continuous,
uninterrupted or secure access to any part of the PayPal services, and operation of our websites,
software, or systems (including any networks and servers used to provide any of the PayPal services)
operated by us or on our behalf may be interfered with by numerous factors outside of our control.
PayPal will make reasonable efforts to ensure that requests for electronic debits and credits involving
bank accounts, debit cards, credit cards, and check issuances are processed in a timely manner but
PayPal makes no representations or warranties regarding the amount of time needed to complete
processing because the PayPal services are dependent upon many factors outside of our control, such
as delays in the banking system or the U.S. or international mail service. Some states do not allow
the disclaimer of implied warranties, so the foregoing disclaimers may not apply to you.

Release
Release of
of PayPal
PayPal
If you have a dispute with any other PayPal account holder, you release PayPal from any and all
claims, demands and damages (actual and consequential) of every kind and nature, known and
unknown, arising out of or in any way connected with such disputes. In entering into this release you
expressly waive any protections (whether statutory or otherwise, for example, California Civil Code §
1542) that would otherwise limit the coverage of this release to include only those claims which you
may know or suspect to exist in your favor at the time of agreeing to this release.

Agreement to Arbitrate
You and PayPal agree that any claim or dispute at law or equity that has arisen or may arise between
you and us will be resolved in accordance with the Agreement to Arbitrate provisions set forth below.
Please read this information carefully. Among other things it:

Affects your and our rights and will impact how claims between you and us are resolved including
your and our agreement to waive the right to trial by jury.

Includes a Prohibition
Prohibition of
of Class
Class and
and Representative
Representative Actions
Actions and
and Non-Individualized
Non-Individualized
Relief
Relief pursuant to which you agree to waive your right to participate in a class action against us.

Requires you to follow the Opt-Out

Opt-Out Procedure
Procedure to opt-out of the Agreement to Arbitrate by
mailing us a written notice and the opt-out notice that must be postmarked no later than 30 days
after the date you accept these terms and conditions for the first time.

If a dispute arises between you and PayPal, our goal is to learn about and address your concerns. If
we are unable to do so to your satisfaction, we aim to provide you with a neutral and cost effective
means of resolving the dispute quickly. Disputes between you and PayPal regarding the PayPal
services may be reported to customer service online through the PayPal
PayPal Help
Help Center
Center at any time,
or by calling (888) 221-1161 from Mon-Fri 5:00 AM to 10:00 PM PT and Sat-Sun 6:00 AM to 8:00
PM PT.

Agreement
Agreement to
to Arbitrate
Arbitrate

Our
Our Agreement
Agreement You and PayPal each agree that any and all disputes or claims
that have arisen or may arise between you and PayPal, including
without limitation federal and state statutory claims, common
 law claims, and those based in contract, tort, fraud,
misrepresentation or any other legal theory, shall be resolved
exclusively through final and binding arbitration or in small claims
court. You or PayPal may assert claims in small claims court
instead of in arbitration if the claims qualify and so long as the
matter remains in small claims court and advances only on an
individual (non-class, non-representative) basis. This Agreement
to Arbitrate is intended to be broadly interpreted. The Federal
Arbitration Act governs the interpretation and enforcement of
this Agreement to Arbitrate.

Notices
Notices of
of Disputes
Disputes Before bringing any dispute or claim, you or PayPal must first
send the other party, by certified mail, a completed Notice
Notice of
of
Dispute
Dispute. You should send this notice to PayPal at: PayPal, Inc.,
Attn: Legal Specialists, Re: Notice of Dispute, P.O. Box 45950,
Omaha, NE 68145-0950. PayPal will send any notice to you to
the address we have on file associated with your PayPal account;
it is your responsibility to keep your address up to date. To be
valid, the Notice of Dispute must contain all information called
for in the Notice of Dispute form, including but not limited to:
your or PayPal’s signature, the email address and phone number
associated with the customer’s PayPal account, a description of
the nature and basis of the claims that are being asserted, a
statement of the specific relief sought, and any relevant
documents and supporting information reasonably available to
the claiming party.

If you and PayPal are unable to resolve the claims described in the
notice within 45 days after the notice is received by you or
PayPal, you or PayPal may commence an arbitration proceeding
or suit in small claims court. A form for initiating arbitration
proceedings is available on the American Arbitration Association's
website at [Link]. The Notice of Dispute requirements are
essential in order to give the parties a meaningful chance to
resolve disputes informally.

Prohibition
Prohibition of
of Class
Class and
and You and PayPal agree that each of us may bring claims against the
Representative
Representative Actions
Actions and
and other only on an individual basis and not as a plaintiff or class
Non-Individualized
Non-Individualized Relief
Relief member in any purported class or representative action or
 proceeding. Unless both you and PayPal agree otherwise, the
arbitrator may not consolidate or join more than one person’s or
party’s claims and may not otherwise preside over any form of a
consolidated, representative or class proceeding. Also, the
arbitrator may award relief (including monetary, injunctive and
declaratory relief) only in favor of the individual party seeking
relief and only to the extent necessary to provide relief
necessitated by that party’s individual claim(s). Any relief
awarded cannot affect other PayPal customers.

Arbitration
Arbitration Procedures
Procedures Arbitration is more informal than a lawsuit in court. Arbitration
uses a neutral arbitrator instead of a judge or jury, and court
review of an arbitration award is very limited. However, the
arbitrator can award the same damages and relief on an individual
basis that a court can award to an individual. All issues are for the
arbitrator to decide, except that a court of competent jurisdiction
shall decide issues relating to arbitrability, the scope or
enforceability of this Agreement to Arbitrate, and issues that this
Agreement to Arbitrate indicates a court can resolve.

Any arbitration will be administered by the American Arbitration

Association (referred to as the "AAA"). For all claims, the
Consumer Arbitration Rules in effect at the time the arbitration is
commenced, as applicable, and as modified by this Agreement to
Arbitrate, shall apply. The AAA’s rules are available at
[Link]. In the event that the AAA is unavailable or unwilling
to administer the arbitration consistent with this Agreement to
Arbitrate, another administrator will be selected by the parties or
by the court.

Any arbitration hearings shall be held in the county in which you

reside or at another mutually agreed location. If the value of the
relief sought is $25,000 or less, the arbitration will be conducted
based solely on written submissions, unless any party requests an
in-person, telephonic, or videoconference hearing or the
arbitrator decides that a hearing is necessary. In cases where an
in-person hearing is held, you and/or PayPal may attend by
telephone or videoconference, unless the arbitrator requires
otherwise.
 The arbitrator will decide the substance of all claims in
accordance with applicable law, including recognized principles of
equity, and will honor all claims of privilege recognized by law. No
court or arbitrator shall be bound by rulings in prior arbitrations
involving different PayPal customers, but a court or arbitrator will
be bound by rulings in prior arbitrations involving the same
PayPal customer to the extent required by applicable law. The
award of the arbitrator shall be final and binding, and judgment
on the award rendered by the arbitrator may be entered in any
court having jurisdiction thereof.

Costs
Costs of
of Arbitration
Arbitration Payment of all AAA or arbitrator fees will be governed by the
AAA’s rules, unless otherwise stated in this Agreement to
Arbitrate. If the value of the relief sought is $10,000 or less, at
your request, PayPal will pay all AAA or arbitrator fees associated
with the arbitration. Any request for payment of fees by PayPal
should be submitted by mail to the AAA along with your Demand
for Arbitration and PayPal will make arrangements to pay all
necessary fees directly to the AAA. If the value of the relief
sought is more than $10,000 and you are able to demonstrate
that the costs of accessing arbitration will be prohibitive as
compared to the costs of accessing a court for purposes of
pursuing litigation on an individual basis, PayPal will pay as much
of the AAA or arbitrator fees as the arbitrator deems necessary to
prevent the cost of accessing the arbitration from being
prohibitive. In the event the arbitrator determines that either the
substance of your or PayPal’s claim or the relief sought was
frivolous or brought for an improper purpose, then you or PayPal
may seek to recover from you or PayPal any fees it paid, including
attorneys’ fees, to the extent permitted by the AAA’s rules and
applicable law.

Severability
Severability
With the exception of any of the provisions in the Prohibition
Prohibition of
of
Class
Class and
and Representative
Representative Actions
Actions and
and Non-Individualized
Non-Individualized
Relief
Relief section above, if a court decides that any part of this
Agreement to Arbitrate is invalid or unenforceable, the other
parts of this Agreement to Arbitrate shall still apply. If a court
decides that any of the provisions in the Prohibition
Prohibition of
of Class
Class
 and
and Representative
Representative Actions
Actions and
and Non-Individualized
Non-Individualized
Relief
Relief section above is invalid or unenforceable because it would
prevent the exercise of a non-waivable right to pursue public
injunctive relief, then any dispute regarding the entitlement to
such relief (and only that relief) must be severed from arbitration
and may be litigated in court. All other disputes subject to
arbitration under the terms of the Agreement to Arbitrate shall
be arbitrated under its terms.

Opt-Out
Opt-Out Procedure
Procedure If you are a new PayPal customer, you can choose to reject this
Agreement to Arbitrate by mailing us a written opt-out notice.
The opt-out notice must be postmarked no later than 30 days
after the date you accept these terms and conditions for the first
time. You must mail the opt-out notice to PayPal, Inc., Attn:
Litigation Department, 2211 North First Street, San Jose, CA
95131.

For your convenience, we are providing an opt-out

opt-out notice
notice form
you must complete and mail to opt out of this Agreement to
Arbitrate. You must complete this form by providing all the
information it calls for, including your name, address, phone
number, and the email address(es) used to log in to the PayPal
account(s) to which the opt-out applies. You must sign the opt-
out notice for it to be effective. This procedure is the only way
you can opt out of the Agreement to Arbitrate. If you opt out of
this Agreement to Arbitrate, all other parts of the terms and
conditions will continue to apply. Opting out of this Agreement to
Arbitrate has no effect on any previous, other, or future
arbitration agreements that you may have with us.

Future
Future Amendments
Amendments to
to this
this Notwithstanding any provision in the terms and conditions to the
Agreement
Agreement to
to Arbitrate
Arbitrate contrary, you and we agree that if we make any amendment to
this Agreement to Arbitrate (other than an amendment to any
notice address or website link provided herein) in the future, that
amendment shall not apply to any claim that was filed in a legal
proceeding against PayPal or you prior to the effective date of the
amendment. The amendment shall apply to all other disputes or
claims governed by this Agreement to Arbitrate that have arisen
 or may arise between you and PayPal. We will notify you of
amendments to this Agreement to Arbitrate by posting the
amended terms on [Link] at least 30 days before the
effective date of the amendments and by providing notice
through email. If you do not agree to these amended terms, you
may close your PayPal account within the 30-day period and you
will not be bound by the amended terms.

Intellectual Property
PayPal’s
PayPal’s trademarks
trademarks
"[Link]," "PayPal," and all logos related to the PayPal services are either trademarks or
registered trademarks of PayPal or PayPal’s licensors. You may not copy, imitate, modify or use them
without PayPal’s prior written consent. In addition, all page headers, custom graphics, button icons,
and scripts are service marks, trademarks, and/or trade dress of PayPal. You may not copy, imitate,
modify or use them without our prior written consent. You may use HTML logos provided by PayPal
for the purpose of directing web traffic to the PayPal services. You may not alter, modify or change
these HTML logos in any way, use them in a manner that mischaracterizes PayPal or the PayPal
services or display them in any manner that implies PayPal’s sponsorship or endorsement. All right,
title and interest in and to the PayPal websites, any content thereon, the PayPal services, the
technology related to the PayPal services, and any and all technology and any content created or
derived from any of the foregoing is the exclusive property of PayPal and its licensors.

License
License grants,
grants, generally
generally
If you are using PayPal software such as an API, developer’s toolkit or other software application,
which may include software provided by or integrated with software, systems or services of our
service providers, that you have downloaded or otherwise accessed through a web or mobile
platform, then PayPal grants you a revocable, non-exclusive, non-sublicensable, non-transferable,
royalty-free limited license to access and/or use PayPal’s software in accordance with the
documentation accompanying such software. This license grant applies to the software and all
updates, upgrades, new versions and replacement software. You may not rent, lease or otherwise
transfer your rights in the software to a third party. You must comply with the implementation,
access and use requirements contained in all documentation accompanying the PayPal services. If you
do not comply with implementation, access and use requirements you will be liable for all resulting
damages suffered by you, PayPal and third parties. PayPal may update or discontinue any software
upon notice to you. While PayPal may have (1) integrated certain third-party materials and
technology into any web or other application, including its software, and/or (2) accessed and used
certain third-party materials and technology to facilitate providing you with the PayPal Services, you
have not been granted and do not otherwise retain any rights in or to any such third-party materials.
You agree not to modify, alter, tamper with, repair, copy, reproduce, adapt, distribute, display,
publish, reverse engineer, translate, disassemble, decompile or otherwise attempt to create any
source code that is derived from the software or any third-party materials or technology, or
otherwise create any derivative works from any of the software or third-party materials or
technology. You acknowledge that all rights, title and interest to PayPal’s software are owned by
PayPal and any third-party materials integrated therein are owned by PayPal’s third-party service
providers. Any other third-party software application you use on the PayPal websites is subject to
the license you agreed to with the third party that provides you with this software. You acknowledge
that PayPal does not own, control nor have any responsibility or liability for any such third-party
software application you elect to use on any of our websites, software and/or in connection with the
PayPal services.

License
License grant
grant from
from you
you to
to PayPal;
PayPal; intellectual
intellectual property
property warranties
warranties
PayPal does not claim ownership of the content that you provide, upload, submit or send to PayPal.
Nor does PayPal claim ownership of the content you host on third-party websites or applications
that use PayPal services to provide payments services related to your content. Subject to the next
next
paragraph
paragraph, when you provide content to PayPal or post content using PayPal services, you grant
PayPal (and parties that we work with) a non-exclusive, irrevocable, royalty-free, transferable, and
worldwide license to use your content and associated intellectual property and publicity rights to
help us improve, operate and promote our current services and develop new ones. PayPal will not
compensate you for any of your content. You acknowledge that PayPal’s use of your content will not
infringe any intellectual property or publicity rights. Further, you acknowledge and warrant that you
own or otherwise control all of the rights of the content you provide, and you agree to waive your
moral rights and promise not to assert such rights against PayPal.

License
License grant
grant from
from sellers
sellers to
to PayPal
PayPal
Notwithstanding the provisions of the prior
prior paragraph
paragraph, if you are a seller using the PayPal services
to accept payments for goods and services, you hereby grant PayPal and its affiliates a worldwide,
non-exclusive, transferable, sublicensable (through multiple tiers), and royalty-free, fully paid-up,
right to use and display publicly, during the term of these terms and conditions, your trademark(s)
(including but not limited to registered and unregistered trademarks, trade names, service marks,
logos, domain names and other designations owned, licensed to or used by you) for the purpose of
(1) identifying you as a merchant that accepts a PayPal service as a payment form, and (2) any other
use to which you specifically consent.

Miscellaneous
Assignment
Assignment
You may not transfer or assign any rights or obligations you have under these terms and conditions
without PayPal’s prior written consent. PayPal may transfer or assign these terms and conditions or
any right or obligation under these terms and conditions at any time.

Business
Business Days
Days

“Business Day(s)” means Monday through Friday, excluding holidays when PayPal’s offices are not
considered open for business in the U.S. Holidays include New Year’s Day (January 1), Martin Luther
King, Jr.’s Birthday (the third Monday in January), George Washington’s Birthday (the third Monday in
February), Memorial Day (the last Monday in May), Independence Day (July 4), Labor Day (the first
Monday in September), Columbus Day (the second Monday in October), Veterans Day (November
11), Thanksgiving Day (the fourth Thursday in November) and Christmas Day (December 25). If a
holiday falls on a Saturday, PayPal observes the holiday on the prior Friday. If the holiday falls on a
Sunday, PayPal observes the holiday on the following Monday.

Consumer
Consumer fraud
fraud warning
warning

We’re always looking for ways to help keep you even more secure. So stay on the lookout for some of
these common scams:

Phishing: a scammer sends forged or faked electronic documents or emails falsely claiming to be
PayPal or coming from PayPal but asks you to send money outside your Balance Account.

Relative in Need: a scammer impersonates a family member (commonly grandchildren) and claims
there is an emergency requiring you to send money.

Lottery or Prize: a scammer informs you that you’ve won a lottery or prize and must send money
in order to claim it.

Debt Collection: a scammer impersonates a debt collector and induces you to send money using
threats or intimidation.

Employment Related: a scammer instructs you to send money in connection with a fraudulent
offer of employment.

Always use common sense when sending money. If something sounds too good to be true, it probably
is. Only send money for yourself and not for others. Please let us know immediately if you believe
someone is trying to scam or defraud you by contacting
contacting us
us.

Dormant
Dormant accounts
accounts

If you do not log in to your Balance Account for two or more years, PayPal may close your Balance
Account and send any funds in the account to your primary address (if we have verified the required
required
identifying
identifying information
information that you have provided to us) or, if required, escheat (send) those funds
to your state of residency. PayPal will determine your state of residency based on the state listed in
the primary address for your PayPal account. If your address is unknown or registered in a foreign
country, the funds in your Balance Account will be escheated to the State of Delaware. Where
required, PayPal will send you a notice prior to escheating any funds in your Balance Account. If you
fail to respond to this notice, the balance in your Balance Account will be escheated to the applicable
state. If you would like to claim any escheated funds from the applicable state, please contact the
applicable state’s unclaimed property administrator.

Governing
Governing law
law

You agree that, except to the extent inconsistent with or preempted by federal law and except as
otherwise stated in these terms and conditions, the laws of the State of Delaware, without regard to
principles of conflict of laws, will govern these terms and conditions and any claim or dispute that has
arisen or may arise between you and PayPal.

Identity
Identity authentication
authentication

You authorize PayPal, directly or through third parties, to make any inquiries we consider necessary
to verify your identity. This may include:

asking you for further information, such as your date of birth, a taxpayer identification number,
your physical address and other information that will allow us to reasonably identify you;

requiring you to take steps to confirm ownership of your email address or financial instruments;

ordering a credit report from a credit reporting agency, or verifying your information against
third-party databases or through other sources; or

requiring you to provide your driver’s license or other identifying documents.

Anti-money laundering and counter-terrorism financing laws may require that PayPal verify
the required
required identifying
identifying information
information if you use certain PayPal services. PayPal reserves the right
to close, suspend, or limit access to your Balance Account and/or the PayPal services in the event
that, after reasonable inquiries, we are unable to obtain information about you required to verify
your identity.

PayPal
PayPal is
is only
only aa payment
payment service
service provider
provider

We act as a payment service provider only. We do not:

Act as an escrow agent with respect to any funds kept in your Balance Account;

Act as your agent or trustee;

Enter into a partnership, joint venture, agency or employment relationship with you;
 Guarantee the identity of any buyer or seller;

Determine if you are liable for any taxes; or

Unless otherwise expressly set out in these terms and conditions, collect or pay any taxes that
may arise from your use of our services.

Privacy
Privacy

Protecting your privacy is very important to us. Please review our Privacy
Privacy Statement
Statement in order to
better understand our commitment to maintaining your privacy, as well as our use and disclosure of
your information.

State
State disclosures
disclosures

In addition to reporting complaints against PayPal directly to PayPal as described above, if you are a
California resident, you may report complaints to the California Department of Business Oversight by
mail at Department of Business Oversight, Attn: Consumer Services, 1515 K Street, Suite 200,
Sacramento, CA 95814 or online through its website
at [Link]
[Link] The California Department of
Business Oversight offers assistance with its complaint form by phone at 866-275-2677. If you are a
California resident, you have a right to receive communications about your PayPal account and the
PayPal services by email. To make such a request, send a letter to PayPal to: PayPal, Inc., Attention:
Legal Department, 2211 North First Street, San Jose, California 95131), include your email address,
and your request for that information by email.

Florida residents may contact the Florida Department of Financial Services in writing at 200 East
Gaines Street, Tallahassee, Florida, 32399, or by telephone at 1-800-342-2762.

Translation
Translation of
of agreement
agreement

Any translation of these terms and conditions is provided solely for your convenience and is not
intended to modify the terms. In the event of a conflict between the English version these terms and
conditions and a version in a language other than English, the English version shall control.

Unlawful
Unlawful internet
internet gambling
gambling notice
notice

Restricted transactions as defined in Federal Reserve Regulation GG are prohibited from being
processed through your Balance Account or your relationship with PayPal. Restricted transactions
generally include, but are not limited to, transactions in which credit, electronic fund transfers,
checks, or drafts are knowingly accepted by gambling businesses in connection with unlawful Internet
gambling.

Your
Your use
use (as
(as aa seller)
seller) of
of personal
personal data;
data; Data
Data protection
protection laws
laws

If you (as a seller) receive personal data about another PayPal customer, you are subject to and must
comply with the data
data protection
protection terms
terms set forth in the PayPal
PayPal Account
Account User
User Agreement
Agreement, which
data protection terms also extend to your use of the PayPal services provided pursuant these terms
and conditions.

PayPal Balance Long Form Disclosure

List of all fees for PayPal Balance account

Fees
Fees Amount
Amount Details
Details

Spending or sending money

International 5% (minimum There’s a fee when you send personal transactions to friends
transaction $0.99 fee; or family with eligible PayPal accounts outside the U.S. using
maximum your Balance Account balance.
$4.99 fee)

If you’re sending in a foreign currency, the fee is a comparable

amount in that currency.

Visa+ 1.75% There’s a fee when you use Visa+ to send money to friends or
transaction (minimum family with non-Venmo Visa+-enabled digital wallets using
(sending money $0.25; your Balance Account balance.
using Visa+ to maximum $25)
non-Venmo
digital wallets)

Adding money to your balance

Add cash at $3.74 - $3.95 There’s a fee of up to $3.95 when you add cash to your
stores Balance Account balance using the PayPal app at participating
stores. Amount varies by store.

Check reload 1.00% There’s a 1.00% fee (with a minimum fee of $5.00) when you
choose to add payroll or government checks (with pre-
 printed signature) to your Balance Account balance. No fee if
(faster check (minimum $5
your check can’t be added.
loads, payroll fee)
and
government
checks)

Check reload 5.00% There’s a 5.00% fee (with a minimum fee of $5.00) when you
(minimum $5 choose to add non-payroll and non-government checks to
(faster check fee) your Balance Account balance in minutes using the PayPal
loads, all other app. No fee if your check can’t be added.
accepted check
types)

Transferring money from your balance

Electronic $0 or 1.75% There is no fee to transfer money from your Balance Account
withdrawal balance to your eligible linked bank account or debit card
(standard or (minimum with the standard option. Money transferred with the
Instant $0.25 fee; standard option is typically available in 1 – 3 business days
Transfer) maximum $25 when sent to a linked bank account or approximately 48
fee) hours when sent to an eligible linked debit card. There’s a fee
to transfer money from your Balance Account balance to your
eligible linked bank account or debit card with the Instant
Transfer option. The money is typically available in minutes
with that option.

Using the PayPal Debit Mastercard® (“PayPal Debit Card”) (optional)

ATM $2.50 There’s a fee for non-MoneyPass ATM withdrawals in the U.S.
withdrawal Fee amount varies by ATM owner. You may be charged an
(out-of- additional amount by the ATM owner even if you don’t
network) complete a transaction.

ATM $2.50 There’s a fee for non-U.S. ATM withdrawals. It applies even if
international the transaction doesn’t need any currency conversion. A
withdrawal 2.50% international transaction fee described below also
 applies to international ATM withdrawals. You may be
charged an additional amount by the ATM owner even if you
don’t complete a transaction.

International 2.50% There’s a foreign transaction fee when you use your PayPal
transaction Debit Card to make purchases or withdrawals at stores or
ATMs outside the U.S. This fee applies even when there’s no
currency conversion.

Add cash at $3.74 - $3.95 There’s a fee to add cash to your Balance Account balance
stores using your PayPal Debit Card at participating stores. Fee
amount varies by store.

Using the PayPal Business Debit Mastercard® (“PayPal Business Debit Card”) (optional)

ATM $2.50 This fee is charged for ATM withdrawals in the U.S. (plus any
withdrawal amounts charged by the ATM owner). You may be charged an
additional fee by the ATM owner even if you don’t complete a
(in-network transaction.
and out-of-
network)

ATM $2.50 There’s a fee for non-U.S. ATM withdrawals. It applies even if
international the transaction doesn’t need any currency conversion. A
withdrawal 2.50% international transaction fee described below also
applies to international ATM withdrawals. You may be
charged an additional amount by the ATM owner even if you
don’t complete a transaction.

International 2.50% There’s a foreign transaction fee when you use your PayPal
transaction Business Debit Card to make purchases or withdrawals at
stores or ATMs outside the U.S. This fee applies even when
there’s no currency conversion.

$3.74 - $3.95
Add cash at There’s a fee to add cash to your Balance Account balance
stores using your PayPal Business Debit Card at participating stores.
Fee amount varies by store.

Third-party digital wallets (optional)

International 2.50% There’s a foreign transaction fee to use PayPal in Google Pay
transaction and Samsung Pay to make a purchase from a non-U.S.
merchant. This fee applies even when there’s no currency
conversion.

Cryptocurrencies
Cryptocurrencies

Buying or There’s a fee for buying or selling cryptocurrencies. Fee will

selling a vary based on the U.S. dollar value of your cryptocurrency
cryptocurrency: purchase or sale amount. These fees do not apply to buying
$0.49 and selling PYUSD.
$1.00 – $4.99 (minimum fee)

$5.00 – $24.99 $0.99

$25.00 – $1.99
$74.99
$2.49
$75.00 –
$200.00 1.80%

$200.01 – 1.50%
$1000.00

$1000.01+

Converting There is a fee to convert PYUSD to/from another type of

between PYUSD cryptocurrency. The fee will vary based on the U.S. dollar
and another value of the cryptocurrency you convert.
cryptocurrency: $0.49
(minimum fee)
$1.00 – $9.99
$0.99

$10.00 –
$1.99
$29.99
$2.49
$30.00 –
$79.99 1.75%

$80.00 – 1.45%
$249.99

$250.00 –
$1000.00

$1000.01 +

Receiving a $0 No fee
cryptocurrency
transfer

Transferring $0 No fee
cryptocurrency
to another
PayPal or
Venmo account

Transferring Amount varies

cryptocurrency (paid in You will be charged a cryptocurrency network fee, payable in
to an address cryptocurrency) the cryptocurrency you transfer, which varies. For more
outside of information, see the PayPal Cryptocurrency Terms and
PayPal or Conditions on the Legal Agreements page at [Link]
[Link]. We
Venmo will display such network fee right before you transfer any
cryptocurrency.

Using PayPal as For When you buy cryptocurrency to be transferred in one step,
a funding cryptocurrency you will also be charged a cryptocurrency network fee,
source to buy other than payable in the cryptocurrency you transfer. The
and transfer PYUSD, 1% + cryptocurrency amount to be transferred in one step to an
cryptocurrency the applicable external wallet plus the cryptocurrency amount you will be
in one step to fee listed in the charged to cover the cryptocurrency network fee is the
external “Buying or “combined cryptocurrency purchase amount.” We will display
cryptocurrency selling a the network fee right before you transfer any cryptocurrency.
wallet cryptocurrency”
providers who section above For cryptocurrency other than PYUSD, you will pay (1) the
support this transaction fee listed in the “Buying or selling a
feature For PYUSD, a cryptocurrency” section above on the U.S. dollar value of the
fee of 1.5% combined cryptocurrency purchase amount and (2) 1% only
on the U.S. dollar value of the cryptocurrency that you
transfer to your external wallet.

For PYUSD, you will pay 1.5% on the U.S. dollar value of the
PYUSD that you transfer to your external wallet. You will not
pay a transaction fee on the combined cryptocurrency
purchase amount.

Using PayPal to For When you transfer and sell cryptocurrency out of a supported
transfer and cryptocurrency external cryptocurrency wallet in one step, you will pay a
sell other than transaction fee on the U.S. dollar value of the
cryptocurrency PYUSD, 1% + cryptocurrency you are selling.
out of the applicable
supported fee listed in the For cryptocurrency other than PYUSD, you will pay (1) the
external “Buying or transaction fee listed in the “Buying or selling a
cryptocurrency selling a cryptocurrency” section above and (2) 1% only on the U.S.
wallets in one cryptocurrency” dollar value of the cryptocurrency that you receive from your
step section above external wallet.

For PYUSD, a For PYUSD, you will pay 1.5% on the U.S. dollar value of the
fee of 1.5% PYUSD that you receive from your external wallet. You will
not pay a transaction fee listed in the “Buying or selling a
cryptocurrency” section above.

Your U.S. dollar funds (but not cryptocurrencies or non-U.S. dollar currencies) are FDIC insured,
up to applicable limits, only if you opened a PayPal Debit Card account, enrolled in Direct Deposit,
or bought or received cryptocurrency with your PayPal Balance account. FDIC insurance does not
protect you against the failure of PayPal.
No overdraft/credit feature.

Contact us at 1-844-629-9108, by mail at PayPal Inc., Attention: Legal Department, 2211 North
First Street, San Jose, CA 95131, or online at [Link]/us/smarthelp/contact-us
[Link]/us/smarthelp/contact-us.

For general information about prepaid accounts, visit [Link]/prepaid

[Link]/prepaid.

If you have a complaint about a prepaid account, call the Consumer Financial Protection Bureau at
1-855-411-2372 or visit [Link]/complaint
[Link]/complaint.
You understand and agree that, to the extent permitted by law, PayPal may, without further notice
or warning, monitor or record telephone conversations you or anyone acting on your behalf has with
PayPal or its agents for quality control and training purposes or for our own protection. You
acknowledge and understand that while your communications with PayPal may be overheard,
monitored, or recorded not all telephone lines or calls may be recorded by PayPal, and PayPal does
not guarantee that recordings of any particular telephone calls will be retained or retrievable.

PayPal’s Rights
PayPal
PayPal suspension
suspension and
and termination
termination rights
rights
PayPal, in its sole discretion, reserves the right to suspend or terminate these terms and conditions,
access to or use of its websites, software, systems (including any networks and servers used to
provide any of the PayPal services) operated by us or on our behalf or some or all of the PayPal
services for any reason and at any time upon notice to you and, upon termination of these terms and
conditions, the payment to you of any unrestricted funds held in your Balance Account.

Security
Security interest
interest
As security for the performance of your obligations under these terms and conditions, you grant to
PayPal a lien on, and security interest in and to, funds held in your Balance Account.

Amounts
Amounts owed
owed to
to PayPal
PayPal
If the balance in your Balance Account becomes negative for any reason, that negative balance
represents an amount that you owe to PayPal. PayPal may deduct these amounts from funds that are
added to your Balance Account later, either by you or from payments you receive. If you have more
than one PayPal account, we may set off a negative balance in one PayPal account against a PayPal
balance in your other PayPal account(s), including a Balance Account. If you continue using your
Balance Account when it has a negative balance, you authorize PayPal to combine the negative
balance with any debit or transaction sent from your personal account when that combination is
disclosed to you in advance of initiating the debit or transaction.

If you hold funds in a Balance Account in multiple currencies, and the balance for one of the
currencies becomes negative for any reason, PayPal may set off the negative balance by using funds
you maintain in a different currency. If you have a negative balance in non-U.S. dollars for a period of
21 days or longer, PayPal will convert this negative balance to U.S. dollars. In either case, a currency
currency
conversion
conversion will be necessary, and PayPal’s transaction exchange rate (including our currency
currency
conversion
conversion spread
spread) will be used.

In addition to the above, if you have a past due amount owed to us or our affiliates, PayPal may debit
your Balance Account to pay any amounts that are past due. This includes amounts owed by using
our various products such as Venmo, Xoom or Braintree.

Insolvency
Insolvency proceedings
proceedings
If any proceeding by or against you is commenced under any provision of the United States
Bankruptcy Code, as amended, or under any other bankruptcy or insolvency law, we’ll be entitled to
recover all reasonable costs or expenses (including reasonable legal fees and expenses) incurred in
connection with the enforcement of these terms and conditions.

Assumption
Assumption of
of rights
rights
If PayPal invalidates and reverses a payment that you made to a recipient (either at your initiative or
otherwise), you agree that PayPal assumes your rights against the recipient and third parties related
to the payment and may pursue those rights directly or on your behalf, in PayPal’s discretion.

No
No waiver
waiver
Our failure to act with respect to a breach of any of your obligations under these terms and
conditions by you or others does not waive our right to act with respect to subsequent or similar
breaches.

Indemnification and Limitation of Liability

In this section, we use the term “PayPal” to refer to PayPal, Inc., our parent PayPal Holdings, Inc., and
our affiliates, and each of their respective directors, officers, employees, agents, joint venturers,
service providers and suppliers. Our affiliates include each entity that we control, we are controlled
by or we are under common control with.

Indemnification
Indemnification
You
You must
must indemnify
indemnify PayPal
PayPal for
for actions
actions related
related to
to your
your Balance
Balance Account
Account and
and your
your use
use of
of
the
the PayPal
PayPal services.
services. You agree to defend, indemnify and hold PayPal harmless from any claim or
demand (including reasonable legal fees) made or incurred by any third party due to or arising out of
your breach of these terms and conditions, your improper use of the PayPal services, your violation
of any law or the rights of a third party and/or the actions or inactions of any third party to whom
you grant permissions to use your Balance Account or access our websites, software, systems
(including any networks and servers used to provide any of the PayPal services) operated by us or on
our behalf, or any of the PayPal services on your behalf.

Limitation
Limitation of
of liability
liability
PayPal’s
PayPal’s liability
liability is
is limited
limited with
with respect
respect to
to your
your Balance
Balance Account
Account and
and your
your use
use of
of the
the
PayPal
PayPal services.
services. In no event shall PayPal be liable for lost profits or any special, incidental or
consequential damages (including without limitation damages for loss of data or loss of business)
arising out of or in connection with our websites, software, systems (including any networks and
servers used to provide any of the PayPal services) operated by us or on our behalf, any of the PayPal
services, or these terms and conditions (however arising, including negligence), unless and to the
extent prohibited by law.

Our liability to you or any third parties in any circumstance is limited to the actual amount of direct
damages. In addition, to the extent permitted by applicable law, PayPal is not liable, and you agree
not to hold PayPal responsible, for any damages or losses (including, but not limited to, loss of
money, goodwill, or reputation, profits, or other intangible losses or any special, indirect, or
consequential damages) resulting directly or indirectly from: (1) your use of, or your inability to use,
our websites, software, systems (including any networks and servers used to provide any of the
PayPal services) operated by us or on our behalf, or any of the PayPal services; (2) delays or
disruptions in our websites, software, systems (including any networks and servers used to provide
any of the PayPal services) operated by us or on our behalf and any of the PayPal services; (3)
viruses or other malicious software obtained by accessing our websites, software, systems (including
any networks and servers used to provide any of the PayPal services) operated by us or on our behalf
or any of the PayPal services or any website or service linked to our websites, software or any of the
PayPal services; (4) glitches, bugs, errors, or inaccuracies of any kind in our websites, software,
systems (including any networks and servers used to provide any of the PayPal services) operated by
us or on our behalf or any of the PayPal services or in the information and graphics obtained from
them; (5) the content, actions, or inactions of third parties; (6) a suspension or other action taken
with respect to your Balance Account; or (7) your need to modify your practices, content, or
behavior, or your loss of or inability to do business, as a result of changes to these terms and
conditions or PayPal’s policies.

Disclaimer of Warranty and Release

No
No warranty
warranty
The
The PayPal
PayPal services
services are
are provided
provided “as-is”
“as-is” and
and without
without any
any representation
representation or
or warranty,
warranty,
whether
whether express,
express, implied
implied or
or statutory.
statutory. PayPal
PayPal specifically
specifically disclaims
disclaims any
any implied
implied
warranties
warranties of
of title,
title, merchantability,
merchantability, fitness
fitness for
for aa particular
particular purpose
purpose and
and non-
non-
infringement.
infringement.

PayPal does not have any control over the products or services provided by sellers who accept PayPal
as a payment method, and PayPal cannot ensure that a buyer or a seller you are dealing with will
actually complete the transaction or is authorized to do so. PayPal does not guarantee continuous,
uninterrupted or secure access to any part of the PayPal services, and operation of our websites,
software, or systems (including any networks and servers used to provide any of the PayPal services)
operated by us or on our behalf may be interfered with by numerous factors outside of our control.
PayPal will make reasonable efforts to ensure that requests for electronic debits and credits involving
bank accounts, debit cards, credit cards, and check issuances are processed in a timely manner but
PayPal makes no representations or warranties regarding the amount of time needed to complete
processing because the PayPal services are dependent upon many factors outside of our control, such
as delays in the banking system or the U.S. or international mail service. Some states do not allow
the disclaimer of implied warranties, so the foregoing disclaimers may not apply to you.

Release
Release of
of PayPal
PayPal
If you have a dispute with any other PayPal account holder, you release PayPal from any and all
claims, demands and damages (actual and consequential) of every kind and nature, known and
unknown, arising out of or in any way connected with such disputes. In entering into this release you
expressly waive any protections (whether statutory or otherwise, for example, California Civil Code §
1542) that would otherwise limit the coverage of this release to include only those claims which you
may know or suspect to exist in your favor at the time of agreeing to this release.

Agreement to Arbitrate
You and PayPal agree that any claim or dispute at law or equity that has arisen or may arise between
you and us will be resolved in accordance with the Agreement to Arbitrate provisions set forth below.
Please read this information carefully. Among other things it:

Affects your and our rights and will impact how claims between you and us are resolved including
your and our agreement to waive the right to trial by jury.

Includes a Prohibition
Prohibition of
of Class
Class and
and Representative
Representative Actions
Actions and
and Non-Individualized
Non-Individualized
Relief
Relief pursuant to which you agree to waive your right to participate in a class action against us.

Requires you to follow the Opt-Out

Opt-Out Procedure
Procedure to opt-out of the Agreement to Arbitrate by
mailing us a written notice and the opt-out notice that must be postmarked no later than 30 days
after the date you accept these terms and conditions for the first time.

If a dispute arises between you and PayPal, our goal is to learn about and address your concerns. If
we are unable to do so to your satisfaction, we aim to provide you with a neutral and cost effective
means of resolving the dispute quickly. Disputes between you and PayPal regarding the PayPal
services may be reported to customer service online through the PayPal
PayPal Help
Help Center
Center at any time,
or by calling (888) 221-1161 from Mon-Fri 5:00 AM to 10:00 PM PT and Sat-Sun 6:00 AM to 8:00
PM PT.

Agreement
Agreement to
to Arbitrate
Arbitrate

Our
Our Agreement
Agreement You and PayPal each agree that any and all disputes or claims
that have arisen or may arise between you and PayPal, including
without limitation federal and state statutory claims, common
 law claims, and those based in contract, tort, fraud,
misrepresentation or any other legal theory, shall be resolved
exclusively through final and binding arbitration or in small claims
court. You or PayPal may assert claims in small claims court
instead of in arbitration if the claims qualify and so long as the
matter remains in small claims court and advances only on an
individual (non-class, non-representative) basis. This Agreement
to Arbitrate is intended to be broadly interpreted. The Federal
Arbitration Act governs the interpretation and enforcement of
this Agreement to Arbitrate.

Notices
Notices of
of Disputes
Disputes Before bringing any dispute or claim, you or PayPal must first
send the other party, by certified mail, a completed Notice
Notice of
of
Dispute
Dispute. You should send this notice to PayPal at: PayPal, Inc.,
Attn: Legal Specialists, Re: Notice of Dispute, P.O. Box 45950,
Omaha, NE 68145-0950. PayPal will send any notice to you to
the address we have on file associated with your PayPal account;
it is your responsibility to keep your address up to date. To be
valid, the Notice of Dispute must contain all information called
for in the Notice of Dispute form, including but not limited to:
your or PayPal’s signature, the email address and phone number
associated with the customer’s PayPal account, a description of
the nature and basis of the claims that are being asserted, a
statement of the specific relief sought, and any relevant
documents and supporting information reasonably available to
the claiming party.

If you and PayPal are unable to resolve the claims described in the
notice within 45 days after the notice is received by you or
PayPal, you or PayPal may commence an arbitration proceeding
or suit in small claims court. A form for initiating arbitration
proceedings is available on the American Arbitration Association's
website at [Link]. The Notice of Dispute requirements are
essential in order to give the parties a meaningful chance to
resolve disputes informally.

Prohibition
Prohibition of
of Class
Class and
and You and PayPal agree that each of us may bring claims against the
Representative
Representative Actions
Actions and
and other only on an individual basis and not as a plaintiff or class
Non-Individualized
Non-Individualized Relief
Relief member in any purported class or representative action or
 proceeding. Unless both you and PayPal agree otherwise, the
arbitrator may not consolidate or join more than one person’s or
party’s claims and may not otherwise preside over any form of a
consolidated, representative or class proceeding. Also, the
arbitrator may award relief (including monetary, injunctive and
declaratory relief) only in favor of the individual party seeking
relief and only to the extent necessary to provide relief
necessitated by that party’s individual claim(s). Any relief
awarded cannot affect other PayPal customers.

Arbitration
Arbitration Procedures
Procedures Arbitration is more informal than a lawsuit in court. Arbitration
uses a neutral arbitrator instead of a judge or jury, and court
review of an arbitration award is very limited. However, the
arbitrator can award the same damages and relief on an individual
basis that a court can award to an individual. All issues are for the
arbitrator to decide, except that a court of competent jurisdiction
shall decide issues relating to arbitrability, the scope or
enforceability of this Agreement to Arbitrate, and issues that this
Agreement to Arbitrate indicates a court can resolve.

Any arbitration will be administered by the American Arbitration

Association (referred to as the "AAA"). For all claims, the
Consumer Arbitration Rules in effect at the time the arbitration is
commenced, as applicable, and as modified by this Agreement to
Arbitrate, shall apply. The AAA’s rules are available at
[Link]. In the event that the AAA is unavailable or unwilling
to administer the arbitration consistent with this Agreement to
Arbitrate, another administrator will be selected by the parties or
by the court.

Any arbitration hearings shall be held in the county in which you

reside or at another mutually agreed location. If the value of the
relief sought is $25,000 or less, the arbitration will be conducted
based solely on written submissions, unless any party requests an
in-person, telephonic, or videoconference hearing or the
arbitrator decides that a hearing is necessary. In cases where an
in-person hearing is held, you and/or PayPal may attend by
telephone or videoconference, unless the arbitrator requires
otherwise.
 The arbitrator will decide the substance of all claims in
accordance with applicable law, including recognized principles of
equity, and will honor all claims of privilege recognized by law. No
court or arbitrator shall be bound by rulings in prior arbitrations
involving different PayPal customers, but a court or arbitrator will
be bound by rulings in prior arbitrations involving the same
PayPal customer to the extent required by applicable law. The
award of the arbitrator shall be final and binding, and judgment
on the award rendered by the arbitrator may be entered in any
court having jurisdiction thereof.

Costs
Costs of
of Arbitration
Arbitration Payment of all AAA or arbitrator fees will be governed by the
AAA’s rules, unless otherwise stated in this Agreement to
Arbitrate. If the value of the relief sought is $10,000 or less, at
your request, PayPal will pay all AAA or arbitrator fees associated
with the arbitration. Any request for payment of fees by PayPal
should be submitted by mail to the AAA along with your Demand
for Arbitration and PayPal will make arrangements to pay all
necessary fees directly to the AAA. If the value of the relief
sought is more than $10,000 and you are able to demonstrate
that the costs of accessing arbitration will be prohibitive as
compared to the costs of accessing a court for purposes of
pursuing litigation on an individual basis, PayPal will pay as much
of the AAA or arbitrator fees as the arbitrator deems necessary to
prevent the cost of accessing the arbitration from being
prohibitive. In the event the arbitrator determines that either the
substance of your or PayPal’s claim or the relief sought was
frivolous or brought for an improper purpose, then you or PayPal
may seek to recover from you or PayPal any fees it paid, including
attorneys’ fees, to the extent permitted by the AAA’s rules and
applicable law.

Severability
Severability
With the exception of any of the provisions in the Prohibition
Prohibition of
of
Class
Class and
and Representative
Representative Actions
Actions and
and Non-Individualized
Non-Individualized
Relief
Relief section above, if a court decides that any part of this
Agreement to Arbitrate is invalid or unenforceable, the other
parts of this Agreement to Arbitrate shall still apply. If a court
decides that any of the provisions in the Prohibition
Prohibition of
of Class
Class
 and
and Representative
Representative Actions
Actions and
and Non-Individualized
Non-Individualized
Relief
Relief section above is invalid or unenforceable because it would
prevent the exercise of a non-waivable right to pursue public
injunctive relief, then any dispute regarding the entitlement to
such relief (and only that relief) must be severed from arbitration
and may be litigated in court. All other disputes subject to
arbitration under the terms of the Agreement to Arbitrate shall
be arbitrated under its terms.

Opt-Out
Opt-Out Procedure
Procedure If you are a new PayPal customer, you can choose to reject this
Agreement to Arbitrate by mailing us a written opt-out notice.
The opt-out notice must be postmarked no later than 30 days
after the date you accept these terms and conditions for the first
time. You must mail the opt-out notice to PayPal, Inc., Attn:
Litigation Department, 2211 North First Street, San Jose, CA
95131.

For your convenience, we are providing an opt-out

opt-out notice
notice form
you must complete and mail to opt out of this Agreement to
Arbitrate. You must complete this form by providing all the
information it calls for, including your name, address, phone
number, and the email address(es) used to log in to the PayPal
account(s) to which the opt-out applies. You must sign the opt-
out notice for it to be effective. This procedure is the only way
you can opt out of the Agreement to Arbitrate. If you opt out of
this Agreement to Arbitrate, all other parts of the terms and
conditions will continue to apply. Opting out of this Agreement to
Arbitrate has no effect on any previous, other, or future
arbitration agreements that you may have with us.

Future
Future Amendments
Amendments to
to this
this Notwithstanding any provision in the terms and conditions to the
Agreement
Agreement to
to Arbitrate
Arbitrate contrary, you and we agree that if we make any amendment to
this Agreement to Arbitrate (other than an amendment to any
notice address or website link provided herein) in the future, that
amendment shall not apply to any claim that was filed in a legal
proceeding against PayPal or you prior to the effective date of the
amendment. The amendment shall apply to all other disputes or
claims governed by this Agreement to Arbitrate that have arisen
 or may arise between you and PayPal. We will notify you of
amendments to this Agreement to Arbitrate by posting the
amended terms on [Link] at least 30 days before the
effective date of the amendments and by providing notice
through email. If you do not agree to these amended terms, you
may close your PayPal account within the 30-day period and you
will not be bound by the amended terms.

Intellectual Property
PayPal’s
PayPal’s trademarks
trademarks
"[Link]," "PayPal," and all logos related to the PayPal services are either trademarks or
registered trademarks of PayPal or PayPal’s licensors. You may not copy, imitate, modify or use them
without PayPal’s prior written consent. In addition, all page headers, custom graphics, button icons,
and scripts are service marks, trademarks, and/or trade dress of PayPal. You may not copy, imitate,
modify or use them without our prior written consent. You may use HTML logos provided by PayPal
for the purpose of directing web traffic to the PayPal services. You may not alter, modify or change
these HTML logos in any way, use them in a manner that mischaracterizes PayPal or the PayPal
services or display them in any manner that implies PayPal’s sponsorship or endorsement. All right,
title and interest in and to the PayPal websites, any content thereon, the PayPal services, the
technology related to the PayPal services, and any and all technology and any content created or
derived from any of the foregoing is the exclusive property of PayPal and its licensors.

License
License grants,
grants, generally
generally
If you are using PayPal software such as an API, developer’s toolkit or other software application,
which may include software provided by or integrated with software, systems or services of our
service providers, that you have downloaded or otherwise accessed through a web or mobile
platform, then PayPal grants you a revocable, non-exclusive, non-sublicensable, non-transferable,
royalty-free limited license to access and/or use PayPal’s software in accordance with the
documentation accompanying such software. This license grant applies to the software and all
updates, upgrades, new versions and replacement software. You may not rent, lease or otherwise
transfer your rights in the software to a third party. You must comply with the implementation,
access and use requirements contained in all documentation accompanying the PayPal services. If you
do not comply with implementation, access and use requirements you will be liable for all resulting
damages suffered by you, PayPal and third parties. PayPal may update or discontinue any software
upon notice to you. While PayPal may have (1) integrated certain third-party materials and
technology into any web or other application, including its software, and/or (2) accessed and used
certain third-party materials and technology to facilitate providing you with the PayPal Services, you
have not been granted and do not otherwise retain any rights in or to any such third-party materials.
You agree not to modify, alter, tamper with, repair, copy, reproduce, adapt, distribute, display,
publish, reverse engineer, translate, disassemble, decompile or otherwise attempt to create any
source code that is derived from the software or any third-party materials or technology, or
otherwise create any derivative works from any of the software or third-party materials or
technology. You acknowledge that all rights, title and interest to PayPal’s software are owned by
PayPal and any third-party materials integrated therein are owned by PayPal’s third-party service
providers. Any other third-party software application you use on the PayPal websites is subject to
the license you agreed to with the third party that provides you with this software. You acknowledge
that PayPal does not own, control nor have any responsibility or liability for any such third-party
software application you elect to use on any of our websites, software and/or in connection with the
PayPal services.

License
License grant
grant from
from you
you to
to PayPal;
PayPal; intellectual
intellectual property
property warranties
warranties
PayPal does not claim ownership of the content that you provide, upload, submit or send to PayPal.
Nor does PayPal claim ownership of the content you host on third-party websites or applications
that use PayPal services to provide payments services related to your content. Subject to the next
next
paragraph
paragraph, when you provide content to PayPal or post content using PayPal services, you grant
PayPal (and parties that we work with) a non-exclusive, irrevocable, royalty-free, transferable, and
worldwide license to use your content and associated intellectual property and publicity rights to
help us improve, operate and promote our current services and develop new ones. PayPal will not
compensate you for any of your content. You acknowledge that PayPal’s use of your content will not
infringe any intellectual property or publicity rights. Further, you acknowledge and warrant that you
own or otherwise control all of the rights of the content you provide, and you agree to waive your
moral rights and promise not to assert such rights against PayPal.

License
License grant
grant from
from sellers
sellers to
to PayPal
PayPal
Notwithstanding the provisions of the prior
prior paragraph
paragraph, if you are a seller using the PayPal services
to accept payments for goods and services, you hereby grant PayPal and its affiliates a worldwide,
non-exclusive, transferable, sublicensable (through multiple tiers), and royalty-free, fully paid-up,
right to use and display publicly, during the term of these terms and conditions, your trademark(s)
(including but not limited to registered and unregistered trademarks, trade names, service marks,
logos, domain names and other designations owned, licensed to or used by you) for the purpose of
(1) identifying you as a merchant that accepts a PayPal service as a payment form, and (2) any other
use to which you specifically consent.

Miscellaneous
Assignment
Assignment
You may not transfer or assign any rights or obligations you have under these terms and conditions
without PayPal’s prior written consent. PayPal may transfer or assign these terms and conditions or
any right or obligation under these terms and conditions at any time.

Business
Business Days
Days

“Business Day(s)” means Monday through Friday, excluding holidays when PayPal’s offices are not
considered open for business in the U.S. Holidays include New Year’s Day (January 1), Martin Luther
King, Jr.’s Birthday (the third Monday in January), George Washington’s Birthday (the third Monday in
February), Memorial Day (the last Monday in May), Independence Day (July 4), Labor Day (the first
Monday in September), Columbus Day (the second Monday in October), Veterans Day (November
11), Thanksgiving Day (the fourth Thursday in November) and Christmas Day (December 25). If a
holiday falls on a Saturday, PayPal observes the holiday on the prior Friday. If the holiday falls on a
Sunday, PayPal observes the holiday on the following Monday.

Consumer
Consumer fraud
fraud warning
warning

We’re always looking for ways to help keep you even more secure. So stay on the lookout for some of
these common scams:

Phishing: a scammer sends forged or faked electronic documents or emails falsely claiming to be
PayPal or coming from PayPal but asks you to send money outside your Balance Account.

Relative in Need: a scammer impersonates a family member (commonly grandchildren) and claims
there is an emergency requiring you to send money.

Lottery or Prize: a scammer informs you that you’ve won a lottery or prize and must send money
in order to claim it.

Debt Collection: a scammer impersonates a debt collector and induces you to send money using
threats or intimidation.

Employment Related: a scammer instructs you to send money in connection with a fraudulent
offer of employment.

Always use common sense when sending money. If something sounds too good to be true, it probably
is. Only send money for yourself and not for others. Please let us know immediately if you believe
someone is trying to scam or defraud you by contacting
contacting us
us.

Dormant
Dormant accounts
accounts

If you do not log in to your Balance Account for two or more years, PayPal may close your Balance
Account and send any funds in the account to your primary address (if we have verified the required
required
identifying
identifying information
information that you have provided to us) or, if required, escheat (send) those funds
to your state of residency. PayPal will determine your state of residency based on the state listed in
the primary address for your PayPal account. If your address is unknown or registered in a foreign
country, the funds in your Balance Account will be escheated to the State of Delaware. Where
required, PayPal will send you a notice prior to escheating any funds in your Balance Account. If you
fail to respond to this notice, the balance in your Balance Account will be escheated to the applicable
state. If you would like to claim any escheated funds from the applicable state, please contact the
applicable state’s unclaimed property administrator.

Governing
Governing law
law

You agree that, except to the extent inconsistent with or preempted by federal law and except as
otherwise stated in these terms and conditions, the laws of the State of Delaware, without regard to
principles of conflict of laws, will govern these terms and conditions and any claim or dispute that has
arisen or may arise between you and PayPal.

Identity
Identity authentication
authentication

You authorize PayPal, directly or through third parties, to make any inquiries we consider necessary
to verify your identity. This may include:

asking you for further information, such as your date of birth, a taxpayer identification number,
your physical address and other information that will allow us to reasonably identify you;

requiring you to take steps to confirm ownership of your email address or financial instruments;

ordering a credit report from a credit reporting agency, or verifying your information against
third-party databases or through other sources; or

requiring you to provide your driver’s license or other identifying documents.

Anti-money laundering and counter-terrorism financing laws may require that PayPal verify
the required
required identifying
identifying information
information if you use certain PayPal services. PayPal reserves the right
to close, suspend, or limit access to your Balance Account and/or the PayPal services in the event
that, after reasonable inquiries, we are unable to obtain information about you required to verify
your identity.

PayPal
PayPal is
is only
only aa payment
payment service
service provider
provider

We act as a payment service provider only. We do not:

Act as an escrow agent with respect to any funds kept in your Balance Account;

Act as your agent or trustee;

Enter into a partnership, joint venture, agency or employment relationship with you;
 Guarantee the identity of any buyer or seller;

Determine if you are liable for any taxes; or

Unless otherwise expressly set out in these terms and conditions, collect or pay any taxes that
may arise from your use of our services.

Privacy
Privacy

Protecting your privacy is very important to us. Please review our Privacy
Privacy Statement
Statement in order to
better understand our commitment to maintaining your privacy, as well as our use and disclosure of
your information.

State
State disclosures
disclosures

In addition to reporting complaints against PayPal directly to PayPal as described above, if you are a
California resident, you may report complaints to the California Department of Business Oversight by
mail at Department of Business Oversight, Attn: Consumer Services, 1515 K Street, Suite 200,
Sacramento, CA 95814 or online through its website
at [Link]
[Link] The California Department of
Business Oversight offers assistance with its complaint form by phone at 866-275-2677. If you are a
California resident, you have a right to receive communications about your PayPal account and the
PayPal services by email. To make such a request, send a letter to PayPal to: PayPal, Inc., Attention:
Legal Department, 2211 North First Street, San Jose, California 95131), include your email address,
and your request for that information by email.

Florida residents may contact the Florida Department of Financial Services in writing at 200 East
Gaines Street, Tallahassee, Florida, 32399, or by telephone at 1-800-342-2762.

Translation
Translation of
of agreement
agreement

Any translation of these terms and conditions is provided solely for your convenience and is not
intended to modify the terms. In the event of a conflict between the English version these terms and
conditions and a version in a language other than English, the English version shall control.

Unlawful
Unlawful internet
internet gambling
gambling notice
notice

Restricted transactions as defined in Federal Reserve Regulation GG are prohibited from being
processed through your Balance Account or your relationship with PayPal. Restricted transactions
generally include, but are not limited to, transactions in which credit, electronic fund transfers,
checks, or drafts are knowingly accepted by gambling businesses in connection with unlawful Internet
gambling.

Your
Your use
use (as
(as aa seller)
seller) of
of personal
personal data;
data; Data
Data protection
protection laws
laws

If you (as a seller) receive personal data about another PayPal customer, you are subject to and must
comply with the data
data protection
protection terms
terms set forth in the PayPal
PayPal Account
Account User
User Agreement
Agreement, which
data protection terms also extend to your use of the PayPal services provided pursuant these terms
and conditions.

PayPal Balance Long Form Disclosure

List of all fees for PayPal Balance account

Fees
Fees Amount
Amount Details
Details

Spending or sending money

International 5% (minimum There’s a fee when you send personal transactions to friends
transaction $0.99 fee; or family with eligible PayPal accounts outside the U.S. using
maximum your Balance Account balance.
$4.99 fee)

If you’re sending in a foreign currency, the fee is a comparable

amount in that currency.

Visa+ 1.75% There’s a fee when you use Visa+ to send money to friends or
transaction (minimum family with non-Venmo Visa+-enabled digital wallets using
(sending money $0.25; your Balance Account balance.
using Visa+ to maximum $25)
non-Venmo
digital wallets)

Adding money to your balance

Add cash at $3.74 - $3.95 There’s a fee of up to $3.95 when you add cash to your
stores Balance Account balance using the PayPal app at participating
stores. Amount varies by store.

Check reload 1.00% There’s a 1.00% fee (with a minimum fee of $5.00) when you
choose to add payroll or government checks (with pre-
 printed signature) to your Balance Account balance. No fee if
(faster check (minimum $5
your check can’t be added.
loads, payroll fee)
and
government
checks)

Check reload 5.00% There’s a 5.00% fee (with a minimum fee of $5.00) when you
(minimum $5 choose to add non-payroll and non-government checks to
(faster check fee) your Balance Account balance in minutes using the PayPal
loads, all other app. No fee if your check can’t be added.
accepted check
types)

Transferring money from your balance

Electronic $0 or 1.75% There is no fee to transfer money from your Balance Account
withdrawal balance to your eligible linked bank account or debit card
(standard or (minimum with the standard option. Money transferred with the
Instant $0.25 fee; standard option is typically available in 1 – 3 business days
Transfer) maximum $25 when sent to a linked bank account or approximately 48
fee) hours when sent to an eligible linked debit card. There’s a fee
to transfer money from your Balance Account balance to your
eligible linked bank account or debit card with the Instant
Transfer option. The money is typically available in minutes
with that option.

Using the PayPal Debit Mastercard® (“PayPal Debit Card”) (optional)

ATM $2.50 There’s a fee for non-MoneyPass ATM withdrawals in the U.S.
withdrawal Fee amount varies by ATM owner. You may be charged an
(out-of- additional amount by the ATM owner even if you don’t
network) complete a transaction.

ATM $2.50 There’s a fee for non-U.S. ATM withdrawals. It applies even if
international the transaction doesn’t need any currency conversion. A
withdrawal 2.50% international transaction fee described below also
 applies to international ATM withdrawals. You may be
charged an additional amount by the ATM owner even if you
don’t complete a transaction.

International 2.50% There’s a foreign transaction fee when you use your PayPal
transaction Debit Card to make purchases or withdrawals at stores or
ATMs outside the U.S. This fee applies even when there’s no
currency conversion.

Add cash at $3.74 - $3.95 There’s a fee to add cash to your Balance Account balance
stores using your PayPal Debit Card at participating stores. Fee
amount varies by store.

Using the PayPal Business Debit Mastercard® (“PayPal Business Debit Card”) (optional)

ATM $2.50 This fee is charged for ATM withdrawals in the U.S. (plus any
withdrawal amounts charged by the ATM owner). You may be charged an
additional fee by the ATM owner even if you don’t complete a
(in-network transaction.
and out-of-
network)

ATM $2.50 There’s a fee for non-U.S. ATM withdrawals. It applies even if
international the transaction doesn’t need any currency conversion. A
withdrawal 2.50% international transaction fee described below also
applies to international ATM withdrawals. You may be
charged an additional amount by the ATM owner even if you
don’t complete a transaction.

International 2.50% There’s a foreign transaction fee when you use your PayPal
transaction Business Debit Card to make purchases or withdrawals at
stores or ATMs outside the U.S. This fee applies even when
there’s no currency conversion.

$3.74 - $3.95
Add cash at There’s a fee to add cash to your Balance Account balance
stores using your PayPal Business Debit Card at participating stores.
Fee amount varies by store.

Third-party digital wallets (optional)

International 2.50% There’s a foreign transaction fee to use PayPal in Google Pay
transaction and Samsung Pay to make a purchase from a non-U.S.
merchant. This fee applies even when there’s no currency
conversion.

Cryptocurrencies
Cryptocurrencies

Buying or There’s a fee for buying or selling cryptocurrencies. Fee will

selling a vary based on the U.S. dollar value of your cryptocurrency
cryptocurrency: purchase or sale amount. These fees do not apply to buying
$0.49 and selling PYUSD.
$1.00 – $4.99 (minimum fee)

$5.00 – $24.99 $0.99

$25.00 – $1.99
$74.99
$2.49
$75.00 –
$200.00 1.80%

$200.01 – 1.50%
$1000.00

$1000.01+

Converting There is a fee to convert PYUSD to/from another type of

between PYUSD cryptocurrency. The fee will vary based on the U.S. dollar
and another value of the cryptocurrency you convert.
cryptocurrency: $0.49
(minimum fee)
$1.00 – $9.99
$0.99

$10.00 –
$1.99
$29.99
$2.49
$30.00 –
$79.99 1.75%

$80.00 – 1.45%
$249.99

$250.00 –
$1000.00

$1000.01 +

Receiving a $0 No fee
cryptocurrency
transfer

Transferring $0 No fee
cryptocurrency
to another
PayPal or
Venmo account

Transferring Amount varies

cryptocurrency (paid in You will be charged a cryptocurrency network fee, payable in
to an address cryptocurrency) the cryptocurrency you transfer, which varies. For more
outside of information, see the PayPal Cryptocurrency Terms and
PayPal or Conditions on the Legal Agreements page at [Link]
[Link]. We
Venmo will display such network fee right before you transfer any
cryptocurrency.

Using PayPal as For When you buy cryptocurrency to be transferred in one step,
a funding cryptocurrency you will also be charged a cryptocurrency network fee,
source to buy other than payable in the cryptocurrency you transfer. The
and transfer PYUSD, 1% + cryptocurrency amount to be transferred in one step to an
cryptocurrency the applicable external wallet plus the cryptocurrency amount you will be
in one step to fee listed in the charged to cover the cryptocurrency network fee is the
external “Buying or “combined cryptocurrency purchase amount.” We will display
cryptocurrency selling a the network fee right before you transfer any cryptocurrency.
wallet cryptocurrency”
providers who section above For cryptocurrency other than PYUSD, you will pay (1) the
support this transaction fee listed in the “Buying or selling a
feature For PYUSD, a cryptocurrency” section above on the U.S. dollar value of the
fee of 1.5% combined cryptocurrency purchase amount and (2) 1% only
on the U.S. dollar value of the cryptocurrency that you
transfer to your external wallet.

For PYUSD, you will pay 1.5% on the U.S. dollar value of the
PYUSD that you transfer to your external wallet. You will not
pay a transaction fee on the combined cryptocurrency
purchase amount.

Using PayPal to For When you transfer and sell cryptocurrency out of a supported
transfer and cryptocurrency external cryptocurrency wallet in one step, you will pay a
sell other than transaction fee on the U.S. dollar value of the
cryptocurrency PYUSD, 1% + cryptocurrency you are selling.
out of the applicable
supported fee listed in the For cryptocurrency other than PYUSD, you will pay (1) the
external “Buying or transaction fee listed in the “Buying or selling a
cryptocurrency selling a cryptocurrency” section above and (2) 1% only on the U.S.
wallets in one cryptocurrency” dollar value of the cryptocurrency that you receive from your
step section above external wallet.

For PYUSD, a For PYUSD, you will pay 1.5% on the U.S. dollar value of the
fee of 1.5% PYUSD that you receive from your external wallet. You will
not pay a transaction fee listed in the “Buying or selling a
cryptocurrency” section above.

Your U.S. dollar funds (but not cryptocurrencies or non-U.S. dollar currencies) are FDIC insured,
up to applicable limits, only if you opened a PayPal Debit Card account, enrolled in Direct Deposit,
or bought or received cryptocurrency with your PayPal Balance account. FDIC insurance does not
protect you against the failure of PayPal.
No overdraft/credit feature.

Contact us at 1-844-629-9108, by mail at PayPal Inc., Attention: Legal Department, 2211 North
First Street, San Jose, CA 95131, or online at [Link]/us/smarthelp/contact-us
[Link]/us/smarthelp/contact-us.

For general information about prepaid accounts, visit [Link]/prepaid

[Link]/prepaid.

If you have a complaint about a prepaid account, call the Consumer Financial Protection Bureau at
1-855-411-2372 or visit [Link]/complaint
[Link]/complaint.