Referral Disclosure Statement

Grifin Refer-a-Friend Program

Referral Disclosure Statement

Effective as of July 7,2023 (the “Effective Date”)

You have received a designated referral code or link (“Code”) to participate in thisRefer-a-Friend program (the “Program”). In order to participate, you must open an advisory account (“Account”) with Interest Financial, LLC d/b/a Grifin(“Grifin”) in accordance with these terms and conditions (“Program Terms”). Your referring friend who sent you this Code is a Grifin customer and has done so through this Program. This invitation does not constitute a statement of your friend’s experience with, or endorsement of, Grifin.

You acknowledge that your referring friend is a client of Grifin, that he or she will receive payment if you choose to open an Account and make a deposit with Grifin, and that this creates a conflict of interest in providing an economic incentive for your referring friend to refer you to Grifin.

You further acknowledge the following:

-       You received the Code from a person that you personally know, and that he or she intended to send you theCode; and

-       You did not receive theCode, and were not solicited, in an impersonal manner such as, as part of a post on social media, including but not limited to Facebook or Twitter, or otherwise through the use of a public forum.

Eligibility

To participate in this Program and receive a cash bonus (“Bonus”) hereunder, you must complete the designated registration process for opening an Account and your Account must be approved and remain in good standing (as defined below). Further, you must make a minimum deposit of $5.00 into your Account within 30 days of completing the account registration process.

To constitute an "Account"hereunder, you must complete the designated registration process for opening anAccount by using your special designated Code included in your invitation, and Grifin must approve the opening of your Account.

Only one Bonus will be awarded foreach person who opens an Account by using their designated Code. You will not earn a Bonus if you have an existing Account or if you do not use the correctCode. You must be able to personally identify the person who referred you and sent you the Code.

Grifin reserves the right to disqualify anyone from the Program at any time. Anyone who violates theseProgram Terms is ineligible to receive a Bonus. Grifin reserves the right to change, modify or cancel the Program at any time, and to change or modify the eligibility requirements for the Program at any time.

Grifin reserves the right to determine in its sole discretion whether an Account is closed and/or in good standing. An Account in good standing for purposes of this Program is an Account for which all requiredAccount opening documentation has been completed and verified, and is not locked, or restricted, or otherwise flagged in any way. If an Account is closed or not in good standing for any reason at any time, any Bonus associated with that Account will be forfeited.

Bonuses

Subject to these Program Terms, for each Eligible Referral, Grifin will compensate you and your Friend in the form of a Bonus. For each Eligible Referral, the Referrer and the Friend shall receive a Bonus equal to $5.00.  The maximum amount of compensation that you may be rewarded under this Program is $1,000.00. Only one Bonus will be rewarded per Referrer and Friend.  

You understand that your referring friend may be eligible to receive additionalBonuses for referral invitations and Codes they send to any of their other referee friends that open an Account in accordance with the terms of theProgram.

Note that any portfolios or securities received as part of the Program may be subject to federal, state, and local income taxes, as well as capital gains taxes. You are responsible for any federal or state taxes resulting from the receipt of aBonus. Please contact your tax advisor if you have questions about the tax treatment of receiving a Bonus. Any Bonus deposited by Grifin hereunder is a fixed cash value and does not constitute stock or any other security, nor is it a recommendation to buy any specific stock or other security.

Any Bonus received must remain in the Account (minus any trading losses or gains) for a minimum of 30 days (“Holding Period”), and for the entirety of the HoldingPeriod, which shall be determined by Grifin in its sole discretion. You and your referring friend must remain in good standing with Grifin and AlpacaSecurities LLC during the Holding Period. Any breach of any agreement associated with your Account (“Additional Agreements”) will result in forfeiture of Bonuses received. Grifin may at any time, in their sole discretion, respectively, terminate, suspend, restrict, or otherwise limit yourAccount per the terms of the Additional Agreements. Any forfeited Bonus will be removed from the Account.

Referral Invitations

Any referral Codes that either (i) were sent prior to the Effective Date where you have not as of the Effective Date created completed the registration process for an Account, or (ii) are sent on or after the Effective Date, will expire will expire thirty (30) calendar days from the date that you completes the registration process for an Account. If your referral Code expires and you have not already completed the registration process for an Account., then you will be eligible to receive future referral Codes valid under this Program. If your referral Code expires after you have already completed the registration process for an Account, then you will not be eligible to receive any future referralCodes from (or earn a Bonus) under this Program.

Changes To These Program Terms

We may modify these Program Terms from time to time which will be indicated by changing the date at the top of this page. We will indicate that changes have been made by updating the “Effective Date” located above at the beginning of these Program Terms. If we make any material changes, we will notify you by email (sent to the email address specified in your Account), by means of a notice on the Grifin mobile app and website prior to the change becoming effective, or as otherwise required by law. Notwithstanding anything herein, we do not have to provide you with prior notice of any amendments to the Program that are beneficial to you. Your continued access to or use of the Program after we make any changes to these Program Terms will be subject to the revised Program Terms, and you will be deemed to be aware of and bound to the revised Program Terms by your continued access to or participation in theProgram. If you do not accept any such revisions or changes, your sole and exclusive remedy is to cease participation in the Program. The Program may be canceled at any time without notice to you.

Other Program Information

The term “Grifin” refers to Interest Financial, LLC, an investment adviser registered with the Securities and Exchange Commission. Grifin is not responsible for incorrect entry or other failure on the part of your Friends to meet the standards of an Account. You cannot earn a Bonus for referring individuals who already have an Account or for individuals who have been referred by someone else. If two or more individuals invite the same Friend to open an Account, Grifin will credit the Bonus to the person whose specially designated referral Code was first used by that Friend to complete their designated registration process with Grifin.

Grifin reserves the right to limit the amount of Bonuses you are eligible to receive, and to refuse or recover any Bonus, or remove you from the Program, if Grifin determines that it was obtained under wrongful or fraudulent circumstances, or was awarded to you in error, or that inaccurate or incomplete information was provided in opening the account, or that any terms of theAdvisory Agreement, Terms of Use, or these Program Terms have been violated.Grifin reserves the right to suspend, cancel, terminate, or modify this Program and/or these Program Terms at any time in its sole discretion.d

Information shown is strictly for illustrative and educational purposes only and should not be considered a solicitation to buy, an offer to sell, or a recommendation for any security in any jurisdiction where such an offer, solicitation or recommendation would be unlawful or unauthorized. Grifin does not offer any warranties, and disclaims all warranties, express or implied, with regard to the Program. Any preliminary information provided by Grifin to prospective customers prior to Grifin agreeing to enter into an advisory relationship does not constitute investment advice and should not be relied on as such.Investment products, Bonuses and other services are offered by Grifin, are notFDIC Insured, and may lose value. Grifin does not guaranty that the Grifin App will be free of errors or interruptions. Grifin reserves the right to correct all typographical and other written errors in connection with the Program.  

Grifin reserves the right to limit the amount of Bonus you are eligible to receive, and to refuse or recover any Bonus, or deem you ineligible for the Program, if Grifin determines that it was obtained under wrongful or fraudulent circumstances, or was awarded to you in error, or that inaccurate or incomplete information was provided in opening the account, or that any terms of the Additional Agreements or theseProgram Terms have been violated. Grifin reserves the right to suspend, cancel, terminate or modify this Program and/or these Program Terms at any time at its sole discretion.

The invalidity or unenforceability of any provision of these ProgramTerms will not affect the validity or enforceability of any other provision. In the event that any provision of these Program Terms are determined to be invalid or otherwise unenforceable or illegal, the other provisions will remain in effect and will be construed in accordance with their terms as if the invalid or illegal provision were not contained herein. Grifin’s failure to enforce any term of these Program Terms will not constitute a waiver of that provision. Participants agree to waive any rights to claim ambiguity of theseProgram Terms. Headings are solely for convenience of reference and will not be deemed to affect in any manner the meaning or intent of the document or any provision hereof. Grifin reserves the right to revoke or extend this offer at any time.

If, in Grifin’s opinion, there is any suspected or actual evidence of electronic or non-electronic tampering with any portion of this Program, or if any difficulties compromise the administration, security, fairness, integrity, or proper conduct of the Program, Grifin reserves the right to modify, cancel, or terminate this Program, in whole or in part, at any time without notice. In the event of time of war, national emergency, accident, dangerous weather conditions, fire, riot, strikes, lock-outs, industrial disputes, acts of terrorism, epidemic, pandemic, extreme market volatility, or other matters beyond Grifin’s reasonable control, Grifin has the right, in its sole discretion, to terminate the Program. Prompt notice of such action will be made to eligible participants.

Your Advisory Agreement with Grifin governs our investment advisory relationship with you, and these Program Terms do not in any way amend, supersede, change or replace such agreement, which include important terms applicable to your use of Grifin that continue to apply here, except to the extent otherwise expressly prescribed hereunder. You may view our Form ADVBrochure, your Advisory Agreement, and other disclosures at grifin.com/legal.This Program is not valid with any other offers and is non-transferrable. TheProgram is currently available to U.S. residents only. The Program is void where prohibited by law. Other restrictions may apply.

If, for any reason, this Program is not capable of running as planned, whether due to infection by computer virus, bugs, tampering, unauthorized intervention, fraud, technical failures, or any other causes beyond the control of Grifin which corrupts or affects the administration, security, fairness, integrity, or proper conduct of this Program, Grifin reserves the right in its sole discretion, to disqualify any individual who tampers with this Program, and to cancel, terminate, modify or suspend this Program. In the event of termination, Grifin may in its sole discretion award Bonuses to those who have satisfied the eligibility criteria set forth herein up until the time of termination. Grifin assumes no responsibility for any error, omission, interruption, deletion, defect, delay in operation or transmission, communications line failure, theft or destruction or unauthorized access to, or alteration of, this Program. Grifin is not responsible for any problems or technical malfunction of any telephone network or lines, computer online systems, servers, or providers, computer equipment, software, failure of any e-mail or entry to be received by Grifin on account of technical problems, human error or traffic congestion on the Internet or at any web site, or any combination thereof, including any injury or damage to any person’s computer related to or resulting from participation in this Program.

All issues and questions concerning the construction, validity, interpretation, and enforceability of these Program Terms, or the rights and obligations of you and Grifin in connection with the Program, shall be governed by and construed in accordance with the laws of the State of California, without giving effect to any choice of law or conflict of law rules (whether of the State of California, or any other jurisdiction), which would cause the application of the laws of any jurisdiction other than in the State of California.

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