Last Updated: November 2026

Terms of Service Agreement

You should read this Terms of Service Agreement (this "Agreement") carefully before accessing or using the website located at www.verivest.com (including all subdomains and related content, regardless of how and where it may be hosted or accessed, the "Site"), or any of Verivest's related services, its fund and syndication administration services, its advisory services, and all related software tools, technology, and related services (collectively, the "Services"). By accessing or using the Site or any of the Services, you are agreeing to accept and be bound by this Agreement. This Agreement constitutes a contract between you and Verivest, in addition to any other written agreements between us. This Agreement supersedes any prior Terms of Service relating to the Services or the Site.

IMPORTANT NOTE: Verivest LLC and its affiliated entities (collectively, "Verivest," "we," or "us") have materially altered our business model over the last few years. These Terms of Service reflect those changes. Some services previously provided by Verivest are no longer offered, including manager directory listings, track record verification services, manager reviews, designations of managers as "Verivest Gold" or "Monitored," Verivest's proprietary online investor management portal, and others. These discontinued products and services are no longer addressed in these Terms of Service. All parties' rights and obligations with respect to discontinued services continue to be governed by the prior versions of the Terms of Service that were in effect when the services were accessed or used. Prior versions of these Terms of Service are available upon request. If you have any questions about whether our current or former Terms of Service apply, please contact us at support@verivest.com.

This Agreement applies to all users of the Services, including all clients who engage Verivest to provide administration or advisory services, any investors whose investments are managed using the Services, and all qualified issuers, managers, and investment managers who use the Site or the Services, including Services used to create offering documents, make offerings available to investors, administer investment offerings, manage relationships with current and prospective investors, or otherwise facilitate investments by investors in investment opportunities (collectively, "Users," each of which may be referred to in this Agreement as "you"). "Users" also include anyone else who accesses or uses the Site or the Services for any other reason.

By accessing, browsing, or using the Services, including the Site, you acknowledge that you have read and understand, and agree to, this Agreement. We may update this Agreement at any time. Your continued use of the Services or the Site after any modifications to this Agreement constitutes your acceptance of the modified terms and conditions. If you do not accept this Agreement, you do not have permission to access, browse, or use the Services or the Site, and your sole and exclusive remedy is to discontinue using them. As such, we strongly recommend that you periodically review this Agreement, which is available upon request or at https://verivest.com/terms. The date of the last revision or update appears at the top of the Agreement under the title.

Your compliance with this Agreement is a condition of your right to access the Site and use the Services. Your breach of any provision of this Agreement will automatically, without the requirement of notice or of any other action, revoke and terminate your right to use the Services and may also entitle us to recover damages from you.

Privacy Policy and Data Usage

For information on how Verivest collects, uses, and discloses information obtained from its Users, please review our Privacy Policy, which is available at https://verivest.com/privacy. Your use of the Services indicates your consent to the data practices stated in our Privacy Policy.

Consistent with our Privacy Policy, you acknowledge and agree that we are entitled to include any data you provide to us about you or about your current and previous investments and other business activities in any aggregated information about the real estate investment market that we provide to the public, sell or otherwise transmit to third parties, including our affiliates, or otherwise use. Except in connection with any information provided to the public about a manager or an opportunity, we will not specifically identify you as the source of any information that we sell or distribute, attribute any specific performance data to you, or include any personally identifiable information in that data.

You further acknowledge and agree that, other than User Content (as defined below), we are the sole and exclusive owners of, and can use, sell, and transmit in any way we elect, all information provided to us by investors and other Users of the Site, including investors introduced to the Site by you.

No Legal Advice, Investment Advice, or Recommendations Provided; Securities Involve a High Degree of Risk

Verivest is not a law firm, registered broker-dealer, funding portal, or investment advisor, and does not conduct any activity that would require professional licensing or regulatory registration. Through its advisory services, Verivest offers business advice relating to setting up and operating real estate funds and syndications, but none of this advice is or should be construed as legal advice. All Users are REQUIRED to consult with competent legal counsel and financial advisors before offering or selling any securities or real estate investment opportunities USING PRODUCTS created by OR IN COOPERATION WITH Verivest.

Similarly, Verivest does not (and cannot) offer any investment advice and it does not recommend or endorse any of the managers who use the Services or any of the investment opportunities administered by us, including any managers in which Verivest or its affiliated entities may invest, or any syndications or funds created through the use of Verivest's advisory services, or who may be referenced or advertised in any manner on the Site. By allowing managers to use its advisory services to structure and create a syndication or a fund, and even by investing in a manager through an affiliated entity, Verivest is not recommending investing in any one or more of those opportunities—it is allowing managers to provide the information solely to make accredited and otherwise qualified investors aware of potential opportunities and to access information about their investments in managers using Verivest's Services. All INVESTOR Users MUST conduct their own due diligence and should consult with competent legal and financial advisors before investing in any opportunities or with any managers WHO HAVE ENGAGED VERIVEST FOR ADVISORY OR ADMINISTRATIVE SERVICES.

No securities or real estate investment opportunities that may be described or referred to on the Site have been registered under the Securities Act, and all are being advertised by their respective sponsor or manager in reliance on certain exemptions provided in of Section 4(2) of the Securities Act and Regulation D, Rule 506, and Regulation S, promulgated under the Securities Act. Securities and real estate investment opportunities sold through private placements are restricted and not publicly traded and are therefore illiquid. All private investments, including those offered by managers who have purchased Services from Verivest, involve risk and uncertainty, including lower than projected returns and a complete loss of invested capital. All such investment opportunities are intended solely for experienced, qualified investors. Investors who cannot afford to lose their entire investment should not invest in private offerings like those managers may engage Verivest to administer or to help them structure.

Neither the U.S. Securities and Exchange Commission nor any state securities commission or other regulatory authority has approved, passed upon or endorsed the merits of any offering administered or referenced in connection with Verivest's Services, and Verivest is not registered with or subject to the supervision of any of those entities.

Advisory Services

Verivest may agree to provide advisory and consulting services in the various areas of fund management and operations, including but not limited to fund and syndication creation and management, review and commentary on drafted or existing PPM offering documents, review of fund financial modeling assumptions, structure, and projections, capital raise strategy, tactics, and channels, review and commentary on pitch decks and other marketing materials, and many other components of all areas of fund management. The scope of services involved in each of these products may vary considerably. We may also agree to provide additional types of advice and consultation in exchange for agreed upon fees. The scope, pricing, and other specific terms and conditions of each such advisory engagement will be agreed upon by the User and Verivest. In addition to those agreed upon terms, the following terms and conditions apply:

  • Verivest's advisory services include guidance and advice concerning various business issues and considerations relating to pooled investment opportunities, such as structural considerations, industry standards and best practices, general investor considerations and expectations, and related issues. None of this advice is or should be considered legal or investment advice.
  • Prior to using any offering documents or other materials delivered to a User in connection with Verivest's advisory services or otherwise reviewed by Verivest, or to sell securities or investment opportunities based on any advice or opinions received during that process, each User is required to consult with competent securities counsel to review all documents and marketing materials, ensure that any sale of securities by the User using the materials delivered or reviewed in connection with the advisory services will not violate applicable securities laws or regulations, and otherwise ensure compliance with all applicable laws and regulations.
  • Verivest may recommend and refer legal counsel options to User for their consideration without any requirement by Verivest that User use any particular referral. Any legal review provided by attorneys recommended by Verivest is provided by that attorney pursuant to a separate engagement agreement with that attorney, and is not endorsed or otherwise adopted by Verivest.
  • Verivest typically does not produce or provide any written materials or documents to Users and instead will review and comment or render opinions on documents provided to us by the User or outside vendors previously engaged and hired by the User. Verivest may, however, provide some written materials to certain Users only pursuant to a customized Advisory Services engagement specific to individual Users. In all instances, Verivest retains all copyrights in and to materials created by Verivest and delivered to a User in connection with Verivest's advisory services, including the right to reuse, resell, license, and create derivative works of those materials.
  • Except as expressly agreed by Verivest in writing, your license to use any materials provided to you in connection with an advisory engagement is limited to the license rights granted in the Intellectual Property section of this Agreement, and is specifically limited to using those materials in connection with the project or entity you have hired Verivest to help you form or with the specific advisory services you have engaged Verivest to provide.
  • All fees for advisory services are to be paid fully in advance and are fully earned on receipt and non-refundable.
  • Unless otherwise agreed, it is expected that all project-specific advisory Services will be provided over a period not to exceed three months. If the timeline extends beyond this period for any reason (other than due to Verivest delays), Verivest reserves the right to request additional compensation to continue in its consulting role with the User.
  • As part of the Services, we may employ generative AI tools or other similar technologies to generate ideas about certain issues that come up during an advisory engagement. While we will not share or make the results of our AI use public, the use of AI tools may create some risk that aspects of our conversation will not be fully protected from disclosure. Pursuant to the third-party terms of service provisions included below, by using the Services, you consent to any disclosure of information that may happen through third-party AI tools, consistent with those providers' terms of service. We may also provide you with copies of or otherwise make accessible to you any "chat" we have with an AI tool. Any such chat will contain Verivest's proprietary information, and you agree not to use or disclose it, except for your internal purposes, consistent with these Terms of Service.
  • Verivest expressly disclaims any representation or warranty that actions discussed or recommended by it comply with securities and other laws and regulations, and all users are required to confirm legal compliance with competent securities counsel before relying on any advice from Verivest or using documents and other materials reviewed or prepared by Verivest and delivered to a user in connection with an advisory engagement.

In connection with its Advisory services, Verivest may refer a User to one or more law firms that are qualified to create offering documents for that User. The costs of these legal services, including all costs of drafting or reviewing offering documents, drafting operating agreements, making state blue sky or other regulatory filings, or any other services, will are to be agreed upon by and between the User and the law firm.

Administration Services

Users who engage Verivest to provide administration Services will be subject to the following terms and conditions concerning those Services, unless otherwise agreed in writing by Verivest. The work that Verivest performs for administration of pooled investment funds or single-asset syndications is listed below; however, each User's contract may or may not include all listed services depending on the type and structure of the offering. For any specific inclusions or exclusions, refer to the "Special Terms" section of the User's contract. Any services not expressly identified below are the User's responsibility and will not be provided by Verivest except pursuant to a separate written agreement between the User and Verivest. If any processes are customized outside of the below services, are performed by the User rather than Verivest, or both, proper disclosures on investor reporting may be required.

Fund and Syndication Accounting

  • Set up a shared online folder and populate it with Verivest's standard folder structure.
  • Create a dedicated distribution list for User to use to communicate with Verivest.
  • Set up each entity for which administration services are being provided (each, an "Entity") in Verivest's accounting systems, including Verivest's standard Chart of Accounts.
  • Create an asset and investor register ("accounting schedules") to be maintained by Verivest.
  • Review all bank account activity regularly against supporting documentation to ensure all transactions have sufficient backup, as determined by Verivest.
  • Follow up with User regarding any outstanding bank transactions for which Verivest has not received appropriate backup, including through automated systems or manual follow ups.
  • Enter all bank account and credit card activity into the Entity's general ledger and update accounting schedules accordingly.
  • Perform a period-end closing reconciliation of the Entity's bank account(s).
  • Generate period-ending reports and schedules, and produce Verivest's standard financial statement package, utilizing User-provided support.
  • Verivest will deliver a financial statement package that includes a Balance Sheet, Income Statement, General Ledger, and read-only supporting files. Reporting and analysis files outside of the standard financial package will be subject to additional fees.
  • The standard financial statement deliverable includes one preliminary package for User review, one round of User-directed revisions, and one final package. This two-touch workflow is included in the base fee. Additional preliminary versions requested by the User, including requests to reflect new or changed information provided after the preliminary package is issued, requests for alternative presentations, or additional review rounds prior to final issuance, will be billed at Verivest's standard hourly rate.
  • Calculate management fees and carried interest waterfall per the Entity's offering documents for each reporting period.
  • If applicable, calculate unit price at the same interval that subscriptions occur (monthly, quarterly, or annually).
  • Prepare an annual tax and audit package, which includes a year-end standard financial statement package, Trial Balance, other supporting schedules, capital account reconciliation, and investor demographic data for the Entity to provide to its tax preparer.
  • Verivest will provide the standard information that Verivest generates in agreement to the Entity's tax preparer and audit firm (if any) for the preparation of K-1s or for an audit. No customized schedules will be produced.
  • For Entities subject to an annual audit, three (3) Verivest hours per year are allotted for audit support, which includes audit inquiries, data consolidation, or other analysis. Any audit support time in excess of three (3) hours will be billed at Verivest's standard hourly rates.

Fund and Syndication Investor Servicing

  • If applicable, generate and issue investor capital call statements and subscribe each investor's contribution into the books and records of the Entity. Verivest requires at least three business days' notice for preparation of capital call statements. Capital call statements are charged per capital call unless otherwise agreed in writing by Verivest.
  • Maintain a register of the Entity's investors, including (as applicable) name, contact information, capital balance, membership units or capital commitments and percentage interests, and ERISA categorization.
  • Where applicable, calculate note holder interest, preferred return, and any distributable cash, return of capital and period-end investor capital account balances in accordance with each Entity's governing documents (e.g., operating agreement or limited partnership agreement).
  • Process investor distributions according to the Entity's governing documents, subject to User approval.
  • Process investor redemptions (if applicable) in accordance with the Entity's governing documents, subject to User approval.
  • Provide User with an investor distribution report and NACHA file for User to use to disburse the approved amounts to investors and User accordingly.
  • Based on the reporting period agreed to by Verivest and the User, prepare investor capital account statements and publish on User's portal if the User has engaged a Verivest preferred portal partner as their portal provider, upon approval from the User. Verivest will not upload documents to portals managed by entities other than Verivest's preferred portal partners. If the User's investors do not use a portal partner preferred by Verivest, investor capital account statements will be provided to the User to distribute to investors.
  • Provide an ERISA compliance report no more frequently than quarterly to enable User's obligation to monitor ERISA limitations, based on User's designation of investor accounts.
  • Generate year-end investor capital account balances for the Entity to provide to its tax preparer to validate and produce K-1s for investors.
  • Upload applicable 1099 tax forms and K-1s produced by the User's tax preparer to a Verivest preferred portal partner for investors to access, if the User has engaged one of Verivest's preferred portal partners as its investor portal. Verivest will not upload documents to portals managed by entities other than Verivest's preferred portal partners.

Additional Services

The services listed in this section are optional add-on services, available for additional fees and pursuant to a separate written agreement or as specified in the User's Special Terms.

Audit Prep Package

  • Prepare an annual Balance Sheet and Profit and Loss Statement summarizing the Entity's financial position and performance for the year.
  • Prepare an annual Statement of Cash Flows outlining the Entity's cash inflows and outflows for the reporting period.
  • Prepare a Schedule of Investments detailing the Entity's investment portfolio.
  • Prepare a Statement of Changes in Net Capital summarizing capital account activity and fluctuations during the year.
  • Calculate Financial Highlights summarizing key fund metrics and performance data.
  • Prepare draft Audit Footnotes providing additional disclosures and context to assist the User's CPA or audit firm in completing the audit.
  • Liaise with the User's audit firm to provide requested documentation, read-only supporting files, and details on accounting and calculation methodologies, ensuring timely and accurate audit preparation.
  • The Audit Prep Package includes a total of fifteen (15) Verivest hours, which encompasses preparation of the financial package, communication with the User and their auditor, and providing audit-related support. Any support time in excess of fifteen (15) hours will be billed at Verivest's standard hourly rates.

AIP Reporting

  • Onboard the User and their Offering(s) onto the AIP platform (DTCC) by creating a sub-account under Verivest's existing approval to expedite setup and activation.
  • Manage data formatting and transmission of required investment and transaction information to custodians through the DTCC network.
  • Maintain ongoing data reporting and compliance requirements associated with AIP participation.
  • Transmit transactional data, including period-end positions, investor contributions, redemptions, distributions, and related activity, as well as email confirmations (when requested), to applicable custodians through AIP once investors are subscribed and approved.
  • Provide ongoing reporting and maintenance to ensure accurate and compliant data flow between Verivest, the User, and custodians.
  • Assist with CUSIP application and registration, if applicable (additional fees apply).

1099-INT/1099-NEC

  • Prepare annual Form 1099-INT filings summarizing interest payments made by the Entity to investors, as directed by User.
  • For Entities which Verivest is engaged for fund accounting services, prepare annual Form 1099-NEC filings summarizing payments made by the Entity to vendors or service providers, as applicable under IRS reporting requirements, based on vendor information provided by User.
  • File 1099 forms electronically with the Internal Revenue Service and applicable state tax authorities and distribute recipient copies as directed by User.
  • Upload applicable 1099 tax forms to a Verivest preferred portal partner for investors to access, if the User has engaged one of Verivest's preferred portal partners as its investor portal. Verivest will not upload documents to portals managed by entities other than Verivest's preferred portal partners.
  • The 1099 Preparation service includes preparation, electronic filing, and distribution of the applicable 1099 forms. Any additional support or amendments requested after filing may be billed at Verivest's standard hourly rates.

Investor Onboarding Support

  • The Setup Fee includes a kickoff meeting with a dedicated Onboarding Manager to review the onboarding process, setup in Verivest systems and initial prospect setup in the User's portal (if needed), development of an investor communication plan for identified prospects in consultation with the Manager, and discussion and alignment on investor communication procedures.
  • The Monthly Investor Onboarding Support Fee begins 30 days after the Contract Start Date and includes regular touch-bases with a dedicated Onboarding Manager, proactive follow-up with identified investors to encourage completion of their investment, and investor communications upon receipt of funds (if needed).
  • The Investor Onboarding Fee is charged per investor once documentation has been executed by the investor and manager. This fee covers the full processing of each investor through onboarding, including AML/KYC verification, accreditation review, and subscription document processing, as well as delivery of funding instructions and a communication to confirm receipt of capital (if desired). Any additional investor communications outside of this prescribed workflow are the User's responsibility.
  • AML/KYC verification performed under this service are conducted through a third-party service provider engaged by Verivest, and not by Verivest directly. User acknowledges that Verivest's role is limited to coordinating this process and relying on the results provided by that third-party provider, and that Verivest does not independently verify, warrant, or guarantee the accuracy of any determination made by the provider or that any such determination complies with applicable laws. User remains ultimately and solely responsible for ensuring that all investor subscription activity complies with applicable AML, KYC, and accreditation requirements.
  • Investor Onboarding Support services are administrative and operational in nature. They do not constitute financial or legal advice, selling to or marketing to investors, investment advice, and do not include capital raise strategy or investor sourcing.

Treasury Services

Treasury Services are the payment-execution layer connecting User's fund accounting to the movement of funds, including payment execution for distributions and fund-level expense payments, as described below.

  • Verivest processes vendor invoices for payment via ACH, check, or wire; routes invoices through an automated approval workflow and maintains an audit trail of related transactions. No payment is released without approval obtained through that workflow.
  • Treasury Services are powered in part by third-party payment and approval-workflow providers ("Payment Processors"). Verivest is not a bank or money transmitter, relies on Payment Processors to execute payment instructions, and is not liable for a Payment Processor's acts, omissions, outages, or security incidents. Use of Treasury Services may also be subject to the applicable Payment Processor's terms.
  • User (or its authorized representative) retains final approval authority over each payment made through Treasury Services. User is responsible for maintaining accurate authorized-approver information and promptly notifying Verivest of any change.
  • Verivest may rely on payment instructions, banking details, and approvals provided by User without independent verification, and is not responsible for losses arising from inaccurate, incomplete, or unauthorized instructions supplied by User.
  • Verivest's liability for any error, delay, or failure in connection with Treasury Services is subject to the limitations set forth in the Limitations of Liability section below.

Accounting Assumptions

The Fund and Syndication Accounting, Fund and Syndication Investor Servicing, and Additional Services described above are subject to the following accounting assumptions.

Financial Reporting

  • Unless otherwise agreed to and specified in the contract, all financial reporting and investor reporting will be on a quarterly basis.

Cash, Non-Cash, and Bank Transactions

  • Verivest will be provided with read-only access to all fund-level bank accounts. Banks that require a desktop banking app or another extensive access setup are not compatible with Verivest and User will need to provide Verivest with the banking transactions no less frequently than weekly.
  • The User will provide backup for all bank and credit card transactions to Verivest on at least a weekly basis via a Verivest-directed process or another method agreed between Verivest and User – best practice is not to wait until month end.
  • For funds that do not deploy or subscribe investors' full commitments upon receipt, separate bank accounts will be established and maintained for subscription and operating bank accounts.
  • For entities that are purchasing direct real estate, separate bank accounts and general ledgers must be maintained and managed for the fund entity and properties. Verivest does not maintain or review the property level reporting.
  • User represents and warrants that all activity in the fund's bank account(s) will consist solely of fund-related activity, and that fund activity will not be held or commingled with funds in any non-fund related bank account.
  • Support for financial completion outside of bank transactions will be provided to Verivest no less frequently than monthly via a Verivest-directed process or another method agreed between Verivest and User.

Property Financial Records

  • Property level accounting is excluded from the scope of services.
  • Any property level transactions will be recorded in bank accounts and general ledgers that are separate from the accounts and ledgers for the Entity Verivest is administering.
  • Any property financial statements will be provided no less frequently than quarterly and will include balance sheet, income statement, and general ledger.
  • Property financial statements should not be modified after they are provided to Verivest to prepare Entity financial statements. Subsequent quarter opening balance sheet should agree to prior quarter property financial statement closing balance sheet.
  • The User will review property level financial statements for completeness and accuracy before providing them to Verivest.
  • If engaged for Syndication Administration or Fund Investor Servicing only, User is responsible for providing accurate period-end Asset/Entity level financials.

Loan Servicer Reports

  • Loan servicing is excluded from the scope of administration services.
  • Third party or internally produced loan servicer reports shall contain the appropriate level of detail to track and account for individual loan activity and terms, including, but not limited to, interest billed and interest collected during the period, rehab balances, interest reserves, unpaid principal balances, interest rates, maturity dates, and all funding activity dates.
  • The User will review loan servicer reports for completeness and accuracy before providing them to Verivest.

Investor Distributions

  • Verivest will prepare distribution files, including NACHA files and provide them to the User.
  • The User will review and approve distribution files and NACHA files to confirm that the investor banking details are accurate and current before providing the files to the bank for processing.
  • Other than distributions to investors, cash disbursements to external or internal parties are out of scope. Verivest can provide Treasury Services, including these disbursements, if separately engaged to do so for additional fees.

Other

  • Unless otherwise agreed to, Verivest's pricing proposals for administration services assume that no more than three (3) of an Entity's investors will have side letters. Side letters in excess of this threshold will be subject to additional costs billed at Verivest's standard hourly rates.
  • Tax services are out of scope; Verivest does not produce or review Form K-1s. Verivest can produce Form 1099-INTs and 1099-NECs if separately engaged to do so for additional fees.
  • Any compliance reporting or testing is out of scope including, for example, REIT compliance testing.
  • Any additional services outside of the standard fund administration services will be scoped and priced in agreement with the User. This might include AIP Reporting, Audit Prep Package, Investor Onboarding Support, and Valuation Services.

User Responsibilities

Each User who engages Verivest to provide administration services acknowledges and agrees that it is ultimately responsible for the proper administration of the Entity. Among other things, each User is responsible for reviewing and confirming the accuracy of any information provided to the Entity or its investors. Each User also acknowledges and agrees that Verivest's ability and obligation to provide the services identified above is contingent on User's timely, accurate, and sufficient performance of each of the following responsibilities:

  • Provide any amendments to an Entity's offering documents within five business days after the documents are amended and provide documentation supporting User's interpretations of all offering documents as it pertains to calculating financial statements, distributions, and other items relating to Verivest's services. Verivest may, at its discretion, provide input into those interpretations, but the final decision must be made by the User and be acceptable to Verivest in its sole discretion. Verivest retains discretion to reject any request for Services and to terminate any existing agreement to provide administration Services if a User insists on an interpretation that Verivest does not accept or that is incompatible with Verivest's systems and processes. Among other things, Verivest may refuse to provide administration Services if amendments to the Entity's offering documents deviate from Verivest's standard Forms.
  • Provide read-only bank access to Verivest for all associated bank accounts for accounting and bookkeeping services to be completed. Promptly notify Verivest of any changes to bank accounts, including providing read-only access to any additional accounts. Failure to properly notify Verivest of any changes may result in delays of deliverables. Banks that require a desktop banking app or another extensive access setup are not compatible with Verivest and User will need to provide Verivest with the banking transactions no less frequently than weekly.
  • Provide complete investor information and timely updates to Verivest as new investors are subscribed, and, if Verivest is assisting in the import or setup of an existing Entity's investor data, provide that complete investor information at the outset of onboarding.
  • Complete investor information will include, but may not be limited to, entity/account type (i.e., Individual, Joint, Retirement, Brokerage, Entity or Trust), accurate tax identification information (SSN/TIN/EIN), email, permanent, and mailing addresses, investment amounts, ERISA classification, and investment class (if applicable).
  • Accept responsibility for ultimately ensuring that all investor subscription activity complies with all applicable laws and regulations, including laws and regulations relating to AML, KYC, and accreditation verification. Verivest only offers AML and KYC verification services through our Investor Onboarding Support service or as a standalone one-time engagement option. User confirms that, for any investors not processed through either of those services, User has performed these verification checks before providing subscription documentation to Verivest for administration services.
  • Provide timely and accurate backup for all transactions reflected in the Entity's bank accounts via the agreed upon method between Verivest and User.
  • Provide timely and accurate support for financial completion outside of bank transactions no less frequently than monthly via the agreed upon method between Verivest and User.
  • Provide a point of contact for inquiries, interpretations, data requests, document review, and other actions as may be required for completion of Verivest's services. If Verivest cannot perform services due to a User's unresponsiveness, those services shall be deemed to have been completed, and any associated fees will be deemed as earned by Verivest. If additional rework is required because of delays in the User providing accurate and sufficient information, rework will be charged at Verivest's standard hourly rate.
  • Accept responsibility for ensuring the accuracy of all information and data provided to Verivest. Rework due to data errors, inaccurate reports, or restatements will result in Verivest incurring additional time which will be billed at Verivest's standard hourly rates.
  • User will not alter or restate prior period financial statements without notification and acceptance by Verivest. Prior period restatements alter the underlying investor capital accounts and current financial statements, impact accuracy, and increase additional workload to restate work already completed for prior periods. Any rework time because of restatement will be subject to hourly billing at Verivest's standard rates.
  • Accept responsibility for complying with all applicable federal, state, and local rules and regulations related to tax reporting requirements, including but not limited to IRS Forms W-9 and 1099. Provide timely and accurate W-9 information for all investors and ensure that all required 1099 filings are completed in accordance with applicable laws and regulations. Verivest may, at its discretion, assist with the preparation of 1099s based on information provided by the User; however, User remains ultimately responsible for the accuracy, completeness, and timeliness of all tax reporting information.
  • Timely delivery of Verivest's services is dependent on the User's timely provision of complete and accurate information. Where Verivest staff must make more than two documented requests for the same information or category of information in connection with a single reporting period, additional professional time incurred in connection with such follow-up will be billed at Verivest's standard hourly rate. For existing Entities onboarding to Verivest mid-cycle, with existing data or reporting prepared by personnel outside of Verivest, User is responsible for validating and confirming the accuracy of prior period data and reporting before Verivest begins onboarding or data conversion. Verivest will not review or validate prior period reporting prepared by outside parties, unless otherwise engaged.

It is each User's sole responsibility to provide Verivest with correct information concerning that User's operations, including all information needed to provide the Services, and to do so in a timely manner. Verivest will communicate applicable deadlines to administration services Users. If a User fails to timely provide information to Verivest or otherwise comply with these deadlines, Verivest's work for User may be delayed and will be completed as and when the Verivest team's availability allows. Verivest may also terminate an agreement to provide administrative services if a User fails to provide information in a timely manner. Verivest shall be entitled to rely on all information and representations provided by a User as factually true and not misleading, without further investigation or diligence. The representations made within any documents produced by Verivest shall be derived from the documentation and materials provided by User to Verivest and are the sole responsibility of User.

Each User agrees to ensure the privacy and security of all investor, financial, and other sensitive information relating to any Offering for which the User engages Verivest to provide administration Services. Among other things, administration Services Users agree to protect and not to disclose any password, account, or similar information used to access documents, deliverables, or other information provided by Verivest, including any password-protected files or shared folders. Verivest is not responsible for, and User agrees to indemnify and hold Verivest harmless from, any claims or damages asserted by any party as a result of any breach of privacy or similar event caused in any way by User's failure to safeguard against unauthorized access to any such materials or User's access credentials.

You acknowledge and agree that Verivest's accounting and other methodologies are not the only methodologies that could be used to provide the Services, and that different results could be achieved using other methodologies. Each User remains fully responsible at all times for the content of any communications with that User's investors and clients, including communications relating to financial performance and results. It is the User's complete and exclusive responsibility to comply with all requirements established under all federal and state securities laws, rules, and regulations. It is also each User's responsibility to ensure that all communications with its investors and clients and other actions taken by User are in full compliance with all applicable laws. Verivest does not warrant or guarantee, expressly or implicitly, the accuracy of any information provided to User or its investors or clients.

Term and Termination of Administration Services Agreements

Unless otherwise agreed to in writing by Verivest, including in Verivest's existing contracts with Users that pre-date these Terms of Service, ALL ADMINISTRATION SERVICES CONTRACTS INCLUDE A MINIMUM TERM OF 24 MONTHS. Subject to Verivest's right to revise pricing based on 60 days' written notice, as described in more detail below, Verivest's pricing for administration services assumes a minimum term of 24 months which starts as of the sign date of the contract. This minimum term allows Verivest to recover the costs of setting up a User's accounts in its system and the other work needed to onboard a new client. Upon the expiration of the initial 24-month term of a User's administration services contract, and any subsequent term, the User's administration services contract will automatically renew for successive terms of 12 months each, unless User provides Verivest written notice of non-renewal at least 60 days prior to the end of the then-current term. Upon receipt of 60 days' notice to terminate services (prior to renewal of current contract term), Verivest will send a final invoice covering services for this period. Final services invoice will not be prorated and is due upon receipt. Final services invoice must be paid prior to Verivest providing final deliverables or offboarding support. User may extend services as needed on a month-to-month basis, also billed in advance. Additional one-time transactions that occur during the 60 days' notice period will be charged in the next monthly billing cycle.

Verivest may terminate its administration services for any User at any time and for any reason, including no reason, on 60 days' notice to the User, or on any shorter time period identified in these Terms of Service.

We reserve the right, in our sole discretion, but not the obligation, to immediately terminate this Agreement and any other agreement then in place with User and cease providing Services without further obligation if any of the following occurs; provided that, in lieu of terminating services, we may also elect to inform User's investors of the following services and continue providing services:

  1. Any invoice remains unpaid for more than forty-five (45) days past its due date;
  2. We become aware of, or you or your management are suspected, accused of, or under investigation by a governmental authority for any criminal, fraudulent, or materially unethical conduct that, in our reasonable judgment, compromises your or your management's integrity;
  3. You fail to provide necessary information or cooperation within a reasonable timeframe, resulting in a material delay or obstruction in the performance of the Services;
  4. Circumstances outside of our control prevent us from completing the engagement or forming a professional opinion as required for the Services, including but not limited to lack of access to essential records, client personnel, or third-party confirmations;
  5. We determine, in our sole discretion and after reasonable consideration, that continuing the engagement would violate applicable professional standards, independence requirements, or legal or regulatory obligations.

If Verivest terminates its administration services due to the User's nonpayment, the User may request to re-engage Verivest after paying all outstanding invoices in full. In such event, the User will be required to pay a new onboarding fee to restart the engagement. The amount of the onboarding fee will be determined by Verivest at the time the User requests to re-engage services.

Verivest reserves the right to require advance payment for any renewed or ongoing services. All such advance payments must be received in full before Verivest will resume work or deliver any final reports, filings, or other deliverables to the User.

Privacy Policy

November 2026

This Privacy Policy (this "Policy") discloses how Verivest LLC and its affiliated entities ("Verivest," "us," "our," or "we") collect and use information and data gathered from and about users (each a "User" and referred to in this Policy as "you") who access and use our website, software tools, technology, and related services, including our advisory and administration services (collectively, the "Services"). Users may access and use the Services in a variety of ways including, but not limited to, by accessing or using Verivest's website at www.verivest.com, including its proprietary fund builder products (collectively, the "Site"). Specifically, this Policy describes the types of information we receive and collect through the Site and the provision of Services, how we use information about current and former Users, and the steps that we take to safeguard the information obtained through the Services or the Site. By using or accessing the Site or any of the Services, you agree to the terms and conditions contained in this Policy.

Information Collected

When we need to collect information from you to complete a requested transaction or provide you with a particular service, we will generally ask you to voluntarily supply us with the information we need. This information may include (a) personal data used to verify your identity, verify your age, run background checks and otherwise conduct the verification and related services we provide, guard against potential fraud, and otherwise operate the Site and provide the Services consistent with legal and regulatory requirements, (b) personal and financial data used to verify your status as an accredited investor, and (c) other personal and financial information used for a variety of purposes, including providing the Services as described on the Site. We may also collect information about you from other sources, including but not limited to: (i) our communications with you, including information obtained when you make an investment with a manager User or otherwise volunteer information; (ii) your interactions with the Site, including information such as how you accessed the site, what specific information you accessed on the site, and for how long, and other information about your preferences and interests based on how you interacted with the Site, (iii) your transactions with us, our affiliates, or other Users, including when you, as an investor, make an investment with another User who is an investment manager who uses the Services to subscribe investors and manage their on-going relationships with those investors; (iv) information about you provided to us by other parties, including Users who use the Services to subscribe investors and manage their on-going relationships with those investors; (v) outside companies, such as credit reporting agencies, to evaluate your creditworthiness and credit history; and, (vi) public sources, such as court and bankruptcy records, regulatory agency records, and real estate records.

We divide information about you into two groups: (i) General Customer Information; and, (ii) Restricted Customer Information. "General Customer Information" is information about you and your business and investment activities, your use of the Site and the Services, including names, addresses, telephone numbers and email addresses, and similar information, including information that may have been gleaned from "Restricted Customer Information." "Restricted Customer Information" refers to particularly sensitive information, such as social security or tax identification numbers, dates of birth, tax returns, financial statements, employment status and salary information, business plans, reports obtained from credit reporting agencies, bank account numbers, including routing numbers, and credit card numbers.

How Verivest Uses and Discloses the Information We Collect

We may use and disclose information provided by you consistent with the Services we provide. This includes transmitting information about you to the manager of an investment opportunity in which you invest or express interest, so that the manager can manage its relationship with you and so that Verivest can perform the administration or advisory services it has been engaged by that manager to provide. If you are onboarded through Verivest's Investor Onboarding Support services, we may also share your information with a third-party service provider engaged by Verivest to perform AML/KYC verification and accreditation review on Verivest's behalf. If a manager you invest with uses a preferred portal partner's investor portal in connection with its offering, we may also share your information with that preferred portal partner to enable your use of the portal and to support the Services provided in connection with it. We may also use and disclose General Customer Information and Restricted Customer Information to companies related to us by common control or ownership ("affiliates"), as well as any third parties, contractors, consultants, and advisers we may engage to assist us in carrying out any transaction that you have requested of us or authorized, or for other business purposes as may be necessary to complete our contractual obligations with you or otherwise provide the Services. We may also use and disclose to affiliates, service providers, and third parties both types of information for technical support, document and data storage, auditing, research, and analysis to operate and improve Verivest's Services. Among other things, we will disclose General Customer Information and Restricted Customer Information to other Users who are issuers or managers who use the Services to subscribe investors and manage their on-going relationships with those investors.

We and our affiliates may also use General Customer information in other ways, including, without limitation, to send you educational or promotional materials that we think may be of interest to you. Manager Users who receive your information through Verivest's Services may also use that information to market and solicit to you, including for purposes of raising capital from you for their investment opportunities. Neither Verivest nor its Affiliates, however, will use any General Customer information obtained exclusively through the Services to engage in direct email or telephone marketing to you concerning investment opportunities in which Verivest or any of its affiliates has an ownership or financial interest. If you no longer wish to receive general promotional e-mails from us, please use the unsubscribe feature found in our commercial e-mails. Please note that you will, however, continue to receive service-related e-mail messages that concern products and services you obtain from or through us.

We may also share and allow others to share Aggregated Information that does not disclose your identity and cannot be connected to your identity with outside companies, or to the public generally, including through general information about the real estate investment market and the historical or ongoing performance of real estate investment opportunities. "Aggregated Information" refers to information Verivest gathers by aggregating non-identifiable information to provide summaries of our Users, their investment patterns, and their interactions with the investment managers whose offerings Verivest administers or advises on. Aggregated Information is used to show usage patterns and to do such things as negotiate with providers of products and services that we may want to offer our customers. Aggregated Information may also include information about the performance of certain investments, market trends and related data, all without disclosing information that can easily be connected to any specific User.

Except as set forth above or as otherwise required or permitted by law, Verivest will not share Restricted Customer Information with third parties without your prior authorization, which may be expressed or implied from the nature of your activities in connection with the Services, including, for example, from your expression of interest in investing in, or your investment in, an opportunity offered by a specific investment manager who has engaged Verivest for advisory or administration services.

Regardless of whether you have opted out of sharing your General Customer Information or provided us authorization to share your Restricted Customer Information, we reserve the right to use and disclose Aggregated Information, General Customer Information and Restricted Customer Information, as required, to comply with the law, applicable regulations, governmental and quasi-governmental requests, judicial proceedings, court orders or subpoenas, to perform and enforce agreements between you and us, our affiliates, or partners, and to protect our and our affiliates' rights, property or safety or to protect the rights, property or safety of others (e.g., to a credit reporting agency for fraud protection, or to prevent or limit fraud).

Storage of Information

The security of the information you provide is important to us. We maintain physical safeguards, such as secure areas in buildings, and electronic and procedural safeguards, such as passwords and access limitations. Access to Restricted Customer Information about you is restricted to authorized employees obtaining the information for business purposes.

After information reaches Verivest, it is stored on secure, virtual servers hosted by one or more third-party service providers, which may include data storage companies, third-parties engaged to perform AML/KYC verification review in connection with Investor Onboarding Support, or a Payment Processor engaged to execute payment instructions in connection with Treasury Services. Any third-party data storage provider will be a large provider with a national presence that is bound by its agreements with Verivest to only use and share your information as needed to perform the services it has contracted with Verivest to provide. Remember, no method of transmission over the Internet, or method of electronic storage, is 100% secure (for example, any information you provide us by email is not encrypted and third-party data storage providers are subject to external attacks). Therefore, while we will use commercially reasonable efforts to protect the information you provide us, we cannot guarantee its absolute security.

We may retain General Customer Information and Aggregated Information indefinitely. Restricted Customer Information will be retained for as long as you are using Verivest's Services, and thereafter to the extent required by applicable record retention policies or regulatory requirements.

You may request the deletion of data that is stored in Verivest databases, so long as the request is compliant with legal requirements and is not required for us to complete previously agreed services you have contracted us to perform. Where your information is also held by a third-party service provider, deletion from that provider's systems is subject to that provider's own policies and any separate agreement you may have with them.

Process for Submitting "Right to Know" or "Right to Delete" Request

Users have the right to make two requests to know or delete data in a twelve-month period by following the processes described below.

You may submit a request to know or delete information, subject to the conditions below, to support@verivest.com. We will produce or delete information in response to up to two verifiable requests per User per year.

We will confirm receipt of a request from a User to know or delete information within 10 days, and will provide information about processing the requests at that time.

We verify the identity of Users who make requests to know or delete information by taking the following steps:

  • We identify the User and associate the information provided by the User in the verifiable request to any personal information we have previously collected by about the User.
  • We identify by category or categories the personal information collected about the User for a time period not to exceed the 12 months preceding the request that most closely describes the personal information collected; the categories of sources from which the User's personal information was collected; the business or commercial purpose for collecting or sharing the User's personal information; and the categories of third parties to whom we disclose the User's personal information.
  • We provide the specific pieces of personal information obtained from a User in a format that is easily understandable to the average User, and to the extent technically feasible, in a structured, commonly used, machine-readable format that may also be transmitted to another entity at the User's request without hindrance. "Specific pieces of information" do not include data generated to help ensure security and integrity or as prescribed by regulation.

If we are unable to verify the requesting User's identity, the requestor will be notified that their identity could not be verified and the request will be denied.

If we are able to verify the identity of the User making the request to know or delete, we will respond within 45 calendar days electronically or by mail (unless a 45-day extension is required, as allowed by law). A designated Verivest employee will be responsible for preserving copies of specific personal information collected about each User. Upon receiving a request, this employee will locate and produce any of the following categories of requested information in response to any request by a verified User:

  • The categories of personal information we collected about the User,
  • The categories of sources from which personal information is collected,
  • The business or commercial purpose for collecting or selling personal information,
  • The categories of third parties with whom we share personal information,
  • The specific pieces of personal information we have collected about the User, and
  • The categories of the User's personal information that were disclosed for business purposes in the 12 months preceding the User's verifiable request.

We will not delete customer information if the information is necessary to accomplish any of the following:

  • Complete a transaction for which the personal information was collected, provide goods and services to the consumer, or otherwise perform a contract with the User;
  • Detect security incidents, fraud, or illegal activity;
  • Exercise free speech, or ensure the right of another User to exercise his or her right of free speech;
  • Enable internal uses that are reasonably aligned with the expectations of the User based on the User's relationship with the business;
  • Comply with a legal obligation; or
  • Otherwise utilize the User's personal information internally and in a lawful manner that is compatible with the context in which the User provided the information.

Personal Information Security Breach Response Process

In the unlikely event that your nonencrypted and nonredacted personal information, or email address in combination with a password or security question that would permit access to your account, is subject to unauthorized access, exfiltration, theft, or disclosure, whether occurring on Verivest's own systems or, to Verivest's knowledge, on the systems of a preferred portal partner, Payment Processor, or other third-party service provider that holds your information on Verivest's behalf, such an event will be addressed through the following process:

  • Determine scope of breach and take steps, or coordinate with the applicable third-party provider to take steps, to prevent any further disclosure of information,
  • Determine if any state privacy laws apply and follow any jurisdiction specific notification requirements applicable,
  • Notify Users impacted by the breach,
  • Report to and cooperate with law enforcement as needed,
  • Offer to provide affected Users with credit monitoring services.

Browsing the Site

The Site does not collect personally identifiable information from your computer when you browse the Site and request pages from our servers. This means that, unless you voluntarily and knowingly provide us with personally identifiable information, we will not know your name, your email address, or any other personally identifiable information. If you do provide us this information, it will only be associated with the General Information we collect concerning your use of the Site. Verivest's servers do automatically record non-personally identifiable information when you visit the Site. Among other things, when you request a page from the Site, our servers log the information provided in the HTTP request header including the IP number, the date and time of the request, the URL of your request, the language used, the browser type and any other information that is provided in the HTTP header. We collect the HTTP request header information in order to make the Site function correctly and provide you the functionality that you see on the Site. We also use this information to better understand how Users use the Site and how we can better tune it, its contents and functionality to meet your needs.

Whenever you visit the Site, we may also send one or more cookies to your computer that store information on your computer, such as your preferences when visiting the Site. We use cookies to better understand how visitors navigate and interact with the Site and to track activity on the Site as a unique visitor. All of this information is stored in an encrypted fashion for security reasons. You can set your web browser to inform you when cookies are set or to prevent cookies from being set. Please note, however, that if you decline to use cookies, you may experience reduced functionality and slower site response times.

Log Files

As is true of most websites, if you visit the Site, we will gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and click stream data.

We use this information to analyze trends, to administer the Site, to track Users' movements around the site, and to gather demographic information about our visitor base as a whole. We only link this automatically-collected data to your General Customer Information and your Restricted Customer Information after you have provided your consent for us to do so.

Links to Other Sites

The Site may contain links to other websites, such as service providers, and other third parties which are not owned or controlled by us. Please be aware that this Policy only addresses Verivest's use and disclosure of information collected on the Site. We are not responsible for the privacy practices of such other sites accessed through links on the Verivest site. We encourage you to be aware when you leave the Site and to read the applicable privacy policies and terms of conditions of each and every website that collects personally identifiable information.

Enhancement of Information

We may purchase marketing data from third parties and add it to our existing user database, to better target our advertising and to provide pertinent offers in which we think you would be interested. To enrich our database of individual Users, we tie this information to the information you have provided to us.

Business Transitions

In the event that Verivest goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your General Customer Information and Restricted Customer Information as well as Aggregated Information will likely be among the assets transferred. By using the Site, you consent to any such transfer of your information to Verivest's acquirers, successors, and assigns.

Services Not Intended for Use of Children

Our Services are not directed to children under the age of 18. We do not knowingly collect information, including personal information, from children. If you believe that data has been collected from children, please contact support@verivest.com.

Changes to this Privacy Policy

We reserve the right to modify this Policy at any time without notice to you other than posting the revisions on the Site. The provisions contained in this Policy supersede all previous notices or policies regarding our privacy practices with respect to the Site or our products and services. Any and all changes made to this Policy will be posted on our Site and become effective immediately upon posting. The date of the current version of this Policy is noted above.

We encourage you to check the Site frequently to see the current Policy. Upon any material changes to the Policy, we will post those changes to this Policy, the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

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