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E-Sign Consent Policy

  1. SCOPE

This document outlines the E-Sign Act Policy (the “Policy”) and establishes the process for using  electronic signatures and authorizations for official business transactions of Best Aid Inc DBA Pursuent Financial and its affiliates and any subsidiaries (collectively referred to as the “Company”).  This policy also establishes the standards for use, maintenance, and retention of electronic signatures and electronic records.

  1. POLICY STATEMENT

Use of electronic signatures increases efficiency of various internal and external transactions that  require signature or authorization.  The Electronic Signatures in Global and National Commerce  Act (E-Sign Act) was signed into law on June 30, 2000, and provides a general rule of validity for  electronic records and signatures for transactions in or affecting interstate or foreign commerce.  The E-Sign Act allows the use of electronic records to satisfy any statute, regulation, or rule of law requiring that such information be provided in writing, if the consumer has affirmatively consented to such use and has not withdrawn such consent.

All Company employees and contractors shall comply with this policy or be subject to disciplinary action under their respective employee handbook, code of conduct, or policies.

  1. DEFINITIONS

Authorized Signatory: a Company employee who has been delegated, pursuant to policies  promulgated by the Board of Directors for the Company, the authority to legally bind the Company to the terms of an External Transaction.

Approved Electronic Signature Mechanism: a software application, system, and process approved  for Electronic Signatures to ensure a level of trustworthiness appropriate for the transaction.

Electronic Record: a record created, generated, sent, communicated, received, or stored in an  electronic or computerized format.

Electronic Signature: a computer data compilation of any symbol or series of symbols, and

specifically including an electronic script signature, associated with a record that is executed,  adopted, or authorized by an individual, and intended to be the legally binding equivalent of the  individual’s handwritten signature.  Scanned, copied, or facsimiles of documents containing a  handwritten signature shall not be considered Electronic Signatures.

External Transaction: any legally binding agreement or contract between the Company and an  individual, entity, business, or government agency.

Internal Transaction: any internal work-flow or approval process that requires a signature or approval on a Company form, document, memo, or other similar format to indicate an individual’s  agreement or compliance with the language or terms contained therein.

Trustworthiness: an Electronic Record containing an Electronic Signature generated with authentication, integrity, and nonrepudiation.

  1. POLICY

The Company permits the use of Electronic Signatures for both external and internal transactions.  When a signature is required by policy, law, or rule, the document must contain an electronic signature  by an authorized signatory.  Such transactions may be retained as an electronic record.

Where law prohibits the use of electronic signature, a physical signature by an authorized signature  must be obtained, and a paper or hard copy record of the transaction must be retained in accordance  with the Record Retention Policy.

  1. External Transactions

The Company will comply with the E-SIGN Act in its relationships with customers when  electronic signatures are requested.  In connection with compliance, Company must do the  following for customers prior to obtaining their consent:

  1. Indicate whether customers have a right, or option, to receive information on paper.
  2. Identify whether the consent relates to a particular transaction (e.g., loan application or  agreement), or to ongoing disclosures over the course of the relationship (e.g., monthly  statements and change-in-terms notices).
  3. Explain that the consumer has the right to withdraw consent and provide the procedures to  withdraw consent, as well as the consequences of withdrawing consent such as fees,  termination of the relationship, loss of preferred pricing, or having to switch account types.
  4. Describe the procedures for updating the consumer’s contact information.  Outline the hardware and software requirements for accessing and retaining records.
  5. Explain how to obtain paper disclosures after consent has been given, and describe any associated fees.

Consumers must also consent electronically, or electronically confirm consent, in a manner that  reasonably demonstrates their ability to receive or access the information electronically.  Having  consumers retrieve a code contained within a document sent to them is one way to demonstrate  accessing of information.

  1. Internal Transactions

Electronic Signatures utilized in connection with an Internal Transaction must be generated and  received through an approved electronic signature mechanism.

  1. Maintenance of Electronic Records – Record Keeping

All electronic records shall be retained pursuant to the Company’s Records Retention Schedule as  defined in the Record Retention Policy, and must remain accessible throughout the retention period.

All records associated with external and internal transactions shall be saved in one format, either in an electronic format and retained as electronic records, or where required by law or policy, in a paper or hard copy format and retained as paper records.

  1. Identification of Approved Electronic Signature Mechanism

The use of software applications, systems, and processes to facilitate the use of electronic  signatures in both internal and external transactions will undergo a review and approval process.  Legal and Compliance will assist employees and departments in identifying and implementing  approved signature mechanisms appropriate for accomplishing electronic signatures by evaluating  whether the proposed mechanism meets any applicable trustworthiness, technical and security  requirements commensurate to the risks of fraud, and nonrepudiation and financial loss associated with given transactions.

The Company’s employees and departments may request that Legal and Compliance review any  additional software applications, systems, and processes used to generate and receive electronic  signatures by submitting a request to the Chief Compliance Officer, or designee.  The use of a third  party vendor will be subject to the Company’s Third Party Risk Management Policy and must be  submitted in accordance with the Third Party Risk Management Procedures.