KINETIQ
Membership platform for access and participation
Boundary Disclosure

PLATFORM ROLE & FINANCIAL SERVICES DISCLOSURE

This Disclosure explains the operational boundaries between KINETIQ, regulated third-party service providers, and Platform participants.

1. Purpose of This Disclosure

This Platform Role & Financial Services Boundary Disclosure ("Disclosure") explains the operational boundaries between KINETIQ, regulated third-party service providers, and Platform participants.

The purpose of this Disclosure is to clearly define KINETIQ’s role, KINETIQ’s limitations, the separation between governance functions and regulated financial functions, responsibility ownership, complaint routing, and data boundary principles.

This document is intended to support transparency, operational clarity, institutional trust, and responsible role separation.

2. KINETIQ’s Role

KINETIQ is a governance technology platform.

KINETIQ provides digital infrastructure designed to support structured governance participation, accountability systems, community coordination, and governance transparency.

Platform functions may include governance participation systems, voting workflows, governance proposal infrastructure, Digital Governance Operating System ("DGOS"), governance integrity monitoring, anti-collusion safeguards, recusal workflows, governance audit trails, participation accountability systems, governance communications, oversight support infrastructure, Platform administration, and technical support.

KINETIQ’s role is governance infrastructure only.

3. KINETIQ is Not a Regulated Financial Institution

KINETIQ is not a bank, a depository institution, a money transmitter, a payment processor, a broker-dealer, an investment adviser, a securities issuer, an exchange, a transfer agent, a custodian, a trust company, a financial institution, a lending institution, a consumer credit provider, or a fiduciary financial services provider.

Use of the Platform does not create regulated financial institution status for KINETIQ.

KINETIQ is a financial navigation and education platform. KINETIQ is not a bank, broker-dealer, registered investment adviser, money transmitter, or financial planner.

KINETIQ does not hold, pool, manage, or transmit member funds. KINETIQ does not provide personalized investment advice or recommendations.

Any FBO accounts established through partner instructions are held at independently chartered financial institutions under those institutions' own terms.

Any introductions to licensed third-party investment firms, lenders, insurance carriers, or other financial service providers are informational only. Members make all financial decisions independently.

KINETIQ does not guarantee any financial outcome, return, or result from use of the Platform or engagement with any introduced partner.

4. Functions KINETIQ Does Not Perform

KINETIQ does not perform regulated financial functions on behalf of participants.

Funds Handling

  • accept deposits
  • receive customer funds
  • hold customer funds
  • custody funds
  • transfer customer funds
  • transmit money
  • settle regulated transactions
  • administer regulated cash movement

Financial Compliance Functions

  • perform KYC
  • perform CIP
  • conduct AML monitoring
  • conduct OFAC screening
  • make sanctions determinations
  • file SARs
  • file CTRs
  • conduct transaction monitoring
  • perform regulated compliance investigations

Regulated Financial Services

  • provide banking services
  • provide brokerage services
  • provide custodial services
  • provide regulated payment services
  • provide securities services
  • provide financial advisory services
  • provide investment advisory services
  • provide portfolio management
  • provide underwriting
  • provide regulated lending

Financial Decision-Making

  • approve financial accounts
  • deny financial accounts
  • freeze regulated accounts
  • restrict regulated financial access
  • approve transactions
  • deny transactions
  • determine investment suitability
  • make asset allocation decisions

5. Core Operational Separation Principle

KINETIQ operates under a deliberate separation-of-responsibilities model.

This means KINETIQ handles governance infrastructure, governance participation systems, governance oversight workflows, and technical Platform operations, while regulated third parties handle regulated financial services, regulated compliance obligations, regulated account administration, and regulated books and records.

This separation is fundamental to Platform architecture.

6. Independent Regulated Third-Party Responsibilities

Where regulated services exist within the broader ecosystem, those services are independently provided by appropriately regulated third parties.

Such providers may include regulated banking institutions, regulated custodial institutions, licensed investment management firms, regulated payments providers, and regulated identity verification providers.

These providers - not KINETIQ - retain responsibility for regulated activities, including customer onboarding, KYC/CIP, AML compliance, OFAC screening, deposit custody, transaction processing, regulated reporting, official books and records, account restrictions, account servicing, and regulated advisory activities where applicable under independent provider authority.

KINETIQ does not perform these activities.

7. No Agency / No Fiduciary Relationship

KINETIQ is not the legal agent, fiduciary, trustee, custodian, or financial representative of users, regulated third-party providers, banking institutions, investment firms, or payment providers unless expressly documented in a separate written agreement.

Use of the Platform alone does not create agency relationships, fiduciary duties, custodial duties, advisory obligations, or regulated representative status.

8. Limited Information Display

Where contractually authorized, KINETIQ may display limited informational indicators supplied by regulated third-party providers.

Such informational display may include account status indicators, participation status indicators, non-authoritative informational summaries, and partner-provided visibility signals.

Important limitations: KINETIQ does not independently originate regulated financial records, maintain official books and records, calculate authoritative regulated account balances, issue official financial statements, or independently validate regulated account records.

Any displayed information is informational only. Official regulated records remain exclusively with the applicable regulated provider. Displayed information may be delayed, incomplete, or dependent upon third-party system availability.

9. Data Boundary Principles

Operational data boundaries are intentionally structured.

In the Governance Domain, KINETIQ may maintain governance-related operational information including governance participation activity, voting records, recusal activity, committee participation, governance standing, accountability metrics, and governance audit trails.

In the Regulated Domain, independent providers maintain regulated financial records including customer identity verification records, compliance records, transaction records, regulated account records, and official books and records.

KINETIQ does not serve as the authoritative regulated recordkeeper.

10. Responsibility Matrix

Issue Type - Responsible Party

  • Governance participation - KINETIQ
  • Voting disputes - KINETIQ
  • DGOS governance enforcement - KINETIQ
  • Platform access issues - KINETIQ
  • Financial account servicing - Independent regulated provider
  • KYC/CIP issues - Independent regulated provider
  • AML / OFAC restrictions - Independent regulated provider
  • Account freezes / restrictions - Independent regulated provider
  • Regulated account disputes - Independent regulated provider
  • Regulated advisory disputes - Independent regulated provider

11. Dispute Ownership Principle

KINETIQ owns disputes arising from KINETIQ-controlled governance and Platform operations only.

KINETIQ does not own disputes arising from regulated account servicing, regulated compliance determinations, banking activity, custodial activity, regulated advisory activity, transaction execution, or official financial records. Those disputes belong to the applicable regulated provider.

12. No Reliance Disclaimer

Users and stakeholders must not rely on KINETIQ as a substitute for regulated financial institutions.

Use of the Platform should not be interpreted as banking participation, regulated advisory participation, regulated account servicing, financial custody, or regulated compliance administration.

Where regulated services exist, reliance must be placed on the applicable regulated provider.

13. Outside Legal Counsel (Institutional Disclosure)

KINETIQ may engage external legal counsel for governance, privacy, commercial, fintech, regulatory, and institutional advisory matters.

As of the effective date of this Disclosure:

Foley & Lardner LLP
Attention: Clyde Tinnen, Partner
777 East Wisconsin Avenue
Milwaukee, WI 53202-5306
Phone: 414.297.5026

Disclosure of counsel does not designate such counsel as a registered agent, legal notice recipient, service-of-process agent, or arbitration notice recipient unless expressly agreed in writing.

14. Contact Information

Questions regarding Platform governance responsibilities may be directed to KINETIQ, [INSERT LEGAL ENTITY NAME], [INSERT BUSINESS ADDRESS], [INSERT LEGAL EMAIL ADDRESS], [INSERT CONTACT URL].

Questions relating to regulated services must be directed to the applicable independent regulated provider.