BrokerBridge™

Broker Protection and Privacy Policy

Effective: September 10,  2025

Scope: Business-purpose loans only; not for owner-occupied 1–4 unit properties.

AT-A-GLANCE (How Broker Protection Works)

1) Register the client by submitting a Broker Registration, Scenario/Deal Intake, or an email to loanscenario@trustbridgecap.com including client name, contact, property, and product. We time-stamp receipt.

2) You are the Broker of Record for that client/deal for 24 months from registration or last material activity.

3) If we fund, we pay broker compensation subject to the caps and rules below (and TrustBridge risk-based adjustment).

1) Definitions

“TrustBridge Capital” or “TBC” means TrustBridge Capital™ and its applicable affiliates or capital partners. “Broker” means the broker/referral partner submitting a client. “Client” means the person or entity introduced to TBC (including affiliates, principals, guarantors, or controlled entities). “Referral” means a client introduction with sufficient identifying information to contact the Client and evaluate a deal. “Protected Deal” means any financing, refinance, construction, or related capital transaction between TBC and the Client during the Protection Period.

2) Client Registration & Broker of Record

A Referral is registered when submitted through TBC’s Broker Registration, Scenario/Deal Intake, or by email to loanscenario@trustbridgecap.com containing client name, contact info, property, and product. TBC will time-stamp receipt in its systems. The registering Broker is the Broker of Record for the referred Client/deal for the Protection Period.

3) Protection Period & Exclusions

Protection lasts 24 months from the later of (i) the referral registration date or (ii) the last material activity with the Client/deal (e.g., updated docs, term sheet, appraisal order, credit pull).

Exclusions (not protected): (a) TBC had a documented, active pre-existing relationship with the Client before registration (TBC will notify within 5 business days after awareness); (b) the Client is unresponsive for 90 consecutive days after reasonable joint follow-ups; (c) Broker withdraws or instructs TBC to stop; (d) the Client independently applies for a clearly different product and declines Broker representation. Protection applies to TBC’s affiliates/capital partners only with respect to the same Protected Deal.

4) Non-Circumvention / Non-Solicitation

TBC will not knowingly circumvent Broker by inducing a registered Client to exclude Broker from a Protected Deal. Routine, non-targeted marketing is permitted. Broker remains Broker of Record unless an exclusion applies or Broker consents in writing.

5) Broker Compensation; Caps, Prohibitions & Disbursement

(a) Only compensation permitted to Broker is “Broker Points.” Broker may not charge or collect any other fees (including application, processing, admin, packaging, underwriting, consulting, doc-prep, marketing, lead), or receive any borrower-paid or third-party side payments.

(b) Caps: Broker Points ≤ 2.00% of the loan amount; Broker Points ≤ Lender Points; and Total Points (Broker + Lender) ≤ 5.00%.

(c) Disbursement method (selected per deal): (i) itemized and paid on the final ALTA/CD at funding; or  (ii) Direct Pay by TBC (Administrative Disbursement): As lender or as administrative agent for its capital partner, TBC may disburse Broker Points from loan proceeds via ACH/wire within two (2) business days of funding and record the payment on TBC’s disbursement ledger. This administrative disbursement is not compensation for brokerage services by TBC and shall not be construed to create any agency, brokerage, or fiduciary relationship between TBC and the borrower or Broker. No borrower side-payments are permitted. 

(d) Auto-adjustment: If pricing/structure changes prior to funding, Broker Points automatically reduce to the maximum amount that keeps Broker ≤ 2.00%, Broker ≤ Lender, and Total ≤ 5.00%.

(e) Third-party pass-through charges (title, escrow, appraisal, recording, taxes) are not Broker compensation, must be bona fide and customary, and may not be marked up or collected by Broker.

(f) Administrative requirements: Broker must provide a completed W-9 and wire instructions prior to funding. TBC may reduce or offset any overage to remain compliant.

6) Risk-Based Adjustment (TBC Right to Reduce)

TBC may, in its sole but good-faith discretion, reduce Broker Points at any time prior to funding if required by deal sizing, underwriting or credit risk, investor/capital-partner criteria, market conditions, or compliance—up to and including 0.00%. If Broker declines the reduced amount before closing documents are issued, Broker may withdraw without penalty and no compensation is due. No side-payments are permitted.

7) No Obligation to Lend; Independent Parties

Nothing obligates TBC to approve or fund any loan. TBC may change terms or decline a loan at any time. The parties are independent contractors; no agency, partnership, joint venture, or fiduciary duty is created.

8) Confidentiality

Each party will keep the other’s non-public information—including pricing, term sheets, underwriting materials, and client documents—confidential and use it solely to evaluate/execute the deal, except where disclosure is legally required or the information is public, previously known without restriction, independently developed, or lawfully received from a third party. Equitable relief is available for threatened breach.

9) Broker Representations & Indemnity

Broker represents it is properly licensed/authorized for the activities it performs; has obtained all necessary consents to share Client information with TBC; and that information provided is accurate to Broker’s knowledge. Broker will comply with applicable laws and will not submit consumer/owner-occupied loan requests. Broker will defend and indemnify TBC from losses arising from Broker’s breach of this Policy or applicable law.

10) Consent to Communications (Email/SMS/Phone)

By submitting a Referral, Broker (and, where Broker provides Client information, Broker warrants Client consent) authorizes TBC to contact via email, phone, and SMS/MMS, including by autodialer or prerecorded voice, about products, services, and deal status. Message and data rates may apply; frequency varies. Text STOP to end and HELP for help. TBC will honor unsubscribe and Do-Not-Call requests.

11) Privacy Notice (Brokers & Referrals)

Data we collect may include identifiers (name, email, phone, address, license info), professional details, deal documents (applications, financials, property data), communications, website/app usage, and compliance/verification results (e.g., KYC). We use data for intake, underwriting, servicing, compliance and fraud prevention, analytics, training, and marketing with proper consent. We share with service providers and capital partners for business purposes and as legally required. We do not sell personal information. If “sharing/targeted advertising” as defined by state law is used, we will provide a “Do Not Sell/Share” mechanism. We apply reasonable administrative, technical, and physical safeguards and retain data only as needed for the purposes above and legal/audit obligations. Depending on your state, you may have rights to access, correct, or delete personal information—contact privacy@trustbridgecap.com to submit a request. We do not direct services to minors.

12) Limitation of Liability

To the fullest extent permitted by law, neither party is liable for indirect, special, incidental, consequential, or punitive damages. Except for confidentiality or indemnity obligations, each party’s aggregate liability is capped at broker fees paid or payable by TBC for the funded deal giving rise to the claim.

13) Governing Law; Venue; Jury Waiver

This Policy is governed by the laws of the State of New York (without regard to conflicts rules). Exclusive venue and jurisdiction lie in the state or federal courts located in Richmond County, New York. The parties waive trial by jury. (If an arbitration agreement is executed, that agreement controls.)

14) Updates

We may update this Policy prospectively. Changes will be posted with a new effective date; material changes will be reasonably notified to registered Brokers.

15) Contact

• Broker Intake & Scenario Submissions: loanscenario@trustbridgecap.com

• Legal/Disputes: legal@trustbridgecap.com

• Privacy Requests: hr@trustbridgecap.com

• Phone: 646.516.4222

• Address: 307 West 38th St, 16th Fl., Suite 1013, New York, NY 10018