Compliance

This page is published by Hutfin Global Technologies, Inc., a Delaware corporation (“Hutfin,” “we,” “us,” “our”), and describes the regulatory and compliance framework that applies to the Hutfin Platform. It is the central reference for the standing disclosures cited across the Platform (“See hutfin.com/compliance”), and is incorporated by reference into the Terms of Service. Where a specific opportunity is presented, its Offering Documents and the Investor Disclosures control.

Hutfin operates a technology platform that lets brokers list commercial real estate and lets eligible investors acquire fractional interests in commercial real estate opportunities. This page summarizes how Hutfin approaches securities compliance, investor eligibility, anti-money-laundering obligations, privacy, and related matters. It is a summary for convenience and does not replace the detailed policies and offering-specific documents referenced throughout.

Fractional interests offered through the Platform are securities. They have not been registered under the Securities Act of 1933 or the securities laws of any state, and are offered and sold in reliance on exemptions from registration. Hutfin’s offerings are currently conducted as private placements to verified accredited investors under Rule 506(c) of Regulation D. The specific exemption relied upon for any offering is stated in that offering’s documents and may differ.

Securities sold in reliance on these exemptions are restricted securities. They are not listed on any public exchange, may not be resold except in compliance with applicable law, and should be considered illiquid.

Hutfin operates a technology platform. Hutfin is not registered with the U.S. Securities and Exchange Commission (SEC) as a national securities exchange, broker-dealer, investment adviser, funding portal, or in any other capacity, and is not a member of FINRA or SIPC. Hutfin is not a licensed real estate broker and does not provide brokerage, appraisal, legal, tax, or investment advice.

Where a specific offering involves a registered broker-dealer, transfer agent, escrow agent, or custodian, that entity and its role are identified in the Offering Documents for that offering. Hutfin’s own role in each offering, for example platform operator, sponsor, or manager, is also disclosed in the Offering Documents.

Investment features are limited to persons who are eligible under the exemption relied upon for the applicable offering. For Rule 506(c) offerings, this means verified accredited investors only.

4.1 Accredited investor status. In general, an individual qualifies with net worth over $1,000,000 (excluding primary residence) or income over $200,000 (or $300,000 with a spouse or spousal equivalent) in each of the two most recent years with a reasonable expectation of the same in the current year. Entities qualify under separate tests described in Rule 501 of Regulation D.

4.2 Verification. Before investing in a Rule 506(c) offering you must be verified as accredited. You may be required to provide subscription documents, questionnaires, income or net-worth documentation, professional-license evidence, and to pass identity, sanctions, and background screening. Investment features remain unavailable until required verification is complete.

4.3 No eligibility from viewing alone. Marketing materials on the Platform are educational. The ability to view an opportunity does not mean you are eligible to invest in it.

Hutfin maintains a risk-based program to deter money laundering, terrorist financing, and sanctions evasion. As a condition of using investment features, you may be required to complete identity verification (KYC), provide source-of-funds information, and be screened against applicable sanctions and watch lists, including those administered by the U.S. Office of Foreign Assets Control (OFAC). Hutfin may refuse, restrict, delay, or reverse activity, and may report activity to authorities, where required by law or where Hutfin reasonably suspects unlawful conduct. Hutfin does not transact with persons or in jurisdictions subject to comprehensive sanctions.

Nothing on the Platform, including listings, valuations, AI-generated outputs, analytics, or projections, is investment, financial, legal, tax, accounting, brokerage, or appraisal advice, and no fiduciary or advisory relationship is created. You are solely responsible for your own due diligence and investment decisions, and you should consult independent legal, tax, and financial advisors before investing.

Statements on the Platform that are not historical fact, including projections, targets, target IRRs, projected yields, and appreciation estimates, are forward-looking. They are based on assumptions and third-party data of varying quality, involve known and unknown risks, and are estimates, not appraisals or guarantees. Actual results may differ materially and may be negative. Do not place undue reliance on forward-looking statements.

Investing in fractional real estate interests involves a high degree of risk, including the risk of complete loss of your investment, illiquidity, absence of a secondary market, real estate market risk, leverage risk, valuation uncertainty, and the risk that distributions are reduced, suspended, or eliminated. The full standing risk factors are set out in the Investor Disclosures, and each offering’s documents contain risk factors specific to that asset which you must read before investing. Invest only if you can afford to lose your entire investment.

Offerings are available only in jurisdictions where they are lawful and only to persons eligible to invest. Persons outside the United States may participate only where the Offering Documents expressly provide and subject to the laws of their own jurisdiction. No person under the age of majority in their jurisdiction may hold a fractional interest under any circumstance. You are responsible for ensuring that your access to and use of the Platform is lawful where you are located.

Hutfin’s collection, use, disclosure, and protection of personal information, including in connection with verification and AI features, are described in the Privacy Policy, the Cookie Policy, and the AI Subprocessors page. Fees that may apply are described in the Fee Schedule.