We are grateful you have chosen to facilitate your charitable giving through The BlueTrust DAF Program (“BlueGive”) and congratulate you on the impact you will be making in the world. These Program Guidelines set forth the policies and procedures for establishing a Donor Advised Fund (“Giving Fund”) and the terms and provisions governing the administration of each Giving Fund.

BlueTrust has partnered with GiveClear Foundation (“GC” or “GiveClear”) as the 501(c)(3) Donor Advised Fund Sponsor and TIFIN WealthTech, LLC (“TIFIN Give”). GiveClear and TIFIN Give envision a new model of philanthropy - a transparent system at your fingertips connecting people to trusted non-profits at scale. GiveClear and TIFIN Give deliver an inspiring charitable giving experience through innovative technology, bringing additional accountability, transparency and effectiveness to philanthropy.

Contributions to your Giving Fund are irrevocable when received and accepted by GiveClear, which retains exclusive legal control over contributions.

All activities of GiveClear and all participation by Donors are subject to these Donor Advised Fund (DAF) Program Guidelines and the policies referenced within.

All prospective Dnors should consult their legal, accounting, and/or tax advisors regarding any implications of participation in BlueGive.

GiveClear Foundation is a 501(c)(3) organization EIN: 81-3222963.

· What is a Giving Fund - A Giving Fund is a charitable Giving Fund designed to invest, grow, and give assets to non-profits for meaningful and lasting impact. Once funds are contributed, they are non-refundable, and the Donor receives an immediate tax receipt.

· Getting Started - A Giving Fund can be opened quickly, easily, and at no cost. Interested clients should contact their Advisor to initiate the account opening process.

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There is no minimum initial contribution required to fund a Giving Fund. There is no minimum balance required to maintain a Giving Fund. Contributions will be accepted from inidivuduals, business entities, donor advised funds, trusts, estates, and other foundations.

· Contribution Acknowledgement & Valuation - All accepted contributions will be acknowledged with a notification, and an official tax receipt will be available immediately, if applicable. All official tax receipts for contributions will comply with the IRS regulations. GiveClear will follow all IRS guidelines and standard practice guidelines for the industry in valuing all contributions.

· Cash (USD): GiveClear accepts contributions of monies in US dollars to a Giving Fund. Donors receive credit into their Giving Fund for each contribution effective the day the funds are received by GiveClear.

· Publicly traded U.S. securities: GiveClear accepts contributions of publicy traded

U.S. securities to a Giving Fund. Donors receive credit into their Giving Fund for each contribution after it has been received and subsequently sold, effective the day the net proceeds are received by GiveClear.

· DAF Transfer (USD): GiveClear accepts incoming transfers of DAF assets (USD only) held at external DAF Sponsors. Donors receive credit into their Giving Fund effective the day the funds are received by GiveClear.

GiveClear Giving Funds will not accept gifts that do not meet the above specifications. GiveClear also recommends that individuals seek Independent Legal Advice (ILA) prior to making any significant contributions, as there are IRS limits on the amounts of charitable contributions that can be deducted in any one year.

· GiveClear Must Accept Contributions Before they are Final - GiveClear reserves the right to decline any contributions for any reason, for example a contribution that it believes does not comply with IRS regulations.

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· Timing of Contributions - Generally, the date of any contribution is the date on which the asset is received by GiveClear. Timing of receipt at year end can be critical. Please see schedule below for cut off dates.

· Investment of Giving Fund Balance - Giving Funds may be invested for tax free growth, while being held prior to grant distributions. BlueTrust and GiveClear offer Giving Fund’s investment options most suitable to each individual Giving Fund’s needs. Giving Funds may invest in commingled Core Investment Models or individual Professionally Managed Portfolios. Donors should agree with their BlueTrust Advisor on the appropriate investment approach for their Giving Fund, consistent with GiveClear’s investment policy guidelines.

Investments should be chosen with consideration for time horizon for granting to non- profits that the Donor has in mind. Funds targeted for immediate grant distribution

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should be left as cash, while those intended to be held for a longer duration or for growth are appropriately invested. It is recommended that enough funds be left in cash to satisfy the next one to three months’ worth of grants.

For further information on investments, please refer to the Investment Policy Statement of the BlueTrust Donor Advised Fund Program.

· Investment Expenses - All investment-related expenses are assessed from the Giving Fund assets; examples include investment management fees, sub-advisory fees, mutual fund or ETF expenses, withholding taxes on offshore income, and trading costs.

· Donor - the original owner of the asset(s) that have been donated to a Giving Fund. Unless the Donor requests that grants be made anonymously, all grants to non-profits will include the Donor’s name and email address. A Donor must be an individual over 18 years of age or an approved legal entity.

· Family Member – an individual nominated by Donor to submit grant recommendations from the Giving Fund.

· Advisor – A financial professional affiliated with BlueTrust who is nominated by the Donor to perform various functions within the Giving Fund on the Donor’s behalf, such as providing charitable planning services.

· Successor - An individual who is nominated in the Giving Fund succession plan to act as Donor when the current Donor is deceased or otherwise unable to act due to incapacity or disability. Each Giving Fund can name one Successor.

· Beneficiary – a charitable beneficiary designated by the Donor as the recommended recipient of any Giving Fund balances when the current Donor is deceased or otherwise unable to act due to incapacity or disability and the Successor does not assume the role.

SUCCESSION PLANNING

In the event of your death or incapacity, you may wish to provide Giveclear Foundation with a digital "succession plan" for your Giving Fund. There are two options to handle the remaining assets in the Giving Fund, and you may allocate a percentage of the Giving Fund to any one of these, or a combination of them.

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A. Name a Successor – provide Giveclear and BlueTrust with digital instructions of the name and contact information for the Successor upon your death or incapacity. GiveClear and BlueTrust will coordinate with the Successor to open a Giving Fund and transfer the allocated amount.

B. Name a Beneficiary – provide GiveClear with digital instructions to recommend a final grant directly to Beneficiary for the Giving Fund allocation upon your death or incapacity.

If no instructions are provided or instructions are no longer valid due to an inability to reach Successor or the loss of tax-exempt status by Beneficiary, Giveclear will make grants to the last 3 grantees made by the donor advised fund in proportion to the grants made by donor during their life. if no grants were made by the donor during their life, or Giveclear determines that following such a policy creates an inappropriate outcome, the board of Giveclear will place the funds with one or more approved charities of its choosing.

Grant Recommendations can be made to IRS approved 501(c)(3) public charities and private operating foundations, with a minimum of $50. Grants cannot be made to private non-operating foundations.

· Grant Recommendation Fulfillment - Grant Recommendations are reviewed for approval on business days within 48 hours of submission unless additional due diligence is required.

Grants are issued to non-profits by GiveClear. To keep administrative costs low, GiveClear makes every effort to transfer grant funds to non-profits electronically. Therefore, if a non- profit is part of the digital payment network used by GiveClear, funds should be received by the non-profit within 2 - 7 business days of grant approval.

For any non-profit that is not part of the digital payment network, a check will be sent within 5 business days of grant processing. Checks not cashed after 6 months of the issue date will be redeposited into the Donor’s Giving Fund. Non-profits will have a $25 Administration Recovery Fee withheld from all grants issued via check for the third and subsequent check sent.

· Grant Restrictions – Any grant recommendations are under the exclusive legal control of GiveClear, which reserves the right to refuse a grant recommendation based on legal obligations, tax-exempt status, internal policies, or improper purposes. In the event that funds granted are for an impermissible purpose, remedial action will be taken to have the grant funds returned. GiveClear reserves the right to assess a Giving Fund for

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extraordinary or unusual costs it incurs due to a Donor’s requests.

Grant recommendations are not permitted if the grant provides personal benefit to the Donor and/or Advisor or a related person to the Donor and/or Advisor. The restrictions for recommended grants are as follows:

· Private benefit for any individual(s)

· Dues or membership fees

· Tuition payments

· Purchasing tickets to a benefit

· Purchasing goods or services at a charitable auction

· Funding a pre-existing, binding pledge which you are legally obligated to fulfill

· Lobbying, political contributions, or political campaigns

1. NOTE: Please refer to IRS guidelines for the full explanation of charitable grant restrictions.

DAF Administrative Fees are used by GiveClear to pay for the administrative and operating expenses incurred in the administration of the BlueTrust DAF Program. DAF Administrative fees will be calculated daily based on the Giving Fund balance and are drawn from the Giving Fund monthly. Fees are charged based on the declining fee structure as outlined below.

CORE INVESTMENT MODELS: SUB-ADVISORY FEES

If a Giving Fund is invested in a Core Investment Model, the Advisor to Donor may earn a sub- advisory fee in their administration of charitable planning and the selection of suitable investment pools for Giving Funds. Sub-Advisory fees will be calculated daily based on the Giving Fund balance and are drawn from the Giving Fund monthly. Sub-Advisory fees will not exceed an annual fee rate of 100 basis points (bps) or 1.0%.

For further information, please contact your BlueTrust Advisor for the Giving Fund.

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PROFESSIONALLY MANAGED PORTFOLIOS: INVESTMENT MANAGEMENT FEES

If a Giving Fund is invested in a Professionally Managed Portfolio, the Advisor to Donor may earn an investment management fee for their investment management services. The investment management fee will be deducted directly from the portfolio by BlueTrust.

For further information, please contact your BlueTrust Advisor for the Giving Fund.

If significant or unusual charitable operating expenses are incurred by GiveClear due to extraordinary contribution, investment, or grant requests of a Giving Fund, GiveClear may allocate these expenses back directly to the Giving Fund in order to recover these expenses.

*BlueTrust and GiveClear Foundation reserve the right to modify the Donor Advised Fund (DAF) program and the Program Guidelines at any time