Terms of Use

The terms and conditions governing your use of TONHANKS Global Trust Financial Group's products, services, and digital platforms.

Effective: January 1, 2026
Last Revised: February 15, 2026
Document ID: TNHK-TOU-2026-01

Binding Agreement: By accessing or using any product, service, or digital platform provided by TONHANKS Global Trust Financial Group, you acknowledge that you have read, understood, and agree to be bound by these Terms of Use and all applicable federal, state, and international laws and regulations.

Sections: Definitions Eligibility Accounts Digital Services Transfers & Wires Loans & Credit Investment E-Consent Intellectual Property Liability Termination Disputes Governing Law Amendments Contact

1 Definitions

Throughout these Terms of Use, the following definitions apply:

  • "TONHANKS," "the Bank," "we," "us," or "our" refers to TONHANKS Global Trust Financial Group, its subsidiaries, affiliates, successors, and assigns, including TONHANKS Global Trust Bank, N.A.
  • "You," "your," or "Customer" refers to any individual or entity that opens, maintains, or uses any account, product, or service offered by TONHANKS
  • "Account" refers to any deposit, lending, investment, retirement, insurance, payroll, or other financial product maintained with the Bank
  • "Services" includes all banking products, online platforms, mobile applications, ATM networks, branch services, and customer support channels
  • "Digital Platforms" includes the TONHANKS website, online banking portal, mobile banking application, and any associated digital tools
  • "Authorised User" refers to any individual granted access to an Account by the primary Account holder through formal written or electronic authorisation

2 Eligibility

To open and maintain accounts with TONHANKS Global Trust Financial Group, you must meet the following requirements:

  1. Be at least eighteen (18) years of age, or the age of majority in your jurisdiction, whichever is greater
  2. Provide valid, government-issued identification satisfying Know Your Customer (KYC) requirements
  3. Maintain a residential or business address that can be independently verified
  4. Not be a person or entity on any sanctions list maintained by OFAC, the UN Security Council, or the European Union
  5. Complete all required tax identification documentation, including IRS Form W-9 (US persons) or W-8BEN (non-US persons)

Custodial accounts may be opened on behalf of minors by a parent or legal guardian who accepts full responsibility for the account. Joint accounts require all parties to individually meet the eligibility criteria above.

3 Account Terms & Conditions

3.1 Account Opening

All accounts are subject to approval by the Bank following satisfactory completion of identity verification, credit review (where applicable), and regulatory screening. The Bank reserves the right to decline any application without obligation to disclose the reason.

3.2 Account Ownership

The person or entity in whose name the account is opened is the owner and bears all rights and obligations associated with the account. In the case of joint accounts, each joint owner is jointly and severally liable for all obligations, including overdrafts, fees, and debts incurred on the account.

3.3 Fees & Charges

Applicable fees for account maintenance, transactions, wire transfers, and ancillary services are detailed in the Bank's Fee Schedule, available at any branch or through your online banking dashboard. The Bank will provide thirty (30) days' written notice before implementing any fee increase on existing accounts.

3.4 Interest Rates

Interest rates on deposit accounts are variable and may change at the Bank's discretion based on market conditions. Current rates are published on the Bank's website and updated monthly. For promotional or introductory rates, the standard rate will apply upon expiration of the promotional period as disclosed at the time of account opening.

3.5 Dormant Accounts

Accounts with no customer-initiated activity for a period of twelve (12) consecutive months may be classified as dormant. Dormant accounts may be subject to a monthly maintenance fee. Accounts dormant for the period required under applicable state escheatment laws will be reported and remitted to the appropriate state authority.

4 Digital & Online Banking Services

4.1 Access & Credentials

You are solely responsible for maintaining the confidentiality of your online banking credentials, including your account number, password, transaction token, and any multi-factor authentication (MFA) codes. You agree to notify the Bank immediately if you suspect any unauthorised access to your account.

4.2 Security Obligations

By using our Digital Platforms, you agree to:

  • Maintain up-to-date antivirus and operating system software on all devices used to access your accounts
  • Avoid accessing online banking through unsecured public Wi-Fi networks
  • Never share your credentials, transaction token, or one-time passwords (OTPs) with any person, including Bank staff
  • Log out of all active sessions when you have finished banking and when using shared or public devices

4.3 Session Management

For your protection, online banking sessions will automatically expire after ten (10) minutes of inactivity. You will be required to re-authenticate to resume your session. The Bank reserves the right to terminate any session that exhibits anomalous behaviour patterns.

4.4 System Availability

While we strive to maintain 99.99% uptime, our Digital Platforms may be temporarily unavailable due to scheduled maintenance, system upgrades, or unforeseen technical events. The Bank shall not be liable for any losses arising from temporary service interruptions.

Reminder: TONHANKS will never contact you by email, phone, or text to request your password, full account number, or transaction token. Any such request is fraudulent and should be reported to our Security Centre immediately.

5 Funds Transfers & Wire Services

5.1 Internal Transfers

Transfers between TONHANKS accounts held by the same customer are processed instantly at no charge. Transfers to accounts held by different customers within TONHANKS are subject to standard verification and may require a brief processing period.

5.2 External Transfers (ACH/EFT)

External transfers initiated through ACH or EFT are typically processed within one (1) to three (3) business days. Daily and monthly limits apply and are disclosed in your account documentation. The Bank reserves the right to delay or decline any transfer that triggers fraud detection alerts.

5.3 Wire Transfers

Domestic wire transfers are typically processed same-day if initiated before the daily cut-off time of 4:00 PM EST. International wire transfers (SWIFT) are processed within one (1) to three (3) business days depending on the destination country and correspondent banking arrangements. Wire transfer fees are detailed in the Bank's Fee Schedule.

5.4 Currency Conversion

For multi-currency transactions, the exchange rate applied will be the Bank's prevailing mid-market rate at the time of processing, plus any applicable markup as disclosed in the Fee Schedule for your account type. Exchange rates are indicative and subject to market fluctuations.

Large Value Transfers: Wire transfers exceeding USD $10,000 require dual-authorisation through your transaction token. New payee accounts are subject to a 24-hour verification hold. These measures are implemented pursuant to the Bank Secrecy Act and Anti-Money Laundering regulations.

6 Lending & Credit Products

6.1 Loan Terms

All lending products, including personal loans, business expansion loans, student loans, and lines of credit, are subject to credit approval and governed by the individual loan agreement executed at origination. These Terms of Use supplement, but do not replace, any specific loan agreement.

6.2 Interest & Repayment

Interest on lending products accrues daily based on the outstanding principal balance at the applicable annual percentage rate (APR). Repayment schedules, minimum payment amounts, and due dates are specified in your individual loan agreement. Late payments may result in late fees and adverse credit reporting.

6.3 Student Loan Programme

The Bank's interest-free student loan programme is subject to specific eligibility criteria, including enrolment verification, satisfactory academic progress, and compliance with the disbursement schedule as defined in the student loan agreement. Failure to maintain eligibility may result in conversion to a standard interest-bearing loan.

6.4 Debt Relief & Restructuring

Customers experiencing financial hardship may apply for loan restructuring or debt relief through the Bank's Hardship Programme. Applications are evaluated on a case-by-case basis. Qualification for the programme does not guarantee approval, modification, or forgiveness of any debt obligation.

7 Investment & Retirement Accounts

7.1 Investment Products

Investment products offered through TONHANKS Global Trust Financial Group are provided by our registered broker-dealer and investment advisory affiliates. Investment products, including those held in retirement accounts (401(k), IRA, Self-Directed Brokerage), are:

  • NOT A DEPOSIT of TONHANKS Global Trust Bank, N.A.
  • NOT FDIC INSURED or insured by any federal government agency
  • NOT GUARANTEED by the Bank or any of its affiliates
  • Subject to investment risk, including the possible loss of principal

7.2 Suitability

Before recommending or selling any investment product, our advisors are obligated to assess the suitability of the product based on your investment objectives, risk tolerance, time horizon, and financial situation as disclosed by you. You are responsible for providing accurate and complete information.

7.3 Founders & Investors Accounts

Capital deployed through the TONHANKS Founders & Investors Hub and Founders & Investors Programme is subject to the terms of the specific investment agreement, including capital lock-up periods, disbursement schedules, and the Bank's Capital Drift Prevention protocols. Investors acknowledge that start-up investments carry inherently higher risk than traditional banking products.

8 Electronic Communications Consent

By opening an account or enrolling in online banking, you consent to receive communications from the Bank in electronic form, including:

  • Account statements and transaction confirmations
  • Legal and regulatory notices, including changes to these Terms of Use
  • Security alerts, fraud notifications, and authentication codes
  • Marketing communications regarding new products and services (opt-out available)
  • Tax documents, including Forms 1099 and annual account summaries

You may withdraw your consent to electronic communications at any time by contacting Customer Service. Withdrawal of consent may result in the imposition of a paper statement fee as disclosed in the Fee Schedule.

9 Intellectual Property

All content on the Bank's Digital Platforms, including but not limited to text, graphics, logos, trademarks, data compilations, software, and user interface designs, is the exclusive property of TONHANKS Global Trust Financial Group or its licensors and is protected by United States and international copyright, trademark, and intellectual property laws.

You may not reproduce, distribute, modify, create derivative works from, publicly display, or commercially exploit any content from our platforms without prior written consent from the Bank's Legal Department.

10 Limitation of Liability

10.1 Scope

To the maximum extent permitted by applicable law, TONHANKS Global Trust Financial Group, its directors, officers, employees, and agents shall not be liable for any indirect, incidental, consequential, special, or punitive damages arising out of or related to your use of, or inability to use, any account, product, service, or digital platform.

10.2 Exclusions

This limitation does not apply to:

  • Losses resulting from the Bank's gross negligence, wilful misconduct, or fraud
  • Obligations under FDIC deposit insurance coverage
  • Claims arising under consumer protection statutes that prohibit limitation of liability, including the Electronic Fund Transfer Act (EFTA/Regulation E)
  • The Bank's $0 Liability Guarantee for verified unauthorised transactions reported within sixty (60) days

10.3 Force Majeure

The Bank shall not be liable for any failure or delay in performing its obligations due to causes beyond its reasonable control, including natural disasters, war, terrorism, epidemics, government actions, power failures, internet or telecommunications outages, or failures of third-party service providers.

11 Account Suspension & Termination

11.1 By the Customer

You may close your account at any time by contacting Customer Service or visiting a branch. Account closure requests are processed within five (5) business days. Any remaining balance will be disbursed to you by cheque or wire transfer as directed. Outstanding loan obligations survive account closure.

11.2 By the Bank

The Bank reserves the right to suspend, restrict, or terminate your access to any account or service, with or without prior notice, if:

  • We reasonably believe the account is being used for illegal, fraudulent, or prohibited activity
  • You fail to comply with these Terms of Use or any applicable account agreement
  • You provide false, misleading, or incomplete information during account opening or ongoing due diligence
  • Your account is subject to a valid legal hold, court order, garnishment, or regulatory directive
  • Continued provision of services would expose the Bank to unacceptable legal, regulatory, or reputational risk

12 Dispute Resolution

12.1 Internal Resolution

If you have a complaint or dispute concerning any account, product, or service, we encourage you to first contact our Customer Service team or visit your local branch. We are committed to resolving disputes promptly and fairly. Most issues can be resolved within ten (10) business days.

12.2 Arbitration

Any dispute, controversy, or claim arising out of or relating to these Terms of Use, or any account or service provided by the Bank, that cannot be resolved through internal dispute resolution, shall be settled by binding arbitration administered by the American Arbitration Association (AAA) under its Commercial Arbitration Rules. Arbitration shall be conducted in New York, New York, before a single arbitrator with expertise in financial services law.

12.3 Class Action Waiver

You agree that any dispute resolution proceedings will be conducted only on an individual basis and not as a class, consolidated, or representative action. You waive any right to participate in any class action lawsuit or class-wide arbitration against the Bank.

Regulatory Complaints: Nothing in this section limits your ability to file complaints with the Consumer Financial Protection Bureau (CFPB), the Office of the Comptroller of the Currency (OCC), or your state banking regulator.

13 Governing Law & Jurisdiction

These Terms of Use shall be governed by and construed in accordance with the laws of the State of New York, United States of America, without regard to its conflict-of-laws provisions. For matters not subject to mandatory arbitration, you consent to the exclusive jurisdiction and venue of the state and federal courts located in New York County, New York.

For customers located outside the United States, the applicability of local consumer protection laws and regulations shall be determined on a jurisdiction-by-jurisdiction basis. Where local law provides greater protections than these Terms, local law shall prevail to the extent required.

14 Amendments & Updates

The Bank reserves the right to amend, modify, or supplement these Terms of Use at any time. When we make material changes:

  1. We will post the revised Terms on our website with an updated "Last Revised" date
  2. For changes that materially affect your rights or obligations, we will provide a minimum of thirty (30) days' advance notice through your online banking dashboard, email, or postal mail
  3. Your continued use of any account, product, or service after the effective date of the amendment constitutes your acceptance of the revised Terms
  4. If you do not agree to the amended Terms, you may close your account without penalty within the thirty (30) day notice period

15 Contact Information

For questions, concerns, or requests regarding these Terms of Use, please contact us:

  • Customer Service: Support is available via our Secure Client Portal and Premier email.
  • Email: legal@tonhanks.com
  • Mail: Legal and Compliance Department, TONHANKS Global Trust Financial Group, One TONHANKS Plaza, 388 Greenwich Street, New York, NY 10013
  • Online: Submit inquiries through the secure message centre in your online banking dashboard

Acknowledgment: By opening an account, using any product or service, or accessing any digital platform of TONHANKS Global Trust Financial Group, you confirm that you have read, understood, and agree to be bound by these Terms of Use in their entirety. These Terms, together with your individual account agreements, constitute the complete agreement between you and the Bank.