Consumer Protection Guidelines for Clients

Effective Date: March 26, 2025

Rail endeavors to comply with all consumer protection laws and regulations in the jurisdictions where we operate — and we are committed to helping our clients do the same. As a Money Services Business (MSB), it is our responsibility to adhere to these guidelines to safeguard consumer rights, prevent unfair practices, and promote transparency.

This document defines those compliance requirements and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) prohibitions, explains how you as a client should handle complaints, correct errors, and ensure marketing and customer service practices protect customers.

1. How to Handle Customer Complaints

1.1 Definition of a Complaint

A complaint is any time a consumer expresses dissatisfaction — whether about a transaction, service, or any other aspect of their experience with your company. This includes things like unauthorized transactions, service failures, pricing disputes, or any other perceived wrongdoing.

Examples of complaints include:

• “You’ve lost my money ! It was supposed to be deposited X days ago. Where is my money?”
• “Your customer service representative was rude.”
• “You said the exchange rate was supposed to be xx:yy, but you charged me aa:yy.”

An inquiry, on the other hand, is a general request for information or clarification and does not necessarily indicate dissatisfaction.

Examples of inquiries include:

• “Where is my transaction?”
• “My money was supposed to be there a minute ago. Where is my money?”
• “How much are the fees?”

1.2 Complaint Handling Process

To ensure consumer concerns are addressed effectively you are required to:

• Maintain a clear, accessible process for consumers to submit complaints (e.g., phone, email, website).
• Acknowledge receipt of complaints within a reasonable timeframe (e.g., within 24-48 hours).
• Investigate complaints thoroughly and fairly.
• Provide a resolution or response within a reasonable period, typically within 30 days.

1.3 Notification to Rail

You must notify Rail of all material complaints related to consumer protection, including fraud, unauthorized transactions, misleading practices, or regulatory violations.

• Email complaints to complaints@rail.io .
• Include details such as the customer’s name, transaction ID, nature of the complaint, and your resolution efforts.
• Escalate complaints that involve potential legal or regulatory violations immediately.

2. Resolving Transaction Errors

You must handle errors related to consumer transactions in accordance with federal regulations, including the Electronic Fund Transfer Act (EFTA) and Regulation E as well as applicable US State regulations where the customer resides.

2.1 Definition of an Error

An error includes, but is not limited to:

• Incorrect transaction amounts
• Unauthorized or fraudulent transactions
• Funds not received by the intended recipient
• Transaction processing delays or failures

2.2 Error Resolution Process

1. Consumers must report errors within 180 days of the transaction date.
2. Clients must notify Rail immediately via complaints@rail.io and must include the transaction ID, the amount of the transaction, the date of the transaction, and the name of the Customer.
3. Client must acknowledge receipt to the customer within 10 business days and provide written confirmation to Rail of this acknowledgement.
4. Rail and Client will work together to investigate and resolve the issue within 45 days (or 90 days for international transactions). If additional time is required for investigation, Rail will provide notification to the Client to convey to the Customer in accordance with Federal Law and regulation.

3. Customer Cancellation Rights for Remittances

Under the Remittance Transfer Rule (Regulation E), customers have the right to cancel remittance transfers under the following conditions:

• Cancellation requests must be submitted within 30 minutes of the transaction in order for a full refund to be possible.
• Funds must not have been picked up, deposited by the Recipient, or made available to the Recipient.
• Customers are entitled to a full refund (fees, taxes, everything) if the transaction is canceled within the allowed timeframe unless the funds have been made available to the Recipient or deposited by the Recipient.
• A remittance transfer provider shall refund, at no additional cost to the Sender, the total amount of funds provided by the Sender within three business days of receiving a Sender's request to cancel the remittance transfer.

4. Avoiding Unfair, Deceptive, or Abusive Practices (UDAAP)

Under the Dodd-Frank Act, you must not engage in Unfair, Deceptive, or Abusive Acts or Practices (UDAAP).

• Unfair Practices: Actions that cause substantial harm to consumers that they cannot reasonably avoid.
• Deceptive Practices: Providing misleading or inaccurate information that misleads consumers.
• Abusive Practices: Taking advantage of consumer confusion or lack of understanding to the consumer’s detriment.

Examples:

1. A website states ‘all transactions clear in less than a minute”.
   1. Potentially Deceptive Marketing statement unless the vast majority of transactions do clear in less than a minute.
2. An advertisement says “fee free transactions”.
   1. Potentially Deceptive Marketing statement unless all transactions are offered for free.

5. Reviewing and Approving Marketing for Compliance

All marketing materials, including websites, advertisements, emails, and social media promotions, must comply with consumer protection laws and regulations.

• Accuracy: Marketing must not contain false, misleading, or exaggerated claims.
• Transparency: Clearly disclose terms, conditions, and applicable fees.
• Fairness: Avoid tactics that could mislead consumers into making uninformed financial decisions.

6. Fraud

You must provide a fraud warning to consumers as part of your payment confirmation process. It should warn consumers not to send funds to people they don’t know, confirm the details of a transaction, be wary of requests for money, and to immediately report potential fraud to you, our Client, so that we may attempt to freeze transactions where available.

7. What to do if a Regulator Contacts You

Unless prohibited by law or regulation, you must notify Rail in writing immediately if you receive a complaint, inquiry, or other contact from a legal or regulatory entity with respect to the services or products that Rail offers. Entities include:

• Consumer Financial Protection Bureau
• State Attorneys General’s Offices
• US Attorney General
• Better Business Bureau
• Law Suit
• State Financial Regulatory Departments
• Local Financial Regulators such as the Financial Conduct Authority (FCA) in the UK, Monetary Authority of Singapore (MAS), Banco de Portugal, etc.

8. Record-Keeping and Compliance Monitoring

You must maintain detailed records of consumer complaints, error resolutions, cancellations, and marketing approvals for at least five (5) years. Rail may conduct periodic compliance audits to ensure adherence to these guidelines.

9. Contact Information

We are committed to ensuring our compliance with applicable regulations and we are here to help. Please contact Rail immediately if you have any questions or concerns.

For complaints and error resolution reporting: complaints@rail.io

For marketing review and approval: marketing@rail.io

For general compliance inquiries: compliance@rail.io

For general support: support@rail.io