1. Purpose

Project Indigo LLC d/b/a Curated Capital ("Curated Capital" or "Company"), a Texas regulated lender operating under Texas Finance Code Chapter 342, Subchapter E, is committed to providing excellent and compliant service to all consumers. This policy establishes procedures for receiving, investigating, responding to, and tracking consumer complaints in a timely, fair, and consistent manner.

Effective complaint handling protects consumers, identifies opportunities to improve operations, and demonstrates the Company's commitment to regulatory compliance and customer service excellence.

2. Scope

This policy applies to all complaints received from borrowers, prospective borrowers, and third parties regarding any aspect of Curated Capital's lending operations and related business activities, including but not limited to:

• Loan terms, pricing, or fees
• Application processing or denial
• Collateral handling, appraisal, or storage
• Customer service interactions
• Collection activities
• Collateral liquidation
• Alleged discrimination or unfair treatment
• Privacy or data security concerns
• Any other matter that may implicate consumer protection or fair lending requirements

3. Definitions

Term	Definition
Complaint	Any expression of dissatisfaction, whether oral or written, regarding the Company's products, services, policies, or employees, where a response or resolution is explicitly or implicitly expected.
Inquiry	A request for information that does not express dissatisfaction. Inquiries are not subject to this policy but should be responded to promptly.
Regulatory Complaint	A complaint received from or forwarded by a regulatory agency, including the Texas Office of Consumer Credit Commissioner (OCCC) or the Consumer Financial Protection Bureau (CFPB).
Consumer	Any individual who has applied for, received, or is affected by the Company's lending products or services, including borrowers and prospective borrowers.

4. Complaint Channels

Curated Capital accepts complaints through the following channels:

Channel	Contact Information
Email	complaints@curatedcapital.com
Phone	Main business line
Mail	Company headquarters address
In-App / Website	Contact form or chat feature
Regulatory Referral	OCCC, CFPB, or other agencies

5. Complaint Handling Procedures

5.1 Receipt and Logging

Upon receipt of a complaint, the Compliance Officer shall:

1. Log the complaint in the Complaint Register, recording: date received, complainant name and contact information, nature of complaint, and channel received
2. Assign a unique complaint reference number
3. Categorize the complaint (e.g., pricing, service, collateral, discrimination, other)
4. Determine if escalation is required per Section 5.4

5.2 Acknowledgment

5.3 Investigation and Response

Standard Complaints:

Regulatory Complaints:

Complaints received from or forwarded by the OCCC, CFPB, or other regulatory agencies shall be prioritized and handled in accordance with the agency's specified timeframes. The Compliance Officer shall coordinate directly with the regulatory agency and provide all requested documentation.

5.4 Escalation

The Compliance Officer shall immediately notify the Executive Committee and escalate complaints when:

• The complaint alleges discrimination on any prohibited basis
• The complaint alleges fraud, misrepresentation, or regulatory violations
• The complaint involves potential legal exposure or threatened litigation
• The complaint is received from or forwarded by a regulatory agency
• The complaint remains unresolved after the initial response
• The complaint involves a pattern of similar issues

Escalated complaints shall be reviewed by the Executive Committee, which will determine the appropriate response and any remedial actions.

5.5 Resolution and Closure

A complaint is considered closed when:

• A final written response has been provided to the complainant
• Any agreed-upon remedial action has been completed
• The Complaint Register has been updated with the resolution and closure date

Resolution categories include:

• Resolved in favor of complainant
• Resolved in favor of Company
• Partial resolution / compromise
• Withdrawn by complainant
• Referred to regulatory agency or legal counsel

6. Complaint Register

The Compliance Officer shall maintain a Complaint Register that tracks all complaints received. The register shall include, at minimum:

Field	Description
Reference Number	Unique complaint identifier
Date Received	Date complaint was logged
Complainant Info	Name and contact information
Channel	Email, phone, mail, app, website, regulatory referral
Category	Pricing, service, collateral, discrimination, etc.
Summary	Brief description of complaint
Date Acknowledged	When acknowledgment was sent
Assigned To	If escalated, who is handling
Response Date	Date of substantive response
Resolution	Resolution category
Date Closed	When complaint was closed
Notes	Lessons learned / additional context

7. Trend Analysis and Reporting

7.1 Quarterly Review

The Compliance Officer shall conduct a quarterly review of complaint data to identify trends, patterns, and systemic issues. The review shall include:

• Total number of complaints received
• Complaints by category
• Complaints by channel
• Average time to acknowledgment and resolution
• Resolution outcomes
• Escalated complaints and outcomes
• Identified trends or recurring issues

7.2 Reporting to Executive Committee

The Compliance Officer shall report quarterly complaint metrics and trends to the Executive Committee. If complaint volume is low, the report may be brief, but the review shall be documented to demonstrate ongoing monitoring.

7.3 Corrective Action

When trend analysis identifies recurring issues or systemic problems, the Compliance Officer shall recommend corrective actions to the Executive Committee. Corrective actions may include policy changes, additional training, process improvements, or other remediation.

8. Recordkeeping

All complaint records, including the Complaint Register, complaint correspondence, investigation notes, and responses, shall be retained for a minimum of five (5) years from the date the complaint is closed. This retention period is consistent with OCCC examination requirements and the Company's general document retention policy.

Records shall be maintained in a manner that allows for easy retrieval and review by the OCCC or other regulatory agencies upon request.

9. Training

All employees shall receive training on this policy, including:

• How to recognize a complaint vs. an inquiry
• Proper procedures for receiving and forwarding complaints
• The importance of timely and professional complaint handling
• Escalation triggers
• Overview of applicable consumer protection and fair lending requirements

Training shall be provided at onboarding for new employees and refreshed annually. The Compliance Officer shall maintain records of training completion.

10. Policy Review

This policy shall be reviewed at least annually and updated as necessary to reflect changes in regulatory requirements, business operations, or lessons learned from complaint handling. The Compliance Officer is responsible for recommending updates to the Executive Committee.