Truth in Lending Disclosure

1 What Is This Document?

Bulisolio — Your AI Crypto Wealth Concierge. The smartest way to manage your crypto with voice-powered AI, instant loans, and professional portfolio tracking.

This is our Truth in Lending Disclosure. It tells you exactly how we decide:

• Whether you can get a loan
• What type of loan you qualify for (see Section 4)
• How much money you can borrow
• What fees we charge (called "Concierge Commission")
• Whether Bulisolio co-signs your loan with our own capital (Delegated Loans)
• What payment obligations come with each loan type
• What specific steps are required to reach Class 3 Full Delegation eligibility (see Section 6A)

We are required by law to explain all of this clearly. If anything is confusing, you can ask Concierge Voice to explain it. Just say "Hey Bulis, explain my loan terms" in the app.

2 Who We Are

Bulisolio LLC is a limited liability company registered in Salt Lake City, Utah, United States. We operate the Bulisolio app — an AI-powered crypto wealth management platform.

What we do:

• Help you track your crypto across 22+ blockchains
• Provide voice-activated AI assistance (Concierge Voice®)
• Connect you to crypto lending protocols on the Base blockchain
• For qualifying users, co-sign loans with our own treasury capital (see Section 5)
• Handle the technical details so you can focus on your financial goals

What we DON'T do:

• We don't hold your crypto long-term (you keep full control via your secure vault)
• We don't lend you money directly — loans come from smart contracts on Base
• We don't give financial advice (we provide tools and information)

Think of Bulisolio as a concierge service — we arrange and manage crypto lending through smart contracts, and in some cases put up our own capital alongside yours.

3 How Bulisolio Loans Work

The Basic Idea

A Bulisolio loan lets you borrow USDC (digital dollars) by putting your crypto up as collateral. You keep owning your crypto — it just gets locked in a smart contract while you have the loan. When you repay, you get it back. If you can't repay, the smart contract automatically sells your crypto to cover what you owe.

Step-by-Step Process

1. You ask Concierge Voice® how much you can borrow ("Hey Bulis, what loan can I get?")
2. The Loan Underwriting Engine evaluates your profile and assigns a Loan Class (see Section 4)
3. Concierge shows you your loan class, limit, terms, and fees before you commit
4. You choose which crypto to use as collateral (ETH or cbBTC on Base)
5. Concierge moves your crypto into your secure vault wallet on Base
6. A smart contract locks your crypto and releases USDC to you
7. Bulisolio deducts the Concierge Commission from your USDC before delivery
8. You spend the USDC directly from your Secure Vault via a non-custodial Visa card

Key Terms

Collateral: Crypto you lock up to back a loan — like leaving collateral at a pawn shop.

USDC: A stablecoin always worth $1. Digital cash on the blockchain.

Smart Contract: Automatic computer code on the blockchain. It runs itself — no bank, no middleman.

Base: A fast, low-cost blockchain network. Your secure vault and loan contracts live here.

LTV (Loan-to-Value): What percent of your collateral's value you borrow. $10,000 in ETH at 70% LTV = up to $7,000 borrowed.

Health Factor: A score showing how safe your loan is. Above 1.5 is healthy. Below 1.0 means liquidation risk.

4 The Four Loan Classes

Not everyone gets the same loan. The Loan Underwriting Engine assigns you a Loan Class based on how much collateral you can provide, your Trust Score, and whether Bulisolio's treasury has enough reserve capital available. Your class determines your maximum loan size, your commission rate, and your payment obligations.

Underwriting tries to put you in the best class you qualify for — starting from Class 1 (safest, cheapest) down to Class 4 (most specialized). You are told your class before you confirm any loan.

Class Assignment Flow (Simplified)

Underwriting evaluates you in order. It assigns the first class you qualify for:

1. Can you cover 100% of the loan with your vault collateral? → Class 1 SC
2. Can you cover at least 40%, Trust ≥ 600, Spectral ≥ 550, HODL Gold+? → Class 2 MB
3. Trust ≥ 700, Spectral ≥ 650, Coinbase EAS Verified, all five FD safeguards passed, markets CALM or ELEVATED? → Class 3 FD (up to $1,000)
4. Are you a Legend Affiliate + Premium + Coinbase EAS Verified? → Class 4 LALoC
5. None of the above? → Loan Denied (Concierge explains exactly what is missing and what to do next)

Class 4 is evaluated as a parallel path — a Legend Affiliate who also qualifies for Class 1 may be offered both options and can choose. The five FD safeguards apply to Class 3 only. They do not affect Class 1 or Class 2 eligibility.

5 Delegated Loans

Classes 2, 3, and 4 are Delegated Loans. This section explains exactly what that means and why it affects your commission rate and payment requirements.

What "Delegation" Means

When Bulisolio "delegates" capital to your loan, it moves a portion of its own USDC from a reserved treasury wallet onto the Base blockchain alongside your collateral. This combined capital — yours plus Bulisolio's — backs the smart contract loan that releases USDC to you.

In plain terms: Bulisolio is putting its own money at risk to get you a bigger or easier-to-access loan. If the loan goes wrong — if you don't pay and the collateral gets liquidated — Bulisolio may lose some of the capital it delegated. This is why delegated loans cost more (higher commission), require more scrutiny (Spectral score, EAS attestation), and require mandatory monthly payments.

Class 3 Full Delegation is the highest-risk loan class for Bulisolio because the user provides little or no collateral — Bulisolio's treasury backs the full amount. This is why Class 3 requires more conditions than any other class. See Section 6A for a full explanation of every Class 3 requirement and why each one exists.

The Delegation Reserve

Bulisolio maintains a Delegation Reserve — a dedicated portion of its treasury set aside specifically to back delegated loans. Think of it as Bulisolio's "co-signing fund." The reserve must stay above a minimum threshold (set by Bulisolio's risk management) before any Class 2/3/4 loan can be offered. When the reserve falls below that minimum, all delegated loan options are temporarily suspended across all users until the reserve is replenished. This is not a punishment — it is a financial safety mechanism.

The Escrow Contract

Every delegated loan (Classes 2, 3, 4) is protected by an additional layer: a Bulisolio Escrow Contract on the Base blockchain. This is a second smart contract, deployed alongside your primary lending protocol contract. Here is what it does:

• It records how much capital Bulisolio has delegated to your loan
• It tracks whether you are meeting your mandatory minimum payment obligations
• If you default (miss payments and cannot cure), it gives Bulisolio the legal and technical ability to initiate a unilateral close of the loan after a mandatory waiting period (timelock)
• The timelock gives you a cure window — time to make a payment and stop the close from happening

What Spectral Finance Is

For Classes 2, 3, and 4, underwriting uses an additional data source called Spectral Finance. Spectral is an on-chain credit scoring service. It looks at your public blockchain history — not your bank or FICO credit score — and gives you a score based on how you've used crypto loans and DeFi protocols in the past. A higher Spectral score means you've proven you handle on-chain loans responsibly.

Bulisolio uses the Spectral score as one input into your loan class assignment. You cannot fake a Spectral score — it reads directly from the blockchain. For Class 3, Spectral ≥ 650 is required — but it is only one of nine total requirements. Passing Spectral alone does not guarantee Class 3 eligibility.

What EAS Coinbase Verified Means

For Classes 3 and 4, you must have a Coinbase EAS Verification. EAS stands for "Ethereum Attestation Service." When you complete identity verification through Coinbase, they issue a cryptographic attestation — a tamper-proof stamp on the blockchain confirming your identity. Bulisolio reads this attestation to verify your identity has been confirmed by a regulated, trusted exchange. This is not the same as our own KYC — it is an additional layer for higher-risk delegated loans.

The Concierge Voice will guide you through getting a Coinbase EAS attestation if you need it for a Class 3 or 4 loan.

6 Who Can Get a Loan?

To get any Bulisolio loan, you must meet the base requirements below. Additional requirements apply per loan class (see Section 4 and Section 6A).

Additional Requirements by Class

Class	Trust Score	Spectral Score	Coinbase EAS	Other
1 · SC	Any (base gate)	Not required	Not required	100% collateral available in vault
2 · MB	≥ 600	≥ 550	Not required	Cover ≥ 40% of loan; HODL Gold or Diamond tier; delegation reserve above minimum
3 · FD	≥ 700	≥ 650	Required	Max $1,000; ≥ 1 repaid in-app SC loan; ≥ 6 continuous Premium months; no Class 3 in prior 12 months; minimum subscription revenue collected; market volatility CALM or ELEVATED only; delegation reserve above minimum. See Section 6A.
4 · LALoC	Any (Legend gate)	≥ 550	Required	Legend Affiliate (500+ active subscribers); Premium subscription; delegation reserve above minimum

Age Requirement

You must be at least 18 years old (or the age of majority in your country).

Geographic Restrictions

Bulisolio loans are not available to users in:

• Countries under US sanctions (North Korea, Iran, Syria, Cuba, Russia, Belarus)
• New York State, USA (BitLicense restrictions)
• Other jurisdictions where crypto lending is restricted at the time of your loan request

We check both your citizenship (from KYC) and your device GPS location at the time of each loan. If either fails the location check, the loan is declined and Concierge Voice will explain why.

6A Full Delegation (Class 3) — The Five Safeguards v3.0

Class 3 Full Delegation is unique among Bulisolio's loan products: Bulisolio provides most or all of the collateral and the user provides none. This means our treasury capital is fully at risk. Because of that, Class 3 requires more than a good on-chain credit score — it requires a demonstrated history of responsible in-app behavior that you build over time, inside the Bulisolio ecosystem.

There are five safeguards that must all be satisfied simultaneously before any Class 3 loan is offered. The Bulisolio app shows you your progress toward each safeguard in My Loans → Full Delegation Progress, and Concierge Voice can explain exactly where you stand and what to do next.

No single safeguard can be bypassed, waived, or substituted — all five must be met. These requirements apply in addition to the base eligibility requirements (Premium subscription, KYC, Coinbase EAS Verification, Spectral Score ≥ 650, Delegation Reserve above minimum, and market volatility being CALM or ELEVATED).

Why These Five Safeguards Exist

Each safeguard addresses a specific risk that is unique to the Class 3 model. Here is the plain-language reason behind each one:

Safeguard	The Risk It Addresses	What It Proves
1 · SC Graduation	A new user with no in-app loan history could pass an external credit check and immediately request a fully-funded $1,000 loan with no skin in the game.	You have put your own collateral at risk inside Bulisolio and paid it back. You understand how our loan system works. You have an in-app repayment record we can trust.
2 · Premium Tenure	Someone could subscribe for one month, qualify quickly, take a Class 3 loan for $1,000, and disappear — netting nearly $1,000 after subscription fees.	Six months of uninterrupted Premium payments demonstrates long-term intent and commitment. Any lapse in that period resets the clock, ensuring the tenure is genuine.
3 · Trust Score Floor of 700	Class 3 is the riskiest class for Bulisolio, but the original requirements allowed a lower Trust Score than Class 2. Higher risk should require higher — not lower — demonstrated trustworthiness.	A score of 700 reflects real in-app history: on-time payments, active loan months, holding behavior, and subscription longevity. An external Spectral score alone cannot substitute for this.
4 · Velocity Limit	After repaying a Class 3 loan, nothing would stop someone from immediately applying for another — repeatedly cycling through $1,000 FD loans and defaulting on some.	One Class 3 loan per rolling 12-month window ensures each loan represents a meaningful financial event, not a recurring exploit. It also gives the system time to observe repayment behavior before re-offering.
5 · Profitability Check	A user who subscribes for the first time and rapidly meets all other criteria could still request a Class 3 loan before Bulisolio has recovered any meaningful revenue from the relationship.	The minimum revenue threshold confirms the lending relationship is economically grounded. If you signed up recently and are racing to qualify, this gate fires as a final sanity check.

How the App Shows Your Progress

The Bulisolio app includes a Full Delegation Progress Tracker in the Loans section. It shows all five safeguards, your current status on each, and what specific action will move you forward. Concierge Voice can read this tracker aloud and answer questions about any step. You will never be left wondering why you don't yet qualify — the app tells you exactly what is needed and by when.

What the App Does When All Five Are Met

When all five safeguards are satisfied — and the other Class 3 requirements (Trust ≥ 700, Spectral ≥ 650, EAS Verified, Delegation Reserve above minimum, market CALM or ELEVATED) are also met — the Class 3 Full Delegation option becomes visible in the app. Until then, Class 3 is hidden from the loan request screen entirely. This is not an error. It means you are still working toward eligibility.

Concierge Voice will proactively notify you in the app the moment you become eligible, including a full explanation of your loan terms before you request anything.

7 The Loan Underwriting Engine

The Loan Underwriting Engine is the system that decides your loan class, your LTV limit, and the Concierge Commission rate you pay. Think of it as an automated underwriter — like a bank loan officer who runs calculations instead of using gut feelings.

What the Engine Does

The engine runs every time you request a loan or ask Concierge "How much can I borrow?" It evaluates nine different modules in sequence, producing a single loan decision that includes your class, terms, and a full breakdown of every factor used.

1. Loan Classification: Assigns you Class 1, 2, 3, 4, or Reject — including all five FD safeguard checks for Class 3
2. System Risk Check: Confirms Bulisolio's portfolio isn't overexposed before approving your loan
3. Trust Score Calculator: Computes your current Trust Score from all signals
4. HODL Index Evaluator: Measures your long-term holding behavior
5. Portfolio Size Multiplier: Scales your LTV based on total portfolio value
6. LTV Doctrine Resolver: Calculates your maximum LTV through six layers of rules
7. Max Loan Amount Calculator: Determines the most you can borrow
8. Commission Resolver: Sets your commission rate for this loan
9. Decision Output: Compiles everything into a single response delivered to the app and Concierge Voice — including a per-safeguard Class 3 eligibility breakdown when relevant

Why the Engine Protects You

The engine protects you from taking loans that are too risky for your situation — and it protects Bulisolio from losing delegation capital on loans that were never going to be repaid. It gives better terms to users who've proven they hold crypto long-term and pay their loans on time. The engine tries to find the safest loan you can realistically repay.

All Parameters Are Configurable

Every threshold, rate, and tier in the engine is stored in a configuration database — not hardcoded in the app. Bulisolio's risk management team can adjust these parameters to respond to changing market conditions. When parameters change, they apply to future loans only. Your existing loan terms are locked at the values in effect when you confirmed the loan.

8 Your Trust Score

Your Trust Score is a number that represents how trustworthy you are as a borrower. Higher scores unlock better loan terms and higher loan classes. The score is calculated entirely from your on-chain and in-app behavior — no external credit bureaus.

Trust Score Signals

Signal	Points	Notes
On-time loan payment	+50 per payment	Responding to Concierge payment prompts
Active loan month	+20 per month	Having an open, healthy contract
Full loan repayment	+100 per loan	Paying off a loan entirely — also satisfies Class 3 Safeguard 1 (SC Graduation)
Fast settlement	+50	Closing a loan in under 24 hours of final payment
HODL Index tier bonus	+0/+25/+50/+100	Bronze / Silver / Gold / Diamond (see Section 9)
Subscription longevity	+10 per month	Each month as a Premium subscriber — also contributes to Class 3 Safeguard 2 (tenure)
Affiliate Legend status	+200 (one-time)	Awarded when reaching Legend tier (500+ subscribers)
Coinbase EAS Verified	+50 (one-time)	On-chain identity attestation confirmed
Spectral MACRO contribution	+0 to +150	Scaled by Spectral score via engine configuration — contributes to score but cannot substitute for in-app behavioral signals required for Class 3
Missed payment (Class 1)	−100 per miss	Voluntary loan, lower penalty
Missed payment (Classes 2/3/4)	−200 per miss	Bulisolio capital at risk — double penalty
Liquidation event	−500	Never fully recoverable. Avoid at all costs.

Trust Score Tiers

Tier	Score Range	Class 1 Max LTV	Notes
Starter	0 – 749	~60%	New users; builds quickly with good behavior
Pro	750 – 1499	~70%	Established users with positive loan history
Elite	1500 – 2249	~75%	Long-term HODLers with multiple repaid loans
Legend	2250+	~80%	Highest trust; best terms; Legend Affiliate bonus possible

Trust Score Minimums by Loan Class

Different loan classes require different minimum Trust Scores. The minimums increase with the level of Bulisolio capital at risk:

• Class 1 (SC): No minimum score required — any Premium + KYC user with sufficient collateral qualifies
• Class 2 (MB): Trust Score ≥ 600 required
• Class 3 (FD): Trust Score ≥ 700 required — higher than Class 2 because Bulisolio bears more risk. A Spectral score from an external platform cannot substitute for the in-app behavioral signals that produce a Trust Score of 700. See Section 6A, Safeguard 3.
• Class 4 (LALoC): Eligibility is gated by Legend Affiliate status; Trust Score is an indirect contributor through the loan approval process

Your Trust Score alone does not guarantee any delegated loan — all class requirements must be met simultaneously.

9 The HODL Index

HODL is crypto slang for "hold" — don't sell your crypto even when prices drop. The HODL Index measures how well you hold. It is one of the most important factors in your Trust Score because long-term holders are statistically less likely to panic and default on loans during market downturns.

HODL Index Tiers

Tier	Behavior Pattern	Trust Score Bonus	Class 2 Impact
Bronze	Some selling; mixed history	+0	Does not qualify for MB
Silver	Mostly holding; limited transactions	+25	Does not qualify for MB
Gold	Strong holding pattern; rarely sells	+50	Qualifies for Class 2 MB
Diamond	Long-term holder; near-zero sell transactions	+100	Qualifies for Class 2 MB (best terms)

What Counts as "Selling" (Hurts Your HODL Index)

• Selling crypto for fiat (USD, EUR, etc.)
• Swapping one crypto for another (BTC → ETH)
• Moving crypto to an exchange to sell
• Any transaction that reduces your tracked portfolio value

What Does NOT Count (Does Not Hurt Your HODL Index)

• Spending USDC from your secure vault wallet (that's what loans are for)
• Making loan payments with USDC
• Transferring crypto to your Bulisolio secure vault on Base
• Moving crypto between your own wallets via WalletConnect
• Loan payment transactions of any amount or type

10 Location & Citizenship Data

Crypto lending is regulated differently in every country and some US states. To comply with applicable law, Bulisolio collects two types of location information at the time of every loan request.

1. GPS Location (Device-Level)

We collect your device's GPS coordinates when you open a loan request. We use this to confirm you are physically located in an allowed jurisdiction. We retain GPS data for 90 days for compliance auditing, then delete it.

2. Country of Citizenship (From KYC)

During KYC we record your country or countries of citizenship. This determines which regulatory framework applies to your loans. For dual citizens, we apply whichever country's rules are more restrictive.

We retain citizenship data for 7 years after account closure as required by anti-money-laundering (AML) laws. For delegated loans (Classes 2/3/4), KYC data is retained for the full duration of any outstanding loan plus 7 years, and for any loan that resulted in a default, for an extended period to support potential legal proceedings.

See our Privacy Policy for full details on data handling and your rights.

11 How Your Loan Limit Is Set (LTV)

Your maximum LTV is determined by a six-layer doctrine — the engine evaluates all six layers and takes the lowest result as your effective LTV. This protects you from taking on more risk than is safe given all current conditions.

The Six LTV Layers

Layer	Name	What It Does
0	Delegation Class Penalty	Class 1: no deduction. Class 2 (MB): deducted by delegation ratio × 10%. Class 3 (FD): flat −15%. Class 4 (LALoC): delegation ratio × 8%. This reflects the additional risk Bulisolio takes on when co-signing.
1	Admin Emergency Override	Bulisolio can lower maximum LTV across all loans instantly in an emergency (flash crash, protocol exploit). Trumps all other layers.
2	Market Volatility Discount	The engine monitors the Crypto Fear & Greed Index and real-time price volatility. Higher volatility → lower LTV. See Section 12.
3	Asset-Specific Cap	ETH and cbBTC may have different LTV ceilings due to their individual volatility profiles and smart contract protocol limits.
4	Trust Tier Soft Cap	Your Trust Score tier sets the maximum LTV your loan history has earned (see Section 8 table). Higher trust = higher soft cap.
5	Protocol Hard Cap − 5% Buffer	The lending protocol (Aave v3, Compound v3) sets an absolute maximum. Bulisolio always stays 5% below that limit as a safety cushion against sudden price moves.

Confused? That's okay — Concierge Voice handles all this math for you. Just ask "How much can I borrow?" and Concierge gives you the answer in plain language with a full breakdown available on request.

12 Market Conditions & Volatility

Crypto prices can move fast. The engine monitors market conditions continuously and adjusts loan terms in real time to protect both you and Bulisolio.

Volatility Regimes

Regime	Conditions	LTV Impact	Class 3 Availability
CALM	Stable prices, low daily swings	No deduction	Available
ELEVATED	Normal market activity, ±5% daily	Small deduction	Available
HIGH	Significant price swings, ±10% daily	Moderate deduction	Suspended
EXTREME	Market crash, major exploit, regulatory ban	Large deduction	Suspended

Class 3 Full Delegation is only available during CALM and ELEVATED volatility regimes. This is because the risk of delegated capital loss increases significantly when markets are in HIGH or EXTREME states. If you satisfy all five FD safeguards but markets are in a HIGH or EXTREME regime at the time of your request, Class 3 will not be offered until conditions improve. The app will show you the current regime and estimated return to eligibility when possible.

The Fear & Greed Index

The engine also incorporates the Crypto Fear & Greed Index — a daily market sentiment score ranging from 0 (Extreme Fear) to 100 (Extreme Greed). During Extreme Greed periods, commission rates may be slightly lower because markets are stable. During Extreme Fear periods, commission rates for Class 4 (LALoC) increase slightly because market instability raises the risk of delegated capital loss. This adjustment is part of the Class 4 dynamic commission formula (see Section 15).

13 Mandatory Minimum Payments (Classes 2, 3, 4)

If you are on a delegated loan (Class 2, 3, or 4), you are required to make mandatory minimum monthly payments. This is fundamentally different from Class 1 loans, where payments are voluntary (though always encouraged).

Why Delegated Loans Require Mandatory Payments

When Bulisolio co-signs your loan with its own capital, it takes on real financial risk. If the value of the collateral drops and you haven't been making payments, the smart contract may liquidate before Bulisolio can recover its delegated capital. Mandatory minimum payments ensure that the loan balance decreases over time and that your health factor stays in a safe range — protecting both your collateral and Bulisolio's capital.

How the Minimum Payment Is Calculated

Your minimum monthly payment has two parts:

1. Monthly Interest: The interest the lending protocol charges on your outstanding loan balance (this is paid to the protocol's liquidity providers, not to Bulisolio)
2. Health Factor Component: An additional principal repayment amount designed to bring your loan's health factor back above a safe target threshold, amortized over a 12-month window

Concierge Voice shows you your exact minimum payment amount inside the app, updated every day. You can always pay more than the minimum — and doing so improves your health factor and Trust Score.

What Happens If You Miss a Payment

The Cure Window

If you miss a payment, the escrow contract starts a cure window — a period during which you can make the overdue payment and restore your loan to good standing. Making the payment during the cure window closes the incident without escrow escalation. If the cure window expires without payment, Bulisolio may initiate the unilateral close process described in Section 5. Concierge Voice will notify you urgently at every stage and tell you exactly how much you need to pay and by when.

Making Payments

Concierge Voice can initiate payments directly from USDC in your secure vault wallet. You can also make payments manually through the Loans section of the app. Payments are processed on-chain and confirmed within minutes.

14 Legend Affiliate Benefits

Bulisolio's Affiliate Program rewards top-performing affiliates with enhanced loan benefits. If you are a Legend-tier affiliate (500+ active referred subscribers) and a Premium subscriber who has completed KYC, you qualify for two distinct benefits.

Benefit 1: Enhanced LTV Terms

Legend affiliates automatically receive the highest LTV underwriting can safely offer — 5% below the smart contract's protocol limit. This applies even if your Trust Score alone would produce a lower LTV. The delegation class penalties (Layer 0 of LTV doctrine) still apply for any delegated components. Only extreme market conditions (EXTREME volatility regime) can lower a Legend affiliate's LTV.

Benefit 2: The LALoC (Class 4 Line of Credit)

Legend affiliates who also hold a Coinbase EAS Verification and meet the Trust Score requirements are eligible for a Legend Affiliate Line of Credit (LALoC) — a revolving credit line on Base, not a one-time loan.

How it works:

• You receive an approved credit limit (up to $50,000, scaled by your affiliate subscriber count)
• You "draw" against the credit line whenever you need funds — each draw creates a new smart contract interaction
• You repay draws over time, and the credit becomes available again (revolving)
• Each draw has its own dynamic commission (see Section 15) and mandatory minimum payment
• Your credit limit scales with your active subscriber count as your affiliate business grows

LALoC Credit Limit Formula

Your LALoC credit limit scales between a minimum anchor ($1,000 at 500 subscribers) and a maximum anchor ($50,000 at or above a configured upper subscriber threshold). The formula uses a square-root scaling curve so that early growth in subscribers produces faster credit limit increases, while very large subscriber counts produce diminishing marginal returns. Exact parameters are configurable by Bulisolio's risk management and may change.

Requirements to Maintain Benefits

1. Active Legend Affiliate status (500+ active subscribers)
2. Active Premium subscription
3. Completed KYC verification
4. Coinbase EAS Verification (for LALoC)
5. No outstanding payment delinquencies

If you drop below 500 active referrals or cancel Premium, the enhanced LTV reverts to your Trust Score baseline and no new LALoC draws are permitted until restored. Existing draws remain active under their original terms until repaid.

15 Concierge Commission

When you take out a loan through Bulisolio, we charge a one-time fee called the Concierge Commission. This is deducted from your loan proceeds at the time the loan is funded. It is not an ongoing interest charge — the smart contract's interest (APR) is separate and goes to the protocol's liquidity providers, not to Bulisolio.

Commission Is Class-Based

Commission rates differ significantly by loan class because the amount of risk Bulisolio takes on differs significantly. Class 1 loans put none of Bulisolio's capital at risk — Class 2/3/4 loans put real treasury capital at risk. This is reflected in the rate structure:

Loan Class	Commission Floor	Rate Formula	Direction
Class 1 · SC	0.25% (floor)	Floor + trust adjustment upward. Higher trust score = potentially lower rate above the floor. No market variable component.	Better trust → lower rate
Class 2 · MB	3.0% (floor)	Floor + (delegation ratio × delegation premium) + trust uplift. The higher the percentage of the loan Bulisolio co-signs, the higher the commission above 3.0%.	More delegation → higher rate
Class 3 · FD	3.0% (floor)	3.0% flat rate + small trust-based uplift only. No delegation ratio component because the delegation is full.	Relatively flat; trust adjusts slightly
Class 4 · LALoC	3.0% per draw (floor)	Three-layer dynamic formula per draw: base rate (scaled by credit limit size) + Fear & Greed Index premium + volatility regime premium. Result must be ≥ 3.0% floor.	Market conditions drive rate daily

The Commission Includes No Hidden Fees

The Concierge Commission is Bulisolio's only fee. There are no application fees, processing fees, early repayment penalties, or monthly account fees. However, be aware that:

• The lending protocol charges interest (APR) on your borrowed USDC — this goes to the protocol's liquidity providers, not to Bulisolio
• The Base network charges gas fees for blockchain transactions — these are separate from commission and are shown before confirmation
• For delegated loans, Bulisolio deploys an escrow contract — the gas cost of deploying this contract is disclosed at origination

What Your Commission Funds

Concierge Commission revenue is used to fund: AI inference costs (Gemini and Claude APIs for Concierge Voice), blockchain gas fees, KYC verification services, security audits and monitoring, the Affiliate Commission Rebate Pool (a portion), customer support, and ongoing app development.

16 Your Loan Terms Summary

Before you confirm any loan, Bulisolio shows you a complete terms summary screen. You must scroll through and acknowledge this screen. The loan does not execute until you confirm.

What You'll See

Bilingual Display

If your app is set to a non-English language, all key numbers and terms are shown in both your language and English side-by-side. All loan records are stored permanently in English for audit and legal compliance.

Permanent Record

Every loan's complete terms are stored in your account. Go to My Loans → Loan History → tap any loan for its full terms summary.

17 Your Rights

Right to Clear Information

You will always see full loan terms before confirming. We will never hide fees or surprise you with unexpected charges.

Right to Cancel Before Confirmation

You can cancel a loan quote at any time before tapping "Confirm Loan" with no penalty. The quote screen stays open for 5 minutes — ask Concierge Voice any questions during this time.

Right to Repay Early

You may repay your loan in full at any time. There is no Bulisolio early repayment penalty. The smart contract may still charge interest up to the repayment date — this is a protocol charge, not a Bulisolio fee. For delegated loans, full early repayment closes the escrow contract and releases all delegated capital.

Right to Know Your Score

Your Trust Score, Trust Tier, HODL Index, Spectral score reference (where applicable), and all contributing factors are visible at any time in the app: My Loans → Trust Score.

Right to Know Your Full Delegation Progress

Your progress toward Class 3 Full Delegation eligibility — across all five safeguards — is visible at any time in the app: My Loans → Full Delegation Progress. Concierge Voice can explain your current status on any safeguard and tell you what actions will move you forward. This is available to all Premium subscribers regardless of current Trust Score or loan history.

Right to Know Your Loan Class and Why

The engine's decision output is fully disclosed. You can see exactly which class you were assigned and which specific requirements were or were not met — including which of the five FD safeguards you do or do not currently satisfy. Concierge Voice can walk through this with you step by step.

Right to Ask Questions

Concierge Voice Education Mode is available 24/7. You can also email loans@bulisolio.com.

Right to Dispute Automated Decisions

If you believe the engine made an error — including an incorrect determination that you do not meet one or more of the five FD safeguards — email loans@bulisolio.com with your account details and explanation. We will respond within 14 business days.

Right to Data Access

Under GDPR (Europe) and CCPA (California), you may request a copy of your data, request corrections, or request deletion (with exceptions for AML compliance). See our Privacy Policy.

18 Important Disclaimers & Warnings

19 Contact Us

If you have questions about this disclosure, your loan terms, your loan class assignment, or your Class 3 eligibility progress, we offer multiple support channels:

Other Channels

• Email (Loan Questions): loans@bulisolio.com — 24–48 hour response
• Email (General Support): support@bulisolio.com
• Education Questions: education@bulisolio.com
• Feedback on This Document: feedback@bulisolio.com
• Mail: Bulisolio LLC, Salt Lake City, Utah, USA

Is something in this document confusing? Tell us. We update this disclosure regularly based on user feedback and evolving regulatory guidance. Our goal is complete transparency — if a section is unclear, that's a problem we want to fix.