Legal

Risk Disclosures

Last Updated: January 26, 2026

⚠️ Important: Please Read Before Using Trebanx

Trebanx is not a bank. Member-to-member lending involves risk of loss. You could lose some or all of your funds. Only participate with money you can afford to lose and people you trust.

This document contains important information about the risks associated with using the Trebanx platform. Please read this entire document carefully before creating an account, joining a Circle, or making any contributions.

Important Warning

PARTICIPATING IN CIRCLES INVOLVES SUBSTANTIAL RISK OF LOSS. YOU SHOULD ONLY CONTRIBUTE FUNDS THAT YOU CAN AFFORD TO LOSE ENTIRELY.

Trebanx facilitates member-to-member lending, where individuals lend money directly to other individuals. Unlike bank deposits, funds contributed to Circles are not insured and may not be recoverable if borrowers default.

1. Platform Status

Trebanx is currently in Early Access Beta. This means:

  • Features and functionality may change without notice
  • Service interruptions may occur
  • The platform may be discontinued at any time
  • Some features may not be fully tested
  • Bugs and errors may affect your experience or transactions

2. Trebanx Is Not a Bank

Trebanx is a technology platform, NOT a bank, lender, or financial institution.

This means Trebanx does NOT:

  • Accept deposits
  • Make loans or lending decisions
  • Pay interest on accounts
  • Issue credit or debit cards
  • Provide investment advice
  • Guarantee any returns or repayments
  • Insure your funds
  • Collect debts on your behalf

We provide software tools that help groups of individuals organize their own lending activities. All lending decisions are made by Circle members, not by Trebanx.

3. Member-to-Member Lending Risks

When you participate in a Circle, you are lending money directly to other members. Key risks include:

Default Risk

  • Borrowers may fail to repay their loans
  • You may lose some or all of your contributed funds if defaults occur
  • There is no guarantee of any return on your contributions
  • Past repayment performance does not guarantee future results

Liquidity Risk

  • Your funds may be locked for the duration of loan terms
  • You may not be able to withdraw funds on demand
  • Circle rules may restrict when and how you can exit

Concentration Risk

  • Circles have limited members, increasing exposure to individual defaults
  • A single default can significantly impact your returns

4. No Guarantees

Trebanx makes NO guarantees regarding:

  • Repayment of any loans
  • Return of your contributions
  • Interest earnings or any particular rate of return
  • The creditworthiness of other Circle members
  • The accuracy of information provided by members
  • The enforceability of Circle agreements
  • The outcome of any disputes between members

All transactions between Circle members are at your own risk.

5. Regulatory Status

Trebanx operates as a technology service provider. We are not:

  • A bank or depository institution
  • A licensed money transmitter (we use licensed partners)
  • A registered investment advisor
  • A securities broker or dealer
  • A credit union or savings and loan

While we maintain compliance programs and work with regulated partners, the regulatory landscape for peer-to-peer lending is evolving. Changes in laws or regulations could affect our ability to operate or the features available to you.

6. FDIC Insurance

Funds in active Circles are member contributions and are NOT FDIC insured.

Understanding FDIC coverage:

  • Active Circle funds: NOT insured. These are member-to-member loans, not bank deposits.
  • Funds held with banking partners: May be eligible for pass-through FDIC insurance up to applicable limits ($250,000 per depositor per institution).
  • In-transit funds: Coverage depends on their status in the transfer process.

7. Tax Obligations

You are responsible for understanding and fulfilling your tax obligations:

  • Interest earned from Circle lending may be taxable income
  • Trebanx may report earnings to the IRS (Form 1099-INT or 1099-MISC)
  • You may need to report Circle activities on your tax returns
  • Losses may or may not be deductible depending on circumstances
  • Tax treatment of defaults and write-offs varies

Trebanx does not provide tax advice. Consult a qualified tax professional for guidance on your specific situation.

8. Circle Governance

Each Circle sets its own rules, which may include:

  • Contribution amounts and schedules
  • Loan approval processes
  • APR (interest rates) and fees
  • Default handling procedures
  • Membership requirements

Governance risks include:

  • Circle rules may be changed by majority vote
  • Disputes between members may be difficult to resolve
  • Trebanx does not enforce Circle rules or mediate disputes
  • Circle agreements may not be legally enforceable depending on jurisdiction

9. Technology Risks

Using the Platform involves technology risks:

  • System outages may prevent access to your account or funds
  • Software bugs may result in errors in transactions or balances
  • Cyberattacks may compromise security
  • Data loss could occur despite backup systems
  • Third-party service failures may affect Platform operations
  • Internet connectivity issues may disrupt access

10. Fraud & Security Risks

Despite our security measures, risks remain:

  • Other members may misrepresent their identity or intentions
  • Account credentials may be compromised
  • Phishing or social engineering attacks may target users
  • Circle organizers may act in bad faith

If you suspect fraud, report it immediately to fraud@trebanx.com.

11. Dispute Resolution

Trebanx provides tools for transparency but does not:

  • Mediate disputes between Circle members
  • Collect debts or enforce repayment
  • Provide legal representation
  • Guarantee any particular dispute outcome

If you have a dispute with another member, you should first attempt to resolve it within your Circle. For unresolved disputes, you may need to seek legal remedies independently. Contact support@trebanx.com for available mediation tools.

12. Acknowledgment

By using the Trebanx platform, you acknowledge that:

  • You have read and understood these Risk Disclosures
  • You understand the risks of member-to-member lending
  • You are participating voluntarily with funds you can afford to lose
  • You will not hold Trebanx liable for losses resulting from Circle activities
  • You have had the opportunity to consult with financial, legal, and tax advisors

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