Terms of Service

By accessing or using the Broker Dealer Management Platform (“BDMP,” “the Platform”), you agree to be bound by these Terms of Service. If you are using BDMP on behalf of a broker-dealer firm, you represent that you have authority to bind that firm to these terms.

BDMP is a multi-tenant compliance operating system designed for FINRA-registered broker-dealer firms. The Platform provides:

• Regulatory compliance management and surveillance tools
• AI-powered compliance analysis and monitoring
• Immutable audit trail and record-keeping infrastructure
• Supervisory review and approval workflows
• Communications surveillance and archival
• AML/BSA compliance screening and reporting
• Regulatory filing preparation and tracking

Access to BDMP requires an authorized account provisioned by a subscribing broker-dealer firm. You agree to:

• Provide accurate and complete registration information
• Maintain the security of your authentication credentials
• Enable multi-factor authentication when required by your role (mandatory for CCO, BD Principal, and System Administrator roles)
• Notify your firm administrator immediately if you suspect unauthorized access
• Not share your credentials with any other person

You agree to use BDMP only for:

• Legitimate compliance and regulatory activities within the scope of your role and permissions
• Accessing data only within your authorized broker-dealer tenant
• Activities consistent with applicable FINRA and SEC regulations

You agree not to:

• Attempt to access data belonging to other broker-dealer tenants
• Circumvent or interfere with platform security controls
• Tamper with or attempt to modify immutable audit records
• Reverse-engineer, decompile, or disassemble any part of the Platform
• Use the Platform for any activity prohibited by law or regulation
• Use automated tools to scrape, harvest, or extract data from the Platform without authorization

Each broker-dealer firm (“tenant”) retains full ownership of its data stored within BDMP. Tenant data is isolated through multiple security layers including database-level row security and application-level access controls.

BDMP does not access, analyze, or share tenant data across firm boundaries except as required by law or regulation.

BDMP is designed to assist broker-dealer firms with regulatory compliance but does not guarantee compliance with any specific regulation. Users are responsible for:

• Ensuring their use of BDMP satisfies their firm's specific regulatory obligations
• Maintaining independent compliance oversight beyond automated platform features
• Reviewing and validating AI-generated compliance analysis before taking action
• Ensuring appropriate supervisory review of all platform-generated reports and alerts

BDMP maintains an immutable audit trail of all actions taken within the Platform, in compliance with SEC Rule 17a-4. Users acknowledge that:

• All actions within the Platform are logged and cannot be deleted
• Audit records are retained for a minimum of 6 years
• Audit logs may be produced in response to regulatory examinations or legal process
• Attempting to circumvent audit logging is a violation of these terms

BDMP incorporates AI-powered features for compliance analysis, surveillance scoring, and regulatory assistance. Users acknowledge that:

• AI-generated outputs are advisory and require human review
• AI features do not constitute legal, regulatory, or compliance advice
• Final decisions on compliance matters must be made by qualified personnel
• AI models process data within AWS infrastructure and do not share tenant data externally

We strive to maintain high availability but do not guarantee uninterrupted access. Planned maintenance windows will be communicated in advance. We are not liable for service interruptions caused by:

• Third-party infrastructure failures (AWS, DNS providers)
• Force majeure events
• Scheduled maintenance performed during communicated windows
• Actions by regulatory authorities

BDMP subscription fees are governed by the separate Master Services Agreement between BDMP and each subscribing broker-dealer firm. Individual users are not directly responsible for platform fees unless otherwise specified in their firm's agreement.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, BDMP SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES ARISING FROM YOUR USE OF THE PLATFORM, INCLUDING BUT NOT LIMITED TO REGULATORY PENALTIES, FINES, OR SANCTIONS IMPOSED BY FINRA, SEC, OR OTHER REGULATORY BODIES.

BDMP's total liability under these terms shall not exceed the fees paid by your broker-dealer firm in the twelve (12) months preceding the claim.

You agree to indemnify and hold harmless BDMP and its officers, directors, employees, and agents from any claims arising from your violation of these terms, misuse of the Platform, or failure to comply with applicable regulations.

We may suspend or terminate your access to BDMP for violation of these terms, at the direction of your broker-dealer firm, or as required by law. Upon termination:

• Audit records and compliance data will be retained per regulatory requirements
• Your firm may request export of its data in a standard format
• Access credentials will be revoked and sessions terminated

These Terms of Service are governed by the laws of the State of Delaware, without regard to conflict of law principles. Any disputes shall be resolved in the federal or state courts located in Delaware.

We may modify these terms with 30 days' notice through the Platform. Continued use after the effective date of changes constitutes acceptance. Material changes will be communicated to firm administrators via email.

To withdraw consent for data processing, contact your firm administrator to request account deactivation. Upon deactivation, access is revoked and future processing ceases. Historical audit records are retained per SEC Rule 17a-4 (minimum 6 years).

For questions about these terms:

• Email: admin@brokerdealermanagementplatform.com
• Mail: Broker Dealer Management Platform, Attn: Legal, [Address TBD]