This document provides a summary of the legal nature, regulatory positioning, and compliance framework applicable to Tontine Trust Europe KB (“Tontine Trust”) and the trust structures it administers, including discretionary Tontine Trust Funds.

This page should be read together with the Legal & Regulatory section of this site.

For avoidance of doubt, Tontine Trust provides fiduciary and administrative trust services only.

Tontine Trust Funds are not investment products, collective investment schemes, insurance contracts, or annuities, and no investment or insurance services are provided.

Executive Summary

Tontine Trust provides fiduciary and administrative services only. Discretionary Tontine Trust Funds are individual irrevocable trusts with shared beneficiary arrangements administered under trust law. They are not investment products, collective investment schemes, or regulated financial instruments. Trustees act within the legal and fiduciary parameters of the trust deed; all asset selection and weighting decisions

Regulatory Characterisation for Banks and Custodians

For bank onboarding and counterparty classification purposes, Tontine Trust Europe KB acts as the fiduciary trust company and primary contractual counterparty.

Tontine Trust Funds should be understood as trust-administered asset arrangements operated by a single trust company, rather than as investment products, funds, or pooled vehicles.

They do not constitute:

• investment products or investment funds;
• collective investment schemes; or
• insurance or annuity products.

Assets are administered by Tontine Trust in its fiduciary capacity and are allocated to individual trust relationships in accordance with trust documentation.
Assets are not pooled, and no collective portfolio is managed for shared investment return.

No party manages assets for collective investment return, underwrites longevity risk, or provides guaranteed outcomes.

1. Trust Company Overview

Tontine Trust is a Swedish fiduciary service provider offering trust administration and fiduciary services only.

Tontine Trust does not:

• Carry on regulated investment business
• Provide investment, financial, or securities advice
• Act as a broker, dealer, or investment adviser
• Manage assets for investment purposes
• Pool client assets for collective investment
• Guarantee returns, income, or performance

All services are provided pursuant to applicable trust law in the relevant jurisdiction.

2. Nature of Trust Structures Administered
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2.1 General Trust Structures

Tontine Trust administers:

• Individual discretionary trusts
• Established by settlors for estate planning, succession, or administrative purposes
• Governed by bespoke trust deeds

Tontine Trust acts as trustee and administrator, with legal and fiduciary discretion in accordance with the trust deed.
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2.2 Tontine Trust Fund Structure (Technical Description)

A Tontine Trust Fund is a discretionary, individual irrevocable trust with shared beneficiary arrangements across a defined population of similar trusts.

Each Tontine Trust Fund:

• Has its own trust property, deed, and settlor
• Administers beneficiaries according to trust deed provisions
• Redistributes beneficial interests solely in accordance with the trust deed

Certain beneficiary interests are defined by reference to standardized provisions across multiple trusts. At no point are assets:

• Commingled for investment purposes
• Managed collectively
• Subject to discretionary investment decision-making by Tontine Trust

3. Regulatory Classification (Key Negative Assertions)

Tontine Trust confirms that Tontine Trust Funds are not:

• Collective Investment Schemes (UK FSMA)
• Alternative Investment Funds (EU AIFMD)
• Regulated investment products
• Pension schemes, annuities, or insurance contracts
• Deposit-taking products
• Securities or derivatives

Tontine Trust does not perform any activity requiring registration or authorisation as an investment firm, broker-dealer, or investment adviser.

4. UK Regulatory Position

For UK-related activity:

• Tontine Trust is not authorised or regulated by the UK Financial Conduct Authority (FCA)
• Activities do not constitute:
• Regulated activities under FSMA 2000
• Financial promotions within the meaning of section 21 FSMA
• Tontine Trust Funds are structured and administered as private discretionary trust law arrangements

Tontine Trust does not market or distribute regulated financial products in or from the United Kingdom. Independent legal, tax, or FCA-authorised financial advice is recommended for UK persons considering participation.

5. EU Regulatory Position

For EU-related activity:

• Services provided fall outside:
• MiFID II
• AIFMD
• No portfolio management, investment advice, or securities services are provided
• Trust administration is conducted on a non-advised, discretionary fiduciary basis

Regulatory treatment of trusts may vary by member state.

6. United States Regulatory Position

For U.S.-related activity:

• Tontine Trust is not a U.S. bank, broker-dealer, or registered investment adviser
• No securities are offered, sold, or solicited
• No investment advisory services are provided to U.S. persons
• Marketing and referral activity is limited to commercial introductions only and is subject to applicable consumer-protection and anti-fraud laws

7. Referral and Introducer Arrangements

Tontine Trust may operate referral or introducer programmes under which:

• Compensation is a flat, fixed fee
• Compensation is not:
• Asset-based
• Performance-based
• Recurring
• Referrers:
• Act solely as introducers
• Do not provide advice
• Do not explain trust mechanics beyond high-level descriptions
• Do not influence asset placement or funding

Referral arrangements are structured to avoid brokerage, advisory, or solicitation activity.

8. Asset Handling and Investment Activity (Discretionary Trusts)

Tontine Trust acts as trustee and administrator of discretionary trusts. It does not provide investment advice or manage assets for investment purposes.

Specifically:

• Tontine Trust does not recommend specific assets or investment strategies
• Asset eligibility is limited to a predefined list of supported asset types, established for administrative, operational, and compliance reasons
• The settlor may specify assets and weightings criteria; Tontine Trust administers these instructions
• Rebalancing or adjustment of assets occurs according to weighting criteria requested by the settlor
• Trustees retain discretion only to execute the trust deed in accordance with settlor instructions and applicable law

9. Illustrations, Models, and Estimates

Any illustrations or estimates provided to clients are:

• Explanatory only
• Hypothetical
• Non-binding
• Not guarantees or projections

10. AML, KYC, and Compliance Framework

Tontine Trust maintains:

• Client due diligence and enhanced due diligence procedures
• Anti-money laundering and counter-terrorist financing controls
• Sanctions screening
• Ongoing monitoring consistent with applicable law

11. Jurisdictional Variability

12. Governing Law