TERMS OF SERVICE

1. INTRODUCTION, ALIGNMENT, AND NATURE OF PROGRAM

1.1 Parties

These Terms of Service and Engagement Conditions (“Terms”) govern the services provided by Frontier Capital Trust, together with its operating affiliates, including Frontier Capital Services LLC (collectively, “FCT,” “we,” “us,” or “our”), to the person or entity engaging such services (“Client,” “you,” or “your”).

1.2 Mission Alignment

FCT operates in alignment with the broader charitable, religious, and educational mission of Father Christ Ministries Trust, a religious and charitable trust. FCT’s activities are intended to support a broader framework of stewardship, fiduciary order, charitable responsibility, family continuity, and disciplined administration.

FCT’s services are offered within what we describe as a Christian Fiduciary Stewardship Program. This Program is intended to be primarily religious, charitable, and educational in character, with any fee-based component secondary and supportive of that broader mission.

1.3 Disclosure Only; No Tax-Status Conclusion

Any references in these Terms to stewardship, charitable purpose, educational purpose, ministry alignment, or Christian fiduciary character are descriptive of FCT’s values, intent, and programmatic orientation only. Nothing in these Terms shall be construed as a legal or tax opinion regarding:

  • church status,

  • integrated auxiliary treatment,

  • § 508(c)(1)(A),

  • tax exemption,

  • unrelated business income, or

  • any related federal or state classification.

Any such matters must be determined solely by qualified legal and tax counsel based on the full facts and circumstances.

1.4 Program Character

The purpose of the Program is to assist clients in organizing, documenting, and administering private fiduciary structures and related systems in a manner consistent with responsible stewardship, lawful operation, family continuity, and charitable responsibility. The Program is intended to include not only technical and administrative assistance, but also stewardship-oriented education, structure, and discipline.

1.5 Continuity of Services

Certain services now provided under these Terms were, prior to the formalization of Frontier Capital Services LLC, conducted through Father Christ Ministries Trust and/or under the name Frontier Capital Trust. These Terms are intended to reflect continuity of those administrative and stewardship-oriented services through the current operating structure.

2. CAPACITY, PROFESSIONAL LIMITS, AND RELIANCE ON LICENSED ADVISORS

2.1 Non-Legal, Non-CPA, Non-Fiduciary Capacity

FCT is not a law firm, CPA firm, registered investment adviser, broker-dealer, or licensed corporate trustee. Unless separately and lawfully engaged through an appropriately licensed professional, FCT does not provide:

  • legal advice or legal opinions;

  • tax advice or tax opinions;

  • legal drafting of governing instruments;

  • preparation or signing of tax returns;

  • securities or investment advice;

  • formal fiduciary services as trustee, co-trustee, protector, signatory, or attorney-in-fact.

2.2 Advisor Reliance

The Client acknowledges that all legal and tax determinations must be made by the Client’s independent licensed attorney and certified public accountant (“CPA”). FCT’s materials, templates, frameworks, and programmatic guidance are educational and administrative and are not a substitute for legal or tax advice.

2.3 Condition of Proper Use

The Client agrees that no legal, tax, or filing decision shall be implemented solely on the basis of FCT materials without review by the Client’s independent licensed professionals.

3. SCOPE OF SERVICES

3.1 Included Services

Subject to the Engagement Letter and these Terms, FCT may provide some or all of the following services within the Christian Fiduciary Stewardship Program:

a. Discovery and Exposure Review

  • Review of current structural, administrative, and fiduciary arrangements;

  • Identification of inefficiencies, governance gaps, risk points, and documentation deficiencies;

  • Preparation of a high-level stewardship and administrative summary.

b. Fiduciary Architecture Design (Educational)

  • Educational presentation of proposed private trust, entity, or governance arrangements for review by the Client and the Client’s counsel;

  • Explanation of structural flows involving governance, accounting, fiduciary administration, and charitable overlays.

c. Governance and Administrative Systems

  • Preparation of non-binding administrative templates, including resolutions, administrative minutes, policies, checklists, and workflow materials for attorney review and adaptation;

  • Development of compliance, governance, and audit-readiness procedures.

d. Trust Accounting Administration Support

  • Development and maintenance support for fiduciary ledgers and administrative accounting systems;

  • Support for classification and organization of trust receipts, disbursements, principal, and income entries;

  • Administrative assistance with annual reconciliation, supporting schedules, and documentation organization for CPA review.

e. Stewardship Education and Formation

  • Educational materials and stewardship-oriented guidance concerning family continuity, charitable responsibility, fiduciary discipline, and administrative order;

  • Support in integrating stewardship-oriented and charitable considerations into trust administration.

f. Coordination with Client’s Advisors

  • Administrative coordination with the Client’s independent attorney and CPA to align administrative procedures, accounting workflows, and governance materials with the approved legal structure;

  • Assistance in translating approved legal structures into operating administrative systems.

g. Ongoing Annual Stewardship Services (if elected)

  • Ongoing trust accounting administration support;

  • Ledger maintenance and record organization;

  • Governance file maintenance and annual compliance organization;

  • Preparation of audit-ready administrative records for use by the Client’s CPA and legal counsel;

  • Updates to procedures, templates, and stewardship documentation.

3.2 Excluded Services

FCT does not provide:

  • legal drafting or legal execution of governing instruments;

  • tax return preparation or tax representation;

  • legal or tax interpretation;

  • formal trustee or fiduciary service;

  • public accounting attest services;

  • litigation or representation before courts or agencies.

4. PRIMARY PROGRAM CHARACTER; SECONDARY REVENUE CHARACTER

4.1 Primary Character

The parties acknowledge that FCT’s services are intended to form part of a broader Christian Fiduciary Stewardship Program and are intended to be primarily educational, charitable, and religious in character, with a focus on stewardship formation, fiduciary order, family continuity, and responsible governance.

4.2 Secondary Revenue Character

To the extent fees are charged, the parties acknowledge that such fees are intended to support, sustain, and administer the Program and its operations, and are not intended to define the Program as a stand-alone secular commercial enterprise.

5. CLIENT REPRESENTATIONS AND RESPONSIBILITIES

The Client represents, warrants, and agrees that:

  1. All information supplied to FCT is true, accurate, and complete to the best of the Client’s knowledge.

  2. The Client has authority to engage FCT and to provide any documents or information necessary for the engagement.

  3. The Client will promptly disclose any fact, change, relationship, liability, or structural circumstance that could affect the administrative or fiduciary work.

  4. The Client will retain independent legal counsel and a CPA for all legal and tax matters.

  5. The Client will not rely upon FCT as a substitute for licensed legal or tax professionals.

  6. The Client will maintain all source records, receipts, statements, and relevant documentation necessary for trust administration, tax review, and compliance.

  7. The Client will cooperate in a timely manner with requests for information, document review, and implementation steps.

6. DELIVERABLES

Depending on the scope of the engagement, FCT may provide one or more of the following:

  • Fiduciary Architecture Design Memorandum

  • Governance and Administrative Framework Package

  • Trust Accounting Administration Framework

  • Fiduciary Accounting & Tax-Reporting Manual

  • Data Protection & Record-Retention Policy

  • Resolution and Governance Template Suite

  • Annual Compliance & Reconciliation Tools

  • Stewardship-oriented educational and administrative materials

All deliverables are educational, organizational, and administrative in character and must be reviewed and approved by the Client’s attorney and CPA before legal or tax implementation.

7. FEES, BILLING, AND NO-USURY POLICY

7.1 One-Time Architecture and Administrative Fee

A one-time fee applies for the design, development, and administrative activation of the fiduciary framework. The specific amount applicable to the Client, together with any prior credits or payments, shall be set forth in the applicable Engagement Letter and/or invoice, which is incorporated by reference into these Terms.

7.2 Annual Fiduciary Stewardship Fee

If elected by the Client, annual stewardship services shall be billed in accordance with the Engagement Letter, which may include a percentage-based stewardship fee tied to verified annual efficiency savings, as determined in coordination with the Client’s CPA or other qualified tax professional.

7.3 Scope of Annual Stewardship

Annual stewardship services may include:

  • ongoing trust accounting administration;

  • maintenance of fiduciary ledgers and accounting records;

  • reconciliation support;

  • governance file maintenance;

  • audit-ready documentation assembly;

  • administrative support for the Client’s CPA and legal counsel.

7.4 Payment Terms

Invoices are payable within the period stated in the applicable invoice or Engagement Letter.

7.5 No Interest, Penalties, or Usury

FCT does not charge interest, penalties, late fees, or any form of usury on overdue amounts.

7.6 Third-Party Costs

Attorney, CPA, valuation, filing, banking, technology, and other third-party costs are not included unless expressly stated in writing.

8. RELATED-PARTY, SUPPORT, AND COMPENSATION BOUNDARIES

8.1 No Hidden Compensation or Reimbursement Created by These Terms

These Terms do not create or approve any compensation, reimbursement, support, or benefit for any trustee, manager, minister, insider, or related party. Any such arrangement must be separately authorized and documented in the applicable trust or entity records.

8.2 Related-Party Caution

The Client acknowledges that any related-party benefits, support arrangements, reimbursements, minister support, or compensation mechanisms require separate governance approval and may have legal and tax consequences. FCT does not determine the tax characterization of such transactions.

8.3 No Inference of Tax Treatment

Nothing in these Terms shall be construed to characterize any related-party payment, support, reimbursement, or certificate-based arrangement as tax-free, exempt, non-inurement, or otherwise compliant as a matter of law.

9. CONFIDENTIALITY, DATA PROTECTION, AND RECORD RETENTION

9.1 Confidentiality

Each party shall keep confidential all non-public information obtained from the other in connection with the Program and shall use such information solely for the purposes of the engagement.

9.2 Data Protection

FCT uses commercially reasonable safeguards to protect Client information, including encryption, restricted access, and periodic backups.

9.3 Retention

FCT follows internal record-retention protocols, including retention of fiduciary and accounting records for not less than seven (7) years, as described in Annex B.

10. INTELLECTUAL PROPERTY

All frameworks, manuals, templates, educational content, forms, diagrams, and related materials created by FCT remain the intellectual property of FCT.

FCT grants the Client a limited, non-exclusive, non-transferable license to use such materials internally for the administration of the Client’s own structures. No other use is permitted without prior written consent.

11. NO GUARANTEE OF OUTCOME

FCT does not guarantee:

  • tax savings,

  • legal validity of any structure,

  • exempt status,

  • UBIT avoidance,

  • church or integrated auxiliary classification,

  • audit outcomes,

  • or any particular result under civil or tax law.

Any examples, projections, comparisons, or savings illustrations provided by FCT are illustrative and educational only and are subject to legal and tax review by the Client’s licensed professionals.

12. LIMITATION OF LIABILITY

To the maximum extent permitted by law, FCT’s aggregate liability for any claim arising from or relating to the Program or these Terms shall not exceed the total fees actually paid by the Client to FCT in the twelve (12) months immediately preceding the event giving rise to the claim.

In no event shall FCT be liable for indirect, incidental, consequential, exemplary, punitive, or special damages, including loss of profits, opportunities, goodwill, or expected tax outcomes.

13. INDEMNIFICATION

The Client agrees to indemnify, defend, and hold harmless FCT, its owners, members, managers, officers, employees, and contractors from and against any and all claims, losses, liabilities, damages, costs, and expenses (including reasonable attorneys’ fees) arising from:

  • the Client’s misuse or misapplication of FCT materials;

  • the Client’s failure to obtain or follow independent legal or tax advice;

  • material inaccuracies or omissions in information supplied by the Client;

  • implementation of legal or tax positions without qualified professional review.

14. GOVERNING LAW AND DISPUTE RESOLUTION

These Terms shall be governed by and construed under the laws of the State of Wyoming, without regard to conflict-of-law principles.

Any dispute arising from or relating to the Program or these Terms shall first be submitted to confidential mediation. If not resolved, such dispute shall be finally resolved by binding arbitration in accordance with the rules identified in the applicable Engagement Letter or, absent such specification, the Commercial Arbitration Rules of the American Arbitration Association.

15. ETHICAL, CHARITABLE, AND EDUCATIONAL CHARACTER

FCT endeavors to conduct its Services within a framework of stewardship, accountability, prudence, good faith, and avoidance of usury.

The parties acknowledge that the Program is intended to be primarily educational, charitable, and religious in character, with any fee-based component secondary and supportive of that mission. This section is descriptive only and does not create or imply any legal conclusion under tax or exemption law.

16. ENTIRE AGREEMENT; AMENDMENTS

These Terms, together with any Engagement Letter, invoice, and Annex B, constitute the entire understanding between the parties regarding the Program and supersede prior discussions or communications on that subject.

Any amendment or modification must be in writing and signed by both parties.

17. ACCEPTANCE

The Client acknowledges that by executing the applicable Engagement Letter, or by otherwise accepting services from FCT under such letter, the Client has read, understood, and agrees to be bound by these Terms.

ANNEX B – DATA-PROTECTION & RECORD-RETENTION POLICY

  • Encryption standard: AES-256 for digital records

  • Access: limited to authorized personnel on a need-to-know basis

  • Backups: encrypted and verified regularly

  • Retention: minimum seven (7) years for fiduciary and accounting records

  • Destruction: secure shredding and certified digital erasure

  • Breach Notification: notice to Client within seventy-two (72) hours of discovery, with summary of affected data and remedial steps