This Property Listing Policy ("Policy") outlines the requirements and procedures for listing real estate properties on the Vestra platform (the "Platform"). This Policy is designed to ensure the integrity, transparency, and compliance of all property listings, protecting both investors and sellers. By listing a property on Vestra, you ("Seller" or "you") agree to adhere to this Policy in its entirety. This Policy is an integral part of the Vestra Terms of Service.

The U.S. Securities and Exchange Commission (SEC) mandates comprehensive disclosure for offerings that constitute securities, which can include fractional interests in real estate. The Securities Act of 1933 requires that any offer or sale of securities be registered with the SEC or qualify for an exemption. This ensures that investors receive material information about the investment, including risks, financial condition of the issuer, and details about the underlying assets. For real estate-focused offerings, the SEC scrutinizes the nature of the investment to determine if it falls under the definition of a security, often applying the "Howey Test" to assess whether there is an investment of money in a common enterprise with an expectation of profits derived solely from the efforts of others. Furthermore, the Financial Crimes Enforcement Network (FinCEN) plays a critical role in combating money laundering and terrorist financing, requiring financial institutions and certain real estate professionals to implement Anti-Money Laundering (AML) programs, including Know Your Customer (KYC) and Know Your Business (KYB) procedures. This is particularly relevant for platforms facilitating real estate transactions, even fractional ones, to prevent illicit financial activities.

1. Eligibility to List

1.1. Authorized Sellers Only: Only verified property owners or licensed real estate agents with explicit authorization from the property owner are permitted to list properties on Vestra.1.2. Verification Process: All Sellers must undergo Vestra's rigorous Know Your Customer (KYC) and, if applicable, Know Your Business (KYB) verification process. This includes, but is not limited to, providing: * Government-issued identification (e.g., passport, driver's license). * Proof of address. * Business registration documents (for entities). * Tax identification numbers. * Proof of professional licenses (for agents). * Any other documentation Vestra deems necessary to confirm identity and legitimacy. 1.3. Legal Capacity: Sellers must have the full legal capacity and authority to offer the property for fractional sale and to enter into binding agreements.

1. Property Requirements

2.1. Legally Owned and Marketable Title: The property must have a clear, unencumbered, and marketable title. Sellers must provide comprehensive legal documentation proving ownership, including: * Deed of Title or equivalent ownership document. * Title insurance policy (if applicable). * Property survey. * Any relevant easements, covenants, conditions, and restrictions (CC&Rs). * Proof that all property taxes and liens are current or will be cleared prior to listing. 2.2. Property Valuation: All listed properties must undergo an independent, professional valuation by a Vestra-approved appraiser or a recognized third-party valuation firm. The valuation report must be current (within the last 6 months) and clearly state the fair market value of the property. 2.3. Physical Inspection and Condition Report: A professional property inspection report, conducted by a certified inspector, must be provided. This report must detail the current physical condition of the property, including any defects, necessary repairs, or maintenance issues. Vestra reserves the right to conduct its own physical inspection or request additional reports. 2.4. Compliance with Laws: The property must be in full compliance with all applicable local, state, and federal laws, zoning regulations, building codes, environmental regulations, and any homeowners' association (HOA) rules or condominium bylaws. Sellers must provide documentation demonstrating such compliance. 2.5. Insurance: The property must be adequately insured with comprehensive property insurance, including liability coverage, for the duration of its listing and fractional ownership period. Proof of insurance must be provided. 2.6. No Encumbrances or Disputes: The property must be free from any active legal disputes, litigation, or significant encumbrances that could materially affect its value or the rights of fractional owners, unless explicitly disclosed and approved by Vestra.

1. Listing Information and Disclosure Requirements

3.1. Accuracy and Completeness: Sellers are solely responsible for the accuracy, completeness, and truthfulness of all information provided in the property listing ("Property Schema"). Any misrepresentation, omission, or fraudulent activity will result in immediate removal of the listing, account termination, and potential legal action.  3.2. Required Information for Property Schema: Each Property Schema must include, but is not limited to, the following detailed information: * Property Details: Full address, property type (e.g., residential, commercial, industrial), size (square footage/meters), number of rooms, year built, and any unique features. * Financials: * Total property valuation (from independent appraisal). * Total number of fractional shares available. * Price per fractional share. * Projected profit schedule (weekly, monthly, yearly) and estimated Annualized Return on Investment (ROI). * Investment duration (term of fractional ownership). * Any associated fees (e.g., management fees, maintenance fees, property taxes, insurance costs) that will impact investor returns. * Detailed breakdown of expected income (e.g., rental income) and expenses. * Legal & Regulatory: * Confirmation of clear title. * Zoning classification and permitted uses. * Any known environmental hazards or historical designations. * Details of any existing leases or tenancy agreements. * Property Management Plan: A clear plan outlining how the property will be managed, maintained, and how income will be generated and distributed. This includes details of the property manager (if applicable) and their experience. * Exit Strategy: Information regarding potential exit options for investors, including the possibility of a secondary market for shares, expected sale of the entire property, or other liquidity events. * Risk Factors: A comprehensive disclosure of all material risks associated with the investment, including market risks, property-specific risks, liquidity risks, and any other relevant risks. * Images and Videos: High-quality, recent photographs and, if possible, virtual tours or videos of the property. Images must accurately represent the current condition of the property. * "No Profit Holidays": If applicable, clearly state any periods during which profits will not be accrued or distributed (e.g., specific dates like 2025-12-10, 2025-08-19, 2025-12-25, and 2026-01-01).  * Cancellation Policy: Clearly state the cancellation terms for investors, if any (e.g., "Cancel In 15 Minutes" or "Cancel In 59 Minutes" for specific properties). 3.3. Updates to Information: Sellers must promptly update Vestra with any material changes to the property information, condition, or legal status during the listing period and the fractional ownership term.

1. Vestra's Review and Approval Process

4.1. Initial Submission: Sellers must submit all required documentation and complete the Property Schema form through the Vestra platform. 4.2. Due Diligence: Vestra's team will conduct thorough due diligence on all submitted properties, including: * Verification of Seller identity and legal capacity. * Review of all legal documentation (title, deeds, surveys, etc.). * Assessment of property valuation and inspection reports. * Confirmation of regulatory and zoning compliance. * Evaluation of the proposed financial model and profit projections. * Assessment of the property management plan. 4.3. Approval or Rejection: Vestra reserves the sole right to approve or reject any property listing at its discretion. Vestra is not obligated to provide reasons for rejection. 4.4. Listing Activation: Once a property is approved, Vestra will activate the listing on the Platform, making it available for fractional investment.

1. Ongoing Obligations and Compliance

5.1. Continuous Compliance: Sellers must ensure that the property remains in compliance with all applicable laws, regulations, and the terms of this Policy throughout the entire fractional ownership period. 5.2. Reporting Requirements: Sellers may be required to provide periodic reports to Vestra regarding the property's performance, financial status, and any significant events or changes. 5.3. Investor Communications: Sellers must cooperate with Vestra in providing transparent and timely communications to fractional investors regarding the property's status, performance, and any material developments. 5.4. Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF): Sellers acknowledge and agree that Vestra operates under strict AML/CTF policies. All transactions and activities related to property listings will be monitored for suspicious activity, and Vestra will report any such activity to the relevant authorities.

1. Consequences of Non-Compliance

6.1. Immediate Action: Vestra reserves the right to take immediate action, including but not limited to: * Temporary suspension or permanent removal of the property listing. * Suspension or termination of the Seller's account. * Forfeiture of any pending payouts. * Reporting to relevant regulatory authorities. * Pursuit of legal remedies for damages incurred by Vestra or its investors. 6.2. Indemnification: Sellers agree to indemnify and hold Vestra harmless from any claims, losses, damages, liabilities, costs, and expenses (including legal fees) arising from any breach of this Policy, misrepresentation, or fraudulent activity by the Seller.

1. Policy Amendments

7.1. Vestra reserves the right to modify, amend, or update this Policy at any time without prior notice. Any changes will be effective immediately upon posting on the Platform. It is the Seller's responsibility to regularly review this Policy to stay informed of any updates.

By proceeding with a property listing on Vestra, you confirm that you have read, understood, and agree to be bound by this Property Listing Policy.