Marketplace Disclosures
Operational disclosures that supplement the Terms of Service and the Marketplace Addenda.
Version 1.0-draft · Last updated: 2026-05-10 · Effective: Pending counsel sign-off
1.What Hardline Is — and What It Is Not
Hardline is a software platform that allows real-estate investors and private lenders to discover each other and communicate directly. Hardline is not a lender, mortgage broker, loan originator, real-estate broker, money transmitter, money services business, payment processor, escrow agent, title agent, investment adviser, securities broker-dealer, or fiduciary of any User.
Hardline does not originate, underwrite, fund, broker, negotiate, modify, or service any loan. Hardline does not take loan applications, present offers from any particular lender, recommend or rank lenders or borrowers, or hold or transmit funds. Users see other Users, deals, and term sheets in chronological order, in an order the User explicitly selects via filter or sort controls, or pursuant to a User’s own selection of counterparties — and not pursuant to any Hardline-determined match, score, or recommendation. All loan terms are negotiated directly between borrowers and lenders. All loans facilitated through Hardline are intended exclusively for business, commercial, or investment purposes secured by non-owner-occupied real property. Funding moves directly between borrower and lender, outside of Hardline, by wire transfer arranged by the parties.
2.Business-Purpose Loans Only
The Service is intended only for loans made primarily for business, commercial, or investment purposes as defined in 12 C.F.R. § 1026.3(a)(1) (Regulation Z) and applicable state-law analogs, secured by non-owner-occupied real property. Owner-occupied dwellings, second homes, and consumer-purpose loans are not eligible for the Service.
Borrowers represent at deal listing — and Lenders represent at term-sheet submission — that the loan is business-purpose and that the property is and will remain non-owner-occupied. Misrepresentation of these facts is a material breach of the Terms of Service, may constitute wire fraud or bank fraud, and may give rise to civil and criminal liability.
3.State Availability
Hardline does not currently make the Service available to residents of New York, New Jersey, Illinois, or California. The list of available states may change without notice. The Service is offered only to United States residents and is not available outside the United States.
Illinois is excluded because identity verification on the Service is performed by a service provider that captures biometric identifiers, and Hardline has not yet implemented the informed-written-consent, written-release, public retention-schedule, and recordkeeping infrastructure required by the Illinois Biometric Information Privacy Act (740 ILCS 14/). New York and New Jersey are excluded because of licensing-law uncertainty for non-bank private-money lenders in those states. California is excluded pre-launch pending outside-counsel sign-off on the platform-only Option A posture under the California Financing Law (Cal. Fin. Code §§ 22000 et seq.) and the California Consumer Financial Protection Law, and on related DFPI enforcement risk; Hardline will reassess California availability after a written specialist opinion is on file.
Lenders are solely responsible for confirming that they hold any required state license or qualify for an exemption in the state where the borrower entity is organized, where the borrower entity does business, and where the property securing the loan is located. Hardline does not provide licensing advice.
4.Wire Fraud Warning — Read Before Sending Any Wire
Wire fraud is the most common form of financial crime in real-estate transactions, and losses are typically unrecoverable. Criminals impersonate title companies, closing agents, attorneys, lenders, and borrowers, and send falsified wire instructions to redirect loan proceeds and closing funds to fraudulent accounts.
Before sending any wire, you will independently verify wire instructions by placing a voice call to a known and previously verified telephone number for the intended recipient (such as the title company’s published main line) and confirming the wire instructions verbally with a known individual. You will not rely on telephone numbers provided in the same email, message, or document that contains the wire instructions themselves.
Be alert to indicators of wire fraud, including:
- last-minute changes to wire instructions;
- pressure to send funds urgently;
- instructions to wire to an out-of-state bank when the title company is local;
- email addresses or domains that differ subtly from prior correspondence;
- requests to use cryptocurrency or unfamiliar payment rails;
- any change to the named beneficiary on the wire.
Hardline does not generate, verify, transmit, or guarantee any wire instructions. Hardline shall have no liability for any loss arising from wire fraud, business email compromise, payment misdirection, or related schemes, and you waive any such claim against Hardline to the maximum extent permitted by law.
5.Sanctions and Anti-Money-Laundering
You acknowledge that Hardline conducts identity verification and sanctions screening against U.S. Treasury OFAC sanctions lists at onboarding and on a periodic basis, including the Specially Designated Nationals and Blocked Persons List and any other lists Hardline’s identity-verification provider routinely screens against. You represent and warrant that:
- You are not, and the entity you represent is not, a person listed on any such list, owned 50% or more in the aggregate by persons listed on such lists, or a national or resident of any comprehensively sanctioned country or region.
- No counterparty in any transaction conducted via Hardline is, to your knowledge after reasonable inquiry, a sanctioned person or located in a sanctioned region.
- Loan proceeds will not be transmitted to, from, or for the benefit of any sanctioned person or jurisdiction.
- You will promptly notify Hardline if you have reason to believe any of the foregoing has become untrue.
Hardline may suspend, terminate, or report your account if Hardline reasonably believes any of the foregoing is or becomes untrue, without liability to you.
6.No Investment, Legal, Tax, or Financial Advice
Nothing on the Service constitutes investment, legal, tax, accounting, financial, real-estate, lending, brokerage, appraisal, or valuation advice. All calculations, displayed metrics, estimated yields, LTV/LTC ratios, ARV figures, debt-service coverage, points, fees, interest rates, comparable property data, scoring or risk indicators, and similar information displayed on the Service are for informational purposes only, may be inaccurate or out of date, and are not a substitute for independent professional advice and your own due diligence.
Hardline does not offer, sell, broker, distribute, or solicit any security, investment, investment contract, or interest in any pooled investment vehicle. Loans transacted via Hardline are bilateral agreements between a single lender and a single borrower; Hardline does not pool, fractionalize, or syndicate any loan. If you fund loans through a fund, syndicate, or vehicle that raises capital from third parties, you are solely responsible for compliance with the Securities Act of 1933, the Securities Exchange Act of 1934, the Investment Company Act of 1940, the Investment Advisers Act of 1940, applicable state Blue Sky laws, and all related regulations.
7.No Endorsement; Independent Diligence
Hardline does not endorse, recommend, vouch for, or guarantee any User, deal, property, valuation, document, statement, listing, or transaction. The presence of a User or deal on the Service does not constitute Hardline’s approval. Hardline does not independently verify the licensing, credit, financial condition, source of funds, track record, or experience of any User, or the accuracy of any deal, property, appraisal, valuation, financial statement, tax return, title, lien position, insurance, or other document or representation.
You are solely responsible for performing your own due diligence, including independent appraisal, title search and title insurance, lien search, environmental review, entity verification, background check, OFAC and sanctions screening, source-of-funds review, and legal and tax review.
8.No Agency, Fiduciary, or Joint Venture
Hardline is not an agent, broker, dealer, fiduciary, advisor, employee, partner, joint venturer, or representative of any User. Hardline has no authority to bind any User, accept any offer on behalf of any User, sign any document on behalf of any User, hold funds on behalf of any User, or make any representation on behalf of any User. Nothing in the Terms of Service or any communication on the Service creates a principal-agent relationship, employer-employee relationship, partnership, joint venture, franchise, or fiduciary duty between Hardline and any User, or between any Users solely by reason of their use of the Service.
9.Fair Lending
Hardline does not display borrower demographic information, photographs, or protected-class proxies to Lenders, and does not allow Lender filters by ZIP code, name, language, or other proxies that could create disparate impact. Lenders are solely responsible for compliance with the Equal Credit Opportunity Act, Regulation B, the Fair Housing Act, and applicable state fair-lending laws on their own loan decisions and documents.
10.Sub-Processors
Hardline relies on the following service providers, each contractually bound to use information only as we direct and to maintain appropriate safeguards:
- Supabase, Inc. — database, authentication, and file storage (United States).
- Stripe, Inc. — identity verification and any payment processing (United States).
- Vercel Inc. — application hosting, edge delivery, and basic analytics (United States).
- Resend — transactional email delivery (United States).
This list is also maintained at /subprocessors and is updated when material changes occur.
11.Contact
Legal: legal@hardlinelending.com
Privacy: privacy@hardlinelending.com
Security: security@hardlinelending.com
Support: support@hardlinelending.com