Governance · Published

Rules of Access

Version  v1.0 Effective  2026·04·01 Drafted by  AEEA General Counsel Amendment notice  30 days, published

1. Purpose and scope

These Rules of Access (the “Rules”) govern admission to and conduct within Ordinact (the “Venue”), a private operating venue for the conduct of complex commercial engagements. The Venue is operated by American Eagle Equity Assets LLC (“AEEA”), the named operator and custodian of record. The working environment through which admitted participants conduct their engagements is the Factivault portal (the “Portal”).

The Rules apply to every admitted participant, every authorized delegate of an admitted participant, every Chamber convened within the Venue, and every record of the Venue from the moment of ingest through final resolution.

2. Definitions

Venue
Ordinact, the private operating venue described herein.
Operator
American Eagle Equity Assets LLC.
Portal
Factivault, the white-labeled working environment provisioned to each Chamber.
Chamber
A bounded engagement convened within the Venue under a single Participant Agreement.
Participant
Any person or firm admitted to the Venue under these Rules.
Counsel
An attorney or law firm engaged by a Participant and granted delegated read or contributory access to a Chamber.
Custodian of Record
The natural person designated by AEEA to make custodial certifications under penalty of perjury.
Record of the Venue
Any artifact, communication, or audit event captured under the five commitments published at ordinact.com/.

3. Eligibility

The Venue admits the following categories of applicant on satisfaction of these Rules and successful KYC/AML verification:

  • Operating companies represented by an authorized officer.
  • Investment vehicles, partnerships, and family offices represented by their general partner or principal.
  • Law firms acting on instruction of an admitted client.
  • Government, regulatory, and arbitral counsel under formal designation.

The Venue does not admit anonymous, pseudonymous, or undisclosed-beneficial-owner applicants under any circumstance.

4. Application and admission

An applicant submits firm details, beneficial ownership disclosure, regulatory standing, and the documentary evidence specified in the application intake. The Ordinact Admissions Committee reviews each application against these Rules and the BSA/AML checklist maintained by Operator’s counsel. The Committee may admit, decline, or request further information. A declined application may be resubmitted no earlier than 90 days after the decision.

On admission, the Participant executes the Participant Agreement with AEEA. No Chamber is provisioned before the Agreement is in force.

5. Conduct within a Chamber

Each Participant agrees to:

  • Submit communications, instructions, and artifacts in their original form, without redaction outside the published redaction protocol.
  • Authorize each action of evidentiary weight with a phishing-resistant authenticator bound to a natural person.
  • Refrain from any attempt to mutate, suppress, or backdate a record of the Venue.
  • Disclose any conflict of interest material to the Chamber within five business days of becoming aware of it.

6. Counsel access

A Participant may grant Counsel delegated read or contributory access to a Chamber by filing the Counsel Access designation with the Operator. Counsel access is identifiable on every action and does not transfer the Participant’s representations or admissions. Termination of Counsel access is effective on filing.

7. Suspension and expulsion

The Operator may suspend a Participant’s access pending investigation into a credible report of breach of these Rules. The Admissions Committee may expel a Participant for material breach, with publication of the sanction in the Trust Center under the Operator’s sanctions disclosure protocol. Records of the Venue produced before suspension or expulsion remain in custody and remain verifiable.

8. The custodial function

The Custodian of Record is a natural person designated by AEEA. The Custodian is the signatory on every custodial certification of a record of the Venue and signs under penalty of perjury. Succession of the Custodian is published, with the outgoing and incoming Custodians cross-attested.

9. Public verification

Records of the Venue are publicly verifiable at ordinact.com/verify. Verification is unauthenticated, deterministic, and binding on the claim of authenticity alone. Verification does not adjudicate the substance of any record.

10. Amendment

These Rules may be amended by the Operator under a 30-day published-notice procedure. The amended Rules become effective on the published effective date and apply prospectively. All prior versions of the Rules are retained and publicly accessible. The Rules in force at the moment of issuance of any record of the Venue are recorded with that record and retrievable on verification.

11. Governing law and forum

These Rules and the Participant Agreement are governed by the laws of the State of Texas, United States, without regard to conflict of laws principles. Disputes between a Participant and the Operator are submitted to confidential arbitration in Houston, Texas, under the AAA Commercial Arbitration Rules.

v1.0 · effective 2026·04·01 · published 2026-04-22