# Policies: complaints, consultation, errors and corrections, missing values

**Version 1.1, 19 October 2026.** Under Methodology v1.1, which governs wherever these policies differ.

> **In short.** How to ask a question or complain about a fund value; how a rule change is consulted on; how an error in a NAV or other fund action is corrected; and what is published when a value cannot be made. Complaints are acknowledged within 2 business days and answered within 20. A material rule change needs 30 days of consultation and 30 days' notice, and is never retroactive. A correction is a new record under the same quorum; the original is never deleted. A value that cannot be made is published as a gap, never estimated.

> **What changed from v1.0.** v1.0 (24 September 2026) was written for the retired price-fixing product. v1.1 restates it for funds. Complaint answers now follow the Methodology (20 business days, not 8 weeks). Corrections follow the NAV error policy (50 bp materiality, or half a cent for a stable-NAV fund) instead of the fixing republication window. The constituent venue list and the benchmark notice are retired: venues sign only a fair value for an asset with no price feed.

## 1. Complaints

**Two tracks**, so that a question is not treated as a complaint:

| Track | Example | Handling |
|---|---|---|
| **Question** | "Why was no NAV struck for TEST-CBTC-CETH on Tuesday?" | Answered from the record within **1 business day**. If the answer is a correction, §3 applies |
| **Complaint** | The methodology was misapplied, a party acted improperly, or ETP Foundry's conduct fell short | The process below |

**Process.**
1. In writing to committee@etpfoundry.com, subject `Complaint — [fund] — [date]`. You may write to the fund's committee without going through ETP Foundry.
2. **Acknowledged within 2 business days**, with a reference number and the investigator's name.
3. The investigator is not a person who proposed, calculated or signed the value in question.
4. **Answered within 20 business days**, with reasons.
5. Unresolved complaints go to the next quarterly committee meeting and are minuted, without naming the complainant unless they agree.
6. Records are kept for at least five years.
7. Nothing here limits your right to go to a regulator or a court.

## 2. Consultation on rule changes

- **Material change:** anything that changes the Methodology's substance: the NAV formula, the price-source order, valuation times, the signing rules, the error thresholds, the roles a fund template requires.
- **Consultation paper:** the change, the reason, the expected effect on funds and their parties, and the proposed effective date.
- **At least 30 days** of public consultation; a published summary of responses (unless a respondent asks for confidentiality); then **at least 30 days' notice** before it takes effect.
- Clarifications and typo fixes take effect on publication.
- Open and closed consultations are listed on etpfoundry.com/news with dates.
- **No retroactive change, ever.**
- A change to one fund's basket or fees is a fund action, signed by its own parties with notice first (Methodology v1.1 §8), not a methodology change.

## 3. Errors and corrections

- A wrong NAV or fund action is corrected by a **new record under the same quorum** that states why the original was wrong. The original stays on the ledger, marked as replaced.
- **Material** when the NAV error is at least **50 bp** (a fund may set a tighter threshold), or at least **$0.005 per share** for a stable-NAV fund.
- **Immaterial:** the record is corrected; no reprocessing; disclosed in the next periodic report.
- **Material:** the record is corrected; every creation and redemption struck at the wrong NAV is reprocessed or compensated; market makers, holders and any lender relying on the NAV are notified; the cause and the fix are recorded.
- A value is corrected only for a wrong input or a misapplied rule, never because the result was unpopular.
- **Quarterly error table**, published from the start:

| Year | Quarter | NAVs signed | Errors found | Corrected | Material | Notes |
|---|---|---|---|---|---|---|
| 2026 | Q4 (DevNet) | 0 by an outside party | 0 | 0 | 0 | No outside party holds a seat |

## 4. When a value cannot be made

- **Missed:** a NAV not signed by the valuation point + 2 hours is published as missed, with the reason. It is a record, not an absence.
- **No proposal:** when an asset has no fresh price, nothing is proposed and the reason is recorded.
- **Carried forward:** a stale price may be carried for one valuation point only, flagged, with the administrator's signature. Never silently.
- **Escalated:** when no usable price source is left, the fund's seats may sign a fair value.
- **Paused or suspended:** creations and redemptions stop; the reason and the end or review time are shown.
- Every such event is shown on etpfoundry.com/status when it happens and listed in the quarter's minutes.

## 5. Notice printed with every value

*Values are calculated by ETP Foundry from the fund's holdings and from prices supplied by the providers named in the fund's terms, and are signed, or not, by the fund's own parties. Each value says whether it is signed or indicative, who signed, and which methodology version produced it. ETP Foundry never signs. Canton DevNet only. ETP Foundry is not authorised or registered with any regulator. Nothing here is investment advice or an offer of any financial product.*

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## Appendix: retired from v1.0

Not in force. Kept on file as a record.
- The constituent venue list and venue nomination process (§4 of v1.0).
- The fixing republication window and the 1 bp restatement threshold (§3).
- `NO FIXING`, `EXCEPTIONAL` and chain-event flags for price fixings (§5).
- The benchmark notice and disclaimer (§6).

*Lucilla, Inc., federal corporation no. 16699448, Toronto, trading as ETP Foundry. Contact: hello@etpfoundry.com.*