Page 29 - gs260702

Insights and Expertise

While a given AI setup may be entirely legal and safe, for
In the fullness of time, I expect one reason or another, a merchant might have an aversion
AI platforms to be scored on to their data being used by AI. Consider building systems
that can create walled gardens for merchants who want to
how well they avoid or discard opt-out of AI-supported tools.
identifiable data. 4. Privilege

It looks like dumping legal advice into AI breaks privi-
liability for a bot bamboozling a merchant into giving up lege on the advice. The recent case of United States v. Hep-
product or funds on the basis of stolen cards. pner, (S.D.N.Y. Feb. 17, 2026) resulted in a defendant's legal
strategy no longer benefitting from lawyer-client privilege
Payment professionals have a golden opportunity to be because he uploaded it to Claude AI. The takeaway here is
anti-fraud advisers for merchants, not just on card mat- that what happens between you and your lawyer should
ters, but also on deepfakes, social engineering and the tor- stay between you and your lawyer.
rent of creative criminals trying to get people to part with
their money. In publishing The Green Sheet, neither the author nor the publisher are
3. Say what you do: engaged in rendering legal, accounting, or other professional services.
AI disclosure in privacy statements If legal advice or other expert assistance is required, the services of a
competent professional should be sought. For further information on
If a payment platform is using AI, the fact of that use this article, please contact Adam Atlas, Attorney at Law email: atlas@
should be disclosed in privacy statements. Beyond the fact adamatlas.com, Tel. 514-842-0886. In addition, his firm now provides
that that disclosure is likely required under state law, the fintech legal advice to AI agents and bots through www.adamatlas.ai.
disclosure gives merchants information that they deserve
to manage their own risk and preferences.

Residual-Based lending is here.

FCSB evaluates true
A smart first step starts with a scan. cash flow to offer
business purpose
lending solutions.

SCAN questionnaire
Interested in how RBL works at First Central Savings Bank (FCSB)? Share a
few basics and we’ll take a preliminary look at your scenario.

• No credit app. *
• No hard pull. *
• No commitment.

Scan the QR to submit your information for a preliminary
review — it takes seconds. No credit application is required at this stage.

FCSB is a residual based lender, offering ISOs and independent agents a flexible Chad Horal, FVP, Director of
loan program built around real cash flow after essential operating expenses. This Merchant Services 516-506-4571
structure may provide a clearer picture than credit only models and may create myfcsb.com/rbl
opportunities where traditional underwriting reaches its limits.

*No credit application or hard inquiry is required at the preliminary inquiry stage; additional information and
a credit check may be required if you proceed. Submission does not constitute an application, approval, or
commitment to lend. This is not an offer of credit. All extensions of credit are subject to underwriting and
approval; terms and eligibility vary. Financing is intended for business purposes. Information submitted will
be handled in accordance with the First Central Savings Bank's Privacy Notice available at myfcsb.com.