Form of BM Technologies, Inc. Insider Trading Policy, dated December 1, 2023

Material Information. Information is considered "material" if a reasonable investor would consider that information important in making a decision to buy, hold or sell securities. Any information that could be expected to affect the Company's stock price, whether it is positive or negative, should be considered material. There is no bright-line standard for assessing materiality; rather, materiality is based on an assessment of all of the facts and circumstances, and is often evaluated by enforcement authorities with the benefit of hindsight. While it is not possible to define all categories of material information, some examples of information that ordinarily would be regarded as material are:

·Projections of future earnings or losses, or other earnings guidance;

·Changes to previously announced earnings guidance, or the decision to suspend earnings guidance;

·Significant regulatory developments impacting the Company;

·A pending or proposed merger, acquisition or tender offer;

·A pending or proposed acquisition or disposition of a significant asset;

·A pending or proposed joint venture;

·A Company restructuring;

·Significant related party transactions;

·A change in dividend policy, the declaration of a stock split, or an offering of additional securities;

·Borrowings or other financing transactions out of the ordinary course;

·The establishment of a repurchase program for Company Securities;

·A change in the Company's pricing or cost structure;

·Major marketing changes;

·A change in executive management;

·A change in auditors or notification that the auditor's reports may no longer be relied upon;

·Development of a significant new product, process, or service;

·Pending or threatened significant litigation, or the resolution of such litigation;

·Impending bankruptcy or the existence of severe liquidity problems;

·The gain or loss of a significant customer or supplier;

·The imposition of a ban on trading in Company Securities or the securities of another company.

The Company has determined that there is a heightened legal risk and/or the appearance of improper or inappropriate conduct if the persons subject to this Policy engage in certain types of transactions. It therefore is the Company's policy that any persons covered by this Policy may not engage in any of the following transactions, or should otherwise consider the Company's preferences as described below:

Short-Term Trading. Short-term trading of Company Securities may be distracting to the person and may unduly focus the person on the Company's short-term stock market performance instead of the Company's long-term business objectives. For these reasons, any director, officer or other employee of the Company who purchases Company Securities in the open market may not sell any Company Securities of the same class during the six months following the purchase (or vice versa).

Short Sales. Short sales of Company Securities (i.e., the sale of a security that the seller does not own) may evidence an expectation on the part of the seller that the securities will decline in value, and therefore have the potential to signal to the market that the seller lacks confidence in the Company's prospects. In addition, short sales may reduce a seller's incentive to seek to improve the Company's performance. For these reasons, short sales of Company Securities are prohibited. In addition, Section 16(c) of the Securities Exchange Act of 1934, as amended (the "Exchange Act") prohibits officers and directors from engaging in short sales. (Short sales arising from certain types of hedging transactions are governed by the paragraph below captioned "Hedging Transactions.")

Publicly-Traded Options. Given the relatively short term of publicly-traded options, transactions in options may create the appearance that a director, officer or employee is trading based on material nonpublic information and focus a director's, officer's or other employee's attention on short-term performance at the expense of the Company's long-term objectives. Accordingly, transactions in put options, call options or other derivative securities, on an exchange or in any other organized market, are prohibited by this Policy. (Option positions arising from certain types of hedging transactions are governed by the next paragraph below.)

Hedging Transactions. Hedging or monetization transactions can be accomplished through a number of possible mechanisms, including through the use of financial instruments such as prepaid variable forwards, equity swaps, collars and exchange funds. Such hedging transactions may permit a director, officer or employee to continue to own Company Securities obtained through employee benefit plans or otherwise, but without the full risks and rewards of ownership. When that occurs, the director, officer or employee may no longer have the same objectives as the Company's other shareholders. Therefore, the Company prohibits you from engaging in such transactions.

Margin Accounts and Pledged Securities. Persons subject to this Policy are prohibited from holding Company Securities in a margin account or pledging Company Securities as collateral for a loan. .

Standing and Limit Orders. Standing and limit orders (except standing and limit orders under approved Rule 10b5-1 Plans, as described below) create heightened risks for insider trading violations similar to the use of margin accounts. There is no control over the timing of purchases or sales that result from standing instructions to a broker, and as a result the broker could execute a transaction when a director, officer or other employee is in possession of material nonpublic information. The Company therefore discourages placing standing or limit orders on Company Securities. If a person subject to this Policy determines that they must use a standing order or limit order, the order should be limited to short duration and should otherwise comply with the restrictions and procedures outlined below under the heading "Additional Procedures." No standing or limit order may be entered into during a Blackout Period.

All persons subject to this Policy must certify their understanding of, and intent to comply with, this Policy.

I certify that:

1.I have read and understand BM Technologies, Inc.'s Amended and Restated Insider Trading Policy (the "Policy"). I understand that the Compliance Officer is available to answer any questions I have regarding the Policy.

2.Since September 29, 2016, or such shorter period of time that I have been an employee of the Company, I have complied with the Policy.

3.I will continue to comply with the Policy for as long as I am subject to the Policy.

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