{ "schema_version": "1.2.0", "data_schema_version": "cya_registry_public_data_v2", "project_id": "crypto-yield-archive", "dataset": "terms_risk", "canonical_origin": "https://cya.badjoke-lab.com", "canonical_only": true, "generated_at": "2026-08-31T16:44:22.893Z", "build": { "commit": "1556a9022d96de62d086007ed7346d1eeaaf89d2", "branch": "main", "generated_at": "2026-08-31T16:44:22.893Z", "verification_marker": "cya_machine_readable_layer_v2" }, "record_count": 130, "records": [ { "platform_id": "cya_plat_000009", "terms_status": "unknown", "asset_ownership_interpretation": "The Singapore court materials establish a group scheme and creditor-classification process, but they do not support one universal ownership or priority rule for every Babel lending, asset-management and prime-finance claim. The 2023 scheme judgment treated one contested trust or secured-claim theory as, at best, an unsecured personal claim, but that reasoning should not be generalized to all customers without product-specific documents.", "affected_product": "Babel institutional lending, managed assets and prime-finance claims", "source_evidence_id": "cya_src_b04_0017", "notes": "Unknown is retained deliberately. Product terms, contracting entity and claim basis may affect treatment under the scheme.", "confidence": "high" }, { "platform_id": "cya_plat_000010", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Nexo product terms and regulatory treatment vary by product and jurisdiction, especially around Earn-style products versus collateralized lending.", "affected_product": "Nexo Earn Interest Product and crypto-backed loans", "source_evidence_id": "cya_src_b04_0003", "notes": "Use product-dependent classification because the regulatory event centered on Earn while the broader platform remained active.", "confidence": "medium" }, { "platform_id": "cya_plat_000011", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Ledn terms and customer treatment vary by product type, including collateralized loans and savings or yield products.", "affected_product": "Ledn bitcoin-backed loans and savings or yield products", "source_evidence_id": "cya_src_b04_0006", "notes": "Active comparator record. Product-level terms should be checked against current official documents over time.", "confidence": "medium" }, { "platform_id": "cya_plat_000012", "terms_status": "unknown", "asset_ownership_interpretation": "Public reporting confirms a client-transfer halt and restructuring process, but does not yet establish a complete account-by-account ownership, priority, or recovery framework for BlockFills balances.", "affected_product": "BlockFills client deposits, institutional financing balances, and trading accounts", "source_evidence_id": "cya_src_b04_0010", "notes": "Keep unknown until direct restructuring, court, or customer-claim documents establish treatment and priority.", "confidence": "high" }, { "platform_id": "cya_plat_000013", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Historical Abra Earn and Abra Boost terms allowed Abra to lend and deploy customer crypto through direct and DeFi lending, with the SEC describing pooled assets controlled by Abra. After conversion to non-interest-bearing Abra Trade accounts, the applicable terms stated that title remained with customers.", "affected_product": "Abra Earn, Abra Boost, and wind-down Abra Trade balances", "source_evidence_id": "cya_src_b05_0005", "notes": "The risk classification changes by product phase: yield-account assets were deployable by Abra, while converted Trade balances were treated differently during the withdrawal and refund process.", "confidence": "high" }, { "platform_id": "cya_plat_000014", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Gemini Earn customer treatment depended on the Earn program structure, Genesis lending exposure, and the Genesis bankruptcy distribution path rather than a standalone exchange-account treatment.", "affected_product": "Gemini Earn customer balances", "source_evidence_id": "cya_src_b06_0003", "notes": "Use product-dependent classification because Gemini Earn was exchange-linked but relied on Genesis lending arrangements and a separate bankruptcy-driven recovery path.", "confidence": "high" }, { "platform_id": "cya_plat_000015", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Kraken staking customer treatment varied by product design, jurisdiction, and staking terms rather than an insolvency claim process.", "affected_product": "Kraken U.S. staking-as-a-service program and later eligible staking products", "source_evidence_id": "cya_src_b07_0001", "notes": "Use product-dependent classification because this is a regulatory staking-service record, not a lending platform bankruptcy case.", "confidence": "high" }, { "platform_id": "cya_plat_000016", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Coinbase staking customer treatment varies by asset, staking product design, jurisdiction, and applicable Coinbase terms rather than an insolvency claim process.", "affected_product": "Coinbase staking services", "source_evidence_id": "cya_src_b08_0006", "notes": "Use product-dependent classification because this is a regulatory staking-service record, not a lending platform bankruptcy case.", "confidence": "medium" }, { "platform_id": "cya_plat_000017", "terms_status": "platform_owned", "asset_ownership_interpretation": "Customer deposits were exposed to BitConnect program risk rather than treated as a simple segregated custody balance.", "affected_product": "BitConnect Lending Program", "source_evidence_id": "cya_src_b09_0001", "notes": "Classification is based on the enforcement record and lending-program structure.", "confidence": "medium" }, { "platform_id": "cya_plat_000018", "terms_status": "unclear", "asset_ownership_interpretation": "BTCJam exposure depended on peer-to-peer borrower repayment and platform marketplace mechanics.", "affected_product": "BTCJam peer-to-peer bitcoin loans", "source_evidence_id": "cya_src_b09_0005", "notes": "Use unclear classification because public sources do not provide a full aggregate recovery dataset.", "confidence": "medium" }, { "platform_id": "cya_plat_000019", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Crypto.com Earn terms vary by asset, term, jurisdiction, account limits, and product conditions.", "affected_product": "Crypto.com Earn", "source_evidence_id": "cya_src_b09_0008", "notes": "Active comparator record. Product terms should be rechecked periodically.", "confidence": "medium" }, { "platform_id": "cya_plat_000020", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Nexo Earn customer treatment varies by product terms, asset, jurisdiction, and regulatory period rather than a single insolvency claim process.", "affected_product": "Nexo Earn Interest Product", "source_evidence_id": "cya_src_b10_0001", "notes": "Use product-dependent classification because this is a regulatory interest-product record, not a platform bankruptcy case.", "confidence": "medium" }, { "platform_id": "cya_plat_000021", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Anchor users interacted with a DeFi protocol and were exposed primarily to UST market, protocol, and smart-contract risks rather than a centralized custodian balance-sheet claim.", "affected_product": "Anchor UST deposit yield product", "source_evidence_id": "cya_src_b11_0001", "notes": "Classified separately from CeFi custodial lender terms because the central failure mode was TerraUSD depeg and ecosystem collapse, not a platform bankruptcy claims process.", "confidence": "medium" }, { "platform_id": "cya_plat_000022", "terms_status": "platform_owned", "asset_ownership_interpretation": "Midas users relied on platform-managed yield accounts and were exposed to platform balance-sheet, strategy, and wind-down treatment rather than holding assets in a segregated, user-controlled smart-contract position.", "affected_product": "Midas yield accounts and managed strategies", "source_evidence_id": "cya_src_b12_0001", "notes": "Classified as platform-owned / platform-managed exposure for registry purposes because the closure involved centralized account balance adjustments and strategy losses communicated by the platform.", "confidence": "medium" }, { "platform_id": "cya_plat_000023", "terms_status": "platform_owned", "asset_ownership_interpretation": "Freeway customers purchased platform-controlled Supercharger simulations and depended on the platform or affiliated entities to repurchase them. The arrangement did not provide direct segregated ownership of the underlying trading portfolio represented by the product.", "affected_product": "Freeway Superchargers", "source_evidence_id": "cya_src_b14_0007", "notes": "Classified as platform-owned exposure for registry purposes because customer exit depended on platform buy-backs and later creditor treatment in the AuBit International liquidation.", "confidence": "high" }, { "platform_id": "cya_plat_000024", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Yield App terms described customer digital assets as lent to the platform and warned that users could become general unsecured creditors if the company could not meet its obligations. The liquidators later reported that extensive wallet commingling led the Seychelles court to adopt pari passu treatment for most claims, while a very small group of assets that had not entered pooled wallets might support different proprietary treatment.", "affected_product": "Yield App digital wealth, Earn, managed yield and withdrawal-pool balances", "source_evidence_id": "cya_src_b15_0007", "notes": "The earlier unknown classification is replaced because the 2024 terms and 2025 court guidance now support a product- and tracing-dependent interpretation. Most commingled claims were treated as unsecured, but the reported judgment did not eliminate every possible proprietary claim.", "confidence": "high" }, { "platform_id": "cya_plat_000025", "terms_status": "unknown", "asset_ownership_interpretation": "Stablegains customer asset treatment remains legally contested and product-specific. Public material supports a platform-managed conversion and yield strategy, but does not justify one universal ownership classification for every customer claim.", "affected_product": "Stablegains stablecoin yield account", "source_evidence_id": "cya_src_b16_0002", "notes": "Keep terms status unknown until a court decision, settlement document, or authoritative product-specific legal analysis establishes customer ownership and claim treatment.", "confidence": "medium" }, { "platform_id": "cya_plat_000026", "terms_status": "unclear", "asset_ownership_interpretation": "MyConstant required customers to place funds into platform-managed products and pooled at least part of the Loan Matching Service funds. Public regulatory and settlement materials do not support one universal ownership classification for every product and customer claim.", "affected_product": "Loan Matching Service, Crypto-Lending Platform account, and Instant Access account", "source_evidence_id": "cya_src_b17_0007", "notes": "Keep the platform-level classification unclear because custody, pooling, product terms, private-plan treatment, and settlement claims differed across products and customers.", "confidence": "high" }, { "platform_id": "cya_plat_000027", "terms_status": "unclear", "asset_ownership_interpretation": "Delio marketed centralized deposit, savings, lending, and staking products under platform custody or administration. Public sources reviewed for this batch do not establish one ownership classification that safely applies to every product, token, and bankruptcy claim.", "affected_product": "Delio crypto savings, lending, and staking products", "source_evidence_id": "cya_src_b18_0001", "notes": "Keep the platform-level classification unclear until bankruptcy records or product-specific terms establish whether particular customer assets are held in trust, treated as property claims, or subject to another legal classification.", "confidence": "medium" }, { "platform_id": "cya_plat_000028", "terms_status": "platform_owned", "asset_ownership_interpretation": "The SEC order states that Linus took complete control of investor assets, pooled them, retained ownership and control over the borrowed assets, and decided how much to hold, lend, and invest.", "affected_product": "Linus Interest Accounts", "source_evidence_id": "cya_src_b19_0002", "notes": "This classification follows the SEC's description of the product structure and applies to the Linus Interest Accounts covered by the order.", "confidence": "high" }, { "platform_id": "cya_plat_000029", "terms_status": "varies_by_product", "asset_ownership_interpretation": "CoinFLEX combined ordinary exchange balances, locked balances, flexUSD and repo-market products. The restructuring treated creditor claims and asset allocations through a court-approved scheme rather than establishing one uniform ownership treatment for every product and account type.", "affected_product": "CoinFLEX exchange balances, flexUSD, locked balances and lending products", "source_evidence_id": "cya_src_b20_0009", "notes": "The product mix and scheme structure support a product-dependent classification. This record does not assume that every customer held the same legal claim or received the same recovery instrument.", "confidence": "medium" }, { "platform_id": "cya_plat_000030", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Official statements and regulatory notices distinguish ordinary exchange-wallet assets from assets transferred into ZipUp and ZipUp+, which were placed through external lending platforms. Treatment may also depend on the contracting Zipmex entity and jurisdiction.", "affected_product": "ZipUp, ZipUp+, Z Wallet and exchange balances", "source_evidence_id": "cya_src_b21_0003", "notes": "Product-dependent classification is used because the reviewed sources show different operational and counterparty paths for yield balances and ordinary exchange assets. The court materials do not establish one universal ownership or priority rule for every creditor class.", "confidence": "high" }, { "platform_id": "cya_plat_000031", "terms_status": "platform_owned", "asset_ownership_interpretation": "Cred accepted customer cryptocurrency and deployed it through company lending and hedging arrangements; customer balances entered the Chapter 11 claim process.", "affected_product": "CredEarn and related customer balances", "source_evidence_id": "cya_src_b22_0007", "notes": "Platform-owned classification reflects the reviewed business model and bankruptcy treatment, not one guaranteed priority or recovery rate for every claim.", "confidence": "high" }, { "platform_id": "cya_plat_000032", "terms_status": "varies_by_product", "asset_ownership_interpretation": "SALT borrower assets served as collateral for outstanding loans. Withdrawal and return depended on repayment, refinancing, loan-to-value conditions and jurisdiction-specific settlement terms.", "affected_product": "SALT crypto-backed loans and collateral", "source_evidence_id": "cya_src_b22_0015", "notes": "Product-dependent classification is used because collateral rights and withdrawal conditions vary by loan agreement and regulatory resolution.", "confidence": "high" }, { "platform_id": "cya_plat_000033", "terms_status": "unclear", "asset_ownership_interpretation": "Donut customer balances were exposed through a Genesis-linked yield arrangement, but the reviewed sources do not establish one uniform ownership priority or claim treatment for every Donut product and user.", "affected_product": "Donut Grow, Build, Save and related account balances", "source_evidence_id": "cya_src_b23_0007", "notes": "Unclear is used because the reviewed public record establishes the counterparty restructuring but not one complete set of Donut contractual ownership terms.", "confidence": "medium" }, { "platform_id": "cya_plat_000034", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Finblox stated that deposited assets used Fireblocks infrastructure and could be held in cold wallets or lent to borrowers for users who opted into Earn, so custody and risk treatment varied by product and use.", "affected_product": "Finblox Earn, Crypto Vault and other custodial balances", "source_evidence_id": "cya_src_b23_0018", "notes": "Product-dependent classification follows Finblox's first-party custody explanation and does not establish one guaranteed recovery priority.", "confidence": "high" }, { "platform_id": "cya_plat_000035", "terms_status": "unclear", "asset_ownership_interpretation": "Pillow operated custodial deposit addresses and promised yield, but the reviewed public sources do not establish one complete contractual ownership or insolvency-priority treatment for all supported assets and products.", "affected_product": "Pillow crypto savings Cases and custodial wallet balances", "source_evidence_id": "cya_src_b24_0001", "notes": "Unclear is retained because a customer-facing product guide establishes custody and yield use but not a complete legal asset-ownership framework.", "confidence": "medium" }, { "platform_id": "cya_plat_000036", "terms_status": "platform_owned", "asset_ownership_interpretation": "The Nuri Bitcoin Interest Account was separately contracted with Celsius. The Celsius Earn Decision concluded that assets deposited in Earn accounts became Celsius property and estate assets, subject to reserved creditor defenses.", "affected_product": "Nuri / Bitwala Bitcoin Interest Account", "source_evidence_id": "cya_src_b24_0019", "notes": "This classification applies only to the Celsius-linked interest account and not to ordinary Nuri bank balances, custody wallets or self-custodial vaults.", "confidence": "high" }, { "platform_id": "cya_plat_000037", "terms_status": "platform_owned", "asset_ownership_interpretation": "Earner customers transferred all rights and title in their cryptocurrency to Block Earner, which could use and lend the assets at its sole discretion while owing a contractual return.", "affected_product": "USD Earner, Gold Earner and Crypto Earner", "source_evidence_id": "cya_src_b25_0013", "notes": "Platform-owned classification follows the product terms described in ASIC's amended concise statement. It applies only to Earner and not to the separate Access product.", "confidence": "high" }, { "platform_id": "cya_plat_000038", "terms_status": "unclear", "asset_ownership_interpretation": "Flint operated custodial yield balances and deployed funds through institutional and DeFi counterparties, but reviewed public sources do not establish one complete legal ownership or insolvency-priority treatment for every product and asset.", "affected_product": "Flint Money fixed-yield products and custodial balances", "source_evidence_id": "cya_src_b25_0017", "notes": "The first-party withdrawal guide establishes platform-controlled lend and unlend mechanics but does not provide a complete legal asset-ownership framework.", "confidence": "medium" }, { "platform_id": "cya_plat_000039", "terms_status": "unclear", "asset_ownership_interpretation": "Inlock operated a custodial Savings Account and controlled the lending, collateral and liquidation processes, but the reviewed public materials do not establish one complete legal ownership or insolvency-priority treatment for every customer asset and recovery path.", "affected_product": "Inlock Savings Account and other custodial customer-asset balances", "source_evidence_id": "cya_src_b26_0002", "notes": "Unclear is retained because product mechanics are documented but the complete contractual ownership and claim-priority framework was not verified across all recovery programs.", "confidence": "medium" }, { "platform_id": "cya_plat_000040", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Historical Stablehouse yield products and the current XBTO custody and trading accounts use different product structures. Current custody terms identify Stablehouse as the custody provider but cannot be applied retroactively to the earlier yield accounts.", "affected_product": "Historical Stablehouse yield accounts and current Stablehouse/XBTO custody accounts", "source_evidence_id": "cya_src_b26_0020", "notes": "Product-dependent classification preserves the distinction between the historical yield offering and the post-acquisition custody and trading platform.", "confidence": "medium" }, { "platform_id": "cya_plat_000041", "terms_status": "varies_by_product", "asset_ownership_interpretation": "AQRU terms cover wallet, custody, exchange, investment and multiple yield or strategy products, while current products use different underlying arrangements. One ownership or insolvency interpretation should not be applied across Auto, Flex, Maple, Trend, Ten, exchange, and receivables products.", "affected_product": "AQRU wallet, exchange, investment and yield products", "source_evidence_id": "cya_src_b27_0008", "notes": "The reviewed terms predate the 2023 ownership restructure and do not fully resolve current product-level asset ownership, counterparty exposure, security, or insolvency treatment. Reverify terms before any status or customer-outcome change.", "confidence": "medium" }, { "platform_id": "cya_plat_000042", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Current YouHodler terms describe segregated and off-balance-sheet handling for covered customer assets and allow custody through disclosed group or third-party providers, but product-specific rights and risks differ across wallets, conversion, Yield Account, loans, trading and other services.", "affected_product": "YouHodler Yield Account, wallets, conversion and crypto-backed loans", "source_evidence_id": "cya_src_b27_0016", "notes": "Segregation and custody language should not be converted into a universal customer-owned classification for every product or jurisdiction. Product terms, legal entity, limits, eligible assets and protections require periodic re-verification.", "confidence": "medium" }, { "platform_id": "cya_plat_000043", "terms_status": "platform_owned", "asset_ownership_interpretation": "Wirex X-Account terms state that customers transfer ownership of deposited crypto-assets to Wirex, which may use, hold, or manage those assets at its discretion while owing the contractual account balance and interest treatment.", "affected_product": "X-Account Flexible, X-Account Plus, and Fixed X-Account", "source_evidence_id": "cya_src_b28_0004", "notes": "The terms also state that X-Accounts are not bank or deposit accounts and are not covered by government-backed depositor compensation, insurance, or guarantee schemes. This classification applies only to X-Accounts, not every Wirex wallet, card, payment, or trading balance.", "confidence": "high" }, { "platform_id": "cya_plat_000044", "terms_status": "varies_by_product", "asset_ownership_interpretation": "SwissBorg Earn provides app-based access to multiple strategy-specific positions, but reviewed public materials do not establish one legal ownership, custody, insolvency, protocol, or liquidity treatment that applies uniformly to Smart Yield and every current Earn strategy.", "affected_product": "SwissBorg Smart Yield and SwissBorg Earn strategies", "source_evidence_id": "cya_src_b28_0012", "notes": "Current pricing establishes strategy-specific fees but does not by itself resolve legal asset ownership or insolvency priority. Each strategy's risk report, protocol allocation, cooldown, cap, redemption, and legal terms require separate review.", "confidence": "medium" }, { "platform_id": "cya_plat_000045", "terms_status": "platform_owned", "asset_ownership_interpretation": "Current CoinRabbit terms state that CoinRabbit acquires ownership of digital assets transferred as loan collateral and owns digital assets topped up into the Earn Interest Product while owing contractual return or balance obligations.", "affected_product": "CoinRabbit Earn Interest Product and crypto-backed loans", "source_evidence_id": "cya_src_b29_0005", "notes": "The current loan page separately markets fully reserved collateral and no rehypothecation. That marketing claim is recorded but does not replace the contractual title-transfer language. Product terms, reserves, use practices, and jurisdiction require continuing review.", "confidence": "high" }, { "platform_id": "cya_plat_000046", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Current May 2026 Renting Terms state that users retain legal ownership while assets are locked and operationally handled through Nebeus infrastructure and authorised providers. Older first-party agreements used a lease model and granted broader operational use rights, so the applicable interpretation depends on product, agreement version, contracting entity, and activation date.", "affected_product": "Nebeus Crypto Renting programs and related legacy agreements", "source_evidence_id": "cya_src_b29_0010", "notes": "Current product-specific terms should control current programs, but older positions may have been governed by different agreements. Loan collateral and general wallet balances are not assigned the same ownership model without separate product review.", "confidence": "medium" }, { "platform_id": "cya_plat_000047", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Matrixport's general platform terms defer to product-specific terms, and the reviewed fixed-income, structured-yield, saving, and loan materials do not establish one universal asset-ownership or custody model across all products and legal entities.", "affected_product": "Matrixport Fixed Income, flexible saving, structured-yield, and loan products", "source_evidence_id": "cya_src_b30_0007", "notes": "Current product pages describe different investment, lending, collateral, redemption, and settlement mechanics. Each product and jurisdiction requires its own terms review; general marketing language does not establish deposit insurance or universal principal protection.", "confidence": "medium" }, { "platform_id": "cya_plat_000048", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Coinchange's historical High Yield Account used an asset-management agreement, while current materials describe multiple individual, business, API, vault, custodial, and planned trust-minimized structures. Ownership and key control therefore depend on product, agreement version, implementation, legal entity, and client-facing arrangement.", "affected_product": "Coinchange Earn accounts, business products, APIs, vaults, and related yield infrastructure", "source_evidence_id": "cya_src_b30_0009", "notes": "Historical 2021 terms must not be silently applied to every current product. Current first-party custody and key-control statements are recorded as claims and require implementation-specific verification.", "confidence": "medium" }, { "platform_id": "cya_plat_000049", "terms_status": "unclear", "asset_ownership_interpretation": "YieldNodes describes customer BTC deposits being converted into operator-selected coins and deployed into masternodes or related activities, while customers held platform account balances and later could claim account-linked NFTs. The reviewed public materials do not establish a single verified legal-title model for the underlying assets, account claims, NFTs, or proposed YieldNodes Pro rights.", "affected_product": "YieldNodes masternode-rental accounts and account-linked restructuring instruments", "source_evidence_id": "cya_src_b31_0002", "notes": "The operator's explanation of fund flows is not a substitute for the complete historical customer contract or risk disclosure. Platform balances, underlying coins, NFT certificates, repurchase language, and future-platform access must remain separate. No asset backing or enforceable recovery value is inferred.", "confidence": "medium" }, { "platform_id": "cya_plat_000050", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Historical Cake DeFi and Bake staking, lending, Savings, liquidity-mining, and membership products used different custody and strategy structures. From 15 April 2026, current terms define only account maintenance and withdrawal of crypto balances converted to USD through Bake and a custodial institution, while all crypto functionality is blocked.", "affected_product": "Cake DeFi and Bake yield products, crypto balances, Bake Pro balances, and converted USD withdrawal accounts", "source_evidence_id": "cya_src_b31_0016", "notes": "Current withdrawal-only terms must not be retroactively applied to every historical product. Marketing statements such as principal protection are not treated as overriding contractual risk, custody, fee, forfeiture, conversion, or withdrawal provisions.", "confidence": "high" }, { "platform_id": "cya_plat_000051", "terms_status": "unclear", "asset_ownership_interpretation": "BitLendingClub operated centralized customer accounts and a peer-to-peer loan marketplace, but the reviewed public reporting and archive indexes do not establish one complete historical contract governing title to account balances, loan principal, borrower repayments, default recovery, or funds affected by the 2016 security incident.", "affected_product": "BitLendingClub and Loanbase peer-to-peer Bitcoin loans and customer account balances", "source_evidence_id": "cya_src_b32_0007", "notes": "Marketplace matching language does not prove that every customer retained direct legal title or that the platform bore borrower-default and security losses. Historical terms, jurisdiction, servicing, fees, default handling, withdrawal conditions, and shutdown procedures require date-specific archive review.", "confidence": "medium" }, { "platform_id": "cya_plat_000052", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Bitbond's historical marketplace lender positions, SME borrower obligations, and BB1 security-token rights were governed by different contracts and legal entities. The current tokenization-infrastructure terms do not replace or retroactively define those historical rights.", "affected_product": "Bitbond peer-to-peer SME loans, legacy lender accounts, and BB1 security-token claims", "source_evidence_id": "cya_src_b32_0009", "notes": "Marketplace lender claims and BB1 token-holder rights must remain separate. Offering descriptions, projected coupons, intended use of proceeds, loan servicing, issuer obligations, subordination, maturity, and redemption conditions should not be collapsed into a single ownership conclusion.", "confidence": "high" }, { "platform_id": "cya_plat_000053", "terms_status": "varies_by_product", "asset_ownership_interpretation": "BitMart's reviewed terms distinguish Savings subscriptions, staking assets, loan collateral, and ordinary Spot Wallet balances. Savings assets were transferred to an Earn account and could be used for BitMart operating purposes, staking assets could be deployed on-chain or through other earning activities, and loan collateral remained frozen under platform control. These structures do not support one uniform ownership or segregation conclusion across the product family.", "affected_product": "BitMart Flexible and Fixed Savings, Staking, Crypto Loans, Earn accounts, and pledged collateral", "source_evidence_id": "cya_src_b33_0004", "notes": "Product-specific agreements, asset, term, maturity, collateral, redemption, liquidation, suspension, and wind-down rules must be read separately. Transfer back to a Spot Wallet and availability of withdrawals do not by themselves establish legal segregation, principal protection, or completed recovery.", "confidence": "high" }, { "platform_id": "cya_plat_000054", "terms_status": "customer_owned", "asset_ownership_interpretation": "KriptoEarn version 4.0 states that users remain sole owners of qualified virtual currencies while authorizing Kriptomat to use them for staking on the user's behalf. The assets were represented in a Kriptomat Earn sub-account and remained subject to protocol-specific deposit and withdrawal periods, service suspension rights, dynamic rewards, partner or protocol execution, fees, and platform operational controls.", "affected_product": "KriptoEarn staking deposits, rewards, Earn account balances, and assets returned to Kriptomat main wallets during wind-down", "source_evidence_id": "cya_src_b33_0011", "notes": "Customer-owned reflects the reviewed KriptoEarn terms and does not imply self-custody, instantaneous withdrawal, guaranteed rewards, absence of partner or protocol exposure, or completed external withdrawal during the 2026 wind-down.", "confidence": "high" }, { "platform_id": "cya_plat_000055", "terms_status": "unclear", "asset_ownership_interpretation": "ASIC states that customer Australian dollars were converted to TAUD and allocated to Finder Wallet for its own working-capital use, with customers receiving Australian dollars when exiting. This establishes centralized economic control but does not, by itself, resolve every legal-title, trust, segregation or insolvency question. The courts held that Finder Earn was not a debenture.", "affected_product": "Finder Earn deposits, TAUD conversion, working-capital allocation, fixed returns and exit balances", "source_evidence_id": "cya_src_b34_0001", "notes": "Do not classify the product as a bank deposit, insured account, self-custody arrangement, trust asset or upheld unlicensed debenture. The full customer return is an outcome fact and does not retroactively remove the product's platform-credit and legal-structure risks.", "confidence": "high" }, { "platform_id": "cya_plat_000056", "terms_status": "unclear", "asset_ownership_interpretation": "The Singapore court records that customer records were missing and customers did not know which AAX entities they contracted with. The reviewed savings materials describe centralized subscriptions and rewards but do not establish one legal owner, segregated pool, trust structure, reserve, deploying entity or creditor class for every savings balance.", "affected_product": "AAX Flexible Savings, Fixed Savings, AAB Plus and associated exchange or wallet balances", "source_evidence_id": "cya_src_b34_0011", "notes": "Savings, spot, derivatives and wallet balances must not be collapsed into one ownership model. Product flexibility, lock-up duration, APY, token rewards, exchange custody, legal entity and liquidation claim treatment vary and remain incompletely documented. Police allegations and missing digital-asset keys do not independently resolve customer legal title.", "confidence": "high" }, { "platform_id": "cya_plat_000057", "terms_status": "unclear", "asset_ownership_interpretation": "CVM records establish that Bluebenx Tecnologia Financeira S.A. offered crypto-linked collective investment contracts and later faced administrative sanctions, but the reviewed sources do not establish one universal customer ownership, segregation, trust, custody or creditor-right model for BlueBenx Finance balances and investment products.", "affected_product": "CriptoSavings, BlueBenx DeFi 90/180/360-day investment contracts and other BlueBenx Finance balances affected by the 2022 suspension", "source_evidence_id": "cya_src_b35_0002", "notes": "Do not infer self-custody, insured deposits, trust assets, platform ownership or a uniform creditor class from the product labels or CVM securities analysis. The later CVM fraud finding concerns securities-market conduct and does not independently resolve customer legal title or recovery.", "confidence": "high" }, { "platform_id": "cya_plat_000058", "terms_status": "unclear", "asset_ownership_interpretation": "Hotbit support notices show that investment products were subscribed, closed and redeemed inside a centralized Hotbit Investment account. This establishes platform-administered account control but does not establish legal ownership of underlying assets, segregation, reserve backing, trust treatment, protocol-level custody or the user's rights during an exchange shutdown.", "affected_product": "Hotbit DeFi Farm, staking investment and related Investment Center products", "source_evidence_id": "cya_src_b35_0005", "notes": "Automatic product redemption into an investment account must not be described as external withdrawal, principal protection or completed repayment. Product-specific staking and DeFi labels do not prove direct user control of validators, protocols or smart contracts.", "confidence": "high" }, { "platform_id": "cya_plat_000059", "terms_status": "unclear", "asset_ownership_interpretation": "Historical FTX Earn support described yield credited to customer accounts, while the post-bankruptcy portal converts account balances and Earn amounts into the relevant customer-entitlement and claim process. The reviewed sources do not establish one universal ownership, segregation, trust, custody or creditor-right model for every FTX-branded Earn variant.", "affected_product": "FTX App Earn and related FTX-branded Earn balances", "source_evidence_id": "cya_src_b36_0002", "notes": "Do not infer that the Earn label created a separate protected asset pool, deposit insurance, direct staking ownership or a product-specific claim class. Contracting entity and jurisdiction remain material to claim treatment.", "confidence": "high" }, { "platform_id": "cya_plat_000060", "terms_status": "unclear", "asset_ownership_interpretation": "The Liquid-Celsius integration confirms a customer-facing yield product and Celsius earning model, but the reviewed material does not establish one universal legal transfer, custody, segregation, title or creditor-right structure for all Liquid Earn balances. Liquid's current claim instructions route customers through the FTX Chapter 11 process rather than clarifying a separate product ownership model.", "affected_product": "Liquid Earn and balances associated with the Celsius yield integration", "source_evidence_id": "cya_src_b36_0006", "notes": "Do not infer that every Liquid Earn customer was a direct Celsius creditor or that every balance was legally held by the same Liquid, Quoine, FTX or Celsius entity. Product marketing does not resolve those boundaries.", "confidence": "high" }, { "platform_id": "cya_plat_000061", "terms_status": "unclear", "asset_ownership_interpretation": "Current Swyftx support establishes that assets were represented in an Earn wallet and later returned to a trade wallet, but the reviewed sources do not establish the historical Earn product's exact legal ownership, segregation, trust, creditor-right or downstream counterparty structure. Current generic Swyftx terms are not applied retroactively to the discontinued product.", "affected_product": "Swyftx Earn / Swyftx Staking", "source_evidence_id": "cya_src_b37_0001", "notes": "Do not infer that the former Staking name meant direct on-chain staking, that assets remained legally customer-owned throughout, or that current generic exchange terms reproduce the historical Earn terms. Product closure and internal return mechanics are better evidenced than historical ownership terms.", "confidence": "high" }, { "platform_id": "cya_plat_000062", "terms_status": "varies_by_product", "asset_ownership_interpretation": "The reviewed KuCoin materials establish account and redemption mechanics for multiple Earn product families but do not support one universal asset-ownership, segregation, trust or creditor-right interpretation across savings, staking, lending and structured products.", "affected_product": "KuCoin Earn", "source_evidence_id": "cya_src_b38_0004", "notes": "Treat product-specific terms separately. Do not infer that a Funding/Financial-account presentation means assets remain legally customer-owned, segregated or principal-protected, and do not infer a single counterparty model across KuCoin Earn categories.", "confidence": "high" }, { "platform_id": "cya_plat_000063", "terms_status": "varies_by_product", "asset_ownership_interpretation": "OKX's Simple Earn User Agreement states that subscribed digital assets are deposited into the service and cannot be accessed, traded, sold, converted or otherwise used while applicable positions are active. The reviewed terms do not justify one universal legal-title or segregation conclusion across all jurisdictions and fixed/flexible product variants.", "affected_product": "OKX Simple Earn", "source_evidence_id": "cya_src_b38_0006", "notes": "The agreement explicitly states that Simple Earn is not principal-protected. Fixed and flexible terms, borrower matching, redemption restrictions and applicable OKX entities can differ, so CYA keeps ownership interpretation product- and jurisdiction-sensitive rather than forcing a customer-owned/platform-owned label.", "confidence": "high" }, { "platform_id": "cya_plat_000064", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Gate's current flexible-term documentation states that subscribed assets are transferred into Simple Earn and used as working capital for lending to other users. The reviewed sources do not justify one universal asset-ownership, segregation, trust or creditor-right conclusion across all flexible, fixed, promotional or future Simple Earn variants.", "affected_product": "Gate Simple Earn", "source_evidence_id": "cya_src_b39_0003", "notes": "Do not convert Gate's reserve or safety marketing into a principal or solvency guarantee. Flexible lending mechanics are directly documented, while fixed-term and other variants must retain separate terms and risk treatment.", "confidence": "high" }, { "platform_id": "cya_plat_000065", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Bybit's current Easy Earn materials describe product-specific subscription, yield and redemption mechanics but do not justify one universal legal-title, segregation, trust or creditor-right conclusion across jurisdictions or all flexible/fixed variants.", "affected_product": "Bybit Easy Earn", "source_evidence_id": "cya_src_b39_0007", "notes": "Bybit currently labels Easy Earn flexible/fixed products as principal-protected. CYA preserves that as attributed product wording and does not reinterpret it as a universal legal obligation, bankruptcy priority, custody segregation or platform-solvency guarantee.", "confidence": "high" }, { "platform_id": "cya_plat_000066", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Reviewed Binance disclosures do not support one universal ownership, segregation, trust or creditor-priority conclusion across all Simple Earn products and jurisdictions. Binance Japan specifically describes lending-based Simple Earn assets as potentially non-segregated and without priority repayment in bankruptcy.", "affected_product": "Binance Simple Earn", "source_evidence_id": "cya_src_b40_0003", "notes": "Do not generalize principal-protection marketing or one jurisdiction's terms to all Binance entities. Product and legal-entity boundaries remain explicit.", "confidence": "high" }, { "platform_id": "cya_plat_000067", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Bitget's current Simple Earn terms state that Bitget is a platform provider, third parties may manage underlying assets, and Bitget or responsible third-party custodians may hold custody. The terms do not create a universal trust or pooled-investment arrangement and do not guarantee return of subscribed assets.", "affected_product": "Bitget Simple Earn", "source_evidence_id": "cya_src_b40_0007", "notes": "Current governing risk terms take precedence over promotional descriptions of principal security. Do not infer one ownership, custody or creditor-right model across all products and networks.", "confidence": "high" }, { "platform_id": "cya_plat_000068", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Phemex's current Earn terms explicitly state that Earn Assets used for Phemex Savings are not segregated, may be commingled with assets of other users, Phemex and affiliates, and may be used for operating purposes such as loans and on-chain staking. The terms therefore do not support treating Savings assets as segregated customer property with universal principal protection.", "affected_product": "Phemex Savings", "source_evidence_id": "cya_src_b41_0002", "notes": "Current governing terms control the canonical risk interpretation. Historical marketing descriptions such as risk-free service or guaranteed estimated returns are retained only as historical company statements and are not treated as overriding current asset-treatment disclosures.", "confidence": "high" }, { "platform_id": "cya_plat_000069", "terms_status": "varies_by_product", "asset_ownership_interpretation": "WhiteBIT's current terms define Crypto Lending as lending digital assets to WhiteBIT using available plans. The reviewed terms do not establish a bank-deposit, regulated-savings, segregated-trust or universal fiduciary arrangement for those lent assets, and they preserve service, market and plan-specific risks.", "affected_product": "WhiteBIT Crypto Lending", "source_evidence_id": "cya_src_b41_0006", "notes": "The canonical record does not generalize promotional security or principal-return language from a specific plan into a universal ownership or solvency guarantee. Third-party proposals appearing in the Crypto Lending section remain outside this WhiteBIT-borrower product identity unless separately reviewed.", "confidence": "high" }, { "platform_id": "cya_plat_000070", "terms_status": "varies_by_product", "asset_ownership_interpretation": "HTX's Simple Earn Agreement governs purchases and redemptions of flexible and fixed-term Earn products and states that Flexible subscriptions are matched with borrowing demand generated by HTX services. The reviewed agreement does not establish that subscribed assets are segregated deposits or trust property, so CYA does not infer universal deposit-like ownership or principal protection.", "affected_product": "HTX Simple Earn", "source_evidence_id": "cya_src_b42_0001", "notes": "Flexible rates are explicitly non-fixed and market-dependent, and the agreement contains broad investment-risk disclosures. Product-specific redemption language is not converted into a platform-wide solvency guarantee.", "confidence": "high" }, { "platform_id": "cya_plat_000071", "terms_status": "varies_by_product", "asset_ownership_interpretation": "CoinEx's reviewed Flexible Savings materials describe subscribed assets generating returns linked to Margin Trading/Loans borrowing demand and document that redemptions may wait when idle savings assets are insufficient until borrowers return coins. The reviewed product materials do not establish a segregated trust or bank-deposit ownership model, so CYA leaves legal title beyond those mechanics unresolved.", "affected_product": "CoinEx Flexible Savings", "source_evidence_id": "cya_src_b42_0008", "notes": "CoinEx characterizes the product as low-risk and some product surfaces use principal-protected language, but those company characterizations are not treated as universal custody, title or solvency guarantees. Exact predecessor rename and launch dates remain unresolved.", "confidence": "high" }, { "platform_id": "cya_plat_000072", "terms_status": "varies_by_product", "asset_ownership_interpretation": "BingX's reviewed Wealth/Earn materials describe centralized subscription and redemption mechanics but do not establish a universal segregated-deposit or trust ownership structure. Wealth assets used as futures margin can be forcibly redeemed and lost through liquidation, so CYA does not treat current 'principal protected' marketing wording as a universal legal or solvency guarantee.", "affected_product": "BingX Earn", "source_evidence_id": "cya_src_b43_0004", "notes": "Current BingX Earn surfaces pair principal-protection / profit-guarantee marketing with an explicit risk warning that users may lose part or all of account funds. The exact Wealth-to-Earn rename date remains unresolved.", "confidence": "high" }, { "platform_id": "cya_plat_000073", "terms_status": "varies_by_product", "asset_ownership_interpretation": "MEXC's current Earn Service Agreement states that subscribed assets may be combined with other users' assets and that users authorize MEXC to deal with those assets as it deems fit to generate returns. The same agreement explicitly states that Earn is not principal-protected and that users risk principal loss in whole or in part. CYA therefore does not infer deposit-like segregation or guaranteed title protection.", "affected_product": "MEXC Savings", "source_evidence_id": "cya_src_b43_0006", "notes": "APR is variable and not guaranteed. Fixed Savings is locked until term expiry, while Flexible Savings supports redemption under product rules. On-Chain Earn is excluded from this product identity.", "confidence": "high" }, { "platform_id": "cya_plat_000074", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Bitfinex's reviewed Margin Funding materials describe users placing assets into a Funding Wallet and supplying them through a P2P market to traders or Bitfinex Borrow demand. They describe collateralisation, liquidation and return mechanics but do not establish a universal segregated-deposit or trust ownership structure. Bitfinex explicitly states that Margin Funding is not risk-free and that extreme losses could ultimately be shared with funding providers.", "affected_product": "Bitfinex Margin Funding", "source_evidence_id": "cya_src_b44_0004", "notes": "Lending Pro is an automation layer for the same funding market. Collateral and Bitfinex risk controls are not treated as a universal principal or solvency guarantee.", "confidence": "high" }, { "platform_id": "cya_plat_000075", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Poloniex's reviewed Earn materials describe subscription and redemption within the exchange but do not establish a universal segregated-deposit or trust structure across all Earn products. Poloniex characterises its Earn products as principal-protected, while separate first-party notices warn of high market risk and possible investment losses; CYA therefore retains principal-protection language only as an attributed product statement.", "affected_product": "Poloniex Earn", "source_evidence_id": "cya_src_b44_0007", "notes": "Flexible and fixed-term mechanics, quotas, APYs and redemption rules vary by product. The launch-related risk warning is separately preserved in evidence `cya_src_b44_0006`.", "confidence": "high" }, { "platform_id": "cya_plat_000076", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Current Premium Earn terms state that participants remain the ultimate legal and beneficial owner of digital assets allocated to Premium Earn, while allocated USDT remains in the Platform Wallet, cannot be withdrawn or transferred during allocation, and can be used as derivatives margin where enabled. The same terms reserve rights to restrict redemption in specified circumstances. CYA does not generalize these Premium Earn terms to every Flipster Earn variant or interpret them as a segregated bank-deposit or insolvency guarantee.", "affected_product": "Flipster Earn / Premium Earn", "source_evidence_id": "cya_src_b45_0002", "notes": "The reviewed 2024 campaign and current Premium Earn product have different reward and risk mechanics. Premium Earn currently uses a 24-hour withdrawal lockup and can remain eligible as derivatives margin.", "confidence": "high" }, { "platform_id": "cya_plat_000077", "terms_status": "unclear", "asset_ownership_interpretation": "Reviewed public Bitrue Power Piggy materials establish exchange-hosted subscription, daily reward and redemption mechanics but do not provide sufficient product-specific legal language to determine one universal segregation, title-transfer or trust structure for all Power Piggy assets and periods. CYA therefore leaves the umbrella legal-title interpretation unresolved rather than inferring deposit-like protection from flexible redemption or reward marketing.", "affected_product": "Bitrue Power Piggy", "source_evidence_id": "cya_src_b45_0008", "notes": "Flexible, BTR-boosted and lockup products can use different mechanics. Current 2026 operation is verified separately; lack of a public umbrella legal-title clause is preserved as uncertainty rather than filled by inference.", "confidence": "medium" }, { "platform_id": "cya_plat_000078", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Current BloFin Earn Service Agreement states users are legal owners of deposited Digital Assets, but after subscription or lockup users entrust and authorize BloFin as an intermediary to perform actions on subscribed assets, including node voting and Digital Asset gain. The same agreement does not guarantee principal repayment or displayed interest. CYA therefore does not treat promotional Simple Earn safety wording as a bank-deposit, trust, segregation or solvency guarantee.", "affected_product": "BloFin Earn", "source_evidence_id": "cya_src_b46_0002", "notes": "Flexible, fixed and Auto-Earn differ in interest and redemption mechanics. Current governing agreement takes precedence over promotional safety descriptions for canonical risk interpretation.", "confidence": "high" }, { "platform_id": "cya_plat_000079", "terms_status": "varies_by_product", "asset_ownership_interpretation": "The LBank Earn Service Agreement requires users to lawfully own assets used in Earn but permits LBank to aggregate assets with those of other users and authorizes the platform to pledge, lend, provide liquidity, hedge or otherwise use assets to generate returns. The agreement explicitly says there is no principal protection and users may face partial or total principal loss, and states LBank is not a trustee or financial adviser. CYA therefore does not infer deposit-like segregation or fiduciary protection.", "affected_product": "LBank Earn", "source_evidence_id": "cya_src_b46_0005", "notes": "Spot Earn has product-specific flexible account and institutional-arbitrage mechanics that must not be generalized to Locked, Futures Earn or all LBank Earn products.", "confidence": "high" }, { "platform_id": "cya_plat_000080", "terms_status": "unclear", "asset_ownership_interpretation": "Reviewed Toobit Earn materials establish that subscribed assets move from the user's Spot account to an Earn account and current general Terms of Use identify jurisdiction-dependent contracting entities. They do not provide sufficient Earn-specific language to determine one universal segregation, title-transfer, trust or insolvency-treatment structure. CYA therefore leaves the legal-title interpretation unresolved rather than inferring deposit-like protection from principal-return mechanics or promotional APR wording.", "affected_product": "Toobit Earn", "source_evidence_id": "cya_src_b47_0004", "notes": "Flexible and Fixed Earn use different accrual and redemption mechanics. Current Toobit Terms of Use identify Hopeful Technology Co. Ltd. for non-EU/EEA users and Elyndret Spółka Z Ograniczoną Odpowiedzialnością for EU/EEA users, but do not resolve an Earn-specific ownership model in the reviewed public text.", "confidence": "medium" }, { "platform_id": "cya_plat_000081", "terms_status": "unclear", "asset_ownership_interpretation": "The Bitunix Easy Earn agreement defines asset movement from Spot Account to Earn Account and describes principal/interest return mechanics plus a 15% interest-distribution risk reserve. The reviewed public terms do not establish a universal segregated bank-deposit, trust, fiduciary or insolvency-protected ownership structure for Easy Earn assets. CYA therefore leaves legal title and segregation unresolved rather than interpreting the risk reserve or educational capital-protection language as a universal guarantee.", "affected_product": "Bitunix Easy Earn", "source_evidence_id": "cya_src_b47_0005", "notes": "The current general Bitunix Risk Disclosure separately states that different services carry distinct risks and Bitunix does not act as a fiduciary or investment manager absent applicable-law requirements.", "confidence": "medium" }, { "platform_id": "cya_plat_000082", "terms_status": "unclear", "asset_ownership_interpretation": "The AscendEX Staking Agreement states that designated tokens are staked through third-party validators and the Yield Farming Agreement states that designated tokens may be deposited into relevant DeFi smart contracts. These agreements identify product mechanisms and a contracting entity but do not establish one universal segregation, trust, title-transfer or insolvency-treatment structure for every AscendEX Earn product. CYA therefore leaves umbrella-product legal title unresolved.", "affected_product": "AscendEX Earn", "source_evidence_id": "cya_src_b48_0004", "notes": "The staking agreement states estimated reward yields are not guaranteed. Product-specific terms for staking, yield farming, fixed earn and other Earn mechanisms must be interpreted separately; current public material is not used to infer deposit-like protection or universal principal protection.", "confidence": "medium" }, { "platform_id": "cya_plat_000083", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Bitpanda Earn must be interpreted by product. For Earn on Stablecoins, first-party material expressly describes a title-transfer loan: ownership passes to Bitpanda during the Earn transaction, the assets are outside regulated custody, and the customer is an unsecured creditor. Reviewed Staking material describes a separate proof-of-stake service and is not used to extend that title-transfer treatment to staking assets.", "affected_product": "Bitpanda Earn", "source_evidence_id": "cya_src_b49_0004", "notes": "Earn on Stablecoins is not a banking or deposit product and has no deposit protection. Staking and stablecoin lending have different legal and economic mechanics, so CYA does not assign one umbrella ownership status beyond `varies_by_product`.", "confidence": "high" }, { "platform_id": "cya_plat_000084", "terms_status": "varies_by_product", "asset_ownership_interpretation": "CEX.IO Earn combines distinct Staking and Savings mechanisms. First-party Savings material states that customer funds may facilitate lending and other crypto-market activity, while Staking material links rewards to proof-of-stake participation. The reviewed sources do not establish one universal legal-title, segregation or insolvency-treatment rule across both products.", "affected_product": "CEX.IO Earn", "source_evidence_id": "cya_src_b49_0007", "notes": "Product-specific terms, jurisdictional availability and redemption mechanics require separate interpretation. The lending description is not converted into an unsupported universal title-transfer conclusion, and the older Automated Staking sunset is not treated as a change in Savings ownership terms.", "confidence": "medium" }, { "platform_id": "cya_plat_000085", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Bitvavo Earn combines Staking provided by Bitvavo B.V. and Lending provided by Bitvavo Custody B.V. Current first-party material describes different mechanisms and counterparties for the two services but does not establish one universal legal-title, segregation or insolvency-treatment rule across the Earn umbrella. CYA therefore preserves product-specific treatment rather than inferring a single ownership model.", "affected_product": "Bitvavo Earn", "source_evidence_id": "cya_src_b51_0001", "notes": "Bitvavo states Staking and Lending are currently outside MiCA regulation and that regulated-service safeguards may not extend to them. This regulatory statement is not itself converted into a title-transfer, deposit or principal-protection conclusion.", "confidence": "medium" }, { "platform_id": "cya_plat_000086", "terms_status": "unclear", "asset_ownership_interpretation": "Coinmetro's BTC Earn launch material states that BTC is held inside the Coinmetro account for a selected fixed term and returned at term end, but the reviewed public material does not establish whether legal title transfers, whether assets are segregated, or how they would be treated in insolvency. CYA leaves those questions unresolved.", "affected_product": "Coinmetro BTC Earn", "source_evidence_id": "cya_src_b51_0006", "notes": "The first-party term-end return promise and statement that no external lending platforms or third-party protocols are used do not establish independent principal protection, insurance, segregation or solvency. Underlying internal reward economics also remain undisclosed in the reviewed material.", "confidence": "medium" }, { "platform_id": "cya_plat_000087", "terms_status": "customer_owned", "asset_ownership_interpretation": "Current reviewed Uphold staking terms state that users retain ownership of eligible cryptoassets chosen for staking and that each staked eligible cryptoasset remains user property while staked. Current U.S. terms additionally state that beneficial ownership remains unaffected while Uphold retains custodial responsibility. CYA records this as customer-owned under the reviewed staking terms, while preserving jurisdictional limitations and separate protocol/custody risks.", "affected_product": "Uphold Staking", "source_evidence_id": "cya_src_b52_0001", "notes": "Customer-owned reflects express current staking-terms language, not a guarantee against slashing, custodial loss, platform insolvency or every jurisdiction's legal treatment. Geographic restrictions and applicable contractual entities vary.", "confidence": "high" }, { "platform_id": "cya_plat_000088", "terms_status": "unclear", "asset_ownership_interpretation": "HashKey Exchange's reviewed launch and staking disclosure materials describe independent-node staking, validator-provider arrangements, rewards, fees and staking risks but do not establish whether customer ETH legal title transfers, whether assets are legally segregated, or how staked ETH would be treated in insolvency. CYA therefore leaves asset ownership treatment unclear.", "affected_product": "HashKey Exchange ETH Staking", "source_evidence_id": "cya_src_b52_0006", "notes": "Independent-node mechanics and statements that node rewards belong to the user do not by themselves resolve legal title, segregation, creditor treatment or principal protection.", "confidence": "medium" }, { "platform_id": "cya_plat_000089", "terms_status": "customer_owned", "asset_ownership_interpretation": "eToro's first-party 2020 launch announcement and current staking surface state that staked cryptoassets remain the property of eToro users while eToro executes the staking process on their behalf. CYA records this as customer-owned product treatment under the reviewed staking materials, while recognizing that contractual entity, eligibility and detailed terms vary by jurisdiction.", "affected_product": "eToro Staking", "source_evidence_id": "cya_src_b53_0002", "notes": "Customer-owned reflects express first-party product language, not a guarantee of segregation, principal protection, custody outcome or insolvency treatment. Slashing, protocol, liquidity, platform and regulatory risks remain material.", "confidence": "medium" }, { "platform_id": "cya_plat_000090", "terms_status": "unclear", "asset_ownership_interpretation": "Robinhood's 2024 Europe launch states that European customers own their crypto while Robinhood holds it on their behalf, but the current staking service spans distinct U.S. and European legal entities and reviewed current U.S. staking material does not establish one universal legal-title, segregation or insolvency-treatment model. CYA therefore leaves current cross-jurisdiction asset ownership treatment unclear.", "affected_product": "Robinhood Crypto Staking", "source_evidence_id": "cya_src_b53_0006", "notes": "The regional ownership statement is preserved without being generalized. Current staking mechanics, third-party partner use and account custody do not by themselves establish universal creditor or insolvency treatment.", "confidence": "medium" }, { "platform_id": "cya_plat_000091", "terms_status": "customer_owned", "asset_ownership_interpretation": "Bitstamp's current first-party staking educational material states that customers maintain full ownership of their crypto assets when staking with Bitstamp Earn, while Bitstamp acts as service provider. CYA records this as customer-owned product treatment under the reviewed staking material while recognizing that contracting entity, supported assets and service availability vary by jurisdiction.", "affected_product": "Bitstamp Earn Staking", "source_evidence_id": "cya_src_b54_0003", "notes": "Customer-owned reflects express first-party product language, not a guarantee of legal segregation, principal protection, custody outcome or insolvency treatment across all Bitstamp entities and jurisdictions. Protocol, slashing, liquidity, market and regulatory risks remain material.", "confidence": "medium" }, { "platform_id": "cya_plat_000092", "terms_status": "customer_owned", "asset_ownership_interpretation": "Current reviewed Revolut staking materials state that Revolut continues holding staked cryptoassets on the user's behalf and that the user remains beneficial owner. CYA records this as customer-owned beneficial-interest treatment for the reviewed staking product while preserving that legal-title, safeguarding, contracting-entity and insolvency treatment may differ by jurisdiction and terms version.", "affected_product": "Revolut Crypto Staking", "source_evidence_id": "cya_src_b55_0002", "notes": "Customer-owned reflects express beneficial-ownership language in current first-party staking terms and product material. It is not a universal conclusion that the customer holds legal title, that assets are legally segregated, or that principal or insolvency protection applies across all Revolut entities and jurisdictions.", "confidence": "medium" }, { "platform_id": "cya_plat_000093", "terms_status": "unclear", "asset_ownership_interpretation": "Reviewed first-party product/help material establishes that Bitso Earnings operates on cryptoassets held in the user's Bitso account and that different yield methods can involve staking, protocols or specialized third-party yield providers. It does not establish one universal legal-title, segregation or insolvency-treatment model across all Earnings assets and methods.", "affected_product": "Bitso Earnings", "source_evidence_id": "cya_src_b56_0004", "notes": "Current marketing/product language about assets users hold or own is not sufficient to classify universal legal title or segregation across provider-sourced, stablecoin, staking and other yield methods. Terms remain unclear rather than extrapolating one product's mechanics to the entire umbrella.", "confidence": "medium" }, { "platform_id": "cya_plat_000094", "terms_status": "customer_owned", "asset_ownership_interpretation": "Current Luno Staking Terms explicitly state that staked cryptocurrencies are not transferred to the third-party validator, Luno continues holding them on the user's behalf, and the user remains beneficial owner in accordance with Luno's Terms of Use.", "affected_product": "Luno Staking", "source_evidence_id": "cya_src_b56_0009", "notes": "Customer-owned reflects express beneficial-ownership language in current first-party staking terms. It is not a universal conclusion about legal-title form, asset segregation, principal protection or insolvency treatment across every Luno entity and jurisdiction. Slashing may affect rewards or principal.", "confidence": "medium" }, { "platform_id": "cya_plat_000095", "terms_status": "customer_owned", "asset_ownership_interpretation": "Ndax's current User Agreement states that users receive full rights, interests and title to Virtual Assets purchased on the platform upon completion of purchase and that assets remaining on-platform are held under disclosed custody arrangements. Current staking disclosures describe staking or delegation of users' Crypto Assets through approved third-party validators. CYA records customer-owned treatment for the reviewed on-platform staking assets without treating it as a principal or insolvency guarantee.", "affected_product": "Ndax Staking", "source_evidence_id": "cya_src_b57_0004", "notes": "Customer-owned is grounded in express current User Agreement title language and current staking/custody disclosures. Staking-specific validator, protocol, slashing, liquidity, custody and regulatory risks remain. This classification should be reverified if Ndax's governing agreement or custody model changes.", "confidence": "high" }, { "platform_id": "cya_plat_000096", "terms_status": "customer_owned", "asset_ownership_interpretation": "VALR's current Terms of Service explicitly state that rights, title and ownership of Staked Assets remain at all times with the Eligible Account Holder and do not transfer to VALR; Staked Assets are held for the account holder, are not VALR property and are not subject to claims of VALR creditors.", "affected_product": "VALR Staking", "source_evidence_id": "cya_src_b57_0007", "notes": "Customer-owned is directly supported by current staking-specific governing terms, including creditor-treatment language. It does not imply guaranteed rewards or eliminate slashing, protocol, validator, market, liquidity or operational risk. Reverify on future terms changes.", "confidence": "high" }, { "platform_id": "cya_plat_000097", "terms_status": "customer_owned", "asset_ownership_interpretation": "Newton's current Terms of Use state that account Digital Assets are fully-paid assets beneficially owned by customers, not Newton, and held in trust. Current staking terms state staked assets remain in Newton omnibus accounts with the custodian, remain attributed to the user's account, and custody, possession and control are not transferred to validators. CYA records customer-owned treatment for the reviewed staking product without treating it as a principal, reward or insolvency guarantee.", "affected_product": "Newton Earn (Staking)", "source_evidence_id": "cya_src_b58_0002", "notes": "Customer-owned is grounded in express current beneficial-ownership, trust and staking-custody language. Validator, protocol, slashing, liquidity, market, platform/custody, regulatory and insolvency-related risks remain. Reverify if Newton's governing terms or staking/custody model changes.", "confidence": "high" }, { "platform_id": "cya_plat_000098", "terms_status": "customer_owned", "asset_ownership_interpretation": "Wealthsimple's current Crypto Product Risk Disclosure states that customer cryptoassets are fully-paid assets beneficially owned by customers, held in trust and separated from Wealthsimple's own assets. CYA records customer-owned treatment for the reviewed staking product while keeping staking, validator, protocol, liquidity and platform risks separate from that ownership treatment.", "affected_product": "Wealthsimple Crypto Staking", "source_evidence_id": "cya_src_b58_0005", "notes": "Customer-owned is grounded in express current beneficial-ownership, trust and separation language. It does not imply guaranteed rewards, principal protection, immediate liquidity or elimination of slashing, validator, protocol, market, operational, regulatory or insolvency-related risk. Reverify on future terms changes.", "confidence": "high" }, { "platform_id": "cya_plat_000099", "terms_status": "platform_owned", "asset_ownership_interpretation": "Bit2Me's current Earn terms state that users transfer and lock eligible cryptoassets in favor of Bit2Me and permit Bit2Me to transfer, dispose of or use those assets during the Earn period. CYA records platform-owned treatment for assets while they are subject to the reviewed Earn arrangement; this classification is product-scoped and is not applied to ordinary Bit2Me wallet balances or other products.", "affected_product": "Bit2Me Earn", "source_evidence_id": "cya_src_b59_0001", "notes": "Platform-owned is grounded in the express current Earn-specific transfer and Bit2Me use/disposal rights. It does not establish guaranteed principal, guaranteed rewards, immediate liquidity or immunity from platform, counterparty, staking, market, operational, regulatory or insolvency-related risk. Reverify if governing Earn terms change.", "confidence": "high" }, { "platform_id": "cya_plat_000100", "terms_status": "platform_owned", "asset_ownership_interpretation": "Coinmerce's current Earn terms define the client as lender and Coinmerce Earn B.V. as borrower of eligible cryptoassets dedicated to the Yield Account. Those assets leave the ordinary Foundation custody structure and may be used by Coinmerce Earn for on-lending or staking. CYA therefore records platform-owned treatment for the reviewed Earn lending arrangement rather than customer-owned custody.", "affected_product": "Coinmerce Earn", "source_evidence_id": "cya_src_b59_0006", "notes": "Platform-owned is grounded in the explicit lender/borrower structure and transfer of dedicated Earn assets outside ordinary Foundation custody. It does not imply guaranteed principal or yield and does not eliminate borrower, third-party, staking, market, liquidity, operational, regulatory or insolvency-related risk. Reverify on future terms changes.", "confidence": "high" }, { "platform_id": "cya_plat_000101", "terms_status": "unclear", "asset_ownership_interpretation": "XORA's June 2026 terms state that supported deposited balances are held in custodial wallets managed by XORA, but the reviewed language does not clearly state whether legal or beneficial ownership transfers to XORA, remains with the customer, or how ownership would be treated in an insolvency. CYA therefore records the asset-ownership treatment as unclear rather than inferring platform-owned or customer-owned status from custody alone.", "affected_product": "XORA Finance XRP Yield", "source_evidence_id": "cya_src_b60_0003", "notes": "Custodial control is not treated as equivalent to legal ownership. The terms also permit withdrawal limits or holds for security/compliance purposes and state that yields are estimates rather than guarantees. Reverify if XORA publishes a more explicit legal-ownership or insolvency-treatment clause.", "confidence": "medium" }, { "platform_id": "cya_plat_000102", "terms_status": "unclear", "customer_claim_priority": "unknown", "governing_law_or_jurisdiction": "The public website terms state Cayman Islands governing law, while the first-party company page identifies Izakaya Limited and a Hong Kong operating address. The logged-in lending flow appears to present separate contract content that was not available in the reviewed public sources.", "asset_ownership_interpretation": "The reviewed public pages do not clearly establish whether lending transfers legal or beneficial ownership of customer assets, the exact lending counterparty, or how lent assets are deployed, rehypothecated, segregated, or treated in an insolvency.", "bankruptcy_treatment": "Not established by the reviewed public terms.", "withdrawal_limitations": "Lending contracts use selected lock periods and campaign rewards may require specified term completion, eligibility checks, or KYC/application steps. No platform-wide withdrawal suspension is established by the reviewed sources.", "source_evidence_id": "cya_src_b61_0012", "last_verified_at": "2026-08-23", "confidence": "medium", "notes": "A current first-party lending article explicitly states that crypto-lending principal is not guaranteed. Generic website terms are not treated as complete lending-product terms. The Hong Kong operator identity and Cayman governing-law clause are preserved separately rather than reconciled by inference. Reverify if IZAKA-YA publishes public lending-contract terms that resolve counterparty, ownership, custody deployment, insolvency treatment, insurance, regulatory authorization, or the economic source of promotional yields." }, { "platform_id": "cya_plat_000103", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Current BTCC Earn support describes centralized subscription and redemption through the BTCC wallet but does not establish a universal segregated-deposit, trust, bankruptcy-remote, or insured ownership structure for Earn assets. CYA therefore does not treat product-return mechanics or VASP-register language as a principal-protection or asset-segregation guarantee.", "affected_product": "BTCC Earn", "source_evidence_id": "cya_src_b62_0003", "notes": "Flexible Earn permits redemption under current product rules, while Fixed Earn is term-based and early redemption forfeits interest. Current product surfaces warn that annualized returns are not actual or guaranteed returns. BTCC POLAND LIMITED is identified in current first-party disclosures, with legacy Lithuania handling for some historic EU accounts; account/entity treatment remains jurisdiction-dependent.", "confidence": "high" }, { "platform_id": "cya_plat_000104", "terms_status": "unclear", "asset_ownership_interpretation": "JBank markets the protocol as decentralized and self-custodial, but staking necessarily places assets under smart-contract/protocol rules and the 4 December 2025 International Version notice says affected long-term staked assets are transferred into that system for management. The reviewed public material does not establish a conventional segregated-deposit structure or an unconditional right to immediate withdrawal while assets are subject to long-term staking or International Version release rules.", "affected_product": "JBank Staking / International Version", "source_evidence_id": "cya_src_b63_0002", "notes": "The issuer-described release paths are six-month delayed release or performance-based accelerated unlocking, with no static returns during those periods. CYA does not treat self-custody marketing, guaranteed-return wording, POL reserves or protocol mechanics as a legal principal guarantee. JUC/JUB token continuity remains unresolved.", "confidence": "medium" }, { "platform_id": "cya_plat_000105", "terms_status": "platform_owned", "asset_ownership_interpretation": "The first-party agreement is explicitly structured as an individual crypto consumption loan to ミライジング株式会社. The customer sends the asset to a company-designated wallet; the company is the borrower and owes return of the same type and quantity plus contractual interest after the agreed term. The terms state that the borrowed crypto is not subject to statutory segregated management under the cited exchange-business framework and that the transaction is unsecured. CYA therefore treats the contractual asset position as platform-owned / counterparty-exposure rather than segregated customer custody during the loan term.", "affected_product": "Smart Crypto Lending", "source_evidence_id": "cya_src_b64_0002", "notes": "The contract is not a deposit and is not deposit-insured. Published terms define 1/3/6/12-month lending periods, permit rate changes, and state that after maturity withdrawal applications are normally returned within seven business days. They also enumerate circumstances in which withdrawal can be delayed or refused, including market stress, concentrated return requests, legal constraints and operational conditions. The terms expressly warn that principal and interest may not be returned if the company fails. Current marketing rates and cold-wallet/security statements are not independent guarantees.", "confidence": "high" }, { "platform_id": "cya_plat_000106", "terms_status": "platform_owned", "asset_ownership_interpretation": "First-party materials expressly characterize the arrangement as crypto lending / a consumption-loan transaction to 株式会社J-CAM. Current terms state that the individual contract forms when the user sends eligible crypto to the company-designated wallet and required conditions are satisfied, and that the company later owes the same type and quantity of crypto. CYA therefore treats the economic structure as platform-owned / borrower-counterparty exposure during the loan, rather than segregated customer custody. This classification does not by itself establish insolvency treatment or legal title beyond the reviewed contract language.", "affected_product": "BitLending", "source_evidence_id": "cya_src_b65_0002", "notes": "Current terms give the company discretion to set lending-fee rates and permit changes to lending conditions for reasonable reasons. Users generally cannot request return for the first 30 days. Following a valid request, the company states that same-type/same-quantity crypto is normally returned within seven business days, but the terms permit postponement when concentrated return requests or similar circumstances make timely return difficult and permit rejection in specified compliance cases. Current marketing APYs, security controls and investment descriptions are not independent guarantees.", "confidence": "high" }, { "platform_id": "cya_plat_000107", "terms_status": "platform_owned", "asset_ownership_interpretation": "First-party materials characterize HashHub Lending as a crypto-asset (quasi-)consumption-loan arrangement: customers lend crypto to the operating company, and the borrower has contractual obligations to return principal-equivalent crypto quantity and lending fees. Current materials also state that borrowed assets may be deployed through arbitrage, third-party lending, staking and DeFi. CYA therefore treats the economic structure as platform-owned / borrower-counterparty exposure during the loan rather than segregated customer custody. This classification does not independently determine legal title or insolvency priority.", "affected_product": "HashHub Lending", "source_evidence_id": "cya_src_b66_0005", "notes": "Current first-party guidance states that return requires an application, the lending period runs through the end of the following month, and return is then executed within five business days, with return fees applying. Monthly lending-fee rates may change. The operator-transition on 2024-04-01 transferred HashHub Lending contractual rights and obligations to SBI Digital Finance. Published rates, security claims and asset-deployment descriptions are not independent guarantees of principal protection or solvency.", "confidence": "high" }, { "platform_id": "cya_plat_000108", "terms_status": "platform_owned", "asset_ownership_interpretation": "Current first-party materials define Coincheck Lending as a crypto-asset consumption-loan contract and expressly state that crypto borrowed under the lending product is not subject to the segregated-management framework for Coincheck's crypto-asset exchange business. The contract is unsecured and the service is not a deposit or deposit-insurance product. CYA therefore treats the economic structure as platform-owned / borrower-counterparty exposure during the loan. This does not independently determine legal title or insolvency priority beyond Coincheck's published contract/risk description.", "affected_product": "Coincheck 貸暗号資産サービス", "source_evidence_id": "cya_src_b67_0001", "notes": "Coincheck warns that lent crypto may not be returned if the company fails. Current rates, lending terms and borrowing-capacity limits can change. Coincheck's exchange-business registration must not be presented as principal protection for this separate lending contract.", "confidence": "high" }, { "platform_id": "cya_plat_000109", "terms_status": "platform_owned", "asset_ownership_interpretation": "Current first-party materials characterize GMO Coin Lending Basic as a crypto-asset consumption-loan arrangement and expressly state that the lending transaction is not a crypto-asset exchange transaction and that borrowed assets are not subject to the exchange-business segregated-management requirements. GMO Coin also states that the product is not a deposit or deposit-insurance product and warns that lent assets may not be returned if the company fails. CYA therefore treats the economic structure as platform-owned / borrower-counterparty exposure during the lending term. This does not independently determine legal title or insolvency priority beyond the operator's published terms.", "affected_product": "GMOコイン 貸暗号資産ベーシック", "source_evidence_id": "cya_src_b68_0001", "notes": "Current rates, courses, recruitment capacity and early-termination terms can change. Exchange-business registration and segregated-management rules applicable to exchange transactions must not be presented as principal protection for this separate lending contract.", "confidence": "high" }, { "platform_id": "cya_plat_000110", "terms_status": "platform_owned", "asset_ownership_interpretation": "Current first-party Terms define PBR LENDING as crypto-asset consumption-loan transactions between customers and Portobello Road株式会社. The Terms state that the lending transaction is not a deposit, is not deposit-insured, is not crypto-asset exchange business, and that borrowed assets are outside statutory segregated-management treatment. They say no physical or personal collateral is provided. Although the operator describes operational separation of borrowed assets from company assets, it expressly says this is not legally complete trust protection and that customer claims become general claims alongside other creditors in insolvency. CYA therefore treats the economic structure as platform-owned / borrower-counterparty exposure during the lending contract, without making a broader legal-title determination beyond the published terms.", "affected_product": "PBR LENDING", "source_evidence_id": "cya_src_b69_0002", "notes": "Current advertised rates, lock periods, supported assets and return procedures can change. Operator claims about security, internal reserves, business investments and repayment performance must not be presented as independent guarantees, reserve proof or solvency evidence.", "confidence": "high" }, { "platform_id": "cya_plat_000111", "terms_status": "platform_owned", "asset_ownership_interpretation": "Current first-party Terms define CRYPTOLENDING as a lending arrangement in which eligible crypto assets/tokens are lent by the user to 株式会社FUELHASH and FUELHASH owes return of the same type and quantity plus contractual interest. The Terms state that this is not crypto-asset exchange business and that the exchange-business segregated-management obligations described there do not apply; they also state that the service is not a bank deposit or deposit-like product and warn that FUELHASH failure may make return impossible. CYA therefore uses `platform_owned` to represent the borrower-counterparty economic exposure during the lending contract, without making a broader legal-title conclusion beyond the published terms.", "affected_product": "FUELHASH CRYPTOLENDING / CRYPTOTREND", "source_evidence_id": "cya_src_b70_0002", "notes": "Current marketing uses principal-guarantee and stable-operation language, but the Terms independently disclose company-failure non-return risk. CYA preserves that distinction and does not convert marketing claims into independent guarantees, insurance, reserve proof, licensing validation or solvency evidence.", "confidence": "high" }, { "platform_id": "cya_plat_000112", "terms_status": "platform_owned", "asset_ownership_interpretation": "Current first-party material defines 貸コイン as a consumption-loan arrangement to SBI VCトレード株式会社. A product-specific Flare lending disclosure states that lent assets are outside exchange-custody segregated-management treatment, the customer does not receive the exchange-custody priority right described there, SBI VC Trade may relend the assets, the lending is unsecured, and insolvency can cause partial or total non-return. CYA therefore uses `platform_owned` to represent borrower-counterparty economic exposure during the lending contract, while preserving that exact contractual terms can differ by asset/course.", "affected_product": "SBI VC Trade 貸コイン", "source_evidence_id": "cya_src_b71_0003", "notes": "SBI VC Trade's crypto-asset exchange registration does not make lending principal segregated, insured or guaranteed. The Flare disclosure is product-specific and is not generalized verbatim to every current or historical course. Current/campaign annual rates remain issuer terms rather than verified realized returns.", "confidence": "high" }, { "platform_id": "cya_plat_000113", "terms_status": "platform_owned", "asset_ownership_interpretation": "The reviewed materials describe customers lending crypto assets to BITMAX under a lending contract in exchange for contractual lending fees. CYA therefore represents borrower/counterparty economic exposure during the contract and does not infer segregated custody, insurance or guaranteed principal from the exchange service. Exact historical legal terms may vary across lending courses and periods.", "affected_product": "LINE BITMAX 暗号資産貸出サービス", "source_evidence_id": "cya_src_b72_0002", "notes": "Fixed-period lending generally could not be cancelled during the term under the reviewed first-party product mechanics. Published rates and campaigns remain issuer terms, not verified realized returns. The shutdown process ended contracts sequentially rather than establishing one universal contract end date.", "confidence": "high" }, { "platform_id": "cya_plat_000114", "terms_status": "platform_owned", "asset_ownership_interpretation": "The reviewed materials describe customers lending crypto assets to bitbank under a lending contract in exchange for contractual usage/lending fees. First-party ETHW fork guidance distinguishes lent ETH from the segregated-management balance used for ordinary exchange custody in the documented fork context. CYA therefore represents borrower/counterparty economic exposure during the lending contract and does not infer segregated custody, insurance or guaranteed principal for lent balances. Exact historical legal terms may vary across periods.", "affected_product": "bitbank 暗号資産を貸して増やす", "source_evidence_id": "cya_src_b79_0003", "notes": "Current first-party support documents one-year maturity and early-termination mechanics. Published rates remain issuer terms, not verified realized returns. Current return mechanics are not evidence of universal historical repayment performance.", "confidence": "high" }, { "platform_id": "cya_plat_000115", "terms_status": "platform_owned", "asset_ownership_interpretation": "The reviewed materials describe customers lending crypto assets to BITPOINT under a consumption-loan contract in exchange for contractual lending fees. BITPOINT explicitly states that lent assets are not subject to statutory segregated management for this service. CYA therefore represents borrower/counterparty economic exposure during the lending period and does not infer exchange-custody protection, deposit protection, insurance or guaranteed principal.", "affected_product": "BITPOINT 貸して増やす", "source_evidence_id": "cya_src_b80_0003", "notes": "Current terms state offering-specific lending periods/rates, no mid-term cancellation, and return/payment after the lending period. Published rates remain issuer terms, not verified realized returns.", "confidence": "high" }, { "platform_id": "cya_plat_000116", "terms_status": "platform_owned", "asset_ownership_interpretation": "The reviewed materials describe customers lending crypto assets to BitTrade under an unsecured consumption-loan contract. BitTrade expressly states that lent assets are not subject to statutory segregated management and that customers have no priority repayment right over other creditors. CYA therefore represents borrower/counterparty economic exposure during the lending period and does not infer exchange-custody protection, deposit protection, insurance or guaranteed principal.", "affected_product": "BitTrade 貸暗号資産", "source_evidence_id": "cya_src_b81_0001", "notes": "Individual contracts are in principle not cancellable mid-term. BitTrade warns that lent crypto may not be returned if it fails. Published rates remain issuer product terms, not verified realized returns.", "confidence": "high" }, { "platform_id": "cya_plat_000117", "terms_status": "platform_owned", "asset_ownership_interpretation": "The reviewed materials describe customers lending crypto assets to OKJ under a crypto-asset consumption-loan arrangement. OKJ expressly states that lent assets are not subject to statutory segregated management. CYA therefore represents borrower/counterparty economic exposure during the lending period and does not infer exchange-custody protection, deposit protection, insurance or guaranteed principal.", "affected_product": "OKJ 貸暗号資産", "source_evidence_id": "cya_src_b82_0002", "notes": "The product is not a deposit or deposit-like product and is not covered by deposit insurance. OKJ warns that lent crypto may not be returned if the company fails. Early cancellation produces no lending fee and return follows the offering-specific return schedule. Published rates remain issuer product terms, not verified realized returns.", "confidence": "high" }, { "platform_id": "cya_plat_000118", "terms_status": "unknown", "asset_ownership_interpretation": "The reviewed first-party support establishes a fixed-term crypto lending arrangement but does not provide sufficient dedicated lending-term authority in this review pass to characterize lent balances as segregated, insured, trust-protected, or otherwise isolated from operator counterparty exposure. CYA therefore records custody/segregation treatment conservatively and does not generalize ordinary exchange-service protections to lent assets.", "affected_product": "CoinTrade Lending", "source_evidence_id": "cya_src_b83_0002", "notes": "Published reward rates are issuer terms rather than verified realized returns. Mid-term cancellation is generally unavailable; approved exceptions receive no lending reward and incur a cancellation fee equal to 10% of the application quantity. Product-specific insolvency/custody treatment remains unresolved unless stronger dedicated terms are reviewed.", "confidence": "medium" }, { "platform_id": "cya_plat_000119", "terms_status": "unclear", "asset_ownership_interpretation": "The reviewed first-party material defines a consumption-loan arrangement and says borrowed assets are operated within HashKey Group. It does not establish segregated custody, trust protection, deposit insurance, insurance, reserve backing, or bankruptcy isolation for lent assets. CYA therefore records operator counterparty exposure conservatively.", "affected_product": "HashKey Japan 貸暗号資産", "source_evidence_id": "cya_src_b84_0002", "notes": "The current page states the service is not a deposit or deposit-like product and is not covered by deposit insurance. Mid-term cancellation is unavailable in principle. Published lending rates and HashKey Group operation statements remain issuer terms/claims.", "confidence": "medium" }, { "platform_id": "cya_plat_000120", "terms_status": "unknown", "asset_ownership_interpretation": "The reviewed first-party FAQ establishes a fixed-period crypto lending contract but does not provide sufficient dedicated authority to characterize lent balances as segregated, insured, trust-protected or otherwise insulated from operator counterparty exposure. Ordinary exchange custody treatment is not generalized to the lending product.", "affected_product": "bitFlyer 定期貸しコイン", "source_evidence_id": "cya_src_b85_0001", "notes": "Published annual rates remain issuer terms rather than verified realized returns. Customer-requested mid-term cancellation is unavailable. Lending-specific insolvency treatment and principal-protection status remain unresolved without stronger dedicated first-party terms.", "confidence": "medium" }, { "platform_id": "cya_plat_000121", "terms_status": "unknown", "asset_ownership_interpretation": "Reviewed first-party launch materials establish a fixed-term product but do not prove segregation, trust protection, enforceable insurance coverage or insolvency priority for EARN balances. BitMEX insurance-fund backing language is recorded only as an operator claim.", "affected_product": "BitMEX EARN", "source_evidence_id": "cya_src_b86_0001", "notes": "Published APRs are issuer terms rather than verified realized returns. Contractual maturity mechanics do not prove universal historical repayment. Current operational status remains unresolved.", "confidence": "medium" }, { "platform_id": "cya_plat_000122", "terms_status": "unclear", "asset_ownership_interpretation": "Current first-party help material states users authorize CoinDCX to deploy supported assets on their behalf, but the reviewed sources do not establish a universal legal-title, segregation, trust or insolvency-priority model for Earn balances. Legacy DCX Lend terms are not generalized to current Earn.", "affected_product": "CoinDCX Earn", "source_evidence_id": "cya_src_b87_0002", "notes": "Variable rates, minimum holding periods, early-exit consequences, service-change discretion and partial/complete-loss risk are preserved as current product terms. Displayed rates are not treated as guaranteed or realized returns.", "confidence": "high" }, { "platform_id": "cya_plat_000123", "terms_status": "unclear", "asset_ownership": "Reviewed terms establish service-provider and validator participation but do not establish one universal legal-title model for all supported assets.", "rehypothecation": "CoinSwitch states EARN does not lend or loan user crypto to third parties; reviewed material supports staking/validator use rather than lending-based rehypothecation.", "withdrawal_terms": "CoinSwitch states users may unlock supported EARN assets, subject to product and blockchain mechanics.", "counterparty_risk": "Exposure includes CoinSwitch/Bitcipher operational risk, validator risk and underlying protocol risk.", "notes": "Do not generalize ordinary wallet custody protections or infer insolvency priority from the reviewed EARN materials.", "confidence": "medium" }, { "platform_id": "cya_plat_000124", "terms_status": "unclear", "asset_ownership_interpretation": "Reviewed first-party Earn material does not establish one universal legal-title, segregation, trust or insolvency-priority model across all supported assets.", "affected_product": "Mudrex Earn", "source_evidence_id": "cya_src_b89_0001", "notes": "Mudrex states zero lock-in for the launch-era Earn flow and describes assets as remaining available in the Mudrex account, but this does not establish universal legal ownership or protection treatment. Yield mechanics vary by asset and are not collapsed into a single staking or lending model.", "confidence": "medium" }, { "platform_id": "cya_plat_000125", "terms_status": "unclear", "asset_ownership_interpretation": "First-party documentation describes a non-custodial lending protocol but does not establish one universal legal-title, insolvency-priority, or recovery framework for all supported assets and markets.", "affected_product": "Kinza Finance Money Market", "source_evidence_id": "cya_src_b90_0003", "notes": "Protocol documentation explains supply, borrow, collateral, utilization and withdrawal mechanics. The current restriction signal is operational, not a basis to infer insolvency treatment or customer loss.", "confidence": "medium" }, { "platform_id": "cya_plat_000126", "terms_status": "unclear", "asset_ownership_interpretation": "Reviewed first-party Earn material does not establish one universal legal-title, segregation, trust or insolvency-priority model for ZebPay Earn balances.", "affected_product": "ZebPay Earn", "source_evidence_id": "cya_src_b91_0001", "notes": "Reviewed FAQ supports 30/60/90-day fixed terms, maturity credit of invested crypto plus earnings, and early exit with no earnings but no principal penalty. Do not infer deposit insurance, segregation, insolvency priority or guaranteed principal.", "confidence": "medium" }, { "platform_id": "cya_plat_000127", "terms_status": "platform_owned", "asset_ownership_interpretation": "Current Smart Lending terms state that ownership of lent crypto transfers to Smart Lending Co., Ltd.; the lending exposure is unsecured, the service is not a deposit, and lent assets are outside statutory segregated management.", "affected_product": "Smart Lending", "source_evidence_id": "cya_src_b92_0001", "notes": "The terms warn that principal and interest may not be returned if the company fails. Advertised fixed annualized rates and return-preparation statements remain operator claims rather than independent guarantees or proof of solvency.", "confidence": "high" }, { "platform_id": "cya_plat_000128", "terms_status": "unclear", "asset_ownership_interpretation": "Neutrl's reviewed public materials establish that NUSD and sNUSD are exposed to protocol reserve and strategy-position liquidity, but the reviewed August 2026 incident sources do not establish a simple customer-owned versus platform-owned legal characterization for all holder claims.", "affected_product": "NUSD / sNUSD", "source_evidence_id": "cya_src_b93_0003", "notes": "The key bounded risk is reserve/strategy liquidity impairment with redemption suspended and recovery value unresolved. Earlier reserve-dashboard totals are dated snapshots and must not be converted into an inferred loss by subtracting the later USD 27 million liquid-asset figure.", "confidence": "medium" }, { "platform_id": "cya_plat_000129", "terms_status": "unclear", "asset_ownership_interpretation": "MORE Markets is non-custodial and smart-contract based, but the reviewed incident evidence does not by itself establish a complete legal characterization of lender claims or loss allocation after the exploit.", "affected_product": "mFlowWFLOW lending market", "source_evidence_id": "cya_src_b94_0001", "notes": "Protocol design is non-custodial, but exploit-loss allocation, any resulting bad debt and any recovery or compensation mechanism remain unresolved as of 2026-08-31.", "confidence": "medium" }, { "platform_id": "cya_plat_000130", "terms_status": "unclear", "asset_ownership_interpretation": "Tectonic is a non-custodial DeFi lending protocol, so conventional centralized customer-versus-platform ownership labels do not map cleanly to supplied assets and protocol claims.", "affected_product": "Tectonic lending markets", "source_evidence_id": "cya_src_b95_0001", "notes": "The principal bounded risk for this record is smart-contract/oracle-or-price-manipulation exposure in a DeFi lending market. Final legal loss allocation and any post-incident socialization, recapitalization or compensation mechanism were not established in the reviewed sources.", "confidence": "medium" }, { "platform_id": "cya_plat_000001", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Celsius Earn account assets were treated differently from some other product categories in bankruptcy-related analysis and rulings.", "affected_product": "Celsius Earn and other Celsius account categories", "source_evidence_id": "cya_src_000005", "notes": "Celsius account and product category affected asset-treatment and customer-outcome analysis. Direct court order citations should be preferred when available.", "confidence": "medium" }, { "platform_id": "cya_plat_000002", "terms_status": "varies_by_product", "asset_ownership_interpretation": "BlockFi customer outcomes and treatment varied across wallet, interest account, loan, and estate claim categories.", "affected_product": "BlockFi Interest Account, Wallet, loans, and related account categories", "source_evidence_id": "cya_src_000007", "notes": "BlockFi requires product-by-product treatment. This record uses a conservative product-dependent classification.", "confidence": "medium" }, { "platform_id": "cya_plat_000003", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Voyager customer treatment depended on estate assets, account balances, recovery process, and litigation recoveries after the platform entered wind-down.", "affected_product": "Voyager customer account balances and rewards-related balances", "source_evidence_id": "cya_src_000012", "notes": "Voyager terms and customer recovery are treated conservatively because recovery details depended on estate and distribution documents.", "confidence": "medium" }, { "platform_id": "cya_plat_000004", "terms_status": "varies_by_product", "asset_ownership_interpretation": "Genesis creditor and Gemini Earn-linked outcomes depended on program structure, claim class, and the bankruptcy plan rather than a single universal customer-ownership rule.", "affected_product": "Genesis lending claims and Gemini Earn-linked claims", "source_evidence_id": "cya_src_000017", "notes": "Genesis terms risk should be read as product- and claim-class dependent. Gemini Earn was connected to Genesis lending but has a separate customer-facing structure.", "confidence": "medium" }, { "platform_id": "cya_plat_000005", "terms_status": "unknown", "asset_ownership_interpretation": "Hodlnaut depositor treatment is liquidation-dependent in this record.", "affected_product": "Hodlnaut interest and yield account balances", "source_evidence_id": "cya_src_000020", "notes": "Use unknown rather than forcing a terms conclusion. The platform halt and liquidation are clear, while product-level asset ownership treatment requires stronger proceeding records.", "confidence": "medium" }, { "platform_id": "cya_plat_000006", "terms_status": "unknown", "asset_ownership_interpretation": "Vauld customer treatment depends on the creditor protection and restructuring process. This record does not establish product-level asset ownership treatment.", "affected_product": "Vauld customer balances, yield accounts, and lending claims", "source_evidence_id": "cya_src_b03_0001", "notes": "Keep terms status unknown until the creditor process can support a stronger product-level classification.", "confidence": "medium" }, { "platform_id": "cya_plat_000007", "terms_status": "unknown", "asset_ownership_interpretation": "Haru Invest customer treatment depends on the legal and claims process. Current public sources do not establish a reliable ownership classification.", "affected_product": "Haru Earn products and custodial balance products", "source_evidence_id": "cya_src_b03_0005", "notes": "Use unknown because the customer outcome is tied to unresolved legal and claims processes.", "confidence": "medium" }, { "platform_id": "cya_plat_000008", "terms_status": "unknown", "asset_ownership_interpretation": "The official CoinLoan bankruptcy notices establish insolvency proceedings and creditor-list administration but do not resolve whether every deposit, interest-account balance, loan claim and collateral category receives identical ownership or priority treatment.", "affected_product": "CoinLoan interest accounts, deposits, loans and collateral claims", "source_evidence_id": "cya_src_b03_0010", "notes": "Unknown is retained deliberately. A stronger product-level classification requires CoinLoan terms or court materials addressing asset ownership and claim priority, not only the bankruptcy declaration.", "confidence": "medium" } ] }