CTF Written Submission

TDC - Crypto Lending Letter Response Exhibit A

July 25, 2025
  • Direct lenders generally use typical lending structures, and securities laws are only implicated when securities are lent or when collateral that is a security is rehypothecated.
  • Custodial crypto lending platforms involve bilateral contractual arrangements with the platform and borrowers, with interest shared proportionately among lenders.
  • Non-custodial liquidity protocols and NCCMPs operate without legal relationships between users, with transactions governed by smart contracts and algorithmic rules.

Last Reviewed or Updated: July 28, 2025