Coinbase updated its User Agreement on May 1, 2026 to explicitly permit the transfer of digital assets to third parties under a new 'Secured USDC' feature tied to the Coinbase One Card. Previously, the terms stated assets would not be transferred except as required by law or per user instruction. The updated language now establishes three exceptions: law-mandated transfers, user instructions, and transfers of USDC designated as 'Secured USDC' pursuant to a separate cardholder agreement. Users who designate USDC as secured agree they cannot withdraw or transfer those funds and that Coinbase may follow third-party instructions without further user consent.
The updated terms establish a new exception to the prior prohibition on transferring user digital assets. Previously, Coinbase stated it would not transfer assets except as required by law or per user instruction. The revised language now permits Coinbase to transfer USDC designated as 'Secured USDC' to third parties pursuant to a Coinbase One Card cardholder agreement. Users who elect to use this feature agree they will be restricted from withdrawing or transferring the secured portion, and they consent to Coinbase following instructions from a designated secured party without further user approval, even if those instructions conflict with the user's own orders to Coinbase. The full terms of this arrangement are stated to be in Appendix 4, which is not included in this summary.
The updated terms create a new category of asset transfers that operate outside the prior framework requiring user instruction or legal mandate. Users who opt into the Secured USDC feature agree to lose withdrawal rights and permit Coinbase to follow third-party instructions without their further approval. This materially changes the control and disposition rights for designated assets and introduces a new product-specific governance structure not previously addressed in the general asset custody provisions.
→ Review Appendix 4 (Coinbase One Card with Security Deposit Cardholder Agreement) before designating any USDC as Secured USDC to understand the withdrawal restrictions and third-party instruction terms.
→ Confirm whether you intend to use the Coinbase One Card Secured USDC feature or prefer to maintain unrestricted withdrawal rights over your assets.
→ If you designate USDC as Secured USDC without reviewing the full cardholder agreement, you will be restricted from withdrawing or transferring that amount for the duration of the secured designation.
→ Coinbase may follow instructions from the designated secured party without your further consent, even if those instructions conflict with your own orders.
This is the 2nd significant Rights Removal change Coinbase has made since ConductAtlas began monitoring.
ConductAtlas has recorded 3 material changes to this document over 55 days of monitoring (since March 2026). An additional minor or cosmetic changes were excluded.
2 of Coinbase's significant changes have been classified as negative for consumers.
Added explicit authority for Coinbase to transfer USDC to third parties when designated as Secured USDC under a cardholder agreement, overriding the prior prohibition on asset transfers absent law or user instruction.
New provision stating Coinbase may comply with third-party instructions for Secured USDC without user consent and without regard to conflicting user instructions.
New provision establishing that users designated USDC as secured accept restriction from any withdrawals or transfers of that amount.
This change record describes what was added, removed, or modified in the document. Analysis reflects what the updated agreement states or permits. It does not constitute a legal determination about enforceability. Applicability may vary by jurisdiction. Methodology
If you opt into the Secured USDC feature, you lose the ability to withdraw or move that money, and Coinbase can follow orders from a third party without asking you first.
Coinbase now has explicit permission to move some of your USDC to a third party if you enroll in their Secured USDC card program.
Coinbase modified Section 2.7 of its User Agreement to carve out a new exception permitting asset transfers related to a 'Secured USDC' feature. This change introduces conditional asset control restrictions and third-party instruction rights that depend on user opt-in to the Coinbase One Card product. Compliance teams should review Appendix 4 to assess whether this arrangement affects custody classification, regulatory capital treatment, or disclosures to financial regulators (OCC, FDIC if applicable). The language suggesting Coinbase follows third-party instructions 'without any regard to...conflicting instructions...given to Coinbase by you' may warrant review under applicable fiduciary or custody rules.
OCC, FDIC (if Coinbase is or will be regulated as a bank), FinCEN (asset custody), state money transmitter laws. Potential relevance to SEC if this constitutes a securities custody or settlement function. The arrangement may implicate state contract law and UCC Article 8 (investment property) or Article 9 (secured transactions) depending on how Secured USDC is classified.
Full compliance analysis
Obligation analysis, escalation trigger, board language, and recommended action.
Watcher: regulatory citations + obligations. Professional: full compliance memo.
ConductAtlas provides verified policy intelligence sourced directly from platform documents. All analysis is intended to support, not replace, legal and compliance review. Record CA-C-001505.
See the full side-by-side comparison of every sentence added, removed, and modified.
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