Coinbase updated its User Agreement on May 1, 2026 to introduce a concept called 'Secured USDC,' which allows certain USDC holdings in your digital asset wallet to be pledged as collateral (a security deposit) for the Coinbase One Card. Previously, Coinbase promised not to sell or transfer your digital assets except as required by law or at your instruction; now, it can also transfer those designated assets to a third party without your further consent if you've set them up as Secured USDC. This matters because once you designate USDC as 'Secured,' you lose the ability to withdraw or transfer it freely, and Coinbase can act on a secured party's instructions instead of yours.
If you use the Coinbase One Card with a security deposit, any USDC you designate as 'Secured USDC' will be frozen — you cannot withdraw or transfer it, and Coinbase can hand it over to the card's secured party without needing your approval. This is a significant reduction in your control over those assets compared to the previous terms, which required your instruction for any transfer. You can avoid this restriction by not designating USDC as Secured USDC and opting not to use the Coinbase One Card security deposit feature.
Coinbase has fundamentally changed the terms under which it controls your digital assets — for Secured USDC, you can no longer instruct Coinbase to return your assets, and a third party can direct Coinbase to transfer them without your approval. This is a material reduction in customer property rights that was previously protected by an unqualified prohibition on unauthorized transfers.
ConductAtlas has recorded 3 material changes to this document over 52 days of monitoring (since March 2026). An additional minor or cosmetic changes were excluded.
ConductAtlas Policy Archive Entity: Coinbase | Document: Coinbase User Agreement | Record: CA-C-000744 Captured: 2026-05-01 06:02:04 UTC URL: https://conductatlas.com/change/2026-05-01-coinbase-coinbase-user-agreement-744/ Accessed: May 2, 2026
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Coinbase has amended its User Agreement effective May 1, 2026 to permit the transfer of customer digital assets (specifically USDC designated as 'Secured USDC') to third-party secured parties under the Coinbase One Card with Security Deposit Cardholder Agreement (Appendix 4), without further customer consent. This directly modifies the asset-custody and control provisions (Sections 2.7.1–2.7.3) and introduces a carve-out to the previous blanket prohibition on unauthorized asset transfers. Compliance teams at any organization relying on Coinbase custody representations — including those using Coinbase for treasury or client asset management — must reassess whether their vendor agreements, internal policies, and customer disclosures remain accurate. Action is required if your organization represents to clients that their Coinbase-held assets cannot be transferred without their instruction.
1. UCC Article 8 & 9 (Uniform Commercial Code): The change explicitly invokes UCC concepts — 'entitlement orders,' 'secured party,' 'security interest,' and 'control' — indicating that Secured USDC is structured as a security entitlement with a perfected security interest. Compliance teams should assess whether this creates a first-priority lien structure and how it interacts with customer asset segregation obligations.
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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-000744.
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