Coinbase · Coinbase User Agreement

Cryptocurrency Custody and Insolvency Risk

High severity
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What it is

In the event of a bankruptcy, Coinbase's customers would be treated as our unsecured creditors. This means that Coinbase's customers with cryptocurrency assets on our platform could lose some or all of the value of their assets in the event of Coinbase's bankruptcy. Coinbase currently holds a portion of customer funds in custodial accounts. Coinbase holds cryptocurrency assets on your behalf and you may not be able to recover these assets.

Why it matters

This is the highest-impact financial risk in the entire agreement: unlike money in an FDIC-insured bank, cryptocurrency held on Coinbase is not protected if Coinbase fails, as demonstrated by the Celsius and FTX collapses where customers lost billions.

Consumer impact

Coinbase's User Agreement gives the company broad unilateral powers to suspend accounts, freeze funds, and reverse transactions with limited notice, directly affecting your access to your money and cryptocurrency. In the event of Coinbase's insolvency, cryptocurrency held in your Coinbase account may be treated as Coinbase's property under bankruptcy law, leaving you as an unsecured creditor rather than the outright owner of your assets. You can withdraw your cryptocurrency to a self-custodied hardware or software wallet to avoid platform insolvency risk, and you can opt out of mandatory arbitration by sending written notice to Coinbase within 30 days of first accepting the agreement.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Export Your Data
    Log in to your Coinbase account, navigate to your Portfolio, select the cryptocurrency you want to withdraw, and send it to a self-custodied wallet address you control to eliminate platform insolvency risk.

Applicable agencies

  • SEC
    The SEC's SAB 121 directly addresses the accounting and disclosure requirements for crypto custody arrangements and the regulator monitors compliance by public companies like Coinbase.
    File a complaint →
  • CFPB
    The CFPB has authority over unfair, deceptive, or abusive practices in consumer financial products and could investigate whether insolvency risk disclosures are adequate and prominent enough.
    File a complaint →

Provision details

Document information
Document
Coinbase User Agreement
Entity
Coinbase
Document last updated
March 24, 2026
Tracking information
First tracked
March 20, 2026
Last verified
April 4, 2026
Record ID
CA-P-002032
Document ID
CA-D-00047
Evidence Provenance
Source URL
Wayback Machine
SHA-256
28b08bdc2391062cc0b1b467b0c8cfeb1e19b51011dcce671448d97947da4585
Verified
✓ Snapshot stored   ✓ Change verified
How to Cite
ConductAtlas Policy Archive
Entity: Coinbase | Document: Coinbase User Agreement | Record: CA-P-002032
Captured: 2026-03-20 06:40:29 UTC | SHA-256: 28b08bdc2391062c…
URL: https://conductatlas.com/platform/coinbase/coinbase-user-agreement/cryptocurrency-custody-and-insolvency-risk/
Accessed: April 4, 2026
Classification
Severity
High
Categories

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