The agreement authorizes Coinbase to hold user digital assets in shared omnibus blockchain addresses across multiple protocols, including layer two networks, alternative layer one networks, and side chains, and to treat different forms of the same asset held across these protocols as interchangeable regardless of wrapping status or the specific protocol on which they are stored.
This analysis describes what Coinbase's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes that Coinbase is not required to maintain segregated blockchain addresses for individual user assets and may commingle holdings across multiple protocols with assets treated as fungible equivalents. This structure has implications for user asset tracing, insolvency risk assessment, and the practical ability to verify on-chain holdings independently.
The updated terms expand Coinbase's authority to liquidate your assets without notice. Previously, Coinbase could liquidate your property only if you failed to pay for securities you purchased or failed to deliver securities you sold through CCM. The revised language adds a new trigger: if a transfer of securities into your CCM account fails or is reversed, Coinbase can now liquidate your property to cover any losses CCM suffers as a result. This means your assets may be liquidated for reasons beyond your direct control, such as a failed inbound transfer initiated by a third party or a reversal by the sending institution.
View change record →The updated terms authorize Coinbase to automatically transfer your digital assets to a newer protocol version when an 'Asset Transformation' occurs, and you are now instructing Coinbase to conduct these 'Coinbase Supported Migrations' at Coinbase's sole discretion. The terms also establish that Coinbase shall not be liable for any loss resulting from your inability to transfer assets during a migration or from an Asset Transformation itself. This means Coinbase can execute asset transfers without advance notice and without bearing responsibility for any resulting losses, even if the transfer fails or the new asset version performs differently than the original.
View change record →The updated terms introduce a new Direct Deposit feature that allows eligible users to receive paychecks and government benefits directly into their Coinbase Account and optionally convert those funds into digital assets through recurring automatic purchases. The terms state that Coinbase will not charge setup or maintenance fees and will waive trading fees on Direct Deposit conversions, though spreads may apply. However, the terms also establish that digital assets are not FDIC-insured, can appreciate or depreciate relative to USD, and that Coinbase reserves the right to set, modify, or reject transfer limits at its sole discretion. You can enroll by providing your employer or government payer with the virtual account and routing numbers Coinbase provides, and you can change your asset allocation at any time through the Coinbase app.
View change record →⚠ Digital assets will be held in omnibus shared addresses as described, with no obligation by Coinbase to maintain a segregated blockchain address for any individual user
Cross-platform context
See how other platforms handle Omnibus Custody and Fungibility of Digital Assets and similar clauses.
Compare across platforms →"You acknowledge and agree that Coinbase may hold Supported Digital Assets in your Digital Asset Wallets in a variety of different ways, including across multiple blockchain protocols, such as layer two networks, alternative layer one networks, or side chains. In connection with its holding of Supported Digital Assets in your Digital Asset Wallets, Coinbase may transfer such Digital Assets off of the primary blockchain protocol and hold such Digital Assets on shared blockchain addresses, controlled by Coinbase, on alternative blockchain protocols in forms compatible with such protocols. You agree that all forms of the same Digital Asset that are held and made available across multiple blockchain protocols may be treated as fungible and the equivalent of each other, without regard to (a) whether any form of such Digital Asset is wrapped or (b) the blockchain protocol on which any form of such Digital Asset is stored.Excerpt from Coinbase's User Agreement
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This provision establishes that Coinbase is not required to maintain segregated blockchain addresses for individual user assets and may commingle holdings across multiple protocols with assets treated as fungible equivalents. This structure has implications for user asset tracing, insolvency risk assessment, and the practical ability to verify on-chain holdings independently.
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