Title Transfer Collateral Arrangements Agreement For Non-Retail Clients Only

Last Updated: June 11, 2026

1.1 This Title Transfer Collateral Arrangement Agreement (“TTCA Agreement”) is entered between you (the “Client” or “You”) and Coinbase Financial Services Europe Ltd. (“Coinbase”, the “Company”, “Us”, or “We”), which is authorised and regulated by the Cyprus Securities and Exchange Commission (“CySEC” or the “Commission”) as a Cyprus Investment Firm (“CIF”) with CIF licence number 374/19.

1.2 The TTCA Agreement forms an integral part of our User Agreement, which is available on our website, and should be read in conjunction with it. Capitalised terms used but not defined in this TTCA Agreement have the same meaning given to them in the User Agreement.

1.3 This TTCA Agreement is provided to you in English, which We consider to be the official language. We may also provide translations in your own language where necessary and/or available. However, the English version shall prevail in the event of any inconsistency. We will communicate with you in English for the duration of this TTCA Agreement, unless otherwise required by applicable law.

2.1 In accordance with Section 17(9) of the Investment Services and Activities and Regulated Markets Law of 2017 (thereafter the “Law”), Part II of the Directive for the Safeguarding of Client Assets, Product Governance Obligations and Inducements (“Directive DI87-01”), as well as the European Commission’s Delegated Regulation 2017/565 and Delegated Directive 2017/593 (together, the “Client Assets Rules”), and Section 5.5 - 5.6 of our User Agreement, Coinbase may from time to time, transfer ownership of assets (including money and Digital Assets) by You to Us for the purpose of covering present or future, actual or contingent or prospective obligations to us (a “Title Transfer Collateral Arrangement” or “TTCA”).

2.2 This TTCA Agreement applies only to Clients who have not been classified as Retail Clients (pursuant to Section 3 of the User Agreement). Only Professional Clients and Eligible Counterparties may enter into this TTCA Agreement with the Company

2.3 We will provide this TTCA Agreement to You only where we determine, acting in accordance with applicable law, that the use of TTCA is appropriate in the context of our relationship with You and the nature of the obligations to be secured.

3.1 Before entering into a TTCA with You, Coinbase will consider the appropriateness of using a TTCA in the context of our relationship with You and the proposed Client Assets to be subject to TTCA, in accordance with Part II of Directive DI87-01 and applicable law.

3.2 Coinbase will keep appropriate records of assets transferred under the TTCA and will make information available to you through the Coinbase Platform, the member area of our website or such other interface as we may make available from time to time, including a clear indication of which assets are subject to the Client Assets Rules and which assets are subject to this TTCA Agreement.

4.1 You acknowledge and agree that, once money and/or Digital Assets are transferred to us under this TTCA, such assets will cease to be treated as Client Assets for the purpose of Client Assets Rules. This means, among other things, that the protections relating to safeguarding, depositing, segregation, use and diversification of client assets will no longer apply to those assets.

4.2 Because full title to the relevant assets is transferred to Us under the TTCA, You will cease to have any proprietary claim to those assets. We may, subject to applicable law, use, deal, hold, transfer, sell, pledge, rehypothecate, assign, invest, commingle or otherwise dispose of such assets as owner, without notice to you and without regard to any interest that you may otherwise have had in them.

4.3 For the avoidance of doubt, where you are a non-retail Client: 

4.3.1 any money is transferred by you to us, or credited to your Coinbase account, by way of title transfer collateral arrangement for the purpose of securing or covering your present, future, or prospective obligations to us, such money will not be held by us in accordance with the CySEC's Directive DI87-01 for the Safeguarding of Financial Instruments and Funds belonging to Clients. Title to that shall pass to us, you will cease to have any proprietary claim to it, and your rights in respect of that money will be limited to a contractual right to the return of equivalent money in accordance with this TTCA Agreement and the User Agreement; and 

4.3.2 any Digital Assets are transferred by you to Us under a TTCA, title to those Digital Assets will pass to Us absolutely and You will cease to have any proprietary claim to them. Your rights in respect of those Digital Assets will be limited to a contractual right to the return of equivalent Digital Assets, in each case subject to this TTCA Agreement and the User Agreement.

4.4 If we become insolvent or are subject to bankruptcy, resolution, or similar proceedings, You will rank as a general unsecured creditor in respect of any claim for the return of equivalent money and/or Digital Assets transferred under the TTCA. You therefore bear our credit risk in respect of all assets transferred under the TTCA, and you should be able to understand and quantify such a risk.

Warning: Assets transferred under TTCA will cease to benefit from the protections available under the Client Assets Rules. As a result You will have a credit risk exposure against Us by virtue of the TTCA.

5.1 Information on the client money or Digital Assets held by Us, including whether such assets are held subject to the Client Assets Rules or pursuant to a TTCA, will be made available to You at all times through the Coinbase Platform or in the Members Area of our website. Such information includes, amongst others, a clear indication of the assets which are subject to Client Asset Rules and those that are not, including assets that are subject to TTCA.

6.1 Where We determine that money and/or Digital Assets transferred under the TTCA are no longer required for the purposes of securing or otherwise covering present, future, actual, contingent or prospective obligations to Us, We shall arrange for the transfer to You of equivalent money and/or equivalent Digital Assets. Following such transfer, any assets subsequently held for You by Us on a safeguarded basis shall, where applicable, be treated in accordance with the Client Assets Rules.

6.2 If your Account will be closed, We will transfer to You an amount equal to any money and/or Digital Assets transferred by You under the TTCA that remain due to You after deducting all amounts owed by You to Us under the User Agreement or otherwise, including in respect of any other account You hold or have held with us or another Coinbase Group entity to the extent permitted by the User Agreement.

7.1 You may terminate this TTCA Agreement by giving Us not less than 14 days’ written notice in a durable medium, including email. Any TTCA shall automatically terminate upon termination of the User Agreement.

7.2 Termination of this TTCA Agreement shall not affect any TTCA already entered into, or any rights, remedies, obligations or liabilities accrued prior to termination, until such time as all obligations secured by the relevant TTCA have been satisfied and we have returned to You any equivalent money and/or equivalent Digital Assets due to You in accordance with this TTCA Agreement and the User Agreement.

8.1 By accepting classification as a Professional Client or Eligible Counterparty and by trading on the Coinbase Cyprus Platform, You confirm and agree that:

8.1.1 You have read and understood the terms of this TTCA Agreement, including the treatment of assets under a TTCA, as well as the risks involved;

8.1.2 You agree to and authorise the transfer to Coinbase of full title to money and/or Digital Assets, for the purposes of securing or otherwise covering all Your present, future, actual, contingent or prospective obligations to Coinbase from time to time;

8.1.3 You understand and agree that, once transferred under a TTCA, such assets will no longer be treated as Client Assets and will no longer be subject to the protections of the Client Assets Rules, including segregation of protections;

8.1.4 You understand that Your rights in respect of assets transferred under a TTCA are limited to a contractual right to the return of equivalent money and/or equivalent Digital Assets in accordance with this TTCA Agreement and the User Agreement; and

8.1.5 You understand that, if this TTCA Agreement ceases to be applicable as a result of a change in law, regulation or the Company’s policies or services we will notify you in writing as required by applicable law.