Disclosure
How we are paid
How we are paid: compensation may come from the lender or OTC desk an enquiry is introduced to, as an introduction or referral fee, or from you under a written agreement, or from both. Any fee payable by you is agreed in writing before an introduction is made. The exact model is not settled, and this page is updated when it is.
Key takeaways
- Two possible sources, both disclosed. An introduction or referral fee from the lender or desk, a fee from you under a written agreement, or both on the same enquiry.
- No fee is payable by you unless you have agreed it in writing. That agreement comes before an introduction is made.
- Compensation is not a matching criterion. An enquiry goes to counterparties whose published criteria fit it, not to whichever firm would pay the most, and where several fit, several are presented.
- No rankings, ratings or league tables. Named firms are described only from their own published terms, dated and sourced. No firm has paid to be named.
- We set no terms. The rate, the loan-to-value ratio, the margin levels and the price come from the lender or desk.
A disclosure, not an offer. This page describes how Crypto Loans HQ may be compensated for introductions. It is not an offer to lend, to arrange a loan on particular terms, or to buy or sell any asset, and it is not investment, legal or tax advice. It is not a fee schedule: no amount or rate is published here, and any fee payable by a client sits in a written agreement with that client.
Where compensation can come from
An introducer is paid by one side, the other, or both, and which one changes the incentive. Every possible arrangement is below, with its conflict and the rule that applies.
| Source | Agreed when | The conflict it creates | How it is handled |
|---|---|---|---|
| Introduction or referral fee from a lender or OTC desk | With that firm, before any enquiry is presented to it | An incentive to steer enquiries to whichever firm pays more | Matching runs on published criteria only; where more than one counterparty fits, more than one is presented; no rankings are published |
| Fee from the client | In writing with you, before an introduction is made | An incentive to make an introduction that adds nothing | You see the amount or basis, what it covers and when it falls due before you commit, and you can go to any lender or desk directly instead |
| Both, on the same enquiry | Both agreements, before an introduction | Compensation twice over, invisible from either side | Both are disclosed to you before an introduction is made |
| Payment to be named, rated or placed on this site | Never | Editorial capture: the site stops being evidence and becomes advertising | Not accepted. Firms are described only from their own published terms, dated and sourced |
| The compensation model is an open owner decision as of 19 September 2026. This table states what is possible and the rule that applies to each case. It is not a price list, and no amount or rate is published on this site. | |||
If a fee is payable by you
The rule is the same whoever you are: no fee is payable by you unless you have agreed it in writing, and that agreement comes before an introduction is made. Nothing is deducted from a loan advance or a trade settlement without it, and nothing is billed afterwards for work you did not agree to.
Such an agreement would state the amount or the basis of calculation, what it covers, when it falls due, and what happens if no counterparty engages. You see all of it before you commit, and sending an enquiry commits you to nothing. You can also approach any lender or desk directly.
What a fee could never buy is advice. Crypto Loans HQ is not an adviser: it does not tell you whether to borrow, how much, which counterparty to choose or what to do with the proceeds. An introduction buys access to counterparties whose published criteria fit, and someone who stays with the enquiry to documentation.
If a lender or desk pays
Where compensation comes from a lender or desk, it is agreed with that firm before any enquiry is presented to it: the firm pays an introduction or referral fee for an enquiry it takes on. Whether that is the model used here is an open decision, and this page is updated when it settles.
It creates the obvious conflict: an introducer paid by counterparties has a reason to send enquiries to the firms that pay most, whether or not they suit the client. That is the conflict this page exists to name, and the controls below are how it is held.
Two consequences are worth stating plainly. A fee paid out of a lender’s revenue is still part of the economics of the loan you sign, so compensation from a counterparty is not the same as an introduction that costs nothing. And the lender or desk, not us, decides your terms, so test them by reading the documents and comparing more than one counterparty: the clauses to read first are in what the documents should answer.
The conflicts, and the rules that hold them
A conflict is not removed by disclosing it. These are the working rules behind the disclosure:
- Matching runs on published criteria — the asset, the size, the client type and the jurisdiction a counterparty accepts. Compensation is not one of them, and where more than one counterparty fits, more than one is presented.
- No firm is recommended. We do not tell you which counterparty to choose, and we publish no ranking, rating or review that would do it indirectly.
- Both sides are disclosed. If compensation could come from a counterparty and from you on the same enquiry, you are told before an introduction is made.
- No client money, no assets, no custody. Collateral, loan proceeds and trade settlement never pass through Crypto Loans HQ, so there is nothing to be gained from one settlement route over another.
- Every page that names a firm links here, so the disclosure travels with the claim. Naming a firm implies no relationship with it, and none is claimed anywhere on this site.
Why there are no rankings or lender reviews
Once an intermediary can be paid by the firms it writes about, any ordering it publishes is compromised, however carefully the criteria are dressed up: the ranking becomes the advertisement.
So this site does not publish one. Named firms appear only as dated, sourced statements of what they publish, such as a loan-to-value band, a cure window or a custody arrangement, so you can check each against that firm’s own page. Where a firm publishes inconsistent figures, both are cited or neither is. Where a claim could not be verified from a primary source, it is not written. That standard is in editorial standards.
The result: this site tells you what to ask and what to compare, and the counterparties tell you their terms. Comparisons of published mechanics, not of firms, are in how do crypto loans work and bitcoin loan rehypothecation and custody.
The rules an introducer sits under
Compensated introductions are regulated in several of the places an enquiry can come from. These are descriptions of published rules, not conclusions about our own status, which is a question for counsel:
- UK credit broking. Article 36A of the Regulated Activities Order makes credit broking a regulated activity, including effecting an introduction of an individual who wishes to enter into a credit agreement to a person who lends under a regulated credit agreement (article 36A). Whether a crypto-backed loan is such an agreement is a legal question.
- UK financial promotions. Since 8 October 2023, promoting cryptoassets to UK consumers has been lawful only through one of four routes, and breach is a criminal offence that also reaches firms overseas (FCA).
- The UK regime from 25 October 2027. SI 2026/102 inserts new regulated activities for qualifying cryptoassets, including arranging deals, with a narrow exclusion for arrangements that are solely an introduction to a firm holding the relevant permission (regulation 40).
- California. The Financing Law defines a broker as a person negotiating or performing any act as broker in connection with loans made by a finance lender (Financial Code section 22004), and section 22100(a) requires a license (section 22100).
- EU. MiCA lists reception and transmission of orders — the reception of an order to buy or sell crypto-assets and its transmission to a third party for execution — among the crypto-asset services that require authorisation. Whether an introduction involving an EU client falls inside that definition is a question for counsel (Regulation (EU) 2023/1114).
Nothing here says we are outside any of those regimes, and no exemption is claimed. This site names no operator and claims no registration or permission: see the legal notice.
Primary sources
- Regulated Activities Order, article 36A: credit broking
- FCA: Marketing cryptoassets to UK consumers
- Cryptoassets Regulations 2026 (SI 2026/102), regulation 40
- California Financial Code section 22004 and section 22100
- Regulation (EU) 2023/1114 (MiCA)
Questions about compensation
Do I pay a fee to send an enquiry?
No fee is payable by you unless you have agreed it in writing first, and that agreement would come before any introduction is made. If you are asked to agree a fee, you see its amount or basis, what it covers and when it falls due before you commit to anything, and you can stop there and approach a lender or desk directly.
Does a lender or desk pay you, and does that change what I am offered?
Compensation may come from the lender or OTC desk an enquiry is introduced to. It plays no part in the matching: an enquiry goes to counterparties whose published criteria fit it, and where more than one fits, more than one is presented. The terms you are offered are set by that firm alone. Crypto Loans HQ sets no rate, no loan-to-value ratio and no price.
Why is there no ranking or lender comparison on this site?
Because a ranking published by an intermediary that the ranked firms may pay cannot be read as independent. This site describes named firms only from their own published terms, dated and sourced, and never rates, ranks or recommends one over another. Which firms fit an enquiry depends on the asset, the size, the client type and the jurisdiction, not on a league table.
Has any firm paid to be named on this site?
No. No firm has paid to be named, described, placed higher on a page or included in a table, and no such arrangement is accepted. Naming a firm is a dated description of what it publishes and implies no relationship with it. Every page that names a lender or desk links to this disclosure.
Private enquiries
Ask what an introduction would cost before you send anything else.
Tell us the asset, the approximate size and whether you want to borrow or to trade, and ask about compensation in the same message. Any fee payable by you is agreed in writing before an introduction is made.