For advisers

Crypto loan referrals for advisers

For registered investment advisers, private bankers, accountants, lawyers, wealth managers and family-office staff whose client needs liquidity without selling, or needs to trade size.

Crypto loan referrals for advisers work like this: you describe the client’s position, we check it against what third-party lenders and OTC desks publish, and where criteria fit we arrange an introduction. Crypto Loans HQ is an introduction service, not a broker, a lender, an OTC desk or an adviser. Your client contracts directly with the counterparty, which sets every term.

Key takeaways

  • Not a broker, and the word matters. Crypto Loans HQ introduces enquiries to third-party lenders and OTC desks. It sets no terms, holds no client assets and gives no advice.
  • Your client contracts with the counterparty. That firm issues its own documents and runs its own identity and anti-money-laundering checks on the contracting party, including beneficial owners of an entity.
  • The client need not be named to us at first. An enquiry needs the asset, an approximate size, the client type and the country; identity documents go to the counterparty, not through us.
  • No referral compensation is offered on this page. No fee, commission or revenue share is held out to advisers, and none should be inferred.
  • Being paid to introduce can itself be a regulated activity. UK credit broking and brokering under the California Financing Law both turn on effecting introductions to a lender. Your own counsel decides what applies to you.

What you are referring into

Crypto Loans HQ qualifies an enquiry, matches it against the published criteria of third-party lenders and OTC desks, and arranges an introduction where those criteria fit. It is not the lender, not the desk, not a custodian, not an exchange, not a broker-dealer and not an adviser. It does not lend, quote, take custody, hold client money or set a single term of what your client signs.

The distinction matters, because “broker” means something specific to an adviser. Some intermediaries here are authorised brokers: the Enness US page states “Enness Global is a broker, not a lender”, and its own footer records that “Enness Global is a trading name of Enness Limited”, which is “authorised and regulated by the Financial Conduct Authority” under registration number 565120 (Enness, accessed September 2026). The authorisation belongs to the legal entity, not to the trading name. Crypto Loans HQ makes no equivalent claim and holds out no authorisation. Its own regulatory status is a question for counsel; this site publishes no conclusion on it, and says nothing about being outside any licensing regime.

How a referral works, end to end

Six stages, and the split is fixed: we run the first three, the counterparty runs the last three with your client. Nothing here is an offer to lend or to arrange a loan on particular terms. The full version is on how it works.

  1. You send the position, not the client file

    Asset (bitcoin, ether, a major stablecoin, or spot bitcoin or ether ETF shares), approximate size, whether the client wants to borrow or to trade, the country of residence or establishment, and the client type, and say that you are an adviser acting for a client. Send no identity documents, account numbers, wallet addresses or passwords.

  2. We qualify it

    Against the working minimums of US$100,000 for a loan and US$250,000 for a crypto OTC trade, and against what lenders and desks publish about the clients, assets, sizes and jurisdictions they accept. We may ask how the asset is held today and which person or entity would sign. An enquiry that fits no published criteria is not taken further.

  3. We present it, with consent

    With your agreement, which we ask for by email before anything is shared, the enquiry goes to counterparties whose published terms suit it: collateral accepted, custody model, size range, client types and jurisdictions served. Where more than one fits, more than one is presented. We do not rank them or tell your client which to choose.

  4. The counterparty responds with indicative terms

    For a loan: amount, starting loan-to-value (LTV) ratio, margin-call and liquidation levels, cure window, interest structure and custody arrangement. For a crypto OTC trade: how the desk quotes, its settlement terms and any fees. Indicative terms are not an offer, and no timing is promised.

  5. Onboarding and documents

    The lender or desk runs identity verification and anti-money-laundering checks on the contracting party, including beneficial ownership for companies and trusts and, where it asks, source of funds and source of wealth. It issues its own documents, which your client signs directly with it.

  6. Funding or settlement

    Collateral moves into the custody arrangement the documents specify, and the loan proceeds go to an account in the client’s name. A crypto OTC trade settles between the client and the desk. Nothing passes through Crypto Loans HQ.

What we ask for, and what stays with you

An introduction should not require you to hand over a client file. The enquiry carries the shape of the position, the counterparty collects the identity, and your relationship stays yours.

Where each piece of information goes in an adviser referral
Information To us, at enquiry To the lender or desk
Asset and approximate size Yes, as an approximate figure Yes, in detail
Client type and country Yes Yes
Client name Not needed at first Required before it contracts
Identity documents Never Yes, through the firm’s own onboarding
Source of funds and wealth Never Where the firm asks for it
Wallet addresses, account numbers, keys Never Only as its documents require
Your fee arrangement with the client Never Never
The enquiry form emails the enquiry and stores nothing else. Nothing is shared with a lender or desk until you agree to it by email: see privacy.

We never ask for a seed phrase, private key, password or two-factor code, never ask anyone to send crypto assets to Crypto Loans HQ, and never market to a client you have referred.

What you can expect to see

An adviser is usually judging two things: whether the counterparty is worth the client’s signature, and what the client is exposed to afterwards. Both live in the documents.

  • Indicative terms from each counterparty that engages, in that firm’s own words. Where more than one fits, your client sees more than one.
  • The custody arrangement in writing. Who holds the collateral, in what structure, and whether the lender may pledge, lend or re-use it. Published positions differ sharply: Unchained states that loan collateral sits in 2-of-3 multisignature addresses in a segregated sub-trust and is not rehypothecated, while Ledn states that collateral on its custodied loans may only be re-posted to an institutional funding partner or a Ledn-sponsored financing vehicle, a published limit on re-use rather than an absence of it (each firm, accessed September 2026).
  • The margin mechanics. How LTV is calculated, whether accrued interest counts in the numerator, which price feed values the collateral, the cure window and whether liquidation is partial or total.
  • No promise of an outcome or a timeline from us at any stage. Onboarding pace belongs to the counterparty.

Where the client holds spot bitcoin or ether ETF shares rather than the asset itself, the collateral is a security and the route is securities-based lending, which FINRA describes as non-purpose demand loans a lender may call at any time. Those questions go to Securities Backed Lending; the crypto-collateral side is in crypto-backed loans and, for ether, borrow against Ethereum.

What counterparties publish about advised clients

Lenders and desks publish their own client criteria, and those criteria, not ours, decide where an enquiry can go. Several state in terms that they serve advised and institutional clients.

What lenders and desks publish about adviser and institutional clients
Firm What it publishes about who it serves
Two Prime Lists corporate treasuries, public bitcoin miners, family offices, registered investment advisers, institutional allocators and high-net-worth individuals. Describes itself as an SEC-registered investment adviser and a CFTC-registered commodity trading adviser. Publishes no sizes or terms
Unchained Commercial loans only, with a US$150,000 minimum and 12-payment terms; financing of US$5 million or more goes to an institutional lending desk for family offices, funds and institutional borrowers
Galaxy Its lending desk serves qualifying institutions, accredited individuals and corporations; its crypto OTC business lists institutional allocators, asset managers, hedge funds, family offices and high-net-worth individuals
FalconX Describes itself as a prime brokerage for asset managers, hedge funds, family offices, venture funds, miners, protocols, banks and other financial institutions. Publishes no minimum
B2C2 States that it does not transact with, or provide any service to, any retail investor or consumer
Each firm’s own pages, accessed 19 September 2026. Naming a firm is a dated description of what it publishes, not a ranking, a recommendation or evidence of a relationship with Crypto Loans HQ: see how we are paid.

One structural point catches advisers out: a “qualified custodian” is a defined term in the US, not a marketing adjective. Under the Advisers Act custody rule it means a bank or savings association, a registered broker-dealer holding client assets in customer accounts, a registered futures commission merchant within limits, or a foreign financial institution that segregates client assets (17 CFR 275.206(4)-2). Lenders use the phrase more loosely than the rule does, so read whose entity actually holds the collateral.

Compensation for referring advisers

This page holds out no fee, commission, revenue share or rebate to advisers, and none should be inferred. It is not a referral program, and no schedule of adviser compensation is published here, because the compensation model itself is still an open decision.

What can be said now is how any compensation is handled. It may come from the lender or desk an enquiry is introduced to, or from the client under a written agreement, or from both, and any fee payable by a client is agreed in writing before an introduction is made. Compensation is never a matching criterion: an enquiry goes to counterparties whose published criteria fit it, not to whichever firm would pay the most. The full disclosure is on how we are paid.

Read it before you refer, for a reason that has nothing to do with us. In the UK, article 36A of the Regulated Activities Order makes credit broking a regulated activity, covering the effecting of an introduction of an individual who wishes to enter into a credit agreement to a person who lends under a regulated credit agreement (RAO article 36A). In California, the Financing Law defines a broker as a person engaged in the business of 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). Whether a crypto-backed loan is a regulated credit agreement, and whether a compensated introduction engages either regime, are questions for your own counsel.

Risk

Risks to weigh before you refer

  • Margin calls and forced liquidation. A price fall raises the loan-to-value ratio. Past the margin-call level the borrower must add collateral or repay part of the loan, commonly within a published cure window of 24 or 48 hours; past the liquidation level the lender sells collateral, and some sell enough to repay the whole balance.
  • Custody and rehypothecation. What the lender may do with the collateral is set by the contract alone. The retail loan terms of Celsius, as quoted by the bankruptcy court, allowed it to pledge, re-pledge, hypothecate, rehypothecate, sell, lend or otherwise transfer pledged assets.
  • Counterparty insolvency. On 9 November 2023 the Celsius court held that collateral posted under those terms by borrowers who objected to the plan was property of the bankruptcy estate. Custody structure and contract wording decided it, not the marketing.
  • Tax on a liquidation. A forced sale is a disposal of the client’s asset, generally taxable, with the proceeds going to the lender. See are crypto loans taxable.
  • Your own obligations travel with the referral. Suitability, your disclosures and any licensing that attaches to a compensated introduction stay yours, and an introduction does not move them.

The mechanics are set out in bitcoin loan margin calls and bitcoin loan rehypothecation and custody.

General information, not advice. This page describes how an introduction to a third-party lender or OTC desk works for an adviser acting for a client. 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 to you or to your client. Terms are set only by the lender or desk, and statements about named firms are dated descriptions of what those firms publish. How we are paid.

Primary sources

Adviser questions

Are you a broker?

No. Crypto Loans HQ is an introduction service: it qualifies an enquiry, matches it to third-party lenders and OTC desks whose published criteria fit, and stays with it to documentation. It is not a broker, a lender, an OTC desk, a custodian or an adviser, it holds no client assets and it sets no terms. What that means for its regulatory status is a question for counsel, and this site publishes no conclusion on it.

Does my client have to be named when I enquire?

No. An enquiry needs the asset, an approximate size, the client type and the country of residence or establishment. A name matters once a counterparty engages, because the lender or desk runs its own identity checks on the contracting party. Identity documents go to that firm directly rather than through us.

Do you pay advisers for referrals?

No fee, commission or revenue share is offered to advisers on this page, and none should be inferred from it. Whether any arrangement with advisers will exist is an open decision. If one is ever introduced, its terms will be published on how we are paid and disclosed before an introduction is made.

Who does my client contract with?

The lender or the OTC desk, directly. That firm issues its own documents, sets the loan-to-value ratio, margin-call levels, interest, price and settlement terms, runs its own identity and anti-money-laundering checks, and holds or releases the collateral. Crypto Loans HQ is not a party to the loan or the trade and holds nothing. Nothing stops your client approaching a lender or desk directly instead.

Adviser enquiries

Send the position, not the client file.

Tell us the asset, an approximate size, the client type and the country, and say that you are acting for a client. Where a lender’s or desk’s published criteria fit, we arrange an introduction; your client contracts directly with that firm.