LlamaRisk | Legal Review of CBAM MLA

LlamaRisk
Wed, 15 Apr 2026 22:09:55 +0000
General

Summary

LlamaRisk has conducted a legal review of the Master Loan Agreement governing Ethena’s reserve-backing asset deployment to Coinbase Asset Management (via Coinbase US Bitcoin Yield Fund LP).

Scope of Review

LlamaRisk assessed counterparty structure and regulatory standing, asset protection mechanisms (collateral, security interests, enforceability), operational provisions (loan origination, termination mechanics, reporting), default and remedies architecture, and protocol-specific considerations relevant to digital asset lending. The specific contractual terms, commercial thresholds, and pricing provisions are confidential and are not disclosed in this public summary.

Findings

The CBAM MLA establishes a bilateral lending framework with Coinbase US Bitcoin Yield Fund LP, a fund vehicle managed by Coinbase Asset Management — a wholly-owned subsidiary of Coinbase Global, Inc. and an SEC-registered Investment Adviser. A notable structural feature is the tri-party custody arrangement: all assets and collateral are held by an OCC-chartered institution under an Account Control Agreement, providing Ethena with perfected, first-priority security interest over collateral without direct counterparty custody exposure to the Borrower.

The CBAM MLA represents the strongest protective framework of the three agreements reviewed by LlamaRisk for Ethena. No recommendations on amendments or fixes have been issued by our side.

Conclusion

LlamaRisk supports the Risk Committee’s approval of the CBAM Master Loan Agreement for the deployment of Ethena’s reserve-backing assets.