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Which bitcoin lenders do not rehypothecate collateral?
Unchained, SALT, APX Lending and Ledn each publish a promise about reusing bitcoin collateral. We read all four word for word and graded who can check it.
By Staff, Lend Ledger
Of the lenders whose policies this desk could read on 23 September 2026, three say in their own words that they do not rehypothecate bitcoin collateral: Unchained, SALT and APX Lending. A fourth, Ledn, says collateral is not lent out to generate interest but allows restricted re-posting to a funding partner. Only Unchained’s page describes a key the borrower holds.
That is the short answer to which bitcoin lenders do not rehypothecate collateral, and it is an answer about published wording, not about conduct. Every line below is a lender describing itself. None of it was audited here, and a lender’s own page is the weakest kind of evidence a borrower can hold. It is also the only kind this desk found in the pages it read.
Why the question exists at all
SALT’s own vetting article opens with the failures of 2022: platforms that reused customer collateral for their own trading and lending collapsed, and customers lost assets they believed were secure. APX Lending’s page names Celsius, Voyager and BlockFi as lenders that rehypothecated client collateral before they failed. Those are lenders’ framings of their competitors’ collapse, and both lenders have a product to sell on the back of it. The underlying point stands without them: if the collateral has been lent onward and the party at the end of the chain fails, the borrower who repays in full can still be owed bitcoin that is not there.
So the useful question is not whether a lender says “no rehypothecation”. All four do something like it. It is what exactly each sentence forbids, and whether the borrower can see it being kept.
Which bitcoin lenders do not rehypothecate collateral, word for word
This desk read each lender’s own page on 23 September 2026. The wording column quotes or closely tracks the page; the two right-hand columns are this desk’s reading of it.
| Lender | What its own page says | Scope of the promise | Can the borrower check it? |
|---|---|---|---|
| Unchained | Does “NOT rehypothecate, or lend to other people/entities, any bitcoin backing an Unchained loan” | No rehypothecation and no lending to anyone | Yes, in part: borrower holds one of three keys on an on-chain 2-of-3 multisig and can verify addresses on a hardware wallet |
| SALT | “Does not rehypothecate borrower collateral”; “never re-lent, traded, or reused” | No reuse of any kind; used only to manage the borrower’s loan | No key described; custody is “institutional-grade”, and no custodian is named in the passages read |
| APX Lending | Does “not engage in rehypothecation. Nor do we re-loan, pool, or co-mingle your collateral” | No reuse “under any circumstances”; says the clause is in its loan agreement | Claims collateral is “visible on-chain, in real time, 24/7”; the passages read do not say the borrower holds a key |
| Ledn | Custodied Loan “allows restricted re-posting” to a USD funding partner or Ledn-sponsored vehicle | Not lent out “to generate interest”; re-posting to a funder permitted | Rests on Ledn’s description and a ring-fencing structure the page tells borrowers to review |
| Strike | Policy page returned 403 to this desk | Not read | Not read |
What each promise actually covers
Unchained: no rehypothecation, and no lending to anyone
Unchained’s help centre page on loan collateral carries the broadest sentence of the four, and the only one that adds lending “to other people/entities” to the ban. It then describes the structure behind it. The borrower deposits bitcoin into a segregated Sub-Trust of the UC Secured Assets Trust Series, under a Trust Agreement dated April 14, 2022, as amended, and receives a Specified Unit of Beneficial Interest representing equitable title. The collateral sits in multisignature addresses “viewable on the blockchain” in a 2-of-3 quorum, with keys held by the Key Agent, Unchained and the borrower, and two of the three keys are needed to move it.
The ban is Unchained’s word. The structure is what makes it more than a word: with one key in the borrower’s hands, Unchained cannot sign a transaction alone. It still can with the Key Agent’s key; the page’s own word for the model is “trust-minimized”, not trustless.
SALT: not re-lent, traded or reused
SALT’s statement comes from its own July 8, 2026 article on vetting lenders, which says the policy is also stated on its personal loans page; that page was not read here. The wording is wide on use: collateral is held separately from SALT’s treasury and operating funds and is never re-lent, traded or reused. It is narrow on proof. The passages this desk read describe “institutional-grade custody” without naming the custodian or offering an address the borrower can watch. SALT’s own checklist tells borrowers to find the commitment in the loan agreement, not only in marketing, which is the right test and one SALT’s article sets for SALT too.
APX Lending: “under any circumstances”
APX Lending’s rehypothecation page adds pooling and co-mingling to the ban and says the promise holds “under any circumstances”. Of the four pages read, it is the only one that says the clause is “written explicitly into our loan agreement”. The page also says collateral is not re-lent, staked or pledged elsewhere, and in the passage read it names BitGo Trust as custodian. Its verification claim is on-chain visibility around the clock. Visibility shows the coins have not moved. It does not show who can move them, and the passages read do not say the borrower holds a key.
Ledn: not lent for interest, but re-posting allowed
Ledn’s custody explainer, marked “Updated 9 September 2026” beneath an older “Last updated: May 16, 2024” header, is the most candid of the four and the narrowest. It says Ledn’s published Custodied Loan description “allows restricted re-posting to an institutional USD funding partner or a Ledn-sponsored financing vehicle”, and that neither Ledn nor those partners may lend the collateral out to generate interest. The explainer does not call that re-posting rehypothecation. A borrower whose bitcoin has been re-posted to a funder is exposed to that funder, which is the exposure the other three pages say they exclude. The detail of Ledn’s wording and its Open Book Report is in our Ledn rehypothecation piece.
Can the borrower check a no-rehypothecation promise?
Three levels of checkability appear across the four pages, and they are not equivalent.
A key the borrower holds is the strongest. On Unchained’s description, a borrower-held key in a 2-of-3 multisig means the collateral cannot move without two signatures, and the borrower can confirm the address on their own hardware wallet. That does not settle legal questions. Ledn’s explainer makes the point itself: multisignature arrangements “do not, by themselves, answer every legal or counterparty question.”
An on-chain visibility claim is weaker. APX says borrowers can see their collateral on-chain. Seeing it proves it is there today; it does not prevent it being moved tomorrow by whoever holds the keys.
A custodian or funding-partner statement is the weakest. SALT’s and Ledn’s models, as described in the pages read, ask the borrower to rely on the lender’s description of what a third party is permitted to do. The liquidation mechanics differ as well, which our Ledn vs Unchained comparison sets out.
What to ask any lender before pledging bitcoin
Two of the four pages publish their own checklists, and they are more useful than their marketing. APX Lending’s tells borrowers to ask where collateral is held and under what name, whether it is segregated or mixed with other assets, who the custodian is, what happens to it if the firm fails, and to be shown the exact clause in the agreement. SALT’s asks whether the lender rehypothecates, how collateral is held, and whether the answer appears in the loan agreement itself.
This desk would add three questions the pages read do not put in these terms:
- Who holds keys, and how many signatures move the coins? A borrower-held key changes what a promise is worth; a view of an address does not.
- Is re-posting to a funder, a financing vehicle or an affiliate permitted? Ledn’s explainer shows the ban can be on lending “to generate interest” while re-posting is allowed. Ask about every form of transfer, not only lending.
- What does the insolvency clause say? A segregated trust, a ring-fenced vehicle and an omnibus account at a custodian are different claims in a failure, and only the contract says which one the borrower has.
If a lender will not put the answers in writing, that is the answer, which both checklists say in their own way.
Why Strike is not in the table
Strike’s page on where bitcoin collateral is held returned a 403 bot block to this desk on 23 September 2026. Its policy is therefore not stated here in any form. A search-result summary of a page is not the page, and this desk does not fill a table cell from one.
What this comparison does not show
It does not show that any of the four keeps its promise. No loan agreement was read, no trust agreement was read, and no on-chain address was checked. It does not cover every lender: it covers the four whose own pages were readable and relevant on the day. The same limit applied to Galaxy’s no-rehypothecation promise: a sentence on a product page is a claim, and the contract is where it binds.
Bitcoin-backed loans and rehypothecation: common questions
Are bitcoin-backed loans safe?
Not safe in any absolute sense. The collateral is exposed to the lender, to whoever holds the keys, and to liquidation if the price falls. A no-rehypothecation promise removes one layer of that exposure, the chain of third parties your bitcoin might be lent to, but only as far as the promise reaches and only as well as the borrower can check that it is being kept.
What is rehypothecation?
Rehypothecation is a lender reusing collateral you pledged, for example by lending it out, trading it or posting it against its own obligations. SALT’s article defines it that way, and APX Lending’s page adds staking and locking into other deals. The borrower then depends on every party down that chain, not only on the lender they chose.
Does Unchained rehypothecate bitcoin collateral?
Unchained’s help centre says it does not. The page read on 23 September 2026 states that Unchained does NOT rehypothecate, or lend to other people or entities, any bitcoin backing an Unchained loan, and describes collateral held in a 2-of-3 multisig in which the borrower holds one key and two keys are needed to move funds.
Does Ledn rehypothecate bitcoin?
Ledn says its collateral is not lent out to generate interest. Its custody explainer, updated 9 September 2026, also says its Custodied Loan description allows restricted re-posting to an institutional USD funding partner or a Ledn-sponsored financing vehicle. Whether a borrower calls that rehypothecation depends on the definition; the explainer does not use the word for it.
Nothing above describes any of these lenders as regulated, licensed, registered or authorised anywhere; no register was read, and a footer link is not a licence. Every promise quoted is the lender’s own. Borrowing against bitcoin carries a high risk of loss, up to the whole of the collateral through counterparty failure or liquidation, and nothing here is financial advice.