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bitcoin & Crypto Loan Glossary

bitcoin & Crypto Loan glossary

74 terms across DeFi and CeFi lending - from LTV and liquidation to smart contracts and tax efficiency - explained in plain English with real examples.

A

AIF (Alternative Investment Fund)

A regulated collective investment vehicle for sophisticated investors. Blockchain Legal runs the Firefish Alternative Fund as a Czech-domiciled AIF under Act 240/2013 (administered by LQ Solutions s.r.o., supervised by the Czech National Bank). Minimum entry is €125,000 (qualified investors only) and the fund targets ~11% net annual return by allocating across the underlying lending marketplace. The AIF wrapper is what brings the marketplace into a vehicle institutional investors can underwrite.

Altcoin

Any digital asset that isn't Bitcoin. Thousands exist, built by founders who pre-mined coins, sold early allocations to insiders, or designed tokenomics that funnel value back to themselves. Unlike Bitcoin, almost every altcoin has identifiable creators with financial interests in its success. Bitcoin had no pre-mine and no founder who enriched himself. Satoshi disappeared entirely in 2011 leaving no one in control. That moment was a once-in-history accident that can’t and doesn’t need to be replicated. Altcoins are mostly attempts to copy it, but none have managed to replicate what makes Bitcoin actually valuable: being a leaderless, neutral monetary network that no one can manipulate.

AML (Anti-Money Laundering)

The regulatory framework that requires financial institutions to identify customers (KYC), monitor transactions for suspicious patterns, and report when triggered. Firefish operates inside this framework as an EEA-based, MiCA-registered service provider. AML is part of why the marketplace has a borrower whitelist by jurisdiction and why funds move through regulated banking rails rather than unregulated bridges.

APR (Annual Percentage Rate)

The yearly cost of a loan stated without compounding. On Firefish, the rate is fixed at origination. What you agree to on day one is what you pay until the loan closes, no surprises. Quoted borrow rates start at 5% p.a. and are set by the marketplace at the time you accept an offer.

APY (Annual Percentage Yield)

A yield figure that includes the compounding effect of reinvestment. Investors evaluating Firefish's marketplace will usually see returns expressed as fixed APR over the loan term rather than APY, bullet repayment loans don't compound during the term, but APY is still useful when comparing Firefish against products that do compound interest internally (most CeFi yield accounts).

B

Bitcoin

The only open, decentralised, leaderless monetary network humanity has ever produced. 21 million coins, no issuer, no foundation, no CEO, no pre-mine. A fixed supply enforced by code and secured by more raw computing power than any other network in existence. Firefish accepts Bitcoin and only Bitcoin as collateral, because its monetary properties are what make the lending model underwritable in the first place. Bitcoin is the signal, everything else is noise. Fix the money, fix the world.

Bitcoin Network

The peer-to-peer network of nodes and miners that runs the Bitcoin blockchain. Every Firefish loan exists on this network: the multisig escrow is a real on-chain address, the closing transactions are real broadcastable Bitcoin transactions, and there's no parallel ledger. This is why Firefish describes its architecture as "on-chain" without qualification. It's the actual Bitcoin mainnet, not a sidechain, no wrapped Bitcoin or other shitcoins.

Bitcoin Wallet

Software or hardware that manages your Bitcoin private keys and signs transactions. To borrow on Firefish you need a wallet you control. Your BTC is sent from it into the escrow at the start of the loan, and returned to your wallet once you repay. Firefish supports any standard Bitcoin wallet supporting Taproot.

Bitcoin-Backed Loan

A loan where you pledge Bitcoin as collateral to receive cash, and recover the same coins after repayment. The whole point is to tap the value of your stack without selling it, because selling means a taxable event, losing future upside, and giving up your Bitcoin for fiat you don’t want to hold long-term anyway. On Firefish, the loan is peer-to-peer. Investors fund loans directly, and your BTC is locked directly on the Bitcoin blockchain rather than sitting on a lender's balance sheet.

Blockchain

A shared, append-only ledger replicated across every node on the network, where each new block cryptographically commits to all prior history. Satoshi Nakamoto called it the Timechain, a more accurate name that some Bitcoiners still prefer. For lending purposes, the blockchain provides the property Firefish leans on hardest: anyone can verify, independently and without permission, that a specific UTXO is locked, where it's locked, and what closing transactions can spend it.

Bullet Loan

A repayment structure where the entire principal is returned in one payment at the loan's maturity date, with interest accrued up to that point. Firefish loans are bullet-repaid by default, no monthly payments.

C

Capital Gains

The taxable profit on the sale of an asset, calculated as sale price minus cost basis. A BTC bought at $5,000 and sold at $80,000 produces $75,000 of capital gain. The same BTC, used as collateral on a Firefish loan that disburses fiat, produces zero capital gain at loan origination. The gain is deferred until the BTC is actually sold (or until liquidation, if that happens).

CASP (Crypto-Asset Service Provider)

The license category that MiCA created for entities offering crypto-asset services: exchanges, custodians, advisors, brokers, and similar services.

CeFi (Centralized Finance)

A financial-services model where a company custodies user assets, runs the order book or matching engine, and processes loans on its own account. Most legacy crypto lenders are CeFi: the company holds your BTC and you hold a contractual claim against the company.

Cold Storage

Keeping Bitcoin in an environment that's never been connected to the internet: a hardware wallet kept offline, an air-gapped signer, or a steel backup. The mental model is that an attacker would need physical access to do anything. Firefish borrowers commonly come into the loan from cold storage and want to return to it after repayment; the escrow architecture is designed so that path doesn't require trusting a custodian in between.

Collateral

The Bitcoin you commit to back a loan. With Firefish, that BTC moves into a multisig escrow on the Bitcoin blockchain where it can only move in pre-defined ways: released back to the borrower when he repays, or transferred to the lender if the borrower defaults or the collateral’s value falls past the liquidation threshold.

Collateral Top-Up

Adding more Bitcoin to an active loan's escrow to lower the LTV and push your liquidation price further away. Firefish allows mid-loan top-ups; this is the proactive equivalent of a margin call. You choose to thicken your buffer instead of waiting for the price oracle to call you. Better safe than sorry. Firefish doesn’t charge a fee on top-ups.

Cost Basis

The acquisition cost of an asset, the figure capital gains are calculated against. While a Bitcoin-backed loan is open, the borrower's cost basis is unchanged. Borrowing isn't selling, so the basis isn't reset. If the loan goes to liquidation, the disposal of the collateral becomes a sale at market price and triggers a gain or loss against that original basis. Tracking cost basis becomes important specifically in liquidation scenarios.

Counterparty Risk

The risk that the entity on the other side of your loan fails, through insolvency, fraud, hack, or shutdown, and you can't recover what's owed. The 2022 collapses (Celsius, BlockFi, Voyager) were counterparty-risk events: customers had contractual claims against companies that no longer existed. Firefish reduces counterparty risk to its components: investor performance risk (mitigated by overcollateralisation and the multisig structure) and protocol-operator risk (mitigated by the fact that Firefish never holds the BTC and uses pre-defined transactions).

Crypto-Backed Loan

A loan secured by digital assets in general, a category that includes Bitcoin-backed loans alongside multi-asset CeFi products and pooled DeFi positions. Firefish narrows this category to Bitcoin-only, because Bitcoin is the only collateral in the space whose supply has a credible scarcity, whose issuer cannot be pressured, and whose liquidity or availability doesn't depend on a founder's continued interest.

Custodian

A party that holds your assets and can move them: Ledn, Nexo, or BlockFi before its collapse. A custodian holds the Bitcoin and the borrower has only a contractual claim. Firefish doesn't have a custodian in this sense: collateral lives in a 3-of-3 escrow on-chain and can only be spent in pre-defined ways.

D

De-peg Risk

The risk that a stablecoin loses its peg to its reference currency. Historically rare but historically real (USDC, March 2023). Firefish borrowers who take disbursement in USDC or USDT carry this risk on the loan amount. The BTC collateral is unaffected because it's denominated in BTC, not in stablecoins.

Default

The loan outcome when a borrower fails to repay by maturity. On Firefish, the lender is made whole up to the amount owed, and the remaining Bitcoin collateral, minus a 5% penalty, is returned to the borrower.

DeFi (Decentralized Finance)

A financial-services model where smart contracts on a blockchain replace the company. No KYC, no support desk, no custodian, just a wallet, a contract, and a transaction. DeFi lending (Aave, Compound, MakerDAO) lives almost entirely on Ethereum and Ethereum Layer 2s. For Bitcoin holders, DeFi typically means wrapping BTC as a synthetic ERC-20 first. Firefish's architecture is closer to DeFi in custody (on-chain, oracle-attested) but stays on Bitcoin and adds a regulated marketplace layer on top.

Disbursement

The transfer of loan funds to the borrower after collateral is locked. Firefish currently supports EUR, CZK, CHF, PLN and USDC/USDT for global borrowers. The funds are being sent directly from the matched investor, not from a Firefish treasury. Speed depends on the rails: stablecoin disbursement settles on-chain, fiat disbursement settles via SEPA or local bank wire.

Disbursement Speed

How fast loan funds reach you after collateral is locked. Firefish settles stablecoin disbursements on-chain. Fiat disbursement runs via SEPA Instant where supported, otherwise standard SEPA timing. Because the lender is a real investor on the other side of the marketplace, end-to-end speed is also a function of when your loan is matched.

Discreet Log Contract (DLC)

A Bitcoin-native smart-contract primitive that uses signed price attestations from oracles to enforce conditional payouts. DLCs are an alternative architecture for Bitcoin-backed loans, and Firefish has publicly argued, in two long-form essays under /resources, that DLCs are a poor fit for retail lending: they require the oracle to attest to a final outcome at a single moment, which forces awkward design tradeoffs around early repayment, top-ups, and rollover. Firefish's pre-signed-transactions approach was chosen explicitly as a counter-proposal to DLC-based lending designs.

E

Early Repayment

Closing a loan ahead of its scheduled maturity. On Firefish, borrowers can request early repayment at any time. You pay back principal plus the full interest for the agreed term, the payment oracle signs, and your Bitcoin unlocks.

Escrow Output

The on-chain Bitcoin transaction output where loan collateral is locked for the loan's duration. On Firefish, the escrow output is a 3-of-3 multisig address controlled by the borrower, price oracle, and payment oracle. Pre-signed closing transactions reference this specific output as their input, which is why a borrower can't double-spend or substitute different collateral after origination.

F

Fiat Currency

State-issued money like Euros, Dollars, Swiss Francs, backed by the issuer's central bank, which means governments can print more whenever it suits them. Firefish makes fiat available against your Bitcoin without forcing you to sell the hardest money ever created: you keep the upside, you spend the fiat.

Fixed-Term Loan

A loan with a defined start date, end date, and repayment schedule. Firefish loans run 3 to 24 months, repaid as a single bullet payment at maturity. There are no monthly amortising installments. The fixed term is what allows investors on the other side of the marketplace to plan their cash flow. Borrowers can request early repayment at any time, though the full interest for the agreed term applies regardless.

H

Hardware Wallet

A physical device that stores your private keys offline and signs transactions only when you approve them on the device itself. Hardware wallets like Ledger, Trezor, Coldcard, BitBox, are the standard tool for sovereign Bitcoiners and the natural counterpart to a non-custodial lending product like Firefish.

HODL

A Bitcoiner's commitment to hold long-term, regardless of cycle. The original misspelling traces back to a 2013 forum post. The philosophy outlasts the typo. Bitcoin-backed loans are the operational expression of the HODL stance. Instead of selling into a tax event to reach liquidity, you lock collateral, draw fiat, and exit with your stack intact when the loan closes.

Hot Wallet

A wallet that's connected to the internet, typically running on a phone or browser. Hot wallets are convenient for spending but exposed to remote compromise. The standard hardcore-Bitcoiner posture is to keep small operating amounts hot and the long-term stack cold. Firefish doesn't operate a hot wallet for collateral because it doesn't custody collateral.

I

Insurance

Third-party coverage against loss from custodian failure, hack, or theft. CeFi platforms often advertise insurance figures (with significant fine-print exclusions). DeFi typically has no insurance unless paired with a dedicated cover protocol. Firefish's posture is that the architecture replaces the insurance: collateral is on-chain, controlled by multisig, and never on Firefish's balance sheet. There's nothing for an insurer to insure that hasn't already been removed by design.

Interest Rate

The cost of money on a loan. Firefish loans use fixed interest set at origination by mutual agreement between borrower and investor on the marketplace. No variable-rate or utilization-based adjustment occurs after the loan is funded. This is structurally different from DeFi lending pools, where rates float minute by minute, and from CeFi credit lines, where the platform may reset your tier.

K

KYC (Know Your Customer)

The identity-verification process regulated platforms run on every customer, typically a government ID, a proof of address, and a liveness check. Firefish runs KYC under MiCA and applicable national rules. It's a non-negotiable part of operating as a regulated CASP in the EEA. KYC is one axis where Firefish is structurally closer to CeFi (a regulated counterparty doing identity checks) than to permissionless DeFi.

L

Leverage

Borrowing against existing assets to take a larger position than your cash alone allows. In a Bitcoin-loan context, leverage often means: deposit BTC, borrow stablecoins, buy more BTC, lock that as additional collateral. This amplifies upside but also amplifies the downside. A 30% drawdown that would have been uncomfortable becomes a chain of liquidations. Better safe than sorry! ________________

Liquidation

The forced sale of collateral when a loan's LTV crosses the agreed liquidation threshold. On Firefish, when the price oracle attests that LTV has hit 95%, price and payment oracle together sign the pre-signed Liquidation closing transaction, and the BTC are being sent to the lender to repay him in full.

Liquidation LTV

The hard ceiling at which the price oracle and payment oracle co-sign the liquidation closing transaction. On Firefish this is 95%. It's not a margin call, it's the line where your collateral gets either sold or transferred directly to the lender. Most CeFi platforms use a softer threshold (typically 80–90%).

Liquidation Penalty

An extra cost layered onto the act of being liquidated, on top of the loss of collateral. DeFi protocols typically pay a liquidation bonus to whichever bot triggers the close (5–10% of the position) which the borrower effectively absorbs. Firefish's approach uses pre-signed transactions and an investor relationship rather than open liquidator auctions, so the structural penalty is closer to the spread and execution slippage on the BTC sale rather than a fixed liquidator-incentive haircut.

Liquidation Threshold

The LTV percentage at which liquidation fires. Firefish sets this at 95%, which is high relative to most CeFi liquidation thresholds (commonly 80–90%) and reflects the deterministic, oracle-driven nature of the close. Borrowers control their distance from the threshold by sizing their original draw and by topping up collateral when they want more cushion.

Loan Rollover

Renewing your loan at maturity instead of closing the position. On Firefish, rollovers are currently handled manually. You open a new loan with fresh collateral, use the received funds to repay and close your old position, and your original BTC is released back to you. Useful when you need to extend your time horizon without fully exiting your borrowing position.

LTV (Loan-to-Value)

The ratio that defines how much you can borrow against your Bitcoin. Firefish opens loans at 50% LTV (you deposit 1 BTC of collateral to borrow 0.5 BTC of value) and triggers automatic liquidation at 95% LTV. The 45-point spread between origination and liquidation is the price-drop buffer your position can absorb before the closing transaction fires. You can lower your LTV and push your liquidation price further away at any time by adding more Bitcoin as collateral.

M

Margin Call

A warning from the platform that your LTV is approaching the liquidation level and you should top up collateral or reduce debt. Firefish notifies borrowers in three steps as the LTV rises. The right mental model: the margin call is an informational warning. The liquidation closing transaction is mechanical, you lose your Bitcoin.

MiCA (Markets in Crypto-Assets Regulation)

The European Union framework governing crypto-asset service providers, in force across the EEA since 2024. MiCA introduced a single licensing regime, Crypto-Asset Service Provider, or CASP, replacing a fragmented patchwork of national registrations. Firefish operates as a CASP and appears on the ESMA Interim MiCA Register.

Minimum Loan Amount

The smallest loan size a platform will originate. Firefish's retail minimum is €800, $1,000 (or local-currency equivalent), set deliberately to keep the marketplace accessible to first-time Bitcoin borrowers without going so low that escrow on-chain costs eat the unit economics.

Multisig (Multi-Signature)

A Bitcoin script that requires multiple keys to sign a transaction. The simplest forms are 2-of-3 (e.g. Unchained's collaborative custody) and 3-of-3 (Firefish's escrow). 3-of-3 is the stricter form: every single key must sign, so no two-party coalition can move collateral. The trade-off is that all three parties must remain available which is why Firefish's protocol works with pre-defined transactions and includes disaster-recovery pathways.

N

Non-Custodial Lending

A lending model where the platform never takes custody of the collateral. Firefish's claim rests on the 3-of-3 escrow: collateral is locked on-chain at an address Firefish cannot move unilaterally, and pre-signed transactions specify every possible loan outcome before funding. The architectural test of "non-custodial" is whether the platform can, technically, take your coins and spend them freely. With Firefish's design, the answer is no. The Firefish protocol is publicly available for everyone to verify. Don’t trust, verify!

O

Open-Ended Loan

A loan with no scheduled maturity, interest accrues until you choose to close the position. Firefish does not offer open-ended loans; every Firefish loan has a hard 3-to-24-month term. If you're looking for an open-ended structure, the closest Firefish equivalent is to roll a finished loan into a new fixed-term loan when the first one matures.

Oracle

Any service that brings off-chain data on-chain so that a contract or pre-signed transaction can act on it. In Firefish's architecture there are two: payment oracle (attests to fiat/stablecoin movements), and price oracle (attests to BTC/EUR market price). In Firefish's case the oracle keys are also escrow signers.

Origination LTV

The starting loan-to-value ratio set when your loan opens. Firefish loans are fixed at 50% origination LTV. There's no slider, no tier system, and no platform-token discount that adjusts it. The fixed origination ratio is part of why investor pricing on the marketplace is consistent. Borrowers can lower their LTV and push their liquidation price further away at any time by adding more Bitcoin as collateral.

Overcollateralisation

Backing a loan with more collateral value than the loan amount. Every Bitcoin-backed loan on Firefish is overcollateralised by definition. Origination LTV is 50%, meaning every Euro borrowed is backed by two Euro of Bitcoin at the start. Overcollateralisation is the structural reason a volatile asset can secure a fixed-rate loan: the buffer absorbs price moves, and the liquidation threshold defines how much of the buffer can be spent before the close.

P

Payment Oracle

A Firefish-operated service that watches for off-chain payment events, loan funding, repayment, or failed funding, and co-signs the corresponding pre-signed transaction once confirmed. It is the bridge between what happens in the banking system and what happens on the Bitcoin blockchain.

Peer-to-Peer (P2P) Bitcoin Lending

A lending model where individual investors fund individual borrowers directly, with the platform acting as marketplace and protocol rather than counterparty. On Firefish you're not borrowing from "Firefish". You're borrowing from a specific investor who saw your loan request, accepted it, and wired their funds. This is the structural difference from balance-sheet CeFi lenders, who pool deposits and lend from treasury.

Pre-Signed Closing Transactions

A set of Bitcoin transactions: repayment, default, liquidation, cancellation, disaster. The borrower signs these transactions in advance, at loan origination, using an ephemeral key. Once signed, those transactions become the only ways the collateral can leave the multisig escrow. The protocol replaces operator discretion with cryptographic enumeration: every possible exit is signed, sealed, and ready before any money changes hands. The Firefish protocol is publicly available for everyone to verify.

Price Oracle

A Firefish-operated service that continuously monitors the Bitcoin price across nine exchanges and co-signs the liquidation transaction once the 95% LTV threshold is crossed. It is the bridge between real-world market prices and the on-chain enforcement of your loan's liquidation rules.

Principal

The face value you actually borrowed. On Firefish, principal is the EUR/CZK/CHF/PLN/USDC/USDT amount disbursed at loan start; interest is calculated on top of it for the loan term, and the bullet repayment closes both.

Private Key

The cryptographic secret that authorises spending from a Bitcoin address. Anyone with the private key has full control of the corresponding coins. Nobody without it can move them. In the Firefish escrow the borrower controls one of three keys when creating the on-chain escrow. The borrower-side ephemeral signing key (B-EPH) is destroyed at origination so no one, including you or Firefish, can rewrite the pre-signed exits.

Proof of Reserves

The set of attestations and audits that demonstrate a custodian actually holds what it claims to hold. Traditional Proof of Reserves (Merkle-tree attestations published quarterly) became standard among CeFi lenders after the 2022 collapses. Firefish argues that for a non-custodial platform, PoR is structurally implicit: every active loan is backed by a specific UTXO in a specific multisig escrow on the Bitcoin chain. The chain itself is the attestation. You don't need an auditor to confirm what anyone with a block explorer can verify.

R

Regulation

The body of laws and authority decisions that govern who can offer crypto-asset services, where, and on what terms. Firefish is registered as a CASP under MiCA (the EU Markets in Crypto-Assets framework) and runs its Alternative Fund under the Czech investment-fund regime (Act 240/2013, CNB-supervised).

Rehypothecation

Re-lending the same collateral to generate a second yield stream. Celsius and BlockFi both did it; both blew up in part because of it. “Where does the yield come from?”. Firefish cannot rehypothecate collateral. The BTC sits in a 3-of-3 escrow on-chain and is movable only via pre-signed closing transactions. There's no balance sheet that could re-pledge it, because there's no balance sheet that holds it.

Repayment

The act of paying back the principal plus interest to close the loan and unlock your Bitcoin. On Firefish, repayment fires the Repayment closing transaction, the payment oracle attests that funds arrived, signs the pre-signed transaction, and the multisig escrow releases the BTC to your wallet. Borrowers can request early repayment at any time, though the full interest for the agreed term applies regardless.

S

Satoshi (Sat)

The smallest unit of Bitcoin: one hundred millionth of a BTC. As price has risen, sats have become the practical unit for small balances and pricing. "Stack sats" entered Bitcoiner vocabulary for a reason. Firefish denominates collateral and rates in BTC by default, but a sat-level mental model is useful when checking on-chain transactions (escrow outputs, top-ups) where amounts are presented in satoshis.

Seed Phrase

A 12- or 24-word mnemonic that encodes the master secret of a Bitcoin wallet. From the seed, all private keys can be regenerated. Lose the seed and you lose the wallet, share the seed and you give up custody. Don't store it digitally, don't photograph it, don’t let anyone else see it.

Self-Custody

Holding the keys that control your coins yourself, with no platform that can move them on your behalf. Pure self-custody is incompatible with Bitcoin-backed loans by design. In a liquidation or default scenario, the lender must be able to recover what they are owed, which requires the collateral to be accessible beyond the borrower's keys alone. Firefish's model is the closest practical alternative: pre-defined transactions that the borrower can verify using Firefish’s public source code, and after repayment your BTC is released to a wallet you control. There's no balance sheet that could collapse with your coins on it.

Smart Contract Risk

The risk that a bug or exploit in lending-protocol code causes loss of funds. EVM-based DeFi lenders carry this risk heavily. Billions have been drained from buggy or unaudited smart contracts on Ethereum. Firefish's architecture has a much smaller code surface: the security model rests on Bitcoin Script (pre-signed transactions, multisig, timelocks) plus the oracles. The Bitcoin-side primitives have been battle-tested for over a decade. The Firefish protocol is open-source Rust.

Stablecoin

A token engineered to track the value of a currency, typically the US dollar. Firefish supports USDC and USDT as disbursement options.

T

Tax Efficiency

Structuring transactions to defer or minimise tax. Bitcoin-backed lending is the textbook tax-efficient pathway for long-term holders: borrow against the stack, spend the borrowed fiat, repay with future income or with Bitcoin sold at a different (potentially more favourable) tax year. Rules vary materially between jurisdictions, what works in Czechia, Switzerland, or the US is not interchangeable. Confirm with a local tax adviser before structuring around it.

Taxable Event

A transaction that the tax authority treats as triggering a gain or loss calculation. In most jurisdictions, selling Bitcoin is a taxable event. Borrowing against it is not. This is one of the core financial arguments for Bitcoin-backed loans: you access fiat without realising gains. Firefish's marketplace is structured around this, the borrower keeps cost basis, time horizon, and tax position intact.

Timechain

The original name Satoshi used for what is now commonly called the Bitcoin blockchain. A chain of blocks, each timestamped and cryptographically linked to the one before, making the history of every transaction permanent and tamper-proof. Some Bitcoiners prefer the term over "blockchain," which has been watered down by altcoin marketing into meaning almost nothing.

Timelock

A Bitcoin-script restriction that prevents a transaction from being broadcast (or accepted) until a specified block height or relative block count has passed. Firefish uses timelocks at multiple stages, for example, a locktime on disaster-recovery transactions, to give all parties time to react before any pre-signed exit can fire.

U

UTXO (Unspent Transaction Output)

The chunk-of-Bitcoin abstraction Bitcoin uses instead of an account balance. Every Firefish loan locks a specific UTXO into a specific multisig escrow. meaning the question "does Firefish actually hold the collateral users have deposited?" can be answered by anyone, by inspecting the Bitcoin blockchain.

V

Variable Rate

An interest rate that fluctuates after the loan opens, typically driven by lending-pool utilisation or platform discretion. Firefish does not use variable rates. Every loan's APR is locked when the borrower and investor match. Variable rates are common in DeFi (Aave, Compound) and in CeFi credit lines (Nexo's tiered structure), and they're a frequent source of payment surprise for borrowers who didn't notice a re-tier.

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Firefish is an open lending marketplace

connecting Bitcoiners, institutions and

investors.

Firefish Europe s.r.o. (ID: 55912974) is authorised as a crypto-asset service provider (CASP) under Regulation (EU) 2023/1114 (MiCA) to provide crypto-asset services referred to in Article 3(1) (16)(a), (c), (d) and (j). This authorisation covers crypto-asset services provided within the Firefish platform offering —operation of the bitcoin collateral escrow environment, liquidation exchange of collateral, and related on-chain transfers. Any other services available through the Firefish platform or Firefish activities connected to the platform operation fall outside the scope of MiCA and are not covered by this authorisation.

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