Schedule 1 - Explanation of Effect of Being Treated as an Accredited Investor under the Consent Provisions
The following sets out, in plain language, the effect under the consent provisions of you being treated by us, Coinut Pte. Ltd., as an Accredited Investor. While every effort has been made to ensure completeness, this Schedule may not set out every consequence under each applicable consent provision. You are encouraged to seek independent advice if you require further clarity before consenting to be treated as an Accredited Investor.
Where we deal with you as an Accredited Investor, we may be exempt from complying with certain safeguards and business conduct requirements otherwise applicable to Retail Customers under the Guidelines.
“DPT”, when used in this document, refers to a digital payment token.
1. Pledging, Lending or Staking of Your Digital Assets
When you are treated as an Accredited Investor, we may facilitate transactions that involve the pledging, lending, or staking of your assets. These activities are not permitted for Retail Customers, who are restricted from using their assets in this manner through us.
Specifically, we may allow you to:
- Mortgage, charge, pledge, or hypothecate your assets;
- Lend, or arrange to lend, your assets;
- Stake, or arrange to stake, your assets (including locking them as collateral in smart contracts in connection with blockchain validation and receiving associated rewards)
For clarity, a transfer of your assets to a DPT account specified by you does not constitute a lending or staking arrangement under the Guidelines.
We may carry out such transactions on your behalf without being required to provide specific written risk disclosures or obtain your written acknowledgement of these risks, which we would otherwise have to do if you were a Retail Customer under the Guidelines.
You are therefore not protected by the restrictions and risk disclosure obligations and are expected to understand and manage the risks associated with these types of transactions.
2. No Risk Assessment – You Are Presumed to have Sufficient Knowledge of the Risks
As an Accredited Investor, we are not required to provide you with detailed information on the risks of the DPT services we offer, nor are we required to assess your understanding of such risks.
You may access DPT services without completing any form of Risk Awareness Assessment, which Retail Customers must undergo before being provided with such services. This includes an assessment of your knowledge of DPT-related risks such as extreme price volatility, loss of assets due to service provider failure, and risks associated with dealing with entities outside of Singapore.
We are also not required to inform you of the outcome of any risk assessment or evaluate whether a particular product or service is suitable for you. You are therefore expected to independently understand and manage the risks involved.
3. Access to Incentives and Promotions
As an Accredited Investor, we may offer you promotional incentives that we are not permitted to offer to Retail Customers, as such customers may be more susceptible to being influenced by incentives or referrals due to their comparatively lower financial sophistication.
This means:
- We may offer you rewards, bonuses, or other benefits to encourage your use of our DPT services;
- We may also offer incentives to third parties (such as existing customers or influencers) to promote or refer our services to you.
These practices are prohibited when dealing with Retail Customers under the Guidelines, but do not apply to Accredited Investors. You are therefore not protected by the restrictions on promotional activities that safeguard Retail Customers from being unduly influenced to transact. You are expected to evaluate any incentive or promotional activity independently and to exercise your own judgment before engaging our services.
4. Access to Credit, Leverage and Derivative Products
As an Accredited Investor, you may be offered products and services involving credit, leverage, or DPT derivatives—which are strictly prohibited for Retail Customers due to the high risk and extreme volatility of DPTs.
These include:
- Being offered credit facilities or loans of DPTs to finance your purchase or continued holding of DPTs;
- Entering into leveraged transactions that may result in amplified gains or losses, including losses that exceed your initial capital;
- Access to DPT derivatives contracts, such as futures or options based on the value of DPTs;
- Making DPT purchases using credit cards or charge cards.
Retail Customers are not permitted to access these products because they may lack sufficient understanding of the risks or the financial resilience to absorb substantial losses.
As an Accredited Investor, you acknowledge that:
- You are not protected by the regulatory restrictions that apply to Retail Customers;
- We are not required to assess the suitability of these products for you or to provide specific risk disclosures before offering such transactions;
- You are expected to understand the high-risk nature of credit- and leverage-related DPT transactions, possess the financial capacity to bear potential losses, and exercise independent judgment when choosing to engage in such activities.
5. Limited Complaint Handling Protections
As an Accredited Investor, you will not be entitled to the same level of complaints handling procedures and oversight that apply to Retail Customers under the Guidelines.
Retail Customers benefit from specific safeguards, including:
- Oversight of the complaints process by a senior manager or committee of senior managers independent of the business unit;
- Structured complaints handling procedures for allegations involving legal or regulatory breaches, unfair practices, or misconduct;
- Internal systems to track complaints data, analyse trends, and implement remedial actions; and
- Unrestricted access to legal recourse through recognised dispute resolution channels in Singapore (e.g., mediation, arbitration, or court proceedings).
As an Accredited Investor:
- We are not required to apply these retail-focused complaints handling measures to your case, although we may do so at our discretion;
- You acknowledge that you may not receive the same procedural protections, level of review, or escalation protocols in the handling of your complaints;
- You may also be subject to different contractual dispute resolution mechanisms that do not necessarily align with those designed for retail customer protection.
You are expected to raise, manage, and resolve disputes with the understanding that you are not protected by the complaints framework prescribed for Retail Customers under the Guidelines.