Regulatory Posture

Tythe’s legal posture follows from its architecture. Because it holds no keys and no funds, it is not a custodian and not a bank. Because it underwrites and arranges credit on an on-chain market it operates, it is a protocol operator with obligations that vary by jurisdiction. This page states the posture, the structure, where Tythe is available, and what is still being confirmed.

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What Tythe is

In one sentence: a noncustodial protocol operator that underwrites and arranges credit, provides the mandate layer as software, and publishes intelligence as information.

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Structure

• Parent. A Delaware C-corporation owns the technology, operates the protocol, underwrites, and services the market.
• UAE operating subsidiary. Planned for licensed activities as licences are obtained; the regulatory home for Phase 1.
• Lending vehicle. A Cayman or BVI vehicle is held in reserve, to be used only if counsel concludes that arranging undercollateralised credit with a first-loss reserve requires a lender-of-record wrapper in the jurisdictions of lenders or borrowers.
• No token. Tythe has no token and no token is in any control path.

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Availability

Availability follows Tythe’s regulatory phases. Onboarding confirms a principal’s jurisdiction and shows which capabilities are open before any funds are committed. Tythe may be required to restrict or withdraw services in a jurisdiction. Restricted persons include anyone on a sanctions list and anyone resident in a jurisdiction Tythe does not serve.

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Why individual borrowing is gated

Credit to a natural person is consumer credit, regulated separately and more strictly in every jurisdiction. Tythe opens Borrow for individuals in a jurisdiction only once counsel confirms a compliant path. Individuals may hold, delegate, save, and lend from day one.

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Conflicts of interest

Tythe discloses the following.

• Tythe’s first-loss reserve is junior capital in the credit market Tythe operates and underwrites for. Tythe’s revenue depends on the market’s performance; its reserve is consumed first when it does not perform.
• Tythe curates the venue allowlist and publishes reference weights for venues it does not manage and takes no fee from. Tythe has no financial relationship with any listed venue beyond what is disclosed on that venue’s dashboard page.
• Tythe’s fees are set out in full under Fee model. Tythe earns on credit it underwrites and on accounts it enforces; it earns nothing on venue yield or on transaction volume.

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Pending counsel

1. Whether the UAE virtual-asset lending framework will licence undercollateralised, underwritten credit, and on what conditions.
2. Operator and arranger licensing for undercollateralised credit in the jurisdictions of lenders and borrowers.
3. Whether the Cayman or BVI lending vehicle is required.
4. Consumer-facing credit for verified individuals, by jurisdiction.
5. The governing law and final text of every instrument principals sign.
6. Treatment of lender interests in the credit market under securities law, by jurisdiction.
7. Data-protection obligations for the Intelligence Layer in each launch market, and whether agent-underwriting outputs constitute regulated credit reporting anywhere.