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Capital Note | Issue 01

commentary
April 9, 2026
5min read

BlockFills and the State of the Crypto Lending Industry

On March 15, BlockFills filed for Chapter 11. Chicago-based institutional crypto lender, backed by Susquehanna and CME Group's venture arm. 2,000 clients across 95 countries. Gone.

At the first day hearing, BlockFills' own counsel confirmed what borrowers feared most: customer funds had always been commingled with company funds. Everything became property of the estate. Borrowers who thought their collateral was safely held would now stand in line alongside every other unsecured creditor.

We've been here before. Celsius. FTX. BlockFi. The script is always the same. Unregulated or offshore platform, funds commingled, collateral gone, and borrowers finding out too late that what they signed never actually protected them.

I wrote a full piece on BlockFills two weeks ago covering the legal mechanics that actually determine whether you get your Bitcoin back when a lender fails. Link in the comments if you haven't read it.

The pattern isn't stopping, and the next one is already out there. So if you're borrowing against crypto today, here's what you should be verifying before you sign anything:

Is your collateral held in a segregated, bankruptcy-remote structure, or is it sitting on the lender's balance sheet? Is it in insured cold storage with a qualified custodian, or do you have no visibility into where it actually sits? Can you verify your holdings on-chain 24/7, or are you waiting for a bi-annual attestation and hoping the numbers are real? Is the lender regulated by a securities authority in your jurisdiction, or operating under an offshore exemption? Can you confirm in writing that your assets cannot be treated as property of the estate in the event of insolvency?

If your lender can't answer those questions clearly, you have your answer.

What We're Building at APX

This is the problem we set out to solve from day one. Every loan APX originates is held through a dedicated SPV structure with collateral segregated from company operations. That structure exists specifically so that if something ever went wrong at the corporate level, borrower collateral would not become part of a bankruptcy estate. All collateral is held in segregated, insured cold storage wallets with BitGo and is visible to borrowers on-chain, 24/7. No waiting for bi-annual reports or attestations. You can verify your collateral is there any time you want.

We first received CSA (Canadian Securities Administrators) exemptive relief in April 2025, granting us regulator approval to offer crypto-backed loans in Canada. We were the first (and still the only one) approved to do so. In March 2026, the CSA expanded that relief to cover USDC-denominated loans across the country. The USDC expansion lets us serve more borrowers in the currency they want, and it validates the regulatory path we chose when other lenders were cutting corners and going offshore.

Zero borrower losses since launch. Not because we've been lucky with markets, but because our protocols and technology are engineered to protect both sides of every loan before volatility becomes a problem.

Scaling the White Label

We're also seeing rising global demand for our white-label infrastructure. We have partners live in the U.S. and others launching in Europe, with active conversations underway with exchanges, banks and fintechs across Canada and Australia. The model is straightforward: regulated platforms that want to offer Bitcoin-backed lending without building the compliance and technology infrastructure from scratch can deploy on ours.

After BlockFills, I expect some borrowers will finally move to regulated platforms. Whether that actually happens at scale will tell us a lot about where this industry is headed. Either way, we'll be here building the infrastructure that makes it all possible.

If you found this useful, please feel free to share it. My inbox is always open.

Andrei Poliakov
Founder and CEO, APX Lending

APX Lending is a crypto-backed lender operating in the US, Canada, and globally. APX Lending does not offer financial or tax advice. We strongly encourage you to consult with a certified financial or tax professional for guidance on any related inquiries you may have.

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