CASE-10 · 20 min
Onboarding with an open perimeter
Type of case study: Constructed scenario with invented figures. No real incident, no real protocol.
Scenario
An investment committee is to decide on a first on-chain position. The analysis is in, and the regulatory line reads “open”. So the question before the committee is not whether the classification is right — it is whether an open point is bearable and how anyone will notice later that it has closed.
Data
- Activity
- deposit into a lending market, no intermediation for third parties
- Entity
- no identifiable issuer or service provider
- Vehicle's jurisdiction
- EU
- Custody
- 3-of-5 in-house, two vendors, three sites
- Intended size
- 0.4 % of the portfolio
- Assumed loss given failure
- 100 %, since collateral realizability under stress is not evidenced
- Regulatory line
- open; the framework is under review at this point
Questions
Can a committee decide on a paper carrying an open regulatory point? Give your reasons.
How should the institution notice that the open point has closed — or closed differently than hoped?
Analysis dimensions exercised
Sources
- EVD-2026-0006 — Amtsblatt der Europäischen Union / EUR-Lex: Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), OJ L 150, 9.6.2023, p. 40–205
- EVD-2026-0007 — Europäische Kommission, GD FISMA: Targeted consultation on the review of the MiCA Regulation
Institutional perspectives
Bank · Asset management · Advisory · Insurance