The window opened
Regulatory guidance lagged member portfolios for a decade. That changed in 2025. Federal agencies issued definitive guidance on digital asset activities. 33 jurisdictions enacted UCC Article 12, creating the legal infrastructure for digital collateral. The institutions that deploy pledged-asset lending infrastructure now will serve modern wealth builders for the next fifty years.
Jurisdictions enacted UCC Article 12
ULC
Alternative allocation, younger investors vs 6% older
Bank of America Private Bank
First loan to close with Aaim
Platform benchmark
Generational wealth transfer through 2048
Cerulli Associates
Federal guidance caught up to member portfolios
For years, regulatory uncertainty constrained alternative asset lending. Banks and credit unions watched members accumulate cryptocurrency, RSUs, and private investments without clear guidance on how to lend against them. That uncertainty resolved in 2025.
FHFA Decision 2025-360 (June 2025)
The Federal Housing Finance Agency directed Fannie Mae and Freddie Mac to develop guidelines permitting cryptocurrency holdings as mortgage reserves without requiring conversion to U.S. dollars. Assets must be held in qualified custodial arrangements on regulated exchanges.
OCC Interpretive Letter 1183 (March 2025)
The OCC rescinded the prior supervisory non-objection requirement for bank digital asset activities. Banks no longer need prior approval to engage in digital asset custody, execution, and related services.
OCC Interpretive Letter 1184 (May 2025)
Further clarification that banks may buy, sell, and outsource cryptocurrency custody at customer direction. This enables the partner model where Aaim provides infrastructure and banks retain lending authority.
CFTC Digital Assets Pilot (December 2025)
The CFTC launched a pilot program permitting Bitcoin, Ethereum, and stablecoins as margin collateral in derivatives markets. This establishes federal precedent for alternative asset collateral.
The legal infrastructure for digital collateral
UCC Article 12, enacted in 33 jurisdictions including New York (December 2025), creates the legal framework for security interests in digital assets. Control-based perfection with super-priority changes the competitive dynamics. First-movers who build compliant control infrastructure gain structural advantages that later entrants cannot overcome through filing alone.
Control-based perfection
Unlike traditional UCC Article 9, Article 12 perfection through control has priority over perfection through filing. Technical architecture matters.
Choice of law flexibility
Section 12-107 permits CERs to specify governing jurisdiction. Transactions can be structured under adopting-state law regardless of borrower location.
Transition period advantage
The adjustment period through 2027 creates a window for building compliant infrastructure before mandatory compliance deadlines.
Safety from commitment and collateral
Pledged-asset lending derives safety from psychology as much as collateral value. A borrower pledging their startup equity or Bitcoin makes an emotional commitment to the asset's future. They believe in the trajectory. They will not default lightly. This behavioral economics advantage compounds the collateral protection.
Secured lending versus 300+ bps unsecured consumer
Source: FDIC Quarterly Banking Profile
Lower cost than unsecured alternatives
Source: Fed G.19, Bankrate
Lower than unsecured personal loans
Source: FDIC Quarterly Banking Profile
Collateral recovery reduces loss severity
Source: FDIC working papers, Moody's
Banks stay banks. Brokerages stay brokerages.
Aaim does not compete with your members' existing financial relationships. We provide infrastructure that lets credit unions and community banks offer liquidity against assets held at third-party custodians. Brokerages keep custody relationships. Banks keep lending authority. Members get access to liquidity without forced liquidation.
Your institution remains the lender
All credit decisions, underwriting, and loan ownership stay with your institution. Aaim provides valuation, perfection, and compliance infrastructure. When examiners ask who the lender is, the answer is unambiguous.
Custodians keep custody
Member assets remain with their existing brokerages and custodians. Schwab stays Schwab. Fidelity stays Fidelity. Coinbase stays Coinbase. We integrate with custodians; we do not replace them.
Members keep their upside
Borrowing against assets is not a sale. Members maintain ownership, voting rights (where applicable), and exposure to appreciation. No forced liquidation. No taxable event.
Deploy in weeks, not years
Building pledged-asset lending infrastructure in-house requires 18-24 months minimum: hiring engineers who understand both Python and UCC law, negotiating custodian integrations, building compliance frameworks, and standing up examination documentation. With Aaim, your first loan can close in 6-8 weeks.
Build In-House
18-24 months minimum. $3-5M first year. Ongoing maintenance $1.5-2.5M annually. Assumes you can hire the talent and custodians return your calls.
Partner with Aaim
6-8 weeks to first loan. SaaS license plus per-loan fees. Your institution retains all lending economics. We handle valuation, perfection, and compliance infrastructure.
The regulatory moment arrived
Federal guidance exists. Legal infrastructure exists. The generational wealth transfer is accelerating. The question is whether your institution will serve modern wealth builders or watch them leave.