Independent consumer advocacy
Before customers commit their money, they deserve clear explanations of what they are buying, Coinbase’s role in the transaction, relevant financial relationships, and the rights they may be agreeing to limit.
We call on public officials to review whether current disclosures, conflict-of-interest controls, and dispute-resolution terms adequately protect retail buyers.
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One customer’s account
“My bank has prompted me to confirm Zelle transfers as small as $1. When I purchased thousands of dollars of tokens through Coinbase, I did not see a comparably clear explanation of Coinbase’s role, the token’s rights, or the risks before purchasing.”
This is my account of the purchasing experience—not a claim that Coinbase publishes no disclosures. The question is whether material information reaches customers clearly, prominently, and before they pay.
What the record says
The following points distinguish Coinbase’s published statements from the consumer-protection questions those statements raise.
Coinbase’s U.S. agreement says customers are responsible for determining whether an investment is appropriate. Section 2.7.1 assigns customers “all risk of loss” for supported digital assets held in the wallet, while Section 2.6 disclaims responsibility for underlying protocol operations and certain resulting losses. These are contractual allocations of risk—not proof that Coinbase is exempt from every legal obligation.
Section 3.2 says that, for the transactions described there, customers are not buying assets from Coinbase or selling them to Coinbase. Instead, Coinbase acts as an agent facilitating customer-to-customer transactions—a marketplace or venue role, rather than the seller in that trade. Section 3.3 says Coinbase generally makes money when customers buy or sell. Buyers should see this distinction before confirming a purchase.
Section 7 and Appendix 5 set out arbitration, jury-trial and class-action terms, subject to the agreement’s terms and exceptions. These provisions affect how customers may pursue disputes; they should not be presented as blanket immunity from accountability.
Coinbase says Coinbase Ventures may invest in projects discussed in its listing-transparency article, and Coinbase may hold those tokens for operational purposes. It also says employees or board members with a financial interest are excluded from the relevant listing decision. These disclosed relationships warrant scrutiny, but do not establish that Coinbase Ventures created the tokens or improperly influenced a listing.
Coinbase’s educational material says governance rights and parameters vary by project, governance tokens are not legal equity, and token allocations or vesting may contribute to concentrated holdings or low initial float. The User Agreement says Coinbase may or may not support protocol voting for certain assets and may discontinue support. Buying a governance token therefore does not guarantee meaningful voting influence or the ability to participate through Coinbase. Buyers deserve clear, token-specific purchase-screen information about rights and how they can be exercised.
Policy proposals
Consumers deserve to understand what they are buying, whose financial interests are involved, and how they can seek redress if something goes wrong.
We ask lawmakers and regulators to evaluate—and, within their authority, implement the following safeguards:
Before customers confirm a purchase, explain when Coinbase is acting as the venue or marketplace and agent facilitating a customer-to-customer trade—not as the seller in that trade. Identify the token issuer and clearly state what a Coinbase listing does—and does not—represent.
Clearly explain whether a token provides voting, equity, revenue-sharing, redemption, or other economic rights—or none of these. If voting rights exist, explain whether and how customers can exercise them through Coinbase.
Prominently disclose relevant investments, token holdings, and material financial relationships involving Coinbase, Coinbase Ventures, and the token issuer.
Explain material risks, including insider allocations, concentrated voting power, scheduled token unlocks, dilution, and the possibility of losing the entire purchase amount.
Provide separate, conspicuous explanations of arbitration requirements and class-action waivers before customers accept them. Evaluate whether customers have affordable, fair, and practical avenues for seeking redress.
Require preservation and review of the disclosures, marketing claims, and acknowledgments customers actually encounter during a purchase—not just published terms and conditions.
Meaningful safeguards should help consumers make informed decisions before buying—and access a fair process when disputes arise.
An invitation to review
To federal and state elected officials, financial regulators, and enforcement agencies:
Please review whether Coinbase clearly explains its retail token purchases before customers complete a transaction, including:
These disclosures should be timely, easy to find, and easy to understand—not merely referenced in legal documents or used only to defend against complaints.
Please coordinate oversight, investigate potential violations where the evidence supports doing so, and use your legislative, regulatory, and enforcement powers to strengthen consumer protections.
This is a request for an evidence-based review, not a claim that unlawful conduct has been proven.
Consumers can accept investment risk. They should not have to search through legal documents to understand what they are buying, whose interests may overlap, or which remedies they are agreeing to limit.
References & limits
This page draws on Coinbase’s own published materials. The personal-experience section reflects the author’s account. The safeguards are policy proposals, not statements that every proposed measure is already legally required.
Source links and section references reflect the materials used to prepare this page. The U.S. User Agreement used here was last updated July 22, 2026. Agreements and policies may change; consult the linked documents for their current wording.
Content prepared October 6, 2026.