Yes, that's my understanding. Those bitcoins are custodial so they're on their balance sheet. So you just sort of have an IOU that they'll give them back to you. So, funnily enough, you're an "unsecured creditor" of the IOU for what used to be your own bitcoins.

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Too risky ATM for me, even tho I like the idea of “buy (btc), borrow (fiat), die”

Sure.

To please the biggest fiat system players, the sequence is rather: "buy (btc), trust (the custodian), sell (to the State, at a forced low price), die".