Coinbase Asset Management, LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)

11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
COINBASE GLOBAL INC
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/06/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
23 CIV. 4738
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
COINBASE GLOBAL INC

6.
Principal Product Type:
Other
Other Product Types: 
THE ADVISORY AFFILIATE OPERATES A CRYPTO ASSET TRADING PLATFORM.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JUNE 6, 2023, THE SECURITIES AND EXCHANGE COMMISSION FILED A COMPLAINT (THE "SEC COMPLAINT") IN THE SOUTHERN DISTRICT OF NEW
YORK AGAINST COINBASE GLOBAL, INC. ("CBG") AND COINBASE INC. ("CBI") (23 CIV. 4738). CBG IS AN ADVISORY AFFILIATE OF COINBASE ASSET
MANAGEMENT, LLC ("CBAM") BECAUSE CBAM IS A WHOLLY OWNED SUBSIDIARY OF CBG. THE SEC COMPLAINT ALLEGES CBI IS OPERATING AS AN
UNREGISTERED NATIONAL SECURITIES EXCHANGE, BROKER, AND CLEARING AGENCY, AND FAILED TO REGISTER ITS STAKING-AS-A-SERVICE PROGRAM
AS A SECURITY. THE SEC COMPLAINT ALLEGES CBG IS LIABLE FOR CBI'S CONDUCT BECAUSE IT EXERCISES CONTROL OVER CBI AS ITS PARENT
COMPANY. AS OF THE DATE OF FILING THIS FORM ADV PART 1A.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Dismissed
11. Resolution Date (MM/DD/YYYY):
02/28/2025
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
NONE
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CASE WAS DISMISSED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON JUNE 6, 2023, THE SECURITIES AND EXCHANGE COMMISSION FILED A COMPLAINT (THE "SEC COMPLAINT") IN THE SOUTHERN DISTRICT OF NEW
YORK AGAINST COINBASE GLOBAL, INC. ("CBG") AND COINBASE INC. ("CBI") (23 CIV. 4738). CBG IS AN ADVISORY AFFILIATE OF COINBASE ASSET
MANAGEMENT, LLC ("CBAM") BECAUSE CBAM IS A WHOLLY OWNED SUBSIDIARY OF CBG. THE SEC COMPLAINT ALLEGES CBI IS OPERATING AS AN
UNREGISTERED NATIONAL SECURITIES EXCHANGE, BROKER, AND CLEARING AGENCY, AND FAILED TO REGISTER ITS STAKING-AS-A-SERVICE PROGRAM
AS A SECURITY. THE SEC COMPLAINT ALLEGES CBG IS LIABLE FOR CBI'S CONDUCT BECAUSE IT EXERCISES CONTROL OVER CBI AS ITS PARENT
COMPANY. AS OF THE DATE OF FILING THIS FORM ADV PART 1A, THIS MATTER REMAINS PENDING. IN JUNE 2023, THE SEC FILED A COMPLAINT IN THE
DISTRICT COURT AGAINST THE COMPANY AND COINBASE, INC. ALLEGING THAT COINBASE, INC. ACTED AS AN UNREGISTERED SECURITIES EXCHANGE,
BROKER, AND CLEARING AGENCY IN VIOLATION OF SECTIONS 5, 15(A) AND 17A(B) OF THE EXCHANGE ACT AND THAT, THROUGH ITS STAKING
PROGRAM, COINBASE, INC. OFFERED AND SOLD SECURITIES WITHOUT REGISTERING ITS OFFERS AND SALES IN VIOLATION OF SECTIONS 5(A) AND
5(C) OF THE SECURITIES ACT. THE SEC ALSO ALLEGED THAT THE COMPANY IS LIABLE FOR THE ALLEGED VIOLATIONS AS AN ALLEGED CONTROL
PERSON OF COINBASE, INC. THE CASE WAS CAPTIONED SEC V. COINBASE, INC. ET AL. THE SEC SOUGHT, AMONG OTHER RELIEF, INJUNCTIVE RELIEF,
DISGORGEMENT AND CIVIL MONEY PENALTIES. THE COMPANY AND COINBASE, INC. FILED AN ANSWER TO THE SEC COMPLAINT IN JUNE 2023,
DISPUTED THE CLAIMS IN THE CASE, AND VIGOROUSLY DEFENDED AGAINST THEM. ON AUGUST 4, 2023, THE COMPANY AND COINBASE, INC. FILED A
MOTION FOR JUDGMENT ON THE PLEADINGS. THE SEC FILED ITS RESPONSE ON OCTOBER 3, 2023 AND THE COMPANY AND COINBASE, INC. FILED
THEIR REPLY ON OCTOBER 24, 2023. ORAL ARGUMENT TOOK PLACE ON JANUARY 17, 2024. ON MARCH 27, 2024, THE DISTRICT COURT DENIED IN PART
THE COMPANY AND COINBASE, INC.'S MOTION FOR JUDGMENT ON THE PLEADINGS WITH RESPECT TO THE SEC'S CLAIMS THAT COINBASE, INC.
OPERATED AS AN UNREGISTERED SECURITIES EXCHANGE, BROKER, AND CLEARING AGENCY AND ENGAGED IN AN UNREGISTERED OFFER AND SALE OF
SECURITIES THROUGH THE COMPANY'S STAKING PROGRAM. THE DISTRICT COURT DISMISSED THE SEC'S CLAIM THAT COINBASE, INC. ACTED AS AN
UNREGISTERED BROKER THROUGH ITS WALLET SERVICE. ON APRIL 12, 2024, THE COMPANY AND COINBASE, INC. FILED A MOTION WITH THE DISTRICT
COURT SEEKING CERTIFICATION OF AN INTERLOCUTORY APPEAL TO THE COURT OF APPEALS. THE DISTRICT COURT GRANTED THAT MOTION ON
JANUARY 7, 2025 AND STAYED PROCEEDINGS IN THE DISTRICT COURT. ON JANUARY 17, 2025, THE COMPANY AND COINBASE, INC. FILED A PETITION
FOR PERMISSION TO APPEAL TO THE COURT OF APPEALS. ON FEBRUARY 28, 2025, THE SEC AND THE COMPANY AND COINBASE, INC. JOINTLY
STIPULATED TO DISMISSAL OF SEC V. COINBASE, INC. ET AL. WITH PREJUDICE. THE CASE IS NOW CONCLUDED. THE RESOLUTION OF THE SEC'S

LAWSUIT DID NOT HAVE A MATERIAL IMPACT ON THE COMPANY'S BUSINESS AND FINANCIAL STATEMENTS.