Understanding Abra’s Evolution to a Regulated Advisory Practice

How ACM’s regulatory status, custody model, compliance program, and client reporting are structured today — and how they compare to the legacy Abra (PLL) platform.

Abra Capital Management (ACM) has completed its transition from the legacy Abra International (PLL) structure to a standalone, SEC-registered investment adviser. The changes below are structural upgrades to regulatory status, custody, and oversight on a new corporate entity — this is not just a rebrand.

The Core Difference — Ownership

Client assets are held in individually titled Separately Managed Accounts (SMAs), segregated from ACM’s balance sheet and never commingled or rehypothecated. Assets are secured with Fireblocks MPC technology, 3-factor authentication, and CoinCover disaster recovery. Transactions are verifiable on-chain in real time.

How ACM Compares to the Legacy Platform

Entity & Regulatory Status

Abra Capital Management (ACM): SEC-registered investment adviser (Abra Capital Management, LP), subject to Investment Advisers Act fiduciary duty and direct SEC exam oversight.

Legacy Abra (PLL): Operated through the Abra International (PLL) entity structure — not a registered investment adviser, with no direct SEC oversight of advisory activity.

Custody Structure & Beneficial Ownership

Abra Capital Management (ACM): Client assets are held in individually titled Separately Managed Accounts (SMAs), segregated from ACM’s balance sheet and never commingled or rehypothecated. Assets are secured with Fireblocks MPC technology, 3-factor authentication, and CoinCover disaster recovery. Transactions are verifiable on-chain in real time.

Legacy Abra (PLL): Assets held on the Abra platform in a pooled structure, commingled with company holdings rather than segregated in each client’s name.

Lending Model

Abra Capital Management (ACM): Borrow against your own BTC or ETH collateral. Loan liquidity is sourced from on-chain lending markets through smart contracts, with no reliance on a corporate borrower’s solvency — and your collateral stays segregated and is not rehypothecated.

Legacy Abra (PLL): Abra Earn let customers lend their crypto to the company for interest, and the company deployed those assets — the SEC charged this as an unregistered securities offering.

Compliance Posture

Abra Capital Management (ACM): Dedicated compliance function led by a Chief Compliance Officer, with formal policies, periodic exams, and ongoing regulatory reporting.

Legacy Abra (PLL): Compliance operated informally, without a registered adviser’s oversight obligations or a dedicated CCO-led program.

Client Reporting & Transparency

Abra Capital Management (ACM): Regular account statements, audited financials, and advisor-ready reporting consistent with RIA fiduciary standards.

Legacy Abra (PLL): Reporting followed legacy platform conventions, without the standardized fiduciary-level disclosures required of a registered adviser.

The Public Record

• Abra Earn operated from around 2020 until it was discontinued in 2022. At its peak it held roughly $600 million, with close to $500 million from US investors.
• In August 2024, Plutus Lending settled SEC charges of unregistered securities offers and sales and of operating as an unregistered investment company, without admitting or denying the allegations, agreeing to an injunction. ACM’s Form ADV reports a January 2025 final judgment with a $1.65 million civil penalty.
• In June 2024, Abra settled with 25 US state regulators and agreed to return roughly $82 million in crypto to customers.
• These actions were part of a broader wave of US regulatory enforcement across crypto lending and yield products in 2022 to 2024 that reached many of the sector’s largest platforms.
• Abra has stated publicly that no customers were harmed in the wind-down of Earn, and that all assets for US Earn customers, including accrued interest, were returned to their Abra Trade accounts in 2023.
• Abra Capital Management was not a party to those proceedings (per ACM Form ADV, Item 9).

Sources: SEC press release 2024-105 (sec.gov); Abra Capital Management Form ADV Part 2A, available via the SEC at adviserinfo.sec.gov (firm 323353).

Addressing Feedback

Many negative reviews and the November 2023 FCA notice are targeted towards Abra’s legacy retail business under PLL: the consumer app, wallets, and the Plutus lending products. Some of the negative feedback is genuine frustration from customers of those products that failed to take action on notifications during Abra’s reorg to move assets off the platform. While we empathize with the frustrations of these customers, we want to highlight that most of these negative reviews are targeted at the legacy entity, not ACM.

We take all customer feedback seriously and remain committed to building a great experience.

Services are offered by Abra Capital Management, LP, an SEC-registered investment adviser.

For informational purposes only; not investment, legal, or tax advice.

IMPORTANT DISCLOSURES

For informational purposes only. This document is not investment, legal, or tax advice and is not an offer to sell or a solicitation of an offer to buy any security or investment product. Past performance is not indicative of future results. Digital assets involve a high degree of risk, including the possible loss of principal. Please review ACM s Form ADV Part 2A and your Advisory Agreement for full terms and risk disclosures.
Abra Capital Management, LP ( ACM ) is an SEC Registered Investment Adviser. Registration does not imply a certain level of skill or training but only indicates that ACM has registered its business with state and federal regulatory authorities, including the United States Securities and Exchange Commission ( SEC ). ACM is not a bank, and advisory accounts managed by ACM are not bank deposits. Such accounts are not insured or guaranteed by any governmental or private deposit-insurance or investor-protection program. No assurances are given as to the safety or recoverability of any assets, and any investment involves a high degree of risk, including the risk of loss. Past performance is not indicative of future results, and no statement herein should be relied upon as a guarantee of any outcome.