Document Requiring User Agreement (Written Explanation on Overthe-counter Crypto Asset Derivatives Trading)(Written Explanation of bitFlyer Crypto CFD Trading)March 28, 2024

bitFlyer, Inc.

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Introduction
Please ensure that you have thoroughly read and understand the contents of thiswritten explanation when trading Over-the-counter derivatives of crypto assets.
“bitFlyer Crypto CFD” trade is trades of Over-the-counter derivatives of crypto
assets that reference the prices of crypto assets handled by bitFlyer, Inc.
(hereafter, the “Company”), in which the Company acts as the counterparty for
the Over-the-counter derivatives of crypto assets, and the transaction is
concluded between the customer and the Company as a negotiated transaction
with the Company as a counterparty to the customer. The transaction is a net
settlement where the settlement is made by an exchange of money calculatedusing the difference between the price of the corresponding crypto asset agreed
upon by the customer and the Company at the time of the new transaction’s
execution and the price of the corresponding crypto asset at the time of thesettlement transaction’s execution (In some cases, the Company may make asettlement by acquiring crypto assets that the customer has deposited with theCompany as a margin deposit in lieu of fiat currency).
The Company will quote the total of the quantity of orders for crypto-assetrelated Over-the-counter derivatives received from other customers and thequantity of crypto-asset-related Over-the-counter derivatives required by thedepartment conducting proprietary trading within the Company as the quantity
at which the Company can accept the order for crypto-asset-related Over-thecounter derivatives from the customer at each price. Further, when the Company
receives an order for crypto-asset-related Over-the-counter derivatives from acustomer, the Company will execute a crypto-asset-related Over-the-counter
derivatives transaction between the customer and the Company when theconditions regarding the price and the quantity that the customer and theCompany offer each other in the opposite direction match. The Company shallnot conduct Over-the-counter derivatives of crypto asset transactions with acustomer in excess of the quantity offered to the customer.
The trading unit used to count the quantity of bitFlyer Crypto CFD transactions
s corresponds to one unit of the crypto asset that Crypto CFD uses for its pricereference. When a new transaction on bitFlyer Crypto CFD is executed between
a customer and bitFlyer, the price per trading unit and the quantity of trading
units are agreed on. These agreed terms become the executed price and executed
quantity for the new bitFlyer Crypto CFD transaction. The executed pricemultiplied by the executed quantity becomes the amount for the new transaction.
bitFlyer Crypto CFD trading contracts expire at 6:00 pm (JST) every businessday. Upon expiration, the transaction amount is recalculated by multiplying
2the executed quantity and the most recent spot trading price per unit of thecrypto asset established at the crypto asset spot exchange (hereinafter referred
to as "Lightning Spot") operated by bitFlyer as a crypto asset exchange operator.
If the required margin to maintain the contract for that transaction has been
confirmed to be deposited by the customer by the next business day at 6:00 pm(JST), the expiration of the contract is extended by one business day (a process
hereinafter referred to as "Rollover"). Should the recalculation of the transaction
amount not be possible at 6:00 pm (JST) due to system failures or other reasons,the recalculation will be conducted at the time it becomes possible.
Upon the completion of a settlement transaction on bitFlyer Crypto CFD by
the customer, the amount of money per trading unit to be transferred between
the customer and bitFlyer is calculated. This amount is based on the difference
between the executed price of the settlement transaction and the executed
price of the new transaction that is the subject of the settlement. bitFlyer will
perform the net settlement by transferring this amount between the customer
and bitFlyer. (Additionally, bitFlyer may also perform the settlement byacquiring, at no cost, crypto asset that the customer had deposited as margin
with bitFlyer, rather than collecting money.)
When a customer performs Over-the-counter derivatives of crypto asset
transactions with the Company, the price of Over-the-counter derivatives ofcrypto asset transactions that can be traded against with the Company may
fluctuate to the customer's disadvantage due to the effects of fluctuations in
supply and demand for the Company's Over-the-counter derivatives of crypto
asset transactions themselves and price fluctuations of the crypto assets
referenced by the corresponding Over-the-counter derivatives of crypto asset
transactions. The price of the Over-the-counter derivatives of crypto asset
transactions that can be traded against the Company may change to thedisadvantage of the customer, and the customer may suffer a loss. In such a case,the customer may suffer losses in excess of the amount of margin deposited by
the customer with the Company in advance.
Therefore, Over-the-counter derivatives of crypto asset transactions are nottransactions that have any guaranteed principal or profit, but are margintransactions in which a large amount of transactions can be conducted based on
a comparatively small amount of margin. While a large amount of profit may beobtained, these transactions involve the risk of incurring a large amount of loss
and may result in losses in excess of the principal amount. Therefore, whenstarting or continuing Over-the-counter derivatives of crypto asset transactions
with the Company, the Company asks that you fully understand not only thisdocument but also the structure of the transactions and the risks involved, and3

that you only trade at your own risk if you deem it appropriate in light of yourfinancial resources, trading experience, and purpose for trading. If you wish to
perform Over-the-counter derivatives of crypto asset transactions, please do so at
your own risk and only if you fully understand the transaction mechanisms andrisks involved.
This document was written and delivered in accordance with Article 37-3 of the
Financial Instruments and Exchange Act, and explains "bitFlyer Crypto CFD" isOver-the-counter derivatives of crypto asset conducted between customers andthe Company by reference to the price of the crypto asset among Over-thecounter derivatives of crypto asset transactions prescribed in Article 2-22-2 of the
Financial Instruments and Exchange Act.

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Contents
Introduction
Important Notes Regarding the Risks of Trading Over-the-counter Derivatives of
Crypto Assets
Structure of Over-the-counter Derivatives of Crypto Assets
Summary of Over-the-counter Derivatives of Crypto Assets
Summary of Taxes
Termination of Accounts
Company Profile
Complaints and Consultations
Dispute Resolution Measures
Definitions
Prohibited Actions for Trading Over-the-counter Derivatives of Crypto Assets
Explanation of Trading Specifics and Related Terms
1. Trading types
2. Trading methods
3. Order reception and execution policy
・Reference index, pairs, and order sizes
・Circuit breaker during rapid price changes
・Circuit breaker during divergence expansion
・bitFlyer Crypto CFD trading rules
・Margin Deposit
・Maintenance Margin Rules
・Margin Call Rules
・Sell Out Rules
・Transfer Payments (inward and outward) for Margins
4. Response to Large-scale Blockchain Divergences
5. Fees
6. Business Reports and the Most Recent Financial Documents
Explanation of the Characteristics of Crypto Assets

This written explanation is offered to customers based on Article 37-3 of the Financial
Instruments and Exchange Act, as well as stipulations in the Written Explanation on Crypto
Asset Derivatives Trading Regulations and Guidelines from the Japan Crypto Asset Trading
Association.

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Important Notes Regarding the Risks of Trading Over-the-counter Derivatives of
Crypto Assets

Fees
Although there are no trading fees, leverage point payments occur
each time a rollover is conducted and the positions that were notoffset by an opposing order by 6:00 pm (JST) within the samebusiness day of bitFlyer are extended to 6:00 pm (JST) of the next
business day. Should system failures or similar issues prevent therollover process from being executed at 6:00 pm (JST), leverage
point payments will be made as soon as the rollover can be
performed.
Additionally, there is a transfer of funding rates between bitFlyer
and the customer on bitFlyer Crypto CFD. The "Funding Rate" isdefined as the mechanism to transfer or the amount transferredcalculated from the price difference between the trading price on
bitFlyer Crypto CFD and the spot trading price of the crypto asset
that bitFlyer Crypto CFD references. This transfer is conducted inaccordance with the customer's held position size, at the designatedtimes every eight hours.
At the time of funding rate transfer, if the trading price on bitFlyer
Crypto CFD exceeds the spot trading price of the referenced crypto
asset, funds are collected from the long position holders andgranted to the short position holders. In the reverse scenario, funds
are collected from short position holders and granted to longposition holders. (If bitFlyer 's proprietary trading department
holds positions, it will also be subject to either fund collection or
grant.)
The amount of money transferred as the funding rate may increaseas the difference between the Over-the-counter crypto asset
derivative price and the crypto asset spot trading price widens,
until it reaches a predetermined upper limit, please refer to “5.
Fees” below.
MarginWhen performing these trades, a margin deposit is required. More6

information on the method of calculating the required margindeposit can be found under “Margin” in section “3. Order reception
and execution policy” below.
Risks Involved in Trading Over-the-counter Derivatives of Crypto
Assets1）Trade Price Fluctuation Risks
Over-the-counter derivatives of crypto assets are conducted byreferencing the price of the crypto asset as an index, and losses
may be incurred due to fluctuations in the trading prices quoted
by the Company for bitFlyer Crypto CFD. Losses may be
incurred due to fluctuations in the price of the underlying crypto
asset.
The Company will quote the total of the quantity of orders forcrypto-asset-related Over-the-counter derivatives received fromother customers and the quantity of crypto-asset-related Overthe-counter derivatives required by the department conducting
proprietary trading within the Company as the quantity at
which the Company can accept the order for crypto-asset-relatedOver-the-counter derivatives from the customer at each Trade
Price. Further, when the Company receives an order for cryptoasset-related Over-the-counter derivatives from a customer, theCompany will execute a crypto-asset-related Over-the-counter
derivatives transaction between the customer and the Company
when the conditions regarding the trade price and the quantitythat the customer and the Company offer each other in the
opposite direction match. Therefore, the Trade Price will rise or
fall under the influence of fluctuations in the supply anddemand balance of Over-the-counter derivatives of crypto asset
transactions at the Company itself. As a result, if the Trade
Price at which the open interest held by the customer can be
traded against fluctuates to the disadvantage of the customer (afall in the Trade Price if the customer holds an open buy
position, or a rise in the Trade Price if the customer holds anopen sell position), the customer will suffer a loss.
Furthermore, because the transaction amount is large comparedto the amount of margin deposited by the customer for thetransaction, the amount of loss may exceed the amount ofmargin deposited by the customer due to fluctuations in the7

Trade Price, resulting in losses in excess of the principal amountfor the customer.
2）Risk of fluctuations in the spot price of the index crypto asset
Over-the-counter derivatives of crypto asset transactions are
conducted referring to the spot price of crypto asset as an index,
and are used by entities (including the Company’s proprietary
trading division) for the purpose of hedging the price fluctuation
risk associated with holding the reference crypto asset, as well
as by entities for arbitrage transactions that expect the price ofthe reference crypto asset and the Trade Price to be close in the
future. Therefore, the Trade Prices the Company quotes are also
affected by fluctuations in the price of the reference crypto asset,
and are determined by reference to such indices. For this reason,
the price of the reference crypto asset may be indirectly affectedby spot price fluctuations of the underlying crypto asset, whichis the crypto asset to be traded, and the index Trade Price may
change to the disadvantage of the customer (a fall in the Trade
Price if the customer holds an open buy position, or a rise in theTrade Price if the customer holds an open sell position), which
may result in losses.
Furthermore, because the transaction amount is large comparedto the amount of margin deposited by the customer for thetransaction, fluctuations in the price of such index transactions
may cause the amount of losses to exceed the amount of margindeposited, resulting in losses in excess of the principal amountfor the customer.
3）Common Risks of Fluctuations in Trade Prices and Crypto
Asset Index Prices
The price of crypto assets may fluctuate rapidly due to changes
in the balance of supply and demand for Over-the-counter
derivatives of crypto asset transactions at the Company,changes in the balance of supply and demand for spot trading of
crypto assets that are the reference assets for Over-the-counter
derivatives of crypto asset transactions, changes in prices, fiat
currency, trends in other markets, natural disasters, war,
political changes, changes in laws and regulations, changes inthe situation pertaining to crypto assets, and other unforeseenor significant events. Depending on the price fluctuations, there8

is a possibility that an order may not be executed, an intended
transaction may not be executed, or an unintended transaction
may be executed.
Be aware that the spot price of the crypto asset being indexed
may become zero.
In addition, the Company's Over-the-counter crypto asset
derivative transactions permit the use of designated spot crypto
assets as margin. In Over-the-counter crypto asset derivativetransactions that reference the same type of crypto asset as the
spot crypto asset used for margin, holding a long position
exposes the holder to the risk of experiencing greater losses than
anticipated when market downturns lead to declines in thevalue of the spot crypto asset provided as margin, coupled withlosses from the revised valuation of the Over-the-counter crypto
asset derivative transactions. Moreover, the margin required tomaintain bitFlyer Crypto CFD positions is continuously
recalculated based on the latest spot crypto asset trading priceestablished on Lightning Spot. Consequently, the amount ofmargin needed to sustain the customer's held positions might
increase in response to changes in the spot crypto asset tradin
prices. In such scenarios, there is an elevated risk ofencountering a margin shortfall due to an increase in valuation
losses on the Over-the-counter crypto asset derivativetransactions.
4）Risks Inherent to Crypto Asset Networks
1 Crypto assets are not fiat currency, but electronic dataexchanged Over-the Internet, and the value is not guaranteedby any specific party. Crypto assets do not necessarily haveunderlying assets. These characteristics affect Over-thecounter derivatives of crypto asset transactions that havecrypto assets prices as reference, and the instability in thevalue of such underlying assets may be reflected in the
instability in the value of Over-the-counter derivatives ofcrypto asset transactions, which may cause customers to incur
losses.
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The blockchain may diverge due to a hard fork, soft fork,
etc., which may cause a significant drop in the value of theunderlying crypto assets for Over-the-counter derivatives of9crypto asset transactions or may retroactively invalidate thetransactions. The Company may have a certain period of time
before and after the divergence when the Company does not
accept transactions such as settlements using the underlying
crypto assets, deposits and transfers of the underlying crypto
assets, etc. In addition, if the Company determines that thedivergence is not permanent, or for other reasons, theCompany may not handle all or part of the relevant crypto
assets. In the event of a blockchain divergence, other changes
in the specifications of crypto assets, or other events such as
airdrops, the Company will decide at the Company’s own
discretion whether or not to respond to such events and thedetails of such response. Therefore, the Company may
suspend or invalidate Over-the-counter derivatives of crypto
asset transactions whose reference crypto asset is subject tothe event, as well as transactions of the subject crypto asset
itself. In addition, there is a possibility that the Company willcollect the rights adjustment amount from holders of open
interest when the Company will grant the rights adjustment
amount to holders of open interest.
3 If a malicious party has a hashrate of 51% or higher in theblockchain network of a crypto asset, there is a risk that thecorresponding malicious party may be able to (1) approve
unauthorized transactions, (2) deny legitimate transactions, or(3) monopolize the mining. If such a situation occurs, the priceof Over-the-counter derivatives of crypto asset transactions
with crypto asset prices as reference may fall sharply or
fluctuate drastically, and customers may suffer losses.
5）Sell Out and other risks
Regardless of the customer’s intention, bitFlyer may forcibly
settle the customer's open positions through an offsetting sale(sell out order) in accordance with the Margin Call Rule and Sell
Out Rule.
bitFlyer conducts a daily assessment at 6:00 pm (JST) to
determine whether the customer's open positions have fallen
into a margin shortfall. During this assessment, the amount ofmargin required is calculated based on the most recent spot
trading prices on Lightning Spot at 6:00 pm (JST) each businessday, and is compared against the customer’s deposited margin
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(this includes valuation gains or losses on the positions held). If
the assessment cannot be carried out at 6:00 pm (JST) due tosystem failures or other reasons, it will be performed as soon as
the calculation of the required margin amount is possible.
If a customer who falls short of margins at 6:00 p.m. on a certain
day does not take necessary measures to resolve the margin
shortage until 5:00 p.m. on the following day, the sell out rule
will be applied to all open positions held by the customer.
In addition to the above, when a customer's margin maintenanceratio declines and reaches 50%, the sell out rule is immediately
applied to all open positions for those customers who hold asingle open position, and to the open positions necessary torecover the margin maintenance ratio among multiple open
positions in the order determined by the Company for customers
who hold multiple open positions.
Further, when price distribution is suspended and thenresumed, there is a possibility of forced sell out transactions dueto the difference between the price before the suspension andthe price after the resumption.
Even in the event of a sell out, it is possible that the amount lost
due to a dramatic and rapid change in the market will cause
losses to exceed the margin deposit. If losses exceed the amountin the margin deposit, the excess amount must be paid (In somecases, the Company may make a settlement by acquiring crypto
assets that the customer has deposited with the Company as amargin deposit in lieu of fiat currency).
Furthermore, since the Company only present customers withorders received from other customers and the volume backed by
the needs of the Company’s internal proprietary trading
department, there are cases where sell out orders placed from acustomer’s account are not executed even if placed, or where sellout trades are executed at a price significantly less favorable tothe customer than the Trade Price at the time the sell out rule istriggered.
Net valuation gains and losses, margin requirements, etc. are
combined in bitFlyer Crypto CFD (open positions on each orderbook will not be offset). Be aware that when open positions are
opened on multiple boards, there is a risk of triggering a sell out
due to sudden market fluctuations in either order book.
When trading Over-the-counter derivatives of crypto asset
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transactions, please consider your own financial resources andinvestment objectives carefully and trade with a sufficientmargin deposit.
Please refer to the parts "Margin Call Rules" and "Sell Out
Rules" in section “3. Order reception and execution policy” fordetails regarding additional payment rules and sell out rules,
respectively.
6）Liquidity Risk
Note that market changes or trading volume may cause acustomer to be unable to close open positions or open new
positions, and such changes may also result in transactions at
undesirable rates. Where an order is delayed, either on the buy orsell side, it may take some time for the order to complete, or it
may fail to fulfill.
7）Credit Risk
The Company’s Over-the-counter derivatives of crypto asset
transactions are conducted between customers and theCompany. Thus, if the Company's business or property
situations, deteriorates and the company becomes unable tofulfill its obligations, it may also become unable to fulfill its
obligations to the customer, making it likely that the customer
may suffer losses (especially when customers' open interest is in
the form of unrealized profit, the customer may not be able torecover such unrealized profits).
The Company manages margin deposits from customers
separately from the Company’s own funds by means of a money
trust.
8）Leverage Point Risks
Regardless of price movements of the crypto assets subject totrading, holding either short or long positions on bitFlyer Crypto
CFD incurs leverage point payments. These payments are added
as valuation losses to the customer's held positions, increasing
the likelihood of an accumulation of valuation losses the longer
the positions are held. Fluctuation in the price of the crypto
asset referenced in the Over-the-counter crypto asset derivativetransactions, changes in the loan rates, etc., for loan

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transactions for the crypto asset, and fluctuation in interest
rates, may prompt bitFlyer to adjust Leverage Point levels.
9） Funding Rate Risks
On bitFlyer Crypto CFD, funding rate transfers take place
between bitFlyer and the customer. The "Funding Rate" isdefined as the mechanism by which money is transferred
based on the amount calculated from the price differential
between the trading price on bitFlyer Crypto CFD and the spot
trading price of the crypto asset that is referenced on bitFlyer
Crypto CFD. This transfer is conducted in accordance with thecustomer's held position size, at the designated times every eight
hours. The term can also refer to the monetary amounttransferred at such times.
If the trading price on bitFlyer Crypto CFD exceeds the spot
trading price of the referenced crypto asset, funds are collectedfrom the long position holders and granted to the short position
holders. In the reverse scenario, funds are collected from shortposition holders and granted to long position holders.
Money transfer resulting from funding rates are added to thevaluation gains and losses of a customer's held positions.
Consequently, if a customer maintains positions that are subject
to money collection, the likelihood of an increase in valuation
losses for these positions grows with the duration of ownership.
Additionally, if bitFlyer 's proprietary trading department holds
positions, bitFlyer will also be subject to either fund collection or
grants pursuant to the funding rate. As a result, in scenarios
where the proprietary trading department's positions qualify forfund receipts, money collected from customers may, in effect, be
granted to bitFlyer 's proprietary trading department.
In addition, bitFlyer might maintain short positions on bitFlyer
Crypto CFD to hedge the risk of price fluctuations in bitFlyer ’s
crypto asset spot inventory, which is held for the operation of
bitFlyer ’s crypto asset exchange business. Should the trading
price on bitFlyer Crypto CFD deviate from the spot price of thereferenced asset, bitFlyer may also maintain positions on
bitFlyer Crypto CFD anticipating a narrowing of this gap, with
the intent of engaging in arbitrage trading.
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For detailed information on bitFlyer ’s proprietary trading
activities, please see "Explanation of Trading Specifics andRelated Terms Trading Methods."
10）System Risks
1 Over-the-counter derivatives of crypto asset trades
performed by customers make use of an electronic trading
system. There may be cases where a trade does not complete
as intended or completes in an unintended manner due tofactors such as customer error when entering data and/or
other causes. Note that trades may not complete as intended
based on the type of order or market conditions.
2 As a result of causes that include, but are not limited to,damage to the telecommunications networks, systems, andequipment used by the Company and customers, damage to aconnection, natural disasters such as earthquakes, lightning,
and fires, or cyber attacks, etc., the electronic trading system
may be rendered unusable temporarily, and transmission ofcustomer orders may be delayed, deleted, or fail to process,resulting in invalidation or completion in an unintended
manner. Note that in the event of electronic trading system
failure, all or part of the Company's services, including theexecution of Over-the-counter derivatives trades by theCompany, may be suspended or restricted.
3 There may be a possibility that the Company's system
calculates an abnormal Over-the-counter derivatives of crypto
asset offer price. The Company reserves the right to render
the listed price invalid and cancel trades which have been
completed in the event that the Company can reasonably
determine that the listed price is, due to system abnormality
or other causes, significantly different from the prevailingmarket price, incorrect, abnormal, or based on unfair
valuations.
11）Consideration Points on Market Order
The Company will not execute a limit order from a customer
with a price more disadvantageous than the designated price by
the customer while placing the limit order. However, whenplacing a market order, or a special order that contains a market
order (including stop order), there may be a difference between
the actual execution price and the price recognized by the14customer on the trade interface while placing the market order.
The corresponding price difference occurs due to the fluctuationof executable price quoted by the Company with reflectingchange of balance between supply and demand for OTC Crypto
Asset Derivatives Contract, between the timing when thecustomer recognizes the executable price quoted by theCompany and the timing when IT infrastructure of theCompany completes taking and execution of the order from thecustomer placed by the customer himself/herself and sent from
his/her IT facility to IT infrastructure of the Company. The
corresponding price difference may result in either anadvantageous price or a disadvantageous price for the customer.
Management Methods for Deposited Assets
Funds received from customers are managed separately from theCompany's assets in Sumitomo Mitsui Banking Corporationaccount and SBI Clearing Trust Co., Ltd. Crypto assets used as amargin deposit are clearly discernible from crypto assets that are
owned by the Company in accordance with the Payment Services
Act. The Company manages crypto asset data in a way that
immediately identifies which crypto assets belong to customers. The
Company manages all customers’ crypto assets in cold wallets.
Some crypto assets are also managed using multisig.
Summary of Cover Trading Partner
There are cases when the Company performs cover trades tomitigate the risk of price fluctuations in trades with customers. The
Company’s cover trading partner is detailed below.
Firm name: Aux Cayes FinTech Co. Ltd (corporation from theRepublic of Seychelles)
Name of competent supervising authority if applicable: None
Business: Trading
Firm name: SBI VC Trade Co., Ltd.
Business: Crypto-asset and Financial instruments business
Other Important Notes
Over-the-counter derivatives of crypto assets are not subject tocooling off as stipulated by Article 37-6 of the Financial Instruments
15and Exchange Act.

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Structure of Over-the-counter Derivatives of Crypto Assets
For more information on the trading methods for bitFlyer Crypto CFD, including margindeposits, please read the Details of Trading Explanation below.

Summary of Over-the-counter Derivatives of Crypto Assets
A summary of the Over-the-counter derivatives of crypto assets can be found under the“Introduction” and “Explanation of Trading Specifics and Related Terms”.

Summary of Taxes
For more information on tax handling for crypto assets-related Over-the-counter derivatives inJapan, please contact your local tax office or tax accountant. The current point of view ofJapanese tax authorities on crypto assets is summarized as follows. However, this point of view
is subject to change.
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Capital gains received by individual customers from trading Over-the-counter
derivatives of crypto assets are generally subject to taxation as miscellaneous
income.
However, the tax treatment may shift to business income tax depending on the amount of
capital gains and compliance with the requirements for maintaining transaction-related
accounting records and documents.
Tax exemptions on miscellaneous income from futures trading and deductions from losses
incurred by balances brought forward in net settlement are excluded from miscellaneous
income from Over-the-counter derivatives trading of crypto assets.
Transfer gains (capital gains) received by corporate clients from crypto-asset-relatedOver-the-counter derivatives transactions can be subject to corporate taxation.

Termination of Accounts
The Company may terminate a customer’s account in the event of the following.
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If the customer violates the rules in this document or any of the Company’s rules
In some cases, customers incur bear losses from the settlement of some or all of thecustomer’s open positions. In this situation, the customer shall be responsible for any
losses incurred in the net settlement.
If a reasonable amount of time has passed with no balance in the account of the assets
corresponding to this agreement
Customers who wish to close their account can make an account closure request throughthe inquiry form on the Company's website.

Company Profile
Company name: bitFlyer, Inc.
Director-General of the Kanto Local Finance Bureau 3294 (Type 1 Financial Instruments
Business)
HQ: 9-7-1 Akasaka, Minato-ku, Tokyo 107-6233
Business purpose: Financial instrument exchange operator, crypto asset exchange operator
Member: Japan Crypto Asset Trading Association
Established: January 9, 2014
Capital stock: 2,061,191,378 JPY

Complaints and Consultations
Inquiries regarding trading and other services can be made through the following methods.
● Inquiry Form: https://bitflyer.com/en-jp/contactpage● Email: info@bitflyer.com

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Mailing address: Midtown Tower 30F 9-7-1 Akasaka, Minato-ku, Tokyo 107-6230
bitFlyer, Inc.
Call center:
Complaints: 03-6434-7624

Regarding restricted transactions, unauthorized logins and fraud damage:03-6434-7957

General Inquiries: 03-6434-5864oooThe call center is open from 9:30 to 17:30 (JST)Only available in JapaneseOutside of the hours of operation, please make inquiries through the Company’s
contact form (https://bitflyer.com/en-jp/contactpage). The Company will respondby email.

Dispute Resolution Measures
The non-profit organization, the Financial Instruments Mediation Assistance Center (FINMAC),
may be used as a designated financial instruments exchange business complaints, conflict, andtrouble resolution center in accordance with the Financial Instruments and Exchange Act.
FINMAC is a public third-party organization and is not affiliated with the Company.
Inquiries and Support

Contact Information

Financial Instruments Mediation
Assistance Center (FINMAC)

Daini Shoken Kaikan, Nihonbashi, Kayabacho 2-11, Chuo-ku, Tokyo 103-0025, Japan
Tel: 0120-64-5005

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Definitions
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Execution
The conditions of a sell order and a buy order match and a buy/sell transaction is
executed.
PositionAn execution that remains unsettled in margin trading.
Short Position (Sell Position)
This term describes a contract in derivative transactions, etc., where a sale is executed,
but the contract has not yet been settled. In the context of bitFlyer 's Over-the-counter
crypto asset derivative transactions , which are classified under the Financial
Instruments and Exchange Act
as "index forward
trading," a contract is referred toas a short position
when the customer
has entered into an Over-the-counter crypto
asset derivative
trading contract with bitFlyer
and will pay money upon settlement
if the trading price of the involved Over-the-counter crypto asset derivativehas
increased.
Long Position (Buy Position)
This term describes a contract in derivative transactions, etc., where a purchase is
executed, but the contract has not yet been settled. In the context of bitFlyer 's Over-thecounter crypto asset derivative transactions, which are classified under the Financial
Instruments and Exchange Act as "index forward trading," a contract is referred to as along position when the customer has entered into an Over-the-counter crypto asset
derivative trading contract with bitFlyer and will receive money upon settlement if the
trading price of the involved Over-the-counter crypto asset derivative has increased.
Repurchase
Process of buying back sell open positions in order to close out (reduce them).
Crypto asset exchange operator
Business entities that are registered with the Finance Bureau of Japan and provide
services such as the exchange of crypto assets for legal tender in Japan.
Financial instruments exchange operator
Business entities registered under the Financial Instruments and Exchange Act andengaged in the business of handling financial instruments transactions, incl. Over-thecounter derivatives of crypto assets, in Japan.
Net settlement
This refers to a method of settlement in which the net profit or loss (i.e., the difference)
resulting from a transaction is resolved through the transfer of funds. In the context ofOver-the-counter crypto asset derivative trading, this involves executing an offsetting
trade and settling the net profit or loss incurred between the trading price at the
inception of the position and the trading price at the time of the offsetting trade. While net settlements are commonly executed via the transfer of funds, bitFlyer may also
conduct net settlements by obtaining, without cost, the crypto assets that customers
have deposited in lieu of a margin. In such instances, the amount of crypto
assetsobtained by bitFlyer is determined to ensure that its value, calculated at 95% of the mostrecent spot trading price in Lightning Spot at the time of acquisition, equals themonetary amount that would have been exchanged in the net settlement.
Leverage Points
These are payments incurred through the maintenance of either short positions or longpositions in Over-the-counter crypto asset derivative trading, irrespective of fluctuationsin the prices of the crypto assets that the Over-the-counter crypto asset derivativetransactions reference. bitFlyer may adjust leverage point levels in response to shifts inthe prices of the crypto assets being referenced as indexes for the Over-the-counter crypto
asset derivative transactions, changes in their loan rates, and interest rate changes.
Funding Rate
For bitFlyer Crypto CFDs, an exchange of Funding Rates takes place between bitFlyerand our customers. The "Funding Rate" is defined as the mechanism by which money istransferred based on the amount calculated from the price differential between the
bitFlyer Crypto CFD trading price and the spot trading price of the crypto asset that isreferenced on bitFlyer Crypto CFD. This transfer is conducted in accordance with the

19

●

●
●

●

●

customer's held position size, at the designated times every eight hours. The term canalso refer to the monetary amount transferred at such times. If the bitFlyer Crypto CFD
trading price exceeds the spot trading price of the crypto asset it references, funds arecollected from the long position holders and granted to the short position holders. In thereverse scenario, funds are collected from the short position holders and granted to thelong position holders. (If bitFlyer 's proprietary trading department holds positions, it will
also be subject to either fund collection or grants.) The amount of money transferredincreases up to a predetermined limit as the difference between the Over-the-counter
crypto asset derivative trading price and the crypto asset spot trading price widens.
RolloverThis refers to the process undertaken on each business day when positions held by thecustomer on bitFlyer Crypto CFD reach their expiration at 6:00 pm (JST). The processextends the expiration of these positions to the next business day at 6:00 pm (JST), after
conducting the following procedures: At the time of expiration of the position, thetransaction amount is recalculated based on the most recent spot trading priceestablished on Lightning Spot, and it is confirmed that the customer has provided thenecessary amount of margin to continue holding the position.
Derivatives trading
Transactions in financial instruments whose prices are derivatively determined based onthe (numerical) value of a reference object. They include futures, options and swaps.
Index Forward Trading
A type of Over-the-counter derivative trading, among derivative trading, which trades
are net settled or traded similarly referencing "financial indices", such as the prices orinterest rates of financial instruments, including crypto assets, and other indices derived
from them. When establishing a transaction between parties, the parties are obliged toenter a contract for net settlement, which involves the transfer of money calculated basedon the difference between the “stipulated value”, which is a numerical value agreed upon
regarding the referenced financial index, and the real figure”, which is the actual value of
said financial index at a certain future point in time from the point of transaction
establishment. Transactions on bitFlyer Crypto CFD are index forward transactions thatreference the price of Bitcoin as the financial index and set the designated future point intime as 6:00 pm (JST) every business day.
Margin Call (Additional Margin)
The margin that must be added by the deadline specified by the financial instruments
exchange operator in the event that the amount of margin submitted (valuation margin),
after adding or subtracting settlement gains or losses, falls below the required amountdue to market fluctuations etc. at the time of determination specified by the financial
instruments exchange operator.
Sell out
The forced settlement of the customer’s open positions by the financial instruments
exchange operator to prevent the customer’s losses from increasing and to manage risk
when a customer’s losses reach a predetermined level or when additional margin is notcleared by the deadline.

The definitions of other terms can be found here (https://bitflyer.com/en-jp/glossary)20

Prohibited Actions for Trading Over-the-counter Derivatives of Crypto Assets
In accordance with the Financial Instruments and Exchange Act, a financial instruments
exchange operator acts as a counterparty and intermediary to customers for making trades ofOver-the-counter derivatives of crypto assets (hereafter “activities related to crypto-asset relatedOver-the-counter derivative transactions”). When acting as an intermediary or representative,
the following acts are prohibited:
1 The use of false information to execute a contract or solicit a contract for trades of Over-thecounter derivatives of crypto assets with customers
2 Offering unreliable information in what can be deemed an assertive manner or making
misleading declarations to execute a contract or solicit a contract for trades of Over-thecounter derivatives of crypto assets with customers
3 Visiting or calling individuals who have not requested solicitation for a contract for trading
Over-the-counter derivatives of crypto assets in order to execute a contract or solicit acontract for trades of Over-the-counter derivatives of crypto assets (does not include
solicitations of individuals with whom the financial instruments exchange operator
maintains a business relationship, the individual has made at least two trades of Over-thecounter derivatives of crypto assets within one year of the date of solicitation, and theindividual maintains a balance of unsettled Over-the-counter derivatives of crypto assets)
4 Executing a contract for trading Over-the-counter derivatives of crypto assets without
confirming in advance if the corresponding customer has the intention to be solicited
5 Continuing to solicit the execution of a contract for trading Over-the-counter derivatives ofcrypto assets to an individual who has indicated that the individual does not wish to besolicited (includes the indication to not continue receiving solicitations) for the execution ofan Over-the-counter trading of crypto assets contract
6 Soliciting the execution or cancelation of a contract for trading Over-the-counter derivativesof crypto assets in-person or Over-the telephone at a time of day that is considered to be a
nuisance for the individual receiving the solicitation
7 Offering an application or agreement to have the Over-the-counter derivatives of crypto
asset exchange operator or a third party wholly or partially compensate or provide
supplemental funds to customers who incur losses or do not meet a predetermined level ofprofitability in trading Over-the-counter derivatives of crypto assets
8 Making an application or promise to customers to have whole or partial compensation forlosses or provide additional profits by the crypto asset exchange operator or a third party
when trading Over-the-counter derivatives of crypto assets to customers or designatedindividuals
9 Offering to give customers or third parties profits above the corresponding customer or third
party’s assets in order to wholly or partially compensate customers’ losses or give additional
profits in trading Over-the-counter derivatives of crypto assets
10 Upon delivery of this document, failure to explain the details of this document so that
customers understand the necessary knowledge, experience, status of assets, and purpose for
executing a contract for trading Over-the-counter derivatives of crypto assets
11 Expressing important matters in a way that creates a misunderstanding when executing or
soliciting a contract for trading Over-the-counter derivatives of crypto assets
12 Offering to provide or promising special profits to customers, designated parties, or third
parties in a contract for trading Over-the-counter derivatives of crypto assets (includes
promises or offers to offer special profits to a third party)
13 Using deceit, violence, or coercion in order to execute or cancel a contract for trading Overthe-counter derivatives of crypto assets
14 Having the contract for trading of Over-the-counter derivatives of crypto assets wholly deny,partially deny, or unreasonably delay the ability to trade Over-the-counter derivatives ofcrypto assets under an obligation from another Over-the-counter derivatives of crypto assets
trading contract
15 Using false market prices to calculate the amount of money, marketable securities, or otherassets to be used as margin deposits or collateral that customers are required to hold as per
the corresponding contract for trading Over-the-counter derivatives of crypto assets

21

16 Gathering customers with the purpose of soliciting the execution of contracts for trading
Over-the-counter derivatives of crypto assets without expressly stating that fact to thecorresponding customers in advance17 Calculating a customer’s Over-the-counter derivative of crypto asset trades in advancewithout obtaining an agreement from the corresponding customer in advance
18 Having an individual financial instruments exchange operator, executive of a financial
instruments exchange operator (includes an executive or corporate body that fills the role),or an employee of a financial instruments exchange operator use customers’ trading order
trends of Over-the-counter derivatives of crypto assets or other specific information obtainedin the course of the corresponding employee’s duties for the purpose of pursuing wholly
speculative profits in trading Over-the-counter derivatives of crypto assets
19 For trades of Over-the-counter derivatives of crypto assets, upon obtaining the customer’s
agreement for total amount of funds, in cases where agreement is not obtained regarding
types of buying or selling, combinations of crypto assets, or volume and prices of trades,
determining trade decisions by computers or predefined methods; pursuant to thesepredefined methods, when financial instrument exchange operators execute a contract toperform trades, the corresponding financial instruments exchange operator shall not do so in
writing (excludes cases where a digital information processing structure or other informationtransmission technology method is used for execution)
20 When a customer trades Over-the-counter derivatives of crypto assets, making solicitations
or other similar actions to customers for equivalent purchase or sale trades of Over-thecounter derivatives of crypto assets (refers to trades that are performed in order to mitigate
losses from the preceding trades)
21 When trading Over-the-counter derivatives of crypto assets, if a customer places a new orderwith an insufficient amount of funds to achieve 25% of the principle in the corresponding
customer’s collateral account (includes calculations of profit and loss), executing thecorresponding trade without promptly requiring the customer to deposit the insufficientamount of collateral once the order has been created
22 When trading Over-the-counter derivatives of crypto assets, at a designated point in time oneach business day, if a customer’s deposited collateral is less than 25% of the principle(includes calculations of profit and loss), executing the corresponding customer’s trades
without having the customer deposit the insufficient amount of collateral
23 Concluding or soliciting a contract for crypto asset-related Over-the-counter derivatives
transactions, or making an advertisement related to the underlying financial instruments
business without showing reasonable grounds supporting such indication or conducting an
act of indicating the matters listed in Article 78, Items 5 to 7 inclusive or item 13 Par. (a) to(e) inclusive of the Cabinet Office Order on Financial Instruments Business, etc. tocustomers.
24 Soliciting the conclusion of crypto asset-related Over-the-counter derivative contracts
without clearly and accurately indicating to customers the matters listed in Article 76, Item
3 (a) and (b) of the Cabinet Office Order. (This includes displaying the letters or numerals of
indication in a size significantly different from the largest letters or numerals in the
documents or other equivalent methods used for indication.)
25 Engaging in derivatives transactions from a customer, while knowing that the customer islikely to conduct derivative transactions that violate the provisions of Article 185-22, Par. 1,
Article 185-23, Par. 1 or Article 185-24, Par. 1 or Par. 2 of the Financial Instruments andExchange Act (including acts conducted in relation to acts in violation of these provisions).
26 Engaging in derivatives transactions pertaining to the cryptographic assets, etc., or
subscribing to such transactions, for the purpose of altering the market price or the market
value calculated based on the market price or trading volume of the cryptographic assets,etc., or increasing the trading volume of the cryptographic assets, etc.
27 Engaging in derivatives transactions pertaining to crypto assets, etc., while knowing thatthe act will cause fluctuations in the market price of the cryptographic assets, etc. or in thevalue calculated based on the market price or trading volume, or increase the trading
volume so that the act will be an artificial act that does not reflect the actual situation.

28 Using information or communicating it to a third party about crypto assets, etc.
pertaining to sales, purchases, or other transactions, etc. of securities or material22information about the corresponding financial instrument exchange operator that isdeemed to influence a customer's decision to buy, sell, or otherwise deal in the
securities pertaining to the crypto assets, etc. (excluding information that is readily
available to all customers of the financial instrument exchange operator andinformation that is necessary for the proper and reliable performance of thefinancial instruments business, etc. conducted by the corresponding financial
instruments exchange operator) for the purpose of benefiting oneself or a third
party.

23

Explanation of Trading Specifics and Related Terms
1. Trading types
bitFlyer Crypto CFD trade is Over-the-counter derivative transactions that reference the price of
crypto assets (Index forward contract).
2. Trading methods
bitFlyer Crypto CFD trade is Over-the-counter derivatives transactions (Over-the-countertransactions) that are concluded between customers and the Company, not on a financial
instruments market or foreign financial instruments market. Customers are required to deposit
a portion of the transaction amount to the Company in advance as a margin deposit, before
settling the transaction with the Company for the difference between the price of the reference
cryptographic asset agreed upon by the customer and the Company at the time of execution of
the new transaction and the relevant price at the time of execution of the settlement transaction.
(In some cases, the Company may settle the transaction by acquiring the cryptographic assetsthat the customer has deposited with the Company as margin, instead of cash. The amount ofcrypto assets that bitFlyer obtains is calculated to ensure that, at the time of obtainment, itsvalue calculated at 95% of the latest spot trading price on Lightning Spot equals the monetaryamount that would have been settled through a net settlement.)
The Company will quote the total of the quantity of orders for crypto-asset-related Over-thecounter derivatives received from other customers and the quantity of crypto-asset-related Overthe-counter derivatives required by the department conducting proprietary trading within the
Company as the quantity at which the Company can accept the order for crypto-asset-relatedOver-the-counter derivatives from the customer at each price. Further, when the Company
receives an order for crypto-asset-related Over-the-counter derivatives from a customer, theCompany will act as the customer’s counterparty and execute a crypto-asset-related Over-thecounter derivatives transaction between the customer and the Company when the conditions
regarding the price and the quantity that the customer and the Company offer each other in the
opposite direction match. (the Company will not execute Over-the-counter derivatives of crypto
asset transactions with the customer in excess of the quantity offered to the customer). The
Trade Price for matching a customer's order with the terms offered by the Company will be
determined based on the "principle of competitive trading." The “principle of competitive trading”
refers to the principle of price priority (the lowest price order for sell orders, the highest priceorder for buy orders, and the price specified by “limit orders”). This principle also includes theprinciple of time priority (when there are buy and sell orders at the same price, the order thatwas placed first in terms of time is prioritized).
For bitFlyer Crypto CFD, the Company's proprietary trading division may quote the volume oforders to buy or sell to the extent deemed necessary to hedge the risk of price fluctuations in theinventory of crypto assets the Company holds, as well as the price (the quotes are combined withthe volume of orders in the same direction as the direction of the proprietary trading division's
quotes, and are quoted to the customer at each price as the volume available for trading). Such
quotes are intended to neutralize the risk of price fluctuations that the proprietary trading
division has in both spot trading of crypto assets and Over-the-counter derivatives of crypto asset
transactions, and the Company does not intend to earn a profit if the price of the corresponding
Over-the-counter derivatives of crypto asset transactions rises or falls.
As conditions that allow for possible transactions, bitFlyer ’s proprietary trading department
may offer quantities desired for trading at certain prices when there is a widening expansion in
the divergence between the trading prices on bitFlyer Crypto CFD and the spot trading prices of
the crypto assets that bitFlyer Crypto CFD references; this will be done within the necessary
scope for conducting transactions on bitFlyer Crypto CFD aimed at arbitrage, in anticipation of
narrowing the aforementioned divergence.
In the case of either of the above-mentioned price fluctuation risk hedging purposes or liquidity
provision purposes, the Company shall not perform front-running*, use customers’ trading24

information, prioritize the processing of the Company’s orders, prioritize the Company’s orders in
the event of any system malfunction, or any other form of inappropriate trading.
*Front-running refers to the act of an operator using order information of customers in order toplace its own order before of customers orders are placed.
3. Order reception and execution policy
・Reference index, pairs, and order sizes

Limitations on Order Volume and Position Holdings
For details on the maximum and minimum order sizes, as well as the limits on the number of
positions that can be held, please consult the following table.
bitFlyer Crypto CFD
Reference index

Unit

BTC-CFD/JPY

BTCCFD

Minimum Order
Size
0.01

Maximum Order
Size

Maximum Held
Position Limit

100

500

If we are concerned that a customer with open positions in excess of 100 BTC-CFD or 100 BFT
has an excessive volume of open positions compared to the total volume of orders from the
opposite side of the order book to which loss-cut orders are placed when loss-cut rules areapplied, and that the security of trading for other customers may be impaired, we will ask thecustomer to reduce the amounts of open positions to the volume we have specified. Failure tocomply with the above will be regarded as a violation of the prohibited activities in our Termsof Use and may result in the suspension of orders for derivative transactions or account closure
with compulsory settlement of open positions.
・Circuit breaker during rapid price changes (measure to prevent sudden changes in trading
prices)To prevent sudden price changes, bitFlyer Crypto CFD have a circuit breaker system. A circuit
breaker temporarily suspends trading in order to prevent erroneous order placement.
The circuit breaker system is summarized below.
Activation
Conditions

The placement of an order which causes the market price to fall outside of
the price fluctuation threshold

Circuit Breaker
Reference Price

The last traded price from 10 minutes priorPrice Fluctuation
Threshold

15% above or below the circuit breaker reference priceSuspension Period

About 5 minutes

Resumption
Procedure

Trading will resume by the Itayose method after the suspension period has
elapsed*When trading resumes, bitFlyer ’s proprietary trading department may
employ the Itayose method to hold positions for the purpose of hedging pricefluctuation risks or for arbitrage trading. In such instances, the price andquantity desired by the proprietary trading department will be reflected on
the order book and displayed in the same manner as orders from othercustomers.

25

*Orders may be placed and cancelled while trading is temporarily suspended.
*If there have been no trades for 10 minutes, the reference price remains at its most recent value.
*The single price determined by the Itayose method is taken as the circuit breaker reference
price for the duration of the 10 minute period following the resumption of trading.
*When trading is temporarily suspended due to circuit breaker activation and the single pricedetermined by the Itayose method falls outside of the price fluctuation threshold, another periodof suspension will immediately follow without resumption of trading. The reference price of thisnew period will be the price at which the price fluctuation threshold was exceeded.
*There may be situations where the Company does not apply the circuit breaker if the Company
determines that, in consideration of trading conditions, applying a temporary suspension to
trading is not appropriate.
*The Company will make a determination as to whether to temporarily suspend trading on eachoccasion that the circuit breaker activation conditions are met. There may be a time difference
between the satisfaction of those conditions and the commencement of a suspension.
*If the regularly scheduled maintenance time starts while the circuit breaker is activated, thecircuit breaker Itayose process will take priority Over-the maintenance period.
*Any opportunity losses, including those due to the introduction of the circuit breaker system,
are under no circumstances the responsibility of the Company.
The Itayose method searches for a price by sequentially matching buy and sell orders using theprescribed priority while making quantitative matches, and then makes purchases and sales
using a single price. The order of priority is as follows.
Sell order
1: Market orders 2: lowest price limit order
Buy order
1: Market orders 2: highest price limit order
If there are multiple limit orders at the same price, the orders will be executed in the order they
were placed. All market orders placed before the single-price auction (Itayose method) is
determined (including orders placed prior to scheduled maintenance) will be considered to havebeen placed at the same time.
・Circuit breaker during divergence expansion (measure to prevent significant divergence from
crypto asset spot trading prices)
bitFlyer Crypto CFD employs a circuit breaker mechanism to temporarily suspend trading withthe aim of preventing a significant divergence between crypto asset
spot trading
prices and
bitFlyer Crypto CFD trading prices.
Below is an overview of the circuit breaker mechanism activated during periods of growing
divergence.
Activation
Conditions

When orders are placed that can be expected to execute a trading contract
on bitFlyer Crypto CFD at trading prices outside the price range limitations

Circuit Breaker
Reference Price

The spot trading price of the crypto asset referenced on bitFlyer Crypto
CFD, utilized as the standard for calculating the trading prices that bitFlyer
offers at the exchange in its role as a crypto asset exchange operator*Under normal market conditions, this reference price matches the crypto
asset spot trading price displayed by bitFlyer on the exchange as the midprice, which is the midpoint of the available buy and sell prices. However,bitFlyer has discretion Over-the presentation of available buy and sell prices
at the exchange, and as a result, the aforementioned Reference Price may
not always coincide with the mid-price.

26

Price Fluctuation
Threshold

5% above or below the circuit breaker reference priceSuspension Period

About 5 minutes

Resumption
Procedure

Trading will resume by the Itayose method after the suspension period has
elapsed* When trading resumes, bitFlyer ’s proprietary trading department may
employ the Itayose method to hold positions for the purpose of hedging pricefluctuation risks or for arbitrage trading. In such instances, the price andquantity desired by the proprietary trading department will be reflected on
the order book and displayed in the same manner as orders from othercustomers.

*Orders may be placed and cancelled while trading is temporarily suspended.
*If there have been no trades for 10 minutes, the reference price remains at its most recent value.
*The single price determined by the Itayose method is taken as the circuit breaker reference
price for the duration of the 10 minute period following the resumption of trading.
*When trading is temporarily suspended due to circuit breaker activation and the single pricedetermined by the Itayose method falls outside of the price fluctuation threshold, another periodof suspension will immediately follow without resumption of trading. The reference price of thisnew period will be the price at which the price fluctuation threshold was exceeded.
*There may be situations where the Company does not apply the circuit breaker if the Company
determines that, in consideration of trading conditions, applying a temporary suspension to
trading is not appropriate.
*The Company will make a determination as to whether to temporarily suspend trading on eachoccasion that the circuit breaker activation conditions are met. There may be a time difference
between the satisfaction of those conditions and the commencement of a suspension.
*If the regularly scheduled maintenance time starts while the circuit breaker is activated, thecircuit breaker Itayose process will take priority Over-the maintenance period.
*Any opportunity losses, including those due to the introduction of the circuit breaker system,
are under no circumstances the responsibility of the Company.
・bitFlyer Crypto CFD trading rules
These rules explain bitFlyer Crypto CFD trading. All times listed are in Japan Standard Time
(JST).
Trades on bitFlyer Crypto CFD (opening an account, placing an order, exchanging funds, etc.)
take place on the Internet. In principle, we do not accept trades made by telephone.
i) Trading days and hours
1）Trading days
bitFlyer Crypto CFD trades are generally available every day.
2） Trading and order reception hours
bitFlyer Crypto CFD trades can be made during the following hours.
24 hours/day, 365 days/year*Excludes periodic and irregular maintenance. More information on periodic maintenance canbe found here (https://bitflyer.com/en-jp/faq/9-25).
*Periodic maintenance is scheduled to occur every day from around 4:00 AM to 4:10 AM. The
start and end times are subject to change.
ii)Orders
1) Order reception hours
Order can be received 24 hours/day, 365 days/year, excluding maintenance periods.

272) Trade types
The following types of trades are available.
1. New•
When a customer places an order through bitFlyer Crypto CFD, the customer
must first make a margin deposit.
•
Only orders within the customer’s available margin can be placed. The available
margin is calculated by subtracting the margin required for the position and themargin required for the order from the customer’s appraised margin amount.
2. Settlement•
Settlement of open positions can be made by either a counter-traded settlement.
*Orders to trade in the opposite direction of existing positions in a quantity less than or equal tothe corresponding positions are settlement orders, and orders to trade in the opposite direction ofexisting open interest in a quantity greater than or equal to the open interest in a case where
there is no open interest or where there is open interest are new orders.
*bitFlyer Crypto CFD contracts expire every business day at 6:00 pm (JST). Upon expiration, arollover process takes place, during which the transaction amount for each unit of assumed
principal is recalculated based on the latest spot trading price for each unit of the respective
crypto asset, as established on Lightning Spot. After confirming that the customer has provided
the necessary margin to sustain the trading contract, the expiration of the contract is extended to
6:00 pm (JST) of the following business day. However, bitFlyer only offers conditions for trading
to customers if their desired direction for trading on bitFlyer Crypto CFD is supported by anorder from the opposite direction. As a result, customers cannot settle their positions at the mostrecent spot trading price at expiration. To settle a position, customers must place and execute asettlement order that aligns with the conditions bitFlyer presents. Since bitFlyer does not
specifically restrict the timeframe from the formation of a position to the issuance and executionof a settlement order to dissolve said position, bitFlyer Crypto CFD transactions are without afixed settlement deadline. (However, bitFlyer
reserves the right to establish a settlement
deadline at its discretion.)*If there is a possibility that a Registered User's order may self-trade with another order of thesame user that has already been received by the Company (meaning a case where the conditions
match and execution may occur), the Registered User may not place such an order.
*The time required for order instructions may differ between the Company’s designated tradinginterface and bitFlyer Lightning API.
3) Order and execution types
Order types

IFD: An abbreviation of “If Done”, If two orders are made at the same time
and the first one is filled, then the second order is automatically placed.
OCO: An abbreviation of “One-Cancels-the-Other”, when two orders are madeat the same time and one is completed, the other side is automaticallycancelled.
IFDOCO: A combination of IFD and OCO, After an IFD order is filled, theOCO order is automatically placed.

28

Execution types

Market order: This is where an order is placed with no price specified,emphasizing the filling of the order above other parameters. A buy orderwithout limit will be filled with the lowest available offer at that time. A sellorder without limit will be filled with the highest available offer at that time.
Price limit order: A price limit order is an order placed to be filled at the pricespecified. With a buy order with price limit, the order will not be filled unlessa price below that specified is found. For a sell order with price limit, theorder will not be filled unless a price above that specified is found.
Stop order: A stop order is a market order without limit that incorporates thefollowing parameters: If the price reaches above the trigger price, buy; and if
the price drops below the trigger price, sell.
Stop limit order: If the price reaches above the trigger price, buy; and if theprice drops below the trigger price, sell.
Notes on the difference between stop orders and stop limit orders
The difference between the above two order types is that, for stop orders, once
the trigger price is reached, a market order without limit is placed. A stop
limit order, by contrast, is when a price limit order is placed once the trigger
price is reached. With a stop limit order, an order will never be filled at a
price more unfavorable than the one specified in the price limit. However, due
to price fluctuations, the order may not be filled.
Trailing stop order: A trailing stop order is where the trigger price for a stoporder is automatically calibrated based on price fluctuations.
*Please note that the IFD (the second order), stop orders, stop limit orders
and trailing stop orders will not be placed or executed in the case of a margin
shortage when actually trying to place an order. Please understand thatshould any special orders be triggered just before service is suspended(includes maintenance), there is the possibility that they will be executed
once the service resumes. If the service resumes under the Itayose method,the order will use the corresponding Itayose method.

Time in ForceGood 'Til Canceled (GTC): A Good 'Til Canceled order is one where the orderremains in effect until it is either filled or cancelled.
Immediate or Cancel (IOC): With an Immediate or Cancel order, all or part ofthe order is immediately filled if a match is found for the price indicated or
better. Orders that fail to fill are canceled in their entirety.
Fill or Kill (FOK): This refers to when the order is cancelled if the volume is
not immediately executed (filled) in its entirety.
*Please note that the same order type will be applied to the second orderwhen you place IFD or IFDOCO.

4) Order validity period
If no order expiration date is specified, the order will be valid for 30 days. (This does not apply if
an expiration date shorter than 30 days is set using the bitFlyer Lightning API.) However,orders may be withdrawn due to factors such as service updates.
5) Order cancellation
Orders that have not been executed are generally able to be cancelled.
6) Expiration of orders

29Orders will expire under any of the following conditions.
1. If the order has exceeded the expiration date as defined in 4)
2. When the margin goes below 100% of the maintenance margin rate, all new orders arevoid as of the time of the decrease.
3. Orders may expire (be cancelled) during system maintenance.
7) Trading limitations
The following trading limitations may be imposed if the Company determines that there are or
may be abnormalities in bitFlyer Crypto CFD trades for all customers or individual customers.
The main trade limitations are as follows.
•
•
•
•
•
•
•

Increase in margin rate
Limitations on quantities of orders or open positions
Limitations or prohibitions on certain types of orders
Suspension or interruption of trading
Temporary changes to trading hours
Circuit breaker during rapid price changes
Circuit breaker during divergence expansion

・Margin Deposit

In order to trade on bitFlyer Crypto CFD, customers are required to make a margin deposit
into the corresponding bitFlyer Crypto CFD account in advance. The Company accepts
Japanese Yen as fiat currency and Bitcoin as a crypto asset in lieu of a margin deposit ofJapanese Yen from customers. The margin can be deposited by transferring the Japanese Yenor Bitcoin balance in the customer’s bitFlyer account.
For bitFlyer Crypto CFD, the Company regularly confirms the status of customers’ margindeposits. If the maintenance margin rate falls below a certain standard, and meets thepredetermined criteria, the Maintenance Margin Rules, Margin Call Rules, and Sell Out Rules
will apply.
The required margin is calculated by multiplying the margin rate and the total of theunexecuted order amount and the amount of the open positions at the time when the open
positions are formed. The order amount of an unexecuted limit order is calculated bymultiplying the limit price by the order quantity, the order amount of an unexecuted market
order is calculated by multiplying the most recently traded price, and the execution amountwhen open positions are formed is calculated by multiplying the execution price by the
number of open positions held.
When a customer holds a position that reaches expiration at 6:00 pm (JST), the expiration ofthis position is extended by one business day, until 6:00 pm (JST) the following businessday. At this time, it is verified whether the customer has deposited the necessary amount ofmargin to continue holding the position. The amount of required margin for the position is
calculated by multiplying the most recent spot trading price for one unit of the relevant
crypto asset, as established on Lightning Spot, by the quantity of the position and themargin rate.
Terms related to margin ratio is defined as follows.
Margin rate(personal accounts)
50% (for 2x leverage) - 100% (for 1x leverage)••

Margin rate may be changed at the Company’s discretion.

The margin rate of corporate accounts is calculated based on the assumed crypto

30

assets risk ratio and fluctuates on a weekly basis. The leverage fluctuation will
be released on our website every week. Please refer to our website for moredetails. (The assumed crypto asset risk ratio is calculated by the Commissioner of
the Financial Services Agency. The method uses the ratio of the risk from pricefluctuations that occur in the crypto asset market to the principal amount. )••Profit and loss (valuation), required margin, etc. are combined across the bitFlyer Crypto
CFD order books.
Please note that positions on different markets do not offset each other in calculation ofrequired margin.

Terms related to margin deposits, profit and loss is defined as follows.
FactorExplanation

Total Margin Deposit

This refers to the margin customers have deposited into theiraccounts with bitFlyer.
Bitcoins deposited as margin are valued at 50% of the most recent
spot trading price on Lightning Spot. This amount is then aggregatedwith the sum of Japanese yen also deposited as margin.
In instances where Bitcoins deposited as margin are obtained by
bitFlyer at no cost as an alternative to money payable to bitFlyer
to handle net settlements by the customer, the amount of Bitcoins tobe obtained by bitFlyer is determined by dividing the cash amountdue by 95% of the most recent spot trading price on Lightning Spot.

Required margin

This refers to the margin necessary for the maintenance of positions
and for the placement of new orders.
Margin Required for Maintenance + Margin Required for Orders

Margin Required for
OrdersThis represents the margin amount necessary for placing new orders.
It is calculated as the sum of "bitFlyer Crypto CFD Trading Order
Price × Order Quantity × Margin Rate" for each order.
Any fractional amounts are rounded up.

Margin Required at
Contract Execution

This refers to the margin required to establish a position at the timeof contract execution.
It is calculated as "Executed Price × Position Quantity × Margin
Rate", with any fractional amounts being rounded up.

Margin Required for
Maintenance of Position

This margin is necessary to maintain a position.
It is calculated as "Most Recent Spot Trading Price Per Unit of the
Applicable Crypto Asset on Lightning Spot × Position Quantity ×
Margin Rate."
Any fractional amounts are rounded up.

Valuation margin

Total Margin Deposit + Valuation Gains and Losses

Maintenance marginrate

This is the ratio of the valuation margin to the required margin.
It is used as a criterion for decisions such as loss cutting.
Valuation Margin ÷ Required Margin

Valuation Gains andLossesPosition Valuation Gains and Losses - Unsettled Leverage Point Loss
- Fees - Unsettled Funding Rate Loss (if the collected funding rate
amount exceeds the granted funding rate amount)31

Position Valuation Gains and Losses - Unsettled Leverage Point
Losses - Fees + Unsettled Funding Rate Gains (if the granted
Funding Rate amount exceeds the collected Funding Rate amount)
Position Valuation Gainsand Losses

This refers to the gains and losses incurred on a position. It is
calculated by multiplying the quantity of the bitFlyer Crypto CFD
position by the difference between the most recent trading price on
bitFlyer Crypto CFD and the executed price at which the position wasformed on bitFlyer Crypto CFD.

Unsettled Leverage
Point Losses

This is the total amount of leverage point losses accumulated until
the position is settled.

Fees

This is the fee for the trade.

Unsettled Funding Rate
Gains/Losses

This refers to the gains or losses that occur due to the collection or
grants of funding rates.
*For more details on the funding rate, please refer to "bitFlyer Crypto
CFD Funding Rate" under “Fees, Etc.”.

・Maintenance Margin Rules•
If the maintenance margin rate falls below 100%, the Maintenance Margin Rules will apply.
•
All outstanding new orders will be revoked (cancelled) (“New orders” shall mean the orders
which increase the customer's position.)•
When the maintenance margin rate is below 100%, transferring out your margin deposit
from your margin accounts (Japanese yen and Bitcoin) to spot accounts, or placing neworders will be suspended.
•
There may be delays in the Maintenance Margin Rules being applied. The Company will not
be held liable for any losses incurred as a result of such delays.

・Margin Call Rules
The Margin Call Rules are as follows:

1. If the margin maintenance ratio falls below 100% at 6:00 pm (JST) on any business day(this condition is referred to as "Margin Shortfall"), bitFlyer will request the customer todeposit an additional margin amount to make up for the shortfall to 100%. At this time,the margin maintenance ratio is calculated according to the following formula. (The"Gains and Losses" in the numerator includes unrealized leverage point losses andunrealized funding rate gains/losses).
DepositMarginAmountMarginmainte
nance
rate

＋

P&L calculated from thedifference between the
average contract price and themost recently traded price of
bitFlyer Crypto CFD open
interest

×

Held
Position＝
Last Traded Price executedin Lightning SPOT

×

32

Held
Position×

MarginRatio

2. All outstanding new orders will be revoked (cancelled).
3. If the margin call has not been resolved by 4:59 PM (JST) on the next business day(including weekends and holidays) after the margin call is triggered, Sell Out Rules will
apply at 5:00 PM (JST). The methods of resolving the margin call are as follows.
・Deposit Japanese yen or Bitcoin into your margin account・Partial or complete settlement of your positions
・Increase the leverage rate**If the leverage rate is set lower than the maximum value, it can be raised to resolve themargin call. It will not be raised if you have selected the maximum leverage rate.
•

•
•

•

Please note that even if the maintenance margin rate exceeds 100% by methods other thanlisted above (market fluctuation, etc.), after the margin call is triggered, the margin call will
not be resolved.
If the market has changed abruptly, the Sell Out Rules is applied before the Margin Call
Rules are applied.
It may take time for the amount of the Margin Call to be reflected on the trade screen evenafter all or part of the Margin Call clears. If the amount is not reflected, wait for a moment
and try again.
There may be delays in the Margin Call rules being applied. The Company will not be held
liable for any losses incurred as a result of such delays.

・Sell Out Rules•

The sell out rule is applied under two conditions: when the margin maintenance ratio falls to
50%, or if a margin shortfall identified under the margin call rule is not rectified by 4:59 pm(JST) on the following business day, leading to application of the sell out rule at 5:00 pm(JST) .

•For the circumstances above where the margin maintenance ratio falls to 50%, the margin
maintenance ratio is calculated according to the following formula. (The "Gains and Losses"
in the numerator includes unsettled leverage point losses and unsettled funding rate
gains/losses). bitFlyer continuously recalculates the margin maintenance ratio. As a result,the margin maintenance ratio fluctuates with changes in both the most recent trading priceon bitFlyer Crypto CFD and the most recent spot trading price established on Lightning
Spot for the crypto asset referenced by bitFlyer Crypto CFD.
The Sell Out Rules are as follows.

DepositMarginAmountMarginmainte
nance
rate

＋

P&L calculated from thedifference between the
average contract price and themost recently traded price of
bitFlyer Crypto CFD open
interest

×

Held
Position＝
Last Traded Price executedin Lightning SPOT×

Held
Position×

MarginRatio1) If the additional margin incurred on the previous day is not cleared at 5:00 pm JST, in
accordance with the Margin Call Rules,•

The Company will close all open positions on bitFlyer Crypto CFD (Sell Out order).

33•Sell Out orders are placed as market orders to settle all open positions•

Trade may not be resumed until settlement orders on all positions are finalized.

2) If the maintenance margin rate falls and reaches 50%,
the open positions on bitFlyer Crypto CFD will be automatically resold or repurchased in thefollowing order to recover the maintenance margin rate to over 50% (sell out order).
All sell out orders are executed as market orders.



Trade may not be resumed until all sell out orders are executed.

In the event of sudden market fluctuations, losses may exceed the amount of margin even if
sell out rules are applied. In such cases, customers are required to promptly allocate cash or
cryptographic assets to eliminate the shortfall. In the event of a shortfall, the sending of
bitcoin, withdrawal of Japanese yen, and use of bitWire（β） will be suspended.
If the customer is unable to deposit more cash than the amount of the shortfall, theCompany may, at its discretion, transfer funds from the customer’s bitFlyer account to thecustomer’s margin account. In such cases, if it is necessary to allocate the insufficientamount, the Company may, at its discretion, cancel instructions to withdraw money or send
cryptographic assets from the customer’s bitFlyer account, cancel orders, dispose of assets
such as cryptographic assets in deposited with the Company, or allocate the money depositedby the customer, including the consideration for disposal, to the repayment of obligations
owed by the customer to the Company. The Company shall not be liable for any losses
incurred as a result of such disposal.
There may be delays in the Sell Out Rules being applied. The Company will not be held
liable for any losses incurred as a result of such delays.
・Transfer Payments (inward and outward) for Margins
1. Transfer in (Spot account to margin account)•
Transfers in can be made 24 hours a day, 365 days a year.
•
Deposit margins will be increased as soon as transfer is completed.
•
Transfers can be made within the range of the transferable amount in yourbitFlyer account.
2. Transfer out (Margin account to Spot account)•
Transfers out can be made 24 hours a day, 365 days a year.
•
Margin Deposit will be decreased as soon as transfer is completed.
•
Transfers can be made within the range of the transferable amount in thecustomer’s margin account.
As a rule, transfers can be made 24 hours a day, 365 days a year. However, the following times
are excluded:• During system maintenance
4. Response to Large-scale Blockchain Divergences
1. Method of reporting to users
In the event that a crypto asset handled by the Company is scheduled to undergo a largescale update where backward and forward compatibility will be lost (hereafter “hardfork”), the Company shall report the Company’s response to the hard fork, including the
beginning and end of temporary suspensions of services related to the corresponding
crypto asset, to customers on the Company’s website, through email, and othercommunication channels that the Company deems appropriate. Additionally, if the priceof the corresponding crypto asset is referenced to crypto-asset related Over-the-counter

34

2.

3.

4.

5.

6.

7.

derivative transactions, the Company will make a notification through thecommunication channels above accordingly.
Service suspension measures for when a hard fork occurs
In the event of a hard fork, the Company may suspend purchases, sales, deposits,
withdrawals, etc. for a period of time determined by the Company. The Company shallconsider when to make and lift a temporary suspension of services based on acomprehensive assessment of the risks of losing mutual compatibility, retroactive
invalidation of trades, large declines in price, etc. Additionally, withdrawals of fiat
currency and crypto assets will be unavailable during the suspension period andavailable once service resumes. In the event that any customers incur losses due to pricemovement, etc. during the suspension period, the Company shall bear no responsibility
for the corresponding losses incurred.
Handling new crypto assets resulting from a hard fork
The Company shall decide if and how to handle the underlying crypto assets of a hardfork and the new crypto assets generated by the hard fork. As a result, the Company may
not grant the new crypto assets to customers or may not adjust the rights of open
positions in Over-the-counter derivatives of crypto asset transactions as described below.
The Company is not responsible for any losses incurred due to not granting new crypto
assets or not adjusting rights. Regarding the fees required for the granting of new crypto
assets, etc.
Fees for granting new crypto assets, etc.
The Company may collect fees from customers for the system construction costs, etc.,
required for operations actually incurred in connection with the granting of new crypto
assets to customers, adjustment of open interest in Over-the-counter derivatives of crypto
asset transactions, and other measures necessary for customer protection.
Regarding the adjustment of rights for new crypto assets in Over-the-counter derivativesof crypto asset transactions
The Company may collect fees from customers for system construction costs and otherexpenses incurred in operations that are actually incurred in connection with theadjustment of rights to new crypto assets for Over-the-counter derivatives of crypto asset
transactions.
Regarding the method of adjustment of open interest in Over-the-counter derivatives ofcrypto asset transactions upon the creation and granting of new crypto assets
The Company shall adjust the method of adjustment of open interest for Over-thecounter derivatives of crypto asset transactions upon the creation and granting of new
crypto assets on a case-by-case basis and will notify customers in advance. The need forand method of rights adjustment will be determined at the discretion of the Company
based on the Terms of Service, but for example, a method in which the rights adjustment
amount is collected from customers who hold open interest in Over-the-counter
derivatives of crypto asset transactions that reference the price of the crypto asset inwhich the subject event occurred, while the rights adjustment amount is granted tocustomers who hold open interest.
The Company’s response guidelines for planned hard forks and new crypto assets
The Company’s response guidelines for expected blockchain divergence resulting from ahard fork and new crypto assets resulting from a hard fork can be found here
(https://bitflyer.com/en-jp/guidelines-hard-forks).

5. FeesIn the event that a customer continues to hold a position in bitFlyer Crypto CFDs, payment ofleverage points will be required. Additionally, the transfer of funding rates may be necessary.
bitFlyer Crypto CFD Leverage Points
If the expiration of the positions held by the customer is extended by one business day at 6:00 pm(JST), the amount of leverage points covering that one business day until the position's
expiration is extended will be calculated based on the quantity of the position and the mostrecent trading price on bitFlyer Crypto CFD at that time. The payment amount for leverage

35

points will be included in the valuation gains and losses of the target position and deducted fromthe margin at the time of settlement of that position.
Leverage point charges apply when a bitFlyer Crypto CFD position is continuously held.
The value of a position is determined by multiplying the customer's held position quantity by themost recent bitFlyer Crypto CFD trading price as of 6:00 pm (JST)
Position
Buy positions

Leverage points
The total of (the absolute value of open positions x 0.04% per day)(Base unit: JPY) *Sell positions* Leverage points may occur on bitFlyer Crypto CFD.
* The total value of open positions is calculated by multiplying the total volume of open positions thecustomer holds by the last traded price of bitFlyer Crypto CFD as of 6:00PM Japan time

bitFlyer Crypto CFD Funding Rate
For bitFlyer Crypto CFDs, funding rate transfers take place between bitFlyer and the customer.
The "Funding Rate" is defined as the mechanism by which money is transferred based on the amountcalculated from the divergence between the bitFlyer Crypto CFD trading price and the spot trading
price of the crypto asset referenced on bitFlyer Crypto CFD. This transfer is conducted in accordancewith the customer's held position size, at the designated times every eight hours. If the bitFlyer Crypto
CFD trading price exceeds the spot trading price of the crypto asset it references, funds are collectedfrom the long position holders and granted to the short position holders. In the reverse scenario, funds
are collected from the short position holders and granted to the long position holders. (If bitFlyer 's
proprietary trading department holds positions, it will also be subject to either fund collection or
grants.)
The amount of money transferred increases as the difference between the Over-the-counter crypto
asset derivative trading price and the spot trading price widens, up to a predetermined limit, but afixed amount is still exchanged from the holders of long positions to the holders of short positions even
if no difference exists between the two prices.
FactorFunding Rate
Transfer Amount

Explanation
Funding Rate Transfer Ratio × Quantity of Position at Time of
Exchange × Most Recent Spot Trading Price at Time of Calculation
If the value is positive, funding is collected from holders of longpositions and granted to holders of short positions (at the time of theexchange, this is recorded as an unrealized loss in the valuation of longpositions and as an unrealized gain in the valuation of short positions).
If the value is negative, funding is collected from holders of shortpositions and granted to holders of long positions (at the time of theexchange, this is recorded as an unrealized loss in the valuation of shortpositions and as an unrealized gain in the valuation of long positions).

Funding Rate
Transfer Ratio

The funding rate transfer ratio is the simple average of the minute-byminute divergence rate, which is calculated every minute throughout
the calculation period.
* However, the absolute value of the funding rate transfer ratio will not
exceed the upper limit of the funding rate.
1) If the calculation result for the above is positive and its absolute36value is less than or equal to "the sum of the lower limit of the funding
rate fixed interval equivalent and the lower limit of the funding rate,"the funding rate basis rate will be equal to the lower limit of thefunding rate.
2) If the calculation result for the above is negative and its absolutevalue is less than or equal to "the difference of the lower limit of thefunding rate fixed interval equivalent subtracted by the lower limit of
the funding rate," the funding rate basis rate will be equal to the lower
limit of the funding rate.
3) If the calculation result for the above is positive and its absolutevalue exceeds "the sum of the lower limit of the funding rate
Fixed Interval Equivalent and the lower limit of the funding rate," thefunding rate transfer ratio will be the calculation result minus thelower limit of the funding rate fixed interval equivalent.
4) If the calculation result is negative and its absolute value exceeds"the difference of the lower limit of the funding rate fixed interval
equivalent subtracted by the lower limit of the funding rate," thefunding rate basis rate will be the calculation result plus the lower limitof the funding rate fixed interval equivalent.
Minute-by-Minute
Divergence Rate

Bid/ask price (either the Impact Bid Price or Impact Ask Price,whichever is closer to the Most Recent Spot Trading
Price) ÷ Most
Recent Spot Trading Price - 100%
If the Most Recent Spot Trading Price is between the Impact Bid Priceand Impact Ask Price, the Minute-by-Minute Divergence Rate is set tozero.

Upper Limit ofTransfer Ratio

0.375% (subject to change by bitFlyer in consideration of market trends)

Lower Limit of theTransfer Ratio

0.010% (collected from long position holders and distributed to shortposition holders)
Lower limit of the funding rate fixed interval equivalent: 0.050 (interval
for keeping funding rate levels at the lower limit of the funding rate)

Impact Ask Price

The expected volume-weighted average executed price of a transaction
on bitFlyer Crypto CFD, assuming the purchase of exactly 1 BTC-CFD,
based on the order situation on bitFlyer Crypto CFD at the time whenthe minute-by-minute divergence rate is calculated.

Impact Bid Price

The expected volume-weighted average executed price of a transaction
on bitFlyer Crypto CFD, assuming the sale of exactly 1 BTC-CFD,
based on the order situation on bitFlyer Crypto CFD at the time whenthe minute-by-minute divergence rate is calculated.

Most Recent Spot
Trading Price

Price per unit of crypto asset referenced by bitFlyer Crypto CFD,
displayed to users as the most recent trading price on Lightning Spot.

Reference Time

Either 6:00 am (JST), 2:00 pm (JST) or 10:00 pm (JST) on eachbusiness day.

Start TimeThe reference time marking the beginning of the calculation period.

Determination TimeThe reference time occurring eight hours after the start time.

37

Exchange TimeThe reference time occurring eight hours after the determination time.

Calculation Period

The interval from the start time to the determination time

* For example, if the start time is designated as 6:00 am (JST) on a given day, the determination timeat 2:00 pm (JST) on that same day, and the calculation period for the funding rate for the actual
exchange being 6:00 am (JST) to 2:00 pm (JST),the Exchange Time, would be set for 10:00 pm (JST)on that same day.

An illustration regarding bitFlyer Crypto CFD funding rates is shown below.

6. Business Reports and the Most Recent Financial Documents
The documents can be found under “Company Profile” on the Company’s website (only inJapanese) (https://bitflyer.com/en-jp/company).

Explanation of the Characteristics of Crypto Assets●●

Crypto assets can be used for tender of payment to non-designated parties as well as forpurchases and sales with non-designated parties.
With no issuer-set limitations, crypto assets can be exchanged for Japanese yen, otherfiat currencies or other crypto assets, given there are exchange markets in place for trade
among these currencies.

The following crypto assets are positioned as the underlying assets and their prices arereferenced for crypto-asset related Over-the-counter derivative transactions that the Company
conducts with customers.
・Bitcoin38

Bitcoin is a crypto asset that began as a concept described in a paper published on the Internet in2008 by someone assuming the name Satoshi Nakamoto.
Through the use of a distributed ledger known as a blockchain, Bitcoin can store and transfer
values Over-the Internet without the need for an issuing authority or administrator.
This English translation is provided for convenience purposes only. The Japanese version of thisdocument shall be regarded as the official version. In the event of a dispute, the Japanese
language version shall prevail.

[Enacted on April 20, 2020][Amended on May 1, 2020][Amended on November 26, 2020][Amended on January 8, 2021][Amended on March 3, 2021][Amended on April 21, 2021][Amended on May 12, 2021][Amended on August 31, 2021][Amended on October 15, 2021][Amended on February 25, 2022][Amended on June 17, 2022][Amended on October 1, 2022][Amended on April 28, 2023][Amended on June 7, 2023][Amended on July 27, 2023][Amended on December 30, 2023][Amended on March 15, 2024][Amended on March 28, 2024]

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