Responses from Chris for compliance review: Asset Management Questionnaire
The following information reflects the products' current operations. Specific arrangements may change based on market conditions, product scale, and risk management requirements.
I. Product Overview
1、Which Earn & Fund products are currently available on Infini?
Infini currently offers three products:
Infini Earn USD: A variable return product denominated in USD, with T+0 subscriptions and redemptions.
Infini Earn BTC: A variable return product denominated in BTC, with T+0 subscriptions and redemptions.
Infini Alpha Quantitative Arbitrage Fund: A fund managed using fund units and net asset value, or NAV, and available to eligible investors.
2、What are the differences between Earn USD, Earn BTC, and Infini Alpha?
Earn USD and Earn BTC both use a variable return note structure. The main difference is the denomination currency. Earn USD is denominated in USD, while Earn BTC is denominated in BTC. Rewards are calculated daily based on actual investment performance.
Infini Alpha is managed using fund units and NAV. Its NAV changes with the performance of the underlying strategies. Subscriptions, redemptions, and performance fees are processed in accordance with the fund rules.
The three products differ in denomination currency, minimum subscription amount, subscription and redemption arrangements, return calculations, and risk allocation. Please refer to the relevant product page for details.
3、Who is responsible for product operations and strategy execution?
Infini is responsible for overall product operations, including subscriptions, redemptions, and liquidity management. The partner quantitative trading team is responsible for operating and executing the strategies.
Each party performs its respective responsibilities based on its area of expertise. The parties coordinate to support the products' daily operations.
Earn USD and Earn BTC use a variable return note structure. The notes are issued by Iron Maple Limited, a company incorporated in the British Virgin Islands.
4、How do the return and risk allocation mechanisms differ across the products?
Infini Alpha uses NAV based management. The NAV changes with strategy performance, and users are exposed to the resulting return fluctuations and potential drawdowns.
The risk and return structure of Infini Earn differs from that of Infini Alpha. Rewards are calculated based on the actual performance of the underlying strategies and do not represent a fixed or guaranteed return.
The treatment of different types of losses and risk events is governed by the applicable product terms and legal documents. Trading venue failures, custody incidents, cybersecurity events, market liquidity conditions, and other systemic events may affect user assets. Users should understand the relevant risks before using any product.
User assets may still be affected by systemic events outside the scope of ordinary strategy management, including the insolvency of an underlying trading venue, theft of assets held in custody, or a material cybersecurity incident.
Infini seeks to mitigate these risks through measures such as diversification across multiple trading venues, limits on exposure to individual strategies and assets, liquidity reserves, and ongoing risk monitoring.
II. Infini Earn
1、What is the difference between Earn USD and Earn BTC?
Earn USD is a variable return stablecoin product denominated in USD. The minimum subscription amount is 1 USDT.
Earn BTC is a variable return product denominated in BTC. The minimum subscription amount is 0.00001 BTC.
Both products support T+0 subscriptions and redemptions, and Rewards are calculated daily.
Because Earn BTC is denominated in BTC, the USD value of the user's holdings will also be affected by changes in the market price of BTC.
2、How are the reference APY and Rewards for Earn calculated?
Earn Rewards are calculated daily based on the actual investment performance of the underlying strategies. The APY displayed externally is a reference annualized yield after fees.
Based on the live trading records currently available, Earn recorded a reference APY above 3% during the relevant historical observation period. Infini plans to provide further disclosures covering monthly reference APY, return performance, and relevant live trading data.
The reference APY reflects historical or current performance over a specified period. It is not a fixed or guaranteed return and does not indicate future performance.
3、How is T+0 defined for Earn, and how are large redemptions handled?
Users may submit subscription and redemption requests at any time.
Infini maintains liquidity reserves to support ordinary subscription and redemption requests. Actual settlement times depend on the processing outcome and prevailing circumstances.
If a single redemption exceeds 10% of the product's total assets under management, part of the strategy portfolio may need to be unwound.
Under normal market conditions, the estimated processing time is approximately 1 to 3 days when seeking to limit additional trading costs or market impact.
4、What fees does Earn charge, and does Earn use any DeFi protocols?
Earn currently does not charge subscription fees, redemption fees, or management fees.
If a subscription or redemption requires conversion between different assets, the execution price will reference market prices on major trading venues.
A spread is maintained between the purchase and sale prices to reduce potential arbitrage arising from repeated subscriptions and redemptions within a short period. As a result, subscribing and redeeming the same amount within a short period may result in a price difference of approximately 2 to 3 basis points, or bps.
This difference results from the asset conversion process and is not an additional product fee.
Earn is not currently integrated with any DeFi protocol.
III. Infini Alpha
1、What is Infini Alpha, and which strategies does it use?
Infini Alpha is a quantitative arbitrage fund managed using fund units and NAV.
The fund primarily allocates capital to market neutral arbitrage strategies that seek to capture pricing differences between assets, contracts, and trading venues.
Fund returns and drawdowns are reflected in the NAV. Users participate in the fund's actual performance based on the number of fund units they hold.
2、How are Alpha's NAV, reference APY, and user returns calculated?
NAV represents the net asset value attributable to each fund unit.
When a user subscribes, the number of fund units is calculated as follows:
Fund units = Subscription amount ÷ NAV at subscription confirmation
During the holding period, the value of the user's position is calculated as follows:
Position value = Fund units held × Latest NAV
When a user redeems, the investment gain or loss is calculated based on the difference between the redemption value and the original subscription principal.
The reference APY displayed for Alpha is an annualized return calculated from the fund's actual NAV performance before performance fees.
If the fund generates a profit, 40% of the profit is charged as a performance fee, and the remaining 60% is allocated to the user.
For example, if an investment generates a gross profit of 10,000 USDT, 4,000 USDT is charged as the performance fee, and the user receives a net profit of 6,000 USDT.
3、What are Alpha's minimum subscription amount and subscription and redemption rules?
The minimum subscription amount for Alpha is 100,000 USDT.
Before submitting a subscription, the user must complete a risk assessment and the applicable eligible investor verification or questionnaire. The user must also meet the relevant investor eligibility requirements.
Users may submit subscription requests at any time. Subscription funds are converted into fund units based on the NAV at the time the subscription is confirmed.
The fund opens for redemptions once each month. Redemptions are processed on the first day of each month.
Users must submit redemption requests at least five days in advance. Interim redemptions are not currently supported at other times.
4、What fees does Alpha charge?
Alpha uses a performance fee model.
If the fund generates a profit, 40% of the profit is charged as a performance fee. No performance fee is charged if the fund does not generate a profit.
The reference APY displayed for Alpha is calculated before performance fees.
The user's net profit after the performance fee is calculated as follows:
Net profit after performance fee = Investment profit × 60%
For example, if an investment generates a profit of 10,000 USDT, the performance fee is 4,000 USDT, and the user receives a final net profit of 6,000 USDT.
IV. Strategies, Risk Management, and Transparency
1、Which strategies are currently used by Infini's asset management products?
The underlying strategies currently used by Infini's asset management products mainly include:
Spot and futures arbitrage involving smaller and larger capitalization digital assets on the same trading venue.
Derivatives arbitrage across different trading venues.
Earn and Alpha allocate capital across combinations of these strategies based on their respective product objectives, liquidity arrangements, and risk management requirements.
The allocation to each strategy may change based on price differences, funding rates, market liquidity, and market capacity.
2、Which trading venues are currently used by the strategies?
The strategies currently use trading venues including Binance, OKX, Bybit, Bitget, Coinbase, and Kraken.
Capital allocations and return contributions across strategies are not fixed.
The strategy team adjusts trading venue and strategy allocations based on price differences, funding rates, liquidity, market capacity, and risk management requirements.
3、How are leverage and concentration risks across trading venues, strategies, and assets managed?
The underlying strategies may use multiple major trading venues. Trading venue and strategy allocations are adjusted based on market liquidity, price differences, funding rates, market capacity, and risk management requirements.
Some strategies may use limited leverage.
Risk limits are applied across trading venues, strategies, and assets to manage concentration. Specific configurations may change with market conditions and risk management requirements.
4、How liquid are the strategies, and how long would it take to adjust larger positions?
The strategy capital is currently allocated to assets and trading positions with available market liquidity. Positions may be adjusted based on market conditions and strategy requirements.
Under normal market conditions, and while seeking to avoid costs beyond ordinary trading fees, the current estimates are:
Approximately three days to close around 50% of the positions.
Approximately one week to close around 90% of the positions.
If exposure needs to be reduced quickly under exceptional circumstances, the strategy team may prioritize an emergency unwind.
Based on the current portfolio size and market liquidity, the full portfolio is estimated to be capable of being unwound in approximately one hour. The corresponding estimated price impact or trading loss would be approximately 1%.
These time and cost estimates are based on the current portfolio size and market liquidity. Actual outcomes may differ under changing market conditions.
5、What third party audits, asset verification, and historical performance data are currently available?
Infini and the partner quantitative trading team periodically conduct third party asset audits or verification.
Infini is also working on integrating a Proof of Reserves mechanism to provide more timely and transparent information about relevant assets.
Infini plans to consolidate and disclose monthly reference APY, return performance, historical drawdowns, and other key data.
Based on the existing live trading records of the underlying strategies, the historical maximum drawdown for Infini Earn was approximately 2%. This occurred on October 11, 2025, and was primarily caused by automatic deleveraging, or ADL, triggered by abnormal conditions on certain trading venues.
Redemptions remained available during the event.
This figure relates to the historical records of the underlying strategies. Drawdowns and other performance data for Infini Alpha since its launch should be assessed using the NAV data displayed on the relevant product page.
