SAEP-10: Update Offchain Collateralized Lending Artifact Section - February 16, 2026

Spark's Operational Facilitator has placed a proposal into the voting system on behalf of nested contributor Phoenix Labs.

Review

The Spark community can hereby express support or opposition to the following changes, as described by the author of the proposal:

Summary

This proposal is submitted by Phoenix Labs in its role as a nested contributor, as defined in section A.6.1.1.1.2.2.2.2.1.2.1.1.1 of the Spark Artifact. The proposal recommends that Spark governance update certain parameters to increase the venue exposure limit and clarify the scope of the approved offchain collateralized lending activities.

Background

In December 2025, Spark governance passed SAEP-08 which authorized offchain collateralized lending activities, initially using Anchorage as custodian and collateral management agent. This has resulted in approximately 150 million USDC in aggregate outstanding loans, with indications of additional demand. Adjusting the venue exposure limit will allow Spark governance to meet that demand while maintaining risk within bounds approved by governance. Additionally, this proposal recommends amending the Artifact to increase the scope of permitted whitelisted addresses in order to facilitate offchain collateralized lending arrangements requiring loan disbursement directly to borrowers, while maintaining appropriate safeguards against operational risk.

Proposal Details

We propose that Spark governance make the following changes:

• Increase venue exposure limit for Anchorage from $200 million to $1 billion
• Increase collateral agent limit for Anchorage Innovations on Anchorage from $200 million to $1 billion
• Adjust account management sections to increase the scope of permitted whitelisted addresses in order to facilitate offchain collateralized lending arrangements requiring loan disbursement directly to a borrower in a manner that maintains appropriate safeguards against operational risk.

Justification

The current aggregate loan volume issued through Anchorage totals $150 million across 3 active loans. There is evident demand for additional loan issuance that would take total aggregate loan amounts over the current $200 million thresholds for approved venue exposure. Anchorage and Anchorage Innovations are industry leading providers with a strong track record of safety and soundness. We submit that increasing the venue exposure limits to the proposed levels of up to $1 billion is consistent with Spark governance’s existing risk framework, because such framework already contemplates the use of qualified custodians and approved collateral agents for offchain collateralized lending activities. The proposed increase would provide additional capacity which we estimate would be sufficient to meet currently-observed demand.

We also propose revisions to the account management sections concerning address whitelisting and transfers, to facilitate offchain collateralized lending arrangements requiring loan disbursement directly to a borrower in a manner that maintains appropriate safeguards against operational risk. This includes permitting payment of custody and collateral management fees directly from Spark Assets Foundation accounts held at custodians or venues, and permitting transfer of loan proceeds to borrowers without requiring a collateral manager to facilitate the transaction. This will allow the protocol to better support standard offchain collateralized lending arrangements and will improve operational efficiency without materially increasing operational risks to the Spark protocol.

The proposed Spark Artifact changes can be found in the following pull request: https://github.com/sky-ecosystem/next-gen-atlas/pull/185

Outcomes

• If "For" receives the most votes, the proposal will be approved. The associated pull request will be merged into Spark's artifact. When required, the listed changes will proceed to implementation by the relevant actors.
• If "Against" receives the most votes, the proposal will be rejected. No changes will be implemented.