Risk management
Risk Mandate and Credit Policy sit at the foundation of Pipeline’s approach to risk management. Both are published, board-approved documents that define what Pipeline finances, on what terms, and within what limits.
Risk Mandate
The Risk Mandate is Pipeline’s foundational risk document. It sets the boundaries within which the Credit Policy is written and the Risk committee operates.
The Mandate defines:
- Risk appetite — target loss rate, protocol-wide loss tolerance, capital-at-risk ceiling
- Authority and discretion of the Risk committee, and what requires Trustee escalation
- Recusal and conflict-of-interest rules
- Review cadence and amendment process
The Trust Company approves the Mandate. The Credit Policy and every committee decision derive from it.
Credit policy
The Credit Policy operationalises the Risk Mandate. It is the underwriting and monitoring rulebook that governs every loan. It defines:
- Eligible commodities, corridors, and counterparty profiles
- Borrower tier framework and pricing envelopes
- LTV ladder with stacking modifiers for corridor, commodity, and counterparty tier
- Duration bounds and structural requirements
- Hedging and benchmark price linkage requirements
- Concentration limits — hard ceilings on commodity, corridor, single-borrower, single-offtaker, and single-Originator exposure, scaled to pool size
- Affiliated-party lending rules and structural protections
- Default triggers and workout protocols
Every loan is underwritten against the Credit Policy by the Originator and re-tested by the Risk committee before origination. A summary is published in Credit policy overview.
Risk committee
The standing body that operates the Credit Policy and acts under the Risk Mandate. Initially includes five legitimate members, including the Trustee. The committee:
- Approves every loan before origination
- Reviews concentration weekly
- Monitors live loans and escalates material events
- Declares default when triggers fire (via on-chain
setDefault) - Proposes protocol-wide shutdown if losses threaten lender principal
- Adjusts the recovery rate upward as recoveries land during shutdown
Decisions reach the protocol via the RISK_COUNCIL MPC (3-of-5, 3-day timelock). Recusal rules apply per the Risk Mandate. See Risk committee.
Continuous monitoring
Every live loan is monitored daily.
Cargo and vessel. Position tracked via CTRM. Independent inspectors verify cargo at every stage of the trade — load port, transit checkpoints, bonded storage handover, and discharge. CMA stock reports flow daily once cargo lands in bonded storage. Material events escalate to the committee within 24 hours.
LTV and price. Cargo value marked daily against independent price assessments. Threshold breach triggers a margin-call event; failure to cure within the window is a default trigger.
Counterparty. Borrower, offtaker, CMA, and inspector under continuous sanctions and adverse-media screening. Hedge positions marked daily.
Default declaration
A loan is declared in default when one of the Credit Policy triggers fires:
- Missed scheduled payment beyond the cure window
- Material covenant breach uncured within the contractual window
- Collateral seizure, fraud discovery, or CMA breach
- Force majeure beyond the covered insurance window
- Sanctions hit on a counterparty
Default is declared by the Risk committee via setDefault on LoanRegistry. From there, Default management governs the workout — collateral seizure and resale through pre-onboarded liquidators, equity-tranche absorption, and only as a last resort, residual flow to senior lenders.