Zerion Inc (“Zerion”) provides a self-custodial wallet interface (the “Interface”) that enables users to interact with decentralized protocols and distributed ledger trading systems using their own self-custodial wallets. Zerion is not registered with or regulated by the U.S. Securities and Exchange Commission (“SEC”) as a broker-dealer in connection with the creation, offering, or operation of the Interface.
When a user initiates a crypto asset transaction through the Interface, certain transaction parameters are pre-populated with default values. Users may customize all default parameters before signing and submitting a transaction. This Policy describes the default transaction parameters used by the Interface, how they are determined, the risks associated with each, and the controls Zerion maintains to address conflicts of interest.
This Policy is maintained in accordance with the SEC Division of Trading and Markets Staff Statement dated April 13, 2026 (File No. 4-894).
The following table lists the default transaction parameters applied by the Interface. All defaults are customizable by the user on a per-transaction or persistent basis.
The default slippage tolerance is set to balance the risk of transaction failure (if slippage is too low) against the risk of receiving a materially worse price than expected (if slippage is too high). The default value is determined based on observed market conditions across the chains and asset types supported by the Interface, and is intended to allow the majority of typical transactions to execute successfully under normal market conditions.
The default gas fee limit is based on real-time gas price data retrieved from supported blockchain networks. The Interface queries current gas prices and pre-populates a gas fee estimate intended to achieve timely transaction confirmation. Gas price data is sourced from on-chain data and is updated in real time.
The default transaction deadline is set to provide a reasonable window for transaction confirmation under normal network conditions, while limiting the user’s exposure to price changes during extended confirmation delays.
When multiple execution routes are available for a transaction, the Interface sorts routes by estimated output amount (i.e., the amount the user is expected to receive) by default. The Interface retrieves quotes from multiple connected venues simultaneously and presents them to the user. The sorting is based solely on the quoted output amount and does not incorporate subjective assessments. Users may re-sort routes by other objective factors such as estimated gas cost or transfer speed.
Price execution risk: The default slippage tolerance permits the transaction to execute at a price that differs from the quoted price by up to the specified percentage. In volatile market conditions, the actual execution price may approach the maximum slippage limit, resulting in the user receiving less than the estimated output amount.
Transaction failure risk: If the default slippage tolerance is insufficient to accommodate market price movement between the time a transaction is signed and the time it is executed, the transaction may fail. The user may still incur gas fees for a failed transaction.
MEV risk: A higher slippage tolerance may increase the user’s exposure to MEV strategies (such as front-running or sandwich attacks) by validators or other participants with discretion over transaction ordering within a block.
Overpayment risk: Gas prices fluctuate based on network demand. The default estimate may result in the user paying more in gas fees than the minimum required for transaction confirmation.
Confirmation delay risk: If network conditions change between the time the gas estimate is retrieved and the time the transaction is submitted, the pre-populated gas fee may be insufficient, potentially resulting in delayed confirmation or transaction failure.
Price exposure risk: A longer transaction deadline increases the window during which market prices may move, potentially resulting in execution at a price that differs materially from the price at the time the transaction was initiated.
Expiration risk: A shorter deadline increases the risk that the transaction expires before confirmation, requiring the user to resubmit the transaction and potentially incur additional gas fees.
Quote accuracy risk: The estimated output amount used for default sorting is a quote, not a guaranteed execution price. Actual execution may differ due to price movement, slippage, and gas costs between the time the quote is generated and the time the transaction is confirmed on-chain.
Venue-specific risk: Different connected venues have different liquidity profiles, security track records, and operational characteristics. Sorting by estimated output does not account for differences in venue risk. Users should refer to Zerion’s Venue Evaluation, Onboarding, and Audit Policy for information about how connected venues are evaluated.
Zerion has identified the following potential conflicts of interest associated with default transaction parameters:
Zerion charges a fixed percentage fee on swap transactions. Because this fee is calculated as a percentage of the transaction value, Zerion’s fee revenue is not affected by the slippage tolerance selected by the user. The default slippage tolerance does not increase or decrease Zerion’s fee revenue.
If any connected venue is affiliated with Zerion, a conflict of interest could arise if the default sorting were designed to favor that venue. Zerion’s default sort order (by estimated output amount) is based on an objective, verifiable metric and does not favor any particular venue. Affiliated venues, if any, are identified in Zerion’s Venue Evaluation, Onboarding, and Audit Policy and are connected on the same terms as unaffiliated venues.
Zerion does not profit from gas fees. Gas fees are paid by the user directly to the blockchain network. Zerion’s gas price estimates are derived from on-chain data and are not adjusted to benefit Zerion.
Zerion’s compensation is limited to a fixed fee charged to the user. Zerion does not receive payment for order flow, referral fees, or other transaction-linked compensation from connected venues. This eliminates the conflict of interest that would arise if Zerion were financially incentivized to route transactions to specific venues.
Zerion maintains the following controls to address the risks and conflicts of interest described above:
All default transaction parameters are customizable by the user. The Interface provides clear controls for adjusting each parameter, along with educational material explaining the parameter’s function and the implications of changing it. No transaction is submitted without the user’s explicit approval.
Default parameter values are determined based on objective, disclosed factors. Zerion does not set defaults in a manner designed to increase its fee revenue or to favor affiliated venues.
Zerion periodically reassesses default parameter values to confirm they remain appropriate in light of current market conditions, network characteristics, and user experience data. Changes to default values are reflected in updates to this Policy.
When evaluating or changing any default parameter, Zerion assesses whether the proposed value creates or exacerbates a conflict of interest. If a conflict is identified, Zerion implements measures to mitigate it before adopting the change. Zerion’s fee structure — a fixed charge to the user that does not vary by route, venue, or counterparty — is designed to minimize conflicts of interest with respect to default parameter selection.
The default values, determination methodology, associated risks, and conflicts of interest are disclosed in this Policy. Users are encouraged to review this Policy and to customize transaction parameters to reflect their own risk tolerance and preferences.
Contact
For questions about this Policy, please contact [email protected].
