Summary
LlamaRisk acknowledges and is encouraged by the recent steps the FRAX team has taken to enhance the transparency of frxUSD and sfrxUSD. However, despite this progress, we cannot recommend onboarding these assets at this time. Based on our analysis, we conclude that the following steps are to be taken before onboarding can be reconsidered:
- frxUSD / sfrxUSD and components introduced in FIP‑419 and FIP430 are audited by an established third-party auditor
- An external bug bounty program is created with an established third-party provider
- Dashboard covering historical sfrxUSD’s yield allocations is deployed, specifying capital deployment frameworks across carry‑trade partners (Ethena, Superstate), DeFi AMOs (Aave, Curve, Convex, Compound), and RWA custodians (BlackRock, FinresPBC) with monthly custodian attestations
- The separation of backing asset balances at the wallet and contract levels is finalized
- Documentation detailing how vault losses would be socialized among frxUSD and sfrxUSD holders is made
- Enforced 48‑hour minimum timelocks with ≥2/3 multisig for critical upgrades, plus a timelock on yield reallocation functions is implemented
Furthermore, a significant concern is Frax’s highly centralized governance model. A core multisig controls all administrative functions, on‑chain governance is largely unused, and there are no timelocks to guard against abrupt upgrades. This concentration of control, without enforced delays, introduces a meaningful risk of arbitrary changes that could jeopardize Aave users’ ability to withdraw funds.
On a more positive note, frxUSD does possess reasonable DEX liquidity, albeit fragmented across LP venues on Sonic. The overall architecture is also conceptually straightforward, though the yield management process currently lacks transparency.
We would welcome a second application should Frax address the above issues. Note that we have been in touch with the team since just before FIP430 was published to raise above listed points.
"Collateral Risk Assessment"
1. Asset Fundamental Characteristics
1.1 Asset
frxUSD is an ERC‑20 stablecoin launched by Frax Finance (a DAO building stablecoin assets since 2020) on Sonic in January 2025 via LayerZero bridging (tx). Its staked counterpart, sfrxUSD, is an ERC‑4626 vault also deployed on Sonic that same month (tx), using LayerZero for cross‑chain communication.
Both tokens were introduced in the December 2024 governance proposal FIP‑419, which passed with 43M FXS for and 183 FXS against. frxUSD is backed 1:1 by off‑chain treasury reserves in four governance‑approved custodial products (BlackRock’s BUIDL on Securitize, Bridge’s USDB and Superstate’s USCC and USTB). sfrxUSD, non‑rebasing token, accrues yield by staking frxUSD at an ever‑increasing share price and can be redeemed on‑chain for frxUSD on Mainnet. It is notable that Sonic contract currently lacks a redemption function.
Users that pass whitelisting with custodians may mint or redeem frxUSD with said custodians for no fee (Superstate) or a 0.15% fee with Securitize. This process is not instant and involves KYCing with the custodian to access underlying value. Frax itself does not charge fees when moving from frxUSD or sfrxUSD. Should off-chain book-entry holdings be used, the Frax team reports they will undergo quarterly audits and public attestations similarly to other leading RWA projects.
Yield is said to come from a blend of on‑chain sources [or AMOs] (Aave, Curve, Convex, Compound) and RWA or carry‑trade partners (Ethena, Superstate, Securitize, FinresPBC), managed by a purported Benchmark Yield Strategy that automatically shifts 100% of vault capital to whichever venue offers the highest risk‑adjusted return—be it carry‑trade, DeFi AMO, or short‑dated U.S. T‑bills. This strategy is available on Frax Facts, though only current allocations (and not historical ones) are available. The arbitrary nature of these allocations introduces significant counterparty, smart contract, duration and economic risk.
This dual‑token design echoes the legacy FRAX/sFRAX and Sky’s sUSDS/USDS pairs, which found product‑market fit under different governance and transparency regimes. However, the lack of verifiable onchain allocation frameworks or detailed loss‑socialization rules introduces material opacity and counterparty risk.
FIP-430, which was recently passed, identifies several changes to make frxUSD compliant with an upcoming Stablecoin Charter the United States is currently discussing. In order to comply with this legislation currently under review (the STABLE Act and the GENIUS Act), Frax is in progress of implementing the following changes:
- A separation of frxUSD and legacy FRAX balance sheets
- Transparency on how sfrxUSD generates yield, as well as the creation of frameworks to modify these yield sources
- The end of FRAX to frxUSD migration capabilities - all migration shall instead occur via Curve pool (which is incentivized for the time being)
1.2 Architecture
Source: frxUSD / sfrxUSD mint and redeem flow, LlamaRisk.
The frxUSD / sfrxUSD architecture is conceptually similar to that of other :
- A user deposits fiat with a custodian and receives frxUSD.
- frxUSD can circulate in DeFi or be staked to mint non‑rebasing sfrxUSD at the current conversion rate.
- To unstake, the user redeems sfrxUSD and receives frxUSD (including any accrued yield).
- frxUSD is redeemable for any custodian asset on demand using one of the designated
frxUSDCustodiancontracts. It is notable that a user needs to be whitelisted for these custodian assets in order to successfully redeem frxUSD.
In practice, staking is free and instantaneous, and each redeemed unit of sfrxUSD returns more frxUSD than originally staked. However, the system’s core yield‑deployment mechanism is opaque:
- frxUSD held in the sfrxUSD vault is cross-chain, with no clear framework detailing allocation strategies or history, apart from general outline of Benchmark Yield Strategy presented in the documentation.
- There is no documented process for handling drawdowns or socializing losses if a strategy underperforms or a liquidity shortfall occurs.
This lack of transparency introduces “unknown unknowns” risks and constitutes an elevated level of operational risk.
1.3 Tokenomics
frxUSD is redeemed for sfrxUSD at an ever-increasing rate. It may be redeemed programmatically for no fee at any time. The FRAX (FKA FXS) token governs this protocol. This token has a capped supply of 100 million FXS holders who can lock tokens to receive governance voting rights. veFRAX holders are entitled to protocol revenue. This system is conventional.
1.3.1 Token Holder Concentration
Source: Top 100 frxUSD holders on Sonic, SonicScan, May 26, 2025.
The top 5 holders of frxUSD on Sonic are:
- Silo Finance: bfrxUSD-37 Token: 80% of the supply.
- CrossCurve frxUSD Liquidity Pool: 7.4% of the supply.
- SwapX frxUSD/sfrxUSD Liquidity Pool: 7.4% of the supply.
- SwapX frxUSD/scUSD Liquidity Pool: 3.2% of the supply.
- Equalizer frxUSD/FXS: 0.4% of the supply
If we inspect the Silo Vault, 85% of the vault is controlled by one EOA. This results in high token holder concentration overall.
Source: Top 100 sfrxUSD holders, SonicScan, May 26, 2025.
The top 5 holders of sfrxUSD on Sonic are:
- Silo bsfrxUSD: 60% of the supply.
- dTrinityLend: 15.8% of the supply.
- SwapX frxUSD/sfrxUSD Liquidity Pool: 7% of the supply.
- dTrinity deployer: 5% of the supply.
- EOA 2.5% of the supply.
Both frxUSD and sfrxUSD supply are concentrated. This presents risk as these percentages may fluctuate rapidly, destabilizing liquidity and preventing profitable liquidation.
2. Market Risk
2.1 Liquidity
Source: frxUSD Liquidity on Sonic, ODOS, May 27, 2025.
There is ±10% slippage for selling 3.75M frxUSD on Sonic.
Source: sfrxUSD Liquidity on Sonic, ODOS, May 27, 2025.
There is ±10% slippage for selling 550K sfrxUSD on Sonic.
Given that sfrxUSD may be redeemed for underlying frxUSD instantly and free on mainnet, this limited swap depth is not of massive concern as liquidators can access underlying value.
2.1.1 Liquidity Venue Concentration
Source: frxUSD Liquidity Pools on Sonic by Trading Volume, DexScreener, May 25, 2025.
The total frxUSD liquidity across DEXs on the Sonic network is approximately $800K, with most frxUSD held in the SwapX frxUSD/sfrxUSD Liquidity Pool. Most of the liquidity is in SwapX liquidity pools. The majority of the volume is held in one pool, the frxUSD/scUSD SwapX pool.
Source: sfrxUSD Liquidity Pools on Sonic by Trading Volume, DexScreener, May 27, 2025.
The total sfrxUSD liquidity across DEXs on the Sonic network is approximately $710K, with most sfrxUSD held in the SwapX frxUSD/sfrxUSD Liquidity Pool. All meaningful liquidity is in SwapX liquidity pools.
2.1.2 DEX LP Concentration
-
SwapX frxUSD/scUSD Liquidity Pool:
- 60% of the liquidity is held by Beefy
- 37% of the liquidity is held by Stability
-
SwapX frxUSD/sfrxUSD Liquidity Pool:
- 60% of the liquidity is held by Stability.
- 20% is held by EOA 0xae02
- 6% is held by EOA 0xf4bb
This level of general concentration (a few large accounts controlling more than 80% of the supply) presents risk as this liquidity could be pulled, jeopardizing profitable liquidation. This is of elevated importance considering the few number of pools dominating volume.
2.2 Volatility
Source: Historical frxUSD Price Chart, CoinGecko, May 27, 2025
frxUSD has held a relatively tight peg throughout the past 3 months. This peg is not perfect as we have seen up to 80 bps (0.8%) secondary market discount on the stablecoin early into the deployment of it.
Source: Historical sfrxUSD Price Chart, CoinGecko, May 27, 2025.
sfrxUSD has kept an ever-increasing peg with underlying frxUSD. This is as expected for a yieldcoin. While small price deviations are noted earlier in the coins’ lifecycle, these have become less prevalent in recent months.
Source: sfrxUSD yield, StableScarab via Dune, 28 May 2025.
sfrxUSD yield has held either 5% or high, with it currently paying 8%. This is determined by calling the exchange rate function on each yieldcoin. This is also how the asset is priced using the pricePerShare function. This yield is consistent with the current treasury bond yields, adjusted for the proportion of frxUSD staked into sfrxUSD.
2.3 Exchanges
frxUSD and sfrxUSD are exclusively traded on DEXs and are not currently listed on any centralized exchange.
2.4 Growth
Source: frxUSD TVL across all chains, CoinGecko, May 27, 2025.
frxUSD total supply is on a downtrend from an all-time high of just under $100M. It currently sits at $61M. This is substantially lower than Legacy FRAX’s market capitalization, which has shrunk from a peak of $2.1B to $300M currently.
Source: sfrxUSD TVL across all chains, CoinGecko, May 27, 2025.
sfrxUSD supply has been steadily growing since its launch. Currently, the circulating supply is worth approximately $31M.
3. Technological Risk
3.1 Smart Contract Risk
frxUSD is not explicitly audited. Significant differences between this contract and FRAX are clear. sfrxUSD is not explicitly audited either. Fewer differences are used, but large additions are made.
While these are ERC20 tokens, the architecture behind them is complex, and this, too, is unaudited. This presents a risk that external smart contract review helps to mitigate. Frax has a long history of auditing its contracts, therefore this lack of audits covering new assets and contracts needs to be addressed by the Frax team to ensure sufficient security standards.
3.2 Bug Bounty Program
Frax Finance has an internal Bug Bounty Program for exploits where user funds or protocol-controlled funds/collateral are at risk. Participants can reach out anonymously to disclose vulnerabilities. Any contract deployed by FRAX-Deployer is in scope, including frxUSD and sfrxUSD. The bounty is calculated as the lower value of 10% of the total possible exploit or $10m worth paid in FRAX+FXS (evenly split), with a “no questions asked” policy.
The program only covers smart contract code (not front-end or server-side code) and applies to any chain managing Frax Protocol or user-deposited value. Slow arbitrage opportunities receive a base compensation of 50,000 FRAX.
We recommend the use of a third-party provider such as ImmuneFi or Cantina as this provides guarantees to whitehats their findings will be treated in the fairest possible manner. Involving a third party increases the likelihood of responsible disclosure and successful user deposits protection.
3.3 Price Feed Risk
sfrxUSD/USD Chainlink Market Price Feed on Sonic is deployed at 0xCC8DA199b159f25E7782494Df9140d2ce0Fe048B. This price feed uses Chainlink’s standard EACAggregatorProxy implementation, with a deviation threshold of 0.5% and a heartbeat of 24 hours. There is currently no market price oracle deployed for frxUSD by Chainlink.
For the sfrxUSD deployment on Aave, the asset would need to be priced via sfrxUSD/frxUSD internal exchange rate, frxUSD/USD market price, covered with CAPO to prevent against donation attacks.
3.4 Dependency Risk
frxUSD’s solvency hinges on institutional partners—most notably BlackRock’s BUIDL fund and Superstate’s tokenized T‑bill products (USCC, USTB) managed by Securitize. Because attestations for these off‑chain reserves are not publicly available, users must trust that custodians safely hold and manage the underlying assets. The Frax team stresses that no off-chain book-entry holdings are currently used and that, should they ever be, public audits and regular attestations will be available.
sfrxUSD allegedly relies heavily on Algorithmic Market Operations (AMOs) that deploy assets into various lending markets (FraxLend, Aave, Curve, Convex, Compound, etc.). Any failure or exploit in one of these integrated platforms could weaken frxUSD’s backing, yet the precise allocation across AMOs is neither documented nor auditable. Similarly, frxUSD’s presence on new networks like Sonic depends on Frax’s bridging infrastructure (LayerZero OFT or Frax Ferry). A bridge malfunction or security breach could distort supply or block redemptions on those chains.
At the heart of sfrxUSD’s yield generation lies the so‑called Benchmark Yield Strategy (BYS), which claims to shift 100 % of vault assets to whichever venue—carry‑trades, DeFi AMOs, or RWA partners—offers the highest risk‑adjusted return. No on‑chain router enforcing these rebalances, no historical allocation dashboard, and no independent attestation to confirm that capital ever rotates as advertised. Without any transparent mechanism or third‑party audit, users cannot verify actual yields, slippage costs, timing or failure modes of rebalances, or how losses would be socialized among vault participants.
These opaque reserve, DeFi, bridging, and yield‑strategy dependencies introduce a material “unknown unknowns” risk that significantly elevates the protocol’s overall dependency risk.
4. Counterparty Risk
4.1 Governance and Regulatory Risk
Governance and Key Dependencies
The Frax stablecoin system depends on properly functioning its governance processes and multisig controllers. Historically, a core team 3/6 Safe multisig, the address 0x87c7A1ef67c67cd57CBF101522a0c3B19D2C3aAc identified as the owner of the frxUSD contract, have had admin control over Frax contracts and assets. This multisig executes parameter changes, upgrades, and allocates reserves. The security of frxUSD and sfrxUSD thus hinges on these signers acting honestly and remaining uncompromised. An abrupt loss of a multisig quorum or a malicious takeover could threaten the stablecoin (e.g., via unauthorized minting or turning off redemption mechanisms).
Frax is introducing a new on-chain governance module (“frxGov”) to mitigate this, but the transition to full decentralization is ongoing. Recent proposals do not receive votes, with the most recent one being voted on was in April of last year .
In the interim, Frax USD’s operation effectively depends on the core team’s multisig and timelock contracts to function correctly. Lastly, Frax’s fiat on/off ramp partners introduce a dependency: frxUSD can be redeemed 1:1 for USD via licensed partners like Kado, so the availability of those partners (and their regulatory compliance) affects users’ ability to move between frxUSD and real dollars.
Legal Evaluation
Frax governance has appointed two custodians - Securitize Markets, LLC with BUIDL and Superstate Inc. with USCC and USTB. Since BUIDL has undergone a thorough evaluation, the present analysis focuses on the legal framework underpinning Superstate Inc.
USTB
USTB operates as a standalone series within the Superstate Asset Trust, a Delaware Statutory Trust (DST) formed under the Delaware Statutory Trust Act (“DSTA”). USTB’s assets and investor capital are legally insulated from Superstate Inc.'s corporate obligations and any other series in the trust through this separate structure.
Under Section 3(c)(7) of the Investment Company Act, USTB qualifies as a private fund, thereby exempting it from various registration obligations that typically govern mutual funds or other publicly offered investment vehicles. This categorization restricts investor participation to “qualified” or accredited purchasers by its Private Placement Memorandum. As a result, USTB must rigorously enforce eligibility requirements, including AML, KYC, and sanctions verifications.
The fund’s investment strategy mandates that at least 95% of its portfolio be allocated to short-duration U.S. Treasury Bills. While as much as 5% of holdings may remain in cash to provide liquidity, the highly liquid makeup of the overall portfolio means that the actual cash position generally remains minimal. Furthermore, the fund maintains an average portfolio duration of one year or less.
Participation in USTB is restricted to individuals and entities meeting the Qualified Purchaser criteria outlined in the Private Placement Memorandum, who must also complete KYC procedures. By the Superstate governance proposal, Finres has already been deemed an eligible investor. As a result, FinresPBC is included on the whitelist (or allowlist) of investors who have satisfied the suitability standards, AML/KYC verification, and address registration requirements.
Superstate Inc. has waived fees until USTB’s assets under management surpass $200M. After that threshold is reached, a management fee and various operational charges will apply, all of which are outlined in the fund’s offering materials. By entering into an Expense Limitation Agreement, Superstate Inc. has committed to assuming or waiving certain expenses, thereby aligning its interests more closely with those of its investors.
Several external service providers are integral to the fund’s operational framework:
- Superstate Inc. serves as the Investment Adviser, functioning under Exempt Reporting Adviser (ERA) status by the Investment Advisers Act. This classification imposes certain compliance and oversight duties, though it does not entail full SEC registration. ERAs manage private funds, including hedge funds, venture capital funds, or private equity vehicles, and are subject to fiduciary obligations, anti-fraud provisions, recordkeeping requirements, and periodic Form ADV reporting.
Source: SEC Investment Adviser Firm Summary, April 14, 2025.
- Federated Hermes, a publicly traded asset manager overseeing approximately $800 billion in client assets, has been engaged by Superstate Inc. as the Fund’s Sub-Advisor, ensuring that a professional team of portfolio managers oversees the assets.
- UMB Bank, N.A., an OCC-chartered institution, acts as the Custodian, holding the fund’s assets in a segregated account under the protections afforded by the Customer Protection Rule. All U.S. Treasury Bills in the fund remain in a custodial account at UMB Bank, preventing rehypothecation, lending, or other encumbrances.
Source: OCC Financial Institution Search, April 14, 2025.
- NAV Fund Administration Group, also known as NAV Fund Services, is based in the United States and provides net asset value calculations, fund accounting, investor services, and regulatory submissions under the legal name NAV Consulting, Inc.
- Ernst & Young LLP serves as the Auditor, while Circle Internet Financial provides USDC-related services.
USCC
Like USTB, USCC is organized as an independent series of the Superstate Asset Trust, structured as a Delaware Statutory Trust, and operates as a private fund under Section 3(c)(7) of the Investment Company Act.
Only Qualified Purchasers can invest in USCC, subject to KYC, AML, and sanctions verifications. FinresPBC is stated to have satisfied these requirements, granting it admission to the fund.
USCC’s primary objective is to generate yield by conducting “cash and carry” trades, which leverage pricing discrepancies between spot and futures markets for digital asset commodities. The fund limits its trading activity to those digital assets with exchange-listed futures contracts sanctioned by the U.S. Commodity Futures Trading Commission (CFTC).
USCC applies a 0.75% management fee, higher than the 0.15% charged by USTB once USTB’s waiver period ends, along with additional operating expenses encompassing administrative, audit, custody, financial statement preparation, Circle Internet Financial fees, and other charges. Notably, Superstate Inc. refrains from levying subscription or “minting” fees and does not impose any charges for redemptions.
Though USCC employs many of the same service providers, it differs concerning custodial arrangements. Crypto and stablecoin assets belonging to USCC are safeguarded by Anchorage Digital Bank N.A., a federally chartered digital banking institution subject to oversight by the U.S. Office of the Comptroller of the Currency (OCC). All crypto and stablecoin holdings remain in segregated accounts established in USCC’s name at Anchorage Digital Bank N.A.
Source: OCC Financial Institution Search, April 14, 2025.
FinresPBC
Financial Reserves and Asset Exploration Inc., doing business as FinresPBC, is a Delaware-formed public benefit corporation that has existed since August 2023. It was selected as FRAX v3’s Offchain RWA Partner through governance proposal FIP-277. Despite its approval as a qualified investor by BUIDL, USDT, and USCC, the public domain provides minimal information regarding FinresPBC’s specific registration or licensure.
Recent statements from the Frax team shed additional light on the role of FinresPBC - the entity engages in no commercial activity beyond serving as an onboarding conduit for Frax DAO regarding RWA integrations. The entity exists chiefly to satisfy the onboarding requirements of designated custodians and other RWA partners. Legal ownership and the attendant representative authority associated with FinresPBC remain vested in the Frax founders. Further information has been requested concerning the precise mandate conferred upon FinresPBC by the DAO; once those particulars are furnished, this analysis will be updated to reflect the enhanced governance context.
Frax Finance Terms
Frax Finance’s Terms of Service allocate considerable responsibility and risk to the end user, making the disclaimers and liability limitations a focal point. As a result, users must remain vigilant about the inherent risks in engaging with the platform. The Terms are governed by the laws of the Cayman Islands, meaning that any legal disputes arising from using the Service would be subject to Cayman Islands jurisprudence.
The scope of the Terms extends to the use of app.frax.finance and facts.frax.finance, among other platform components. However, the platform’s latest iteration, accessible via https://frax.com/, does not feature publicly available Terms of Service. As a result, there is a noticeable lack of clarity regarding the legal framework governing usage of that version.
The documentation clarifies that, although frxUSD is fully collateralized, there is no guarantee that it can be redeemed for specific underlying assets, such as BUIDL or USTB. This risk is evident when, for instance, all BUIDL tokens held by the Blackrock frxUSDCustodian contract have already been redeemed or vice versa. Nevertheless, so long as the frxUSDCustodian contracts continue to hold collateral tokens, frxUSD remains redeemable on demand through those custodians.
This explanatory statement, however, does not appear in the governing Terms of Service or risk disclosures and thus likely carries no enforceable legal effect. From a user protection and transparency standpoint, the absence of definitive guidelines or at least a baseline level of disclosures for the asset in question (e.g., Terms of Service or Terms of Use) constitutes a substantial drawback. While Frax makes its Terms of Service publicly available at Frax Finance, no equivalent documentation appears on the primary domain at https://frax.com. The team remains to clarify whether comprehensive Terms, risk disclosures, and disclaimers will be published on the flagship site.
Clarification (Frax team) - not independently verified:
FinresPBC (approved via governance vote) serves as the interim issuer of frxUSD—holding IP, managing custodian contracts, and distributing yields—through July 2025. Once U.S. stablecoin legislation passes, a fully regulated corporate entity (not the DAO) will issue frxUSD, handle mint/redemption flows, own the IP, and distribute earnings. A revised Terms of Service on frax.com will reflect this change.
4.2 Access Control Risk
4.2.1 Contract Modification Options
Both frxUSD and sfrxUSD are deployed as upgradeable proxies, allowing their logic to be modified by an admin. On Sonic, the owner of both contracts is 3 of 6 SAFE 0x87c7A1ef67c67cd57CBF101522a0c3B19D2C3aAc, a Frax-controlled multisig. On mainnet, a Safe deployed to the same address is 2/3.
This multisig can upgrade the contracts, change parameters, or pause functionality. sfrxUSD vault strategies are also adjustable by governance, meaning allocation decisions are subject to admin discretion. Although this allows fast responses to bugs or incidents, it introduces centralization risk: a compromised or malicious admin could unilaterally change token behavior.
4.2.2 Timelock Duration and Function
No timelock mechanism is implemented on Sonic, meaning there is no enforced delay in administrative actions.
4.2.3 Multisig Threshold / Signer identity
The address 0x87c7A1ef67c67cd57CBF101522a0c3B19D2C3aAc is identified as the owner of the frxUSD contract and has had admin control over Frax contracts and assets. It is a 3/6 Safe multisig, and the signers are as below:
- 0x13Fe84D36d7a507Bb4bdAC6dCaF13a10961fc470
- 0xcbc616D595D38483e6AdC45C7E426f44bF230928
- 0x8d8290d49e88D16d81C6aDf6C8774eD88762274A
- 0x05FB8eC3C41da95b26fCb85503DaF8B89B89A935
- 0xc28339c70054bC22255A74E927a0B9e9A475F224
- 0x6e74053a3798e0fC9a9775F7995316b27f21c4D2
Note: This assessment follows the LLR-Aave Framework, a comprehensive methodology for asset onboarding and parameterization in Aave V3. This framework is continuously updated and available here.
Aave V3 Specific Parameters
N/A
Price feed Recommendation
N/A
Disclaimer
This review was independently prepared by LlamaRisk, a community-led decentralized organization funded in part by the Aave DAO. LlamaRisk is not directly affiliated with the protocol(s) reviewed in this assessment and did not receive any compensation from the protocol(s) or their affiliated entities for this work.
The information provided should not be construed as legal, financial, tax, or professional advice.