Author: JAE
The DeFi market has surpassed $150 billion in size, but the overcollateralization model still limits its penetration into broader lending areas. Uncollateralized lending remains one of the directions the DeFi market is actively exploring, but various protocols have failed along the way.
Recently, 3Jane, a rising star in unsecured lending, announced that it expects to launch its mainnet in early November. As an unsecured lending protocol backed by leading crypto VC Paradigm, 3Jane represents another significant step for Paradigm in the lending sector, attracting widespread market attention.
3Jane positions itself as a "credit-based peer-to-peer pooled money market," aiming to provide algorithm-driven, real-time uncollateralized USDC credit lines to those unable to meet overcollateralization requirements. 3Jane has a clear customer profile, explicitly encompassing not only ordinary crypto investors but also liquidity miners, traders, arbitrageurs, enterprises, and AI agents. This target customer group indicates that 3Jane has positioned itself from the outset in a high-turnover, high-capital-efficiency institutional-grade credit market.
The essence of unsecured lending is that lenders must bear the credit risk of borrowers. In traditional finance, such businesses typically require borrowers to undergo rigorous KYC (Know Your Customer)/AML (Anti-Money Laundering)/CDD (Due Diligence) and credit assessments. However, the permissionless and anonymous nature championed by DeFi contradicts KYC/AML requirements. Therefore, if DeFi unsecured lending is to achieve large-scale commercialization, especially in acquiring institutional funding at the $50 million level, it must balance the contradiction between the spirit of decentralization and regulatory compliance requirements.
In its early stages, lenders can mint USD3 on 3Jane by depositing USDC, or by staking USDC/USD3 into the protocol to mint sUSD3, earning up to 27% APY. To date, over $7 million in credit lines on 3Jane are backed by approximately $83.1 million in verified assets.
For borrowers, 3Jane limits its scope to U.S. residents with total assets exceeding $150,000, with an initial lending limit of approximately $50 million. This restriction is primarily due to the need for asset verification to determine credit limits and to screen qualified borrowers to mitigate risk. The requirement for borrowers to be U.S. residents also facilitates future debt collection.
The protocol's access mechanism directly addresses the SEC's (Securities and Exchange Commission) regulatory requirements for "accredited investors." While the definition of an accredited investor typically requires net assets exceeding $1 million, 3Jane's entry threshold and its nationality requirements demonstrate the protocol's emphasis on compliance. From the outset, the product design limits users to a specific group that meets KYC and asset thresholds, thereby minimizing regulatory risks.
For 3Jane, the prerequisite for its closed-loop business model is no longer just how accurate its technical risk control model is, but more importantly, whether it can meet the stringent regulatory requirements of institutional investors. This means that 3Jane needs to prove that it is a protocol with a verifiable compliance layer in order to attract its target audience to the DeFi market.
Jacob Chudnovsky, founder of 3Jane, admitted that previous uncollateralized lending protocols in the crypto market had all failed due to a lack of sound credit underwriting mechanisms and legal recourse, and because a large number of transactions occurred off-chain. To address the challenges of risk control and compliance in uncollateralized lending, the protocol created a new technological architecture by combining the 3Jane Credit Risk Algorithm (3CA) with the zkTLS protocol.
3CA is used to capture user interaction data across DeFi, CEXs (centralized exchanges), and traditional banks, using it as part of credit assessment. 3CA underwrites credit limits based on a user's Jane Score and asset type. The Jane Score is a user's credit score on the 3Jane protocol, composed of both on-chain and off-chain creditworthiness. The on-chain Jane Score is fed by Cred Score and Blockchain Bureau Score, both protocols that have established credit assessment frameworks based on user on-chain behavior; the off-chain score integrates VantageScore 3.0 from TransUnion and Equifax (two of the three major US credit agencies) as data sources. Furthermore, the Jane Score includes default penalty mechanisms, deterring bad actors by restricting access and increasing interest rates.
In short, Jane Score will comprehensively assess users' credit risk from both on-chain and off-chain perspectives. If a user attempts to borrow from the protocol by artificially inflating their asset value through external borrowing or transfers, this behavior will be collected and scored by Jane Score. For new users with limited past on-chain or off-chain borrowing activity, their initial credit score will not be high, and the credit limit issued by the protocol will be controlled within a manageable range to prevent serious bad debts due to lending large amounts of assets.
In addition, 3Jane places great emphasis on compliance, and after the agreement is finalized, the credit data of defaulting users may be fed back to off-chain credit institutions to constrain user behavior.
3CA's cross-domain data inputs have helped the protocol build a "credit graph" that transcends a single on-chain dimension. Through Jane Score, 3Jane has also shifted the credit risk assessment of lending behavior from reliance on over-collateralization (asset value) to an uncollateralized (user credit) model, which is the foundation supporting the protocol in issuing credit to complex entities such as enterprises and AI agents.
3CA's assessment of user credit relies on obtaining user behavior data across Web2 and Web3, which contradicts the need to protect user privacy. 3Jane then introduced the zkTLS (Zero-Knowledge TLS) protocol to overcome this "privacy compliance paradox."
zkTLS acts as a cryptographic bridge built using zero-knowledge proof technology. It allows borrowers to connect to financial data in the Web2 world, such as bank accounts or CEX accounts connected via Plaid, and to privately generate proofs to verify a user's repayment ability or asset ownership, without disclosing sensitive data to 3Jane or any third party.
zkTLS's value proposition lies in providing compliance verification in the form of "zero-knowledge proofs." For regulated financial institutions, the core requirements of KYC/AML include customer identification, identity verification, and due diligence on the authenticity of transactions. zkTLS can complete these due diligence steps while ensuring user privacy, thus fulfilling its regulatory responsibilities. This technological innovation has significantly enhanced 3Jane's attractiveness to compliant institutional funding.
On June 4th, 3Jane secured $5.2 million in seed funding led by top venture capital firm Paradigm. This investment not only provides financial support but also strongly endorses Paradigm's commitment to building a "scalable, compliant, crypto-native credit infrastructure."
In reality, Paradigm's investment in 3Jane is a bet on a DeFi blueprint that aligns with regulatory trends and possesses institutional-grade access capabilities. The success of 3Jane's institutionalization strategy heavily depends on Paradigm's frequent communication with the SEC to ensure regulatory support.
Paradigm's regulatory lobbying efforts aim to address key compliance hurdles currently facing the crypto market, particularly in the integration of traditional finance and DeFi. Their lobbying work is also a crucial strategic asset for 3Jane in attracting institutional funding from a compliance standpoint.
Custody is one of the biggest bottlenecks for institutional funds entering DeFi. SAB 121 (SEC Employee Accounting Announcement No. 121) requires financial institutions to list custodied client crypto assets as liabilities on their balance sheets.
This requirement forces custodians to incur unnecessary expenses, deterring traditional financial institutions such as banks and trust companies and significantly limiting the number of qualified custodians. Paradigm believes that SAB 121 is essentially stifling industry growth and therefore has requested the SEC to rescind SAB 121.
Following industry lobbying, SAB 121 was revoked by the SEC in January 2025, significantly lowering the custodian threshold for institutions. For 3Jane, the revocation of SAB 121 serves as a "liquidity gateway" paved by Paradigm. Enterprises are one of 3Jane's target customer groups, and these institutional users require qualified custodian services. Now that SAB 121 is revoked, institutions can compliantly deposit larger sums of money into the protocol to meet a $50 million credit requirement, ensuring 3Jane has a stable and compliant source of funding.
Paradigm's regulatory lobbying efforts have created more reliable conditions for institutional entry into 3Jane, making 3Jane's technological compliance advantages more commercially viable. Against the backdrop of traditional financial institutions seeking to simultaneously meet KYC/AML and on-chain efficiency requirements, 3Jane may offer a feasible and institutionally friendly compliant DeFi model.
The strategic collaboration between 3Jane and Paradigm also indicates that DeFi is shifting from serving crypto-native users to the broader traditional credit market, especially the trillion-dollar corporate and trade credit sectors. Once the most challenging credit assessment and compliance issues in uncollateralized lending are effectively resolved by 3CA and zkTLS, DeFi may be able to support the entire product line of traditional finance, freeing itself from the constraints of over-collateralization.
At that time, DeFi will not only retain the high efficiency of decentralization, but will also achieve the accountability required by regulations. The mainnet launch in early November will test whether 3Jane can leverage the massive credit liquidity of traditional finance amidst the wave of compliance.
However, investors should still pay close attention to 3Jane's credit risk. While the current probability of default is low, expanding its target customer base to businesses and AI agents could amplify the risk should an economic recession occur. If mismanaged, unsecured lending could repeat the mistakes of traditional finance; therefore, investors also need to monitor the effectiveness of recourse mechanisms, such as collection and legal auctions.


