FIGR · CIK 2064124
What Figure Technology Solutions, Inc. told the SEC could break it.
Figure's disclosures describe a business concentrated at nearly every layer: HELOCs were over 98% of its 2025 loan originations, its top three loan buyers absorbed 57% of sale volume (up from 38% a year earlier), and 74% of its loans were notarized by remote online notaries based in a single state, Nevada. Layered on top is regulatory exposure that is unusually open-ended — it relies on money-transmitter licenses across most states, leans on a novel, court-untested remote-notary approach, and could face sanctions if assets offered on its Figure Exchange are later deemed securities it wasn't registered to handle.
5 self-disclosed vulnerabilities, pulled from its own filings, each in the company’s words, with the source. This is the risk register almost nobody reads.
In its own words
What could break it.
Regulatory & policy
- digital-asset securities registration (Figure Exchange)high
Figure could face judicial or administrative sanctions if digital assets/products it offered on Figure Exchange are deemed securities and it operated without registering as a national securities exchange, ATS, broker-dealer or investment company.
“As such, we could be subject to judicial or administrative sanctions for failing to offer or sell the digital asset, product or service in compliance with the registration requirements, or for acting as a broker, dealer, national securities exchange, clearing agency, or investment company without appropriate registration or an available exemption or exclusion.”
SEC filing →As of 2026 - state money transmitter licensingmedium
Figure must hold and maintain money transmitter licenses in most U.S. states and territories and comply with money-transmission, money-services and virtual-currency requirements.
“State laws and regulations that impose licensing and other requirements related to money transmission, money services, and virtual currency activity, including with respect to the money transmitter licenses that we hold in most U.S. states and territories.”
SEC filing →As of 2026
Customer concentration
- loan purchasershigh
Figure's loan-sale volume is concentrated in a few buyers — its top three loan purchasers were 57% of 2025 loan sale volume (individually 22%, 18%, 17% / $1.3B, $1.0B, $1.0B), up sharply from 38% in 2024.
“For example, our top three loan purchasers in 2025 collectively accounted for 57% of our loan sale volume, and individually accounted for 22%, 18%, and 17%, or $1.3 billion, $1.0 billion, and $1.0 billion, respectively.”
SEC filing →As of 2026
Geographic concentration
- Nevada remote online notarizationmedium
Figure concentrates loan notarization in Nevada — 74% of 2025 security instruments were notarized by remote online notaries located in Nevada — and the use of out-of-state remote notaries is a novel, court-untested legal approach.
“For example, during the origination process in 2025, 74% of the security instruments associated with our loans were notarized by remote online notaries located in Nevada.”
SEC filing →As of 2026
Other disclosures
- HELOC product concentrationmedium
Figure's loan originations are concentrated in a single product — HELOCs comprised over 98% of total loan originations in 2025, exposing it to housing/HELOC-specific demand and rate shifts.
“During the year ended December 31, 2025, HELOCs comprised over 98% of our total loan originations.”
SEC filing →As of 2026
The hidden graph
Who it depends on, and who depends on it.
Relationships surfaced from filings, including ones disclosed by the other side, which is how the non-obvious ones come to light.
Its suppliers
Anchorage Digital Bank, N.A.
“At present, we entrust the collateral for digital asset-secured loans to Anchorage Digital Bank National Association (“Anchorage”), a qualified custodian.”
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