The SEC waits for investors
The SEC's claim is paid only after Classes 4 and 5 are paid in full. It has no share of the Class 5 pool.
Who gets paid, and in what order, in the Terraform Labs bankruptcy. Select a step to see the details and the court filing behind each number.
Money fills each step before it flows to the next.Hover, click or use ↑ ↓
Second Amended Plan, Dkt. 717, confirmed Sept. 20, 2024
The SEC's claim is paid only after Classes 4 and 5 are paid in full. It has no share of the Class 5 pool.
Kwon paid his $204.3M SEC settlement in kind, mostly in tokens, into a fund reserved for Class 5. At today's prices, it is worth about $83.5M to $85M, not $204.3M.
For estate cash, Crypto Loss Claims receive what is left of the GUC Pool once Class 4 is paid in full.
What the public filings show
Two sources. The trust has not published a current balance for either.
Kwon settled with the SEC for $204.3M and paid in kind, mostly in tokens. Their value has fallen since 2024: at today's prices, the fund is worth about $83.5M to $85M, not $204.3M.
AVAX: the Avalanche Foundation contested the transfer and bought the tokens back, approved Oct 2024. PYTH: transferred to the trust under a 2025 court order. Sales, if any, not published. Today's PYTH price: about $0.062 to $0.065 on Nov 2, 2026.
Class 5 also receives what is left of the GUC Pool, once costs are covered and Class 4 is paid in full. The Disclosure Statement lists the estate's assets at July 2024 values.
Total cash disbursements reported by the trust each quarter, Dkt. 997 to Dkt. 1376.
Miscellaneous, not counted as assets: possible recoveries from preference actions, third-party settlements and assets found later. Pursuing them costs money up front, and any recovery is uncertain.
Every allowed Crypto Loss Claim, in dollars.
Crypto loss claims cited by Piper Sandler, which serves as Plan Administrator of the Wind Down Trust (May 2025). This is the amount claimed. The allowed total has not been published.
No percentage is shown here: the claims agent says the recovery rate cannot be determined yet. Kroll FAQ
October 2026
Initial decisions went out from August 2025. Final decisions have started.
No date announced. Paid in U.S. dollars after identity checks.
−$5.6M last quarter, −$65.2M since Oct 2024. Nothing reported paid to creditors in Classes 4 and 5.
It is the order in which the Terraform Labs Wind Down Trust pays claims under the confirmed Chapter 11 plan (Dkt. 717). Cash first refills the trust's reserves, then pays secured and priority claims, then general unsecured claims (Class 4). What remains goes to Crypto Loss Claims (Class 5), together with the SEC Settlement Fund. The SEC claim (Class 6) comes after Classes 4 and 5.
No. The SEC claim is allowed at $4,473,828,306, but Plan §4.6(b) provides for no distributions on it unless Classes 4 and 5 are satisfied in full. Payments to those classes count toward the SEC judgment.
For estate cash, yes. Under Plan §§1.40 and 1.70, the GUC Pool is released to the Crypto Loss Claim Pool only once Class 4 is paid in full. Class 5 also receives the SEC Settlement Fund, which the plan reserves for holders of Allowed Crypto Loss Claims alone (§1.107).
No. Do Kwon's $204.3M SEC settlement was paid in kind: about $7M of cash, the Luna Foundation Guard's 1,973,554 AVAX and 500,000,000 PYTH. The AVAX were sold for $45.5M. The PYTH, valued at about $180M in July 2024, are worth about $31M to $32.5M at Nov. 2, 2026 prices. In total, the fund is worth about $83.5M to $85M at those prices, and it is reserved for Crypto Loss Claims.
Piper Sandler, which serves as Plan Administrator of the Wind Down Trust, cites $5B+ of crypto loss claims (May 2025). That is the amount claimed. The total allowed dollar amount has not been published, and the claims agent says the recovery rate cannot be determined yet.
No distribution date has been announced. The trust reported $0 paid to unsecured claims through September 30, 2026 (Dkt. 1376). Claims are still being decided, and payments will be in U.S. dollars after identity checks (Kroll CLC FAQ).
No. In his criminal case (S.D.N.Y. 23 Cr. 151), the government said forfeited assets go through its own remission process, separate from the bankruptcy (ECF 60). What Kwon contributes comes from his SEC settlement instead, paid in kind into the SEC Settlement Fund.
Yes. Claims are transferable, and each transfer is recorded on the bankruptcy docket through a notice under Bankruptcy Rule 3001(e). TerraClaim operates a marketplace for Terraform Labs Crypto Loss Claims.
| Class | Who | Treatment under the plan | Plan |
|---|---|---|---|
| Unclassified | Administrative, fee and priority tax claims | Paid in full (tax claims may be paid over up to five years) | §§2.1 to 2.5 |
| 1 | Priority non-tax claims | Paid in full in cash | §4.1 |
| 2 | Other secured claims | Paid in cash, otherwise left unimpaired, or collateral returned | §4.2 |
| 3 | Beltran allowed secured claims | Paid from the Beltran escrow; any excess becomes a Crypto Loss Claim | §4.3 |
| 4 | General unsecured claims | Pro rata share of the GUC Pool, up to payment in full | §4.4 |
| 5 | Crypto Loss Claims | Share of the Crypto Loss Claim Pool under the claims procedures | §4.5 |
| 6 | SEC claim | Allowed at $4,473,828,306; nothing until Classes 4 and 5 are paid in full | §4.6 |
| 7 | Intercompany claims | Reinstated or cancelled | §4.7 |
| 8 | Intercompany interests | No recovery | §4.8 |
| 9 | 510(c) subordinated claims | Expunged | §4.9 |
| 10 | Terraform equity interests | Shares kept but diluted; no distribution expected | §4.10 |
This page summarizes public court filings in In re Terraform Labs Pte. Ltd., No. 24-10070 (BLS) (Bankr. D. Del.), and related cases. It is for information only, not legal, tax or investment advice, and not an estimate of any recovery. The plan and court orders control. TerraClaim LLC operates a marketplace for Terraform Labs Crypto Loss Claims.
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