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Attributing Qualified Turtle TVL

Turtle charges on Net New Turtle TVL using a deterministic, auditable attribution system. To ensure auditability and eliminate subjective reconciliation, Turtle operates two parallel ledgers:
  • Ledger A: Attribution Ledger
  • Ledger B: TVL Ledger
Fees are calculated by reconciling these two ledgers via a deal-specific whitelist of eligible wallets.

Ledger A: Attribution

Records wallet interaction with:
  • The Turtle front end
  • A Turtle Earn SDK–integrated front end
  • (If applicable) an approved distributor front end
A wallet that meets the selected engagement criteria is added to a deal-specific whitelist.Ledger A determines who qualifies.

Ledger B: TVL

Tracks:
  • The Total Value Locked (TVL) of whitelisted wallets
  • Within the specified protocol/opportunity
  • From the deal go-live date forward
Turtle charges on TVL over time, not deposit/withdrawal flow. This eliminates manipulation risk, looping behavior, and cross-interface complexity. TVL is objectively verifiable at the protocol level.

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Defining “Qualified TVL”

For each opportunity, we will reconcile these two ledgers with one another. Ledger A will tell us who to refine ledger B down by. Ledger A can have different parameters to widen or reduce the scope of whitelisted users, ledger B will always remain as is. The reconciliation process:
  1. Attribution List: identify qualified wallets from Ledger A (qualified whitelist).
  2. TVL Figures: pull TVL of those wallets from Ledger B (qualified TVL).

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Attribution List Configuration

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(Ledger A parameters to define the whitelist)

This is how we refine the scope of users. For most projects we will charge on the default model of Deal Specific Turtle TVL, but for projects that we’re more involved in or are earlier stage, we will charge on all Turtle Member TVL, for projects where we are instrumental in their growth, we will charge on all TVL. See definitions below:

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Deal Specific Turtle TVL (Default)

(Infrastructure Model) Measures growth only from wallets that engaged with Turtle infrastructure (front end or SDK) for the specific opportunity after launch date. “Did this user deposit to this opportunity through Turtle?” When Used: Applied as the default institutional standard where attribution must be strictly infrastructure-verifiable and opportunity-specific.

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Turtle Member TVL

(Ecosystem Model) Measures growth from verified Turtle member wallets, excluding balances that existed prior to membership after launch date. “Is this user a Turtle member?” When Used: Applied when Turtle contributes meaningful distribution across its member base but is not the sole driver of total protocol growth.

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All TVL

(Protocol Growth Model) Measures total protocol growth from the listing date, regardless of wallet source after launch date. “All users were made aware of this through Turtle.” When Used: Applied where the bulk of protocol launch, distribution, and capital formation efforts are driven exclusively by Turtle.

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Fee Structure

Fees are applied to Qualified TVL. Example structure:
  • 30-70 bps during initial 30-day launch window
  • 50-110 bps annualized thereafter
Exact rates are defined in the commercial agreement. The incentive window begins at deal go-live, not per LP deployment.

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Auditability

In the event of a dispute:
  • Ledger A provides whitelist qualification evidence
  • Ledger B provides protocol-level TVL snapshots (every 12 hours)
The reconciliation is auditable and reproducible.