By Eric, Foresight News
On September 28, a post titled “The Foundation Misappropriated v2 DAI Reserves” appeared on the Compound governance forum.
The author gurmersin accused the Compound Foundation of violating its governance authorization by exchanging 8.42 million DAI reserves entrusted by the DAO into the governance token COMP, and entrusting voting rights to the foundation's own address 58 minutes before the deadline for voting on key proposals, thereby promoting the transfer of the V4 plan and financial management rights totaling $52 million. The post attached a complete transaction record on the chain, with harsh words and hinted that evidence had been retained to prepare for legal action.
According to the author's verification, the funding path described in the post is basically true. After the problem was exposed, COMP only experienced a slight decline of about 1%. It continued to rebound at 11 o'clock today. As of the time of writing, the price of COMP was reported at $24.55, having recovered all of yesterday's decline.
On March 10, the foundation's multi-signature address starting with 0x0F51, which stores DAI, exchanged 8.42 million DAI for the same amount of USDC through Spark PSM 1:1, and then deposited it into the Compound v3 USDC market;
From March 11th to 12th, the Compound Foundation first spent about 430,000 USDC to buy 25,000 COMP through OTC. April 9, 15, and 25: 7.988 million USDC was withdrawn from v3 in three transactions, transferred to an intermediate wallet starting with 0xfb20, and then flowed into a Binance deposit account in units of millions of dollars;
Subsequently, the address starting with 0xb03e withdrew approximately 420,000 COMP from the Binance hot wallet and Wintermute address. On May 5, 344,780 COMP returned to the Foundation’s multi-signature address via the transit address starting with 0x729d.
Independent verification by Bitquery, a third-party data agency, confirmed that this batch of DAI was indeed converted into USDC and flowed into Binance through the trading desk. About 345,000 COMP subsequently flowed out of the exchange and returned to the multi-signature wallet managed by the foundation. The arrival time was indeed less than an hour before the proposal snapshot, and the voting rights had indeed been entrusted to the foundation’s public voting address. The foundation later issued a statement acknowledging the trading behavior, but argued that this was the scope of authorization in the original proposal to maintain the COMP reserve required for governance execution. The assets are still owned by the DAO and have not been used for the foundation's own expenses.
If the story ends there, this seems to be a classic case of trustee overreach. But a Bitquery check also revealed another side of the post. Just five days before this post, the same author wrote in another thread on the forum that everyone here knows that Humpy is entrusting the ticket to me. This sentence changed the nature of the entire incident.
Humpy is one of the most controversial whales in the DeFi space. In 2022, he regained control of governance decisions at Balancer by accumulating a large amount of voting power. The two parties were forced to sign a settlement agreement after fighting for nearly a year. In March 2024, the head of SushiSwap publicly accused him of trying to manipulate the flow of token emissions to his own pool. In July of the same year, the Golden Boys group he led pushed through Compound’s Proposition 289 after three attempts, trying to import treasury COMP worth $24 million into yield products controlled by itself. This was widely recognized by the community as a governance attack, and ultimately ended in a settlement plan that increased the delay in the execution of the proposal and established a staking product. Security parties such as OpenZeppelin and Wintermute characterized it as a predatory attack on the protocol at the time.
On-chain records show that after May 2026, the address cluster associated with Humpy became active again.
Bitquery tracked that 33 wallets held a total of approximately 1.61 million voting rights. This batch of COMP tokens was gradually gathered into one address from May to September, and the voting rights were uniformly exercised. On September 14, a delegation of approximately 25,000 votes moved the address across the threshold required to submit a proposal. Five days later, Proposal No. 608 was put on the chain. The content was to transfer control of a new institutional lending market to DAO governance. This proposal was drafted by gurmersin himself on the forum on September 9. The associated cluster voted 1.77 million in favor of its passage, with the foundation voting against but unable to block it. The immediate following, Regular Proposal No. 609, was defeated by the same vote base.
This reversed the events themselves. The COMP purchased by the Foundation from its reserves happened to make Propositions 580 and 582 mathematically immune to potential opposition votes from the cluster, which would have overturned the proposals without this batch of tokens. In other words, the controversial purchase effectively fended off the very forces associated with the poster. When the accusations were posted, the cluster had just completed a successful power expansion with its own proposals, and for the first time demonstrated its ability to veto others' proposals.
Compound’s core mission in the past six months has been to develop the v4 version, focusing on institutional credit infrastructure, RWA support, capital efficiency improvements, liquidation mechanism upgrades, partner integration tools, etc. The controversial proposal this time was a regular proposal to hand over the remaining reserves in the market to the foundation after the v2 version was abolished.
In May, Compound established a “Treasury Management Committee” to manage almost all of Compound DAO’s treasury assets. The committee is a multi-signature controlled committee responsible for allocating treasury funds to professional money managers (via RFP tenders) for robust asset management.
The foundation's use of the remaining funds from the abandoned version is essentially a defensive operation to ensure that the development of the v4 version of the protocol's "big plan" can proceed smoothly. On the other hand, Compound’s actions also conform to a major trend in current DAO governance, which is to partially take back the management authority of funds to the project team and “concentrate efforts on big things.”
On September 8, Compound launched its first v4-related product, Institutional Market, which provides a USDC lending market and accepts ETH, wstETH, WBTC, cbBTC, etc. as collateral, with a maximum LTV of 87% and a higher liquidation threshold. Within a week of the product’s launch, approximately $20 million was deposited and approximately $14.8 million was borrowed.
It is important to emphasize that the on-chain facts on which the allegations are based are not themselves disproven. It is true that DAI turned into COMP, it is true that the address entrusted to the foundation itself is true, and it is true that the account arrived 58 minutes before the snapshot. Whether the foundation's operations are fully in line with the original intention of the authorization, the community still has reasons to ask. But it is also true that the person who initiated the accusation was openly commissioned by a whale with a record of multiple governance attacks. The proposal he drafted relied on this vote bank to be passed, and the timing of the accusation was just after the balance of power between the two parties had reversed. This can hardly be seen as a neutral community oversight, but more like a public opinion offensive in a two-year war for control.