Legal Framework • 2026

Step-In Rights for GPU Collateral

How lenders protect access to GPU hardware deployed in third-party colocation facilities. Essential reading for private credit teams structuring equipment-backed loans.

Summary34 Data Sources

What happens if a colocation provider defaults (step-in rights)?

Step-in rights allow lenders to assume control of a borrower's colocation agreement if the borrower defaults. For GPU-backed loans, this is critical because the physical hardware is located in a third-party facility. Key provisions include: (1) direct agreement with the colo provider, (2) notice and cure periods (typically 30-60 days), (3) ability to relocate equipment, and (4) assumption of service contracts. Without proper step-in rights, lenders may face stranded collateral.

Key Data Points

  • Direct Agreement with colo provider required
  • Typical cure period: 30-60 days
  • Must include equipment relocation rights
  • Service contract assumption provisions

Why Step-In Rights Matter for GPU Loans

In a traditional equipment loan, the lender can repossess collateral directly from the borrower's premises. GPU-backed loans are different: the hardware typically resides in a third-party colocation facility under a separate service agreement.

Without proper step-in rights, a lender faces a nightmare scenario:

The "Stranded Collateral" Problem

Borrower defaults. Lender attempts to recover GPUs. Colocation provider refuses access, citing unpaid bills or lack of authorization. GPUs sit idle, depreciating, while lawyers negotiate. By the time access is granted, collateral value has dropped 30%.

Key Provisions in a Step-In Agreement

1. Direct Agreement

A tri-party agreement between lender, borrower, and colo provider. The colo provider acknowledges the lender's security interest and agrees to cooperate in enforcement scenarios.

2. Notice Requirements

Colo provider must notify lender of any borrower default (usually non-payment). Lender gets 30-60 days to cure the default or take over the agreement.

3. Facility Access

Explicit right for lender (or its agent) to enter the facility, inventory equipment, and arrange for removal or continued operation.

4. Contract Assumption

Option for lender to assume the colocation agreement and continue service, or to assign it to a new operator/purchaser of the GPUs.

Negotiating with Colocation Providers

Most major colocation providers (Equinix, Digital Realty, QTS, etc.) have standard forms for lender acknowledgment letters. Key negotiation points:

  • Cure period length: Push for 60+ days to allow time for workouts
  • Lender payment priority: If lender cures borrower's arrears, those payments should reduce secured debt
  • Equipment marking: Clear identification of which racks/GPUs are covered by the security interest
  • Relocation rights: Ability to move equipment to another facility without provider consent
  • Insurance: Lender named as additional insured on equipment policies

UCC Considerations

Step-in rights complement—but don't replace—proper UCC-1 filings. The security interest must be perfected under Article 9, with filings in:

  • Borrower's state of organization (for general intangibles)
  • State where equipment is located (for fixtures, if applicable)

Pro Tip: Equipment Schedules

Maintain detailed equipment schedules with serial numbers, rack locations, and acquisition dates. This simplifies both UCC descriptions and physical recovery. Our platform exports IC-ready equipment schedules with one click.

Enforcement Scenarios

ScenarioLender ActionTypical Timeline
Borrower colo defaultCure arrears, assume agreement30-60 days
Borrower loan defaultExercise step-in, continue operations or sell60-90 days
Borrower bankruptcySeek relief from stay, adequate protection90-180 days
Colo provider insolvencyRelocate equipment to alternative facility30-60 days
Critical Market Intelligence

The 'Lender Remedies' Playbook

  • Model tri-party step-in agreement
  • UCC-1 filing checklist for GPU equipment
  • Enforcement timeline and cost estimates

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