We are at CSA 815-40. Without going into extreme detail, this guide tells us that SAFE is in debt due to certain factors. The first is that SAFE is not indexed to its own shares in accordance with ASC 815-40-15-5 to 15-8a, see ASC 815-40-55-33 as an example. Therefore, the classification of shares is excluded. If, for some reason, it was thought that safe was pegged to its own shares, there would still be other considerations that would lead to safe being considered debt, which is found in ASC 815-40-25-7 to 25-35. Some of the possibilities are as follows: SAFE`s requires the company to provide a variable number of shares based on an unknown future price cycle (discount) or a valuation cap. .