Cryptocurrency lending operation Genesis and its parent company Digital Currency Group (DCG) say that over 230,000 retail creditors who used Gemini’s Earn program stand to be made “nearly whole” under a proposed remuneration deal to be voted on later this year.

Earn was offered to customers of the Gemini crypto exchange, but Genesis supplied the financial infrastructure that ran the program. That turned into a problem for Gemini customers when Genesis was forced to halt withdrawals and then filed for bankruptcy protection.

A filing on Wednesday states that if assorted Genesis creditor groups vote to approve a proposed deal, then “Gemini Earn users are estimated to recover approximately 95-110% of their claims.” Attorneys for Genesis and DCG had previously said unsecured creditors could receive up to 90% of the U.S. dollar equivalent of their holdings through the company’s reorganization.

Genesis' lending arm filed for bankruptcy in January after a double whammy from the collapse of hedge fund Three Arrows Capital and crypto exchange FTX. A resolution has been delayed for months by talks over the contribution that DCG should make.

In the meantime, an acrimonious, public battle has been waged by the owners of the Gemini exchange, Cameron and Tyler Winklevoss, against DCG founder Barry Silbert. (DCG is also the owner of CoinDesk.) Tuesday’s filing takes shots at Gemini, alleging the company was not contributing financially to making its own customers whole in the bankruptcy.

The Earn customers’ claim is being calculated based on what will be returned from the Genesis bankruptcy estate, plus Gemini user collateral of more than 30 million shares of the Grayscale Bitcoin Trust (GBTC), worth approximately $607 million, according to bankers for DCG. (Grayscale is another DCG division.)

“Depending on how the bankruptcy claim is calculated, the Earn customers are estimated to get between $440 million and $765 million of a claim,” a DCG executive, who asked not to be identified, said in an interview. “That claim is estimated to receive distributions of $400 million to $535 million. And then on top of that Earn customers get the $600+ million dollars of collateral that Gemini is holding. So, they're looking at total recoveries of a billion dollars or more, which is roughly their total claim. Essentially, it’s a full recovery for current customers under these scenarios.”

According to the proposed agreement in principle, shared on Aug. 29, some of these repayments would be in-kind, meaning some crypto holders would receive crypto, rather than a payment made in actual U.S. dollars.

DCG aims to file an amended version of the proposed plan by Oct. 6 and to solicit votes by Dec. 5. The hope is to confirm a plan by the end of the year with distributions contemplated to be made as quickly as possible thereafter, according to the filing.