FDIC Letter on Bank's Crypto Divestment

FDIC
Federal Deposit Insurance Corporation
25 Jessie Street at Ecker Square, Suite 2300
San Francisco, California 94105

Division of Risk Management Supervision
San Francisco Regional Office
(415) 546-0160

March XX, 2023

XXXXX
President and Chief Executive Officer
XXXXX

Sent via secure email

Subject: Divestiture Plan

Dear XXXXX

On January 3, 2023, we received the letter you sent on behalf of XXXXX detailing plans to divest of crypto-assets XXXXX that the Bank currently holds and requesting the FDIC’s approval of the transaction. The transaction detailed in your letter does not require a filing with the FDIC and, therefore, would not require the FDIC’s approval.

Management should ensure that its valuation and valuation methodology of the crypto-assets are appropriate. The Bank should ensure that its documentation adequately supports the valuation, valuation methodology, assumptions, and determination; the accounting entries and treatment of the transaction; and compliance with Sections 23A and 23B of the Federal Reserve Act. Management’s supporting documentation will be reviewed at future examinations.

Please provide written confirmation if you decide to move forward with the transaction. The written confirmation should include the date the bank completes its divestment of the crypto-assets.

Questions regarding this correspondence should be directed to Senior Case Manager XXXXX at XXXXX or XXXXX

Sincerely,

Kathy L. Moe
Regional Director

cc: XXXXX

This letter is confidential and may not be disclosed or made public in any manner. Additional information regarding these confidentiality restrictions may be found in Part 309 of the FDIC Rules and Regulations. Please notify us immediately if you receive a subpoena or other legal process calling for the production of this letter or a description of its content.