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Crypto Activities Information Request

Crypto-Related Activities Notification Request Items

Attachment – Request Items

  1. XXXXX contracts with XXXXX
  2. Overview of the contracting process (e.g., who is/was involved in the review, analysis, and structuring)
  3. Detailed description of the settlement process for customer buy/sell transactions between XXXXX and any other related parties
  4. Permissibility analysis and determination – if any, in addition to the email with attorney XXXXX
  5. XXXXX Assessment of SEC SAB 121 and its applicability
  6. Cost-benefit analysis for involvement with XXXXX through XXXXX, include expected volumes of activity, income projections used to determine whether the products are financially feasible, and any other analysis performed to support launching the products
  7. Project Plan and implementation plan,
  8. Description of any transaction limitations imposed by XXXXX of XXXXX on the amount Bitcoin a consumer may purchase or sell (e.g. daily, weekly, monthly), including how the limitations are determined and calculated.
  9. Other than proposed advertisement to be developed in the future, any marketing materials, press releases, internal scripts, educational materials, and any other publicly distributed information related to the activity, including any screen shots/screen recordings of any online banking or mobile application interfaces that will be made visible to consumers by or through the XXXXX in connection with activities
  10. Board and committee minutes reflecting discussion, analysis, and any documentation provided on the activity, assuming not approved yet
  11. If previously provided document titled “XXXXX Summary-20220414.docx in the April 2022 documents submitted by XXXXX is not the risk assessment, provide a copy of the risk assessments
  12. Internal training materials related to the activity
  13. XXXXX policies and procedures (not XXXXX’s) that will govern the crypto-related activity, include those related to consumer compliance and complaint resolution
  14. If not outlined in policies and procedures, framework of assigned responsibilities and qualifications for those involved in day-to-day administration of digital asset activity, including internal controls responsibilities. Description of oversight responsibilities (e.g. management, staff, committees (including members, frequency of meetings), and collectively, their approval authority)
  15. XXXXX noted in CIC XXXXX email on 6/8/22
  16. XXXXX strategic plan that details how crypto asset activity achieves objectives of the Board and the Contingency Plan should the activity fail to achieve the objectives
  17. XXXXX Fintech Review document answers “Yes” to the following question: “Do the fintech’s financial reports demonstrate an ability to fulfill their financial obligations,” as well as several other questions in the Financial Condition section relating to the fintech’s ability to fulfill their financial obligations. Provide documentation of XXXXX’s analysis for those questions and the documentation utilized by XXXXX to perform the analysis.