Inquiry on Crypto Deposit Accounts

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Request List

Please provide the below items for all digital asset related deposit accounts at the Bank:

  • Provide analysis on digital asset related deposit volatility and how such deposits are considered in liquidity risk management functions including:
  • concentration risk limits;
  • key risk indicators outlining the minimum level of highly liquid assets held against crypto-related deposits; and
  • any other supporting metrics to assist with understanding how management assesses and manages the overall risk related to digital asset related deposit accounts.
  • Include related board and committee reporting.
  • Provide a list of all accounts, account titling, month-end deposit levels for the last 12 months, monthly transaction volumes, and account purpose.
  • Reflect which digital asset related deposit accounts hold funds on behalf of the digital asset firms’ customers or function as reserve assets for a stablecoin, if any. For such accounts:
  • Provide copies of any account agreements or contracts with the digital asset related firms.
  • Provide the most recent copies of any account agreements, disclosures, or advertisements related to accounts provided by or through the Bank and digital asset related firms.
  • Provide policies and procedures that govern the Bank’s process for reviewing third-party account disclosures, marketing materials, and advertisements that use the bank’s name or branding or related to deposit insurance.
  • Describe the process used by the Bank, digital asset firm, or any other third-party to maintain records, ledgers, or reconciliations, or other evidence reflecting the balance of user funds held at the Bank that are subject to the FDIC pass through insurance disclosure. This would include any documentation of the policies and procedures relating to the flow of funds for these accounts.
  • Describe any role the bank has in verifying stablecoin reserves, if any are held, to a digital asset firm, their customers, or their customers’ customers.
  • Provide documentation of any internal or external analysis, including legal opinions, conducted to determine whether the digital asset firm disclosures and any related third party’s account agreements are accurate as it relates to the availability of FDIC pass through deposit insurance.