For permitted payment stablecoin issuers and the programs they issue for

The reserve report, derived — not just attested.

From 18 January 2027 each permitted issuer publishes the monthly composition of its reserves, has it examined each month, and has its CEO and CFO certify it. We build the derivation underneath that signature.

18 Jan 2027: GENIUS Act effective date, 18 months after enactment (§ 20); U.S. Congress — Pub. L. 119-27 (GENIUS Act) — GENIUS Act § 20 (12 U.S.C. 5901 note) (US)
Monthly: public reserve composition report, examined by a registered public accounting firm (§ 4(a)(1)(C), § 4(a)(3)(A)); U.S. Congress — Pub. L. 119-27 (GENIUS Act) — GENIUS Act § 4(a)(1)(C) (US)
CEO + CFO: certify the monthly report's accuracy to the regulator, with 18 U.S.C. 1350(c) penalties (§ 4(a)(3)(B)–(C)); U.S. Congress — Pub. L. 119-27 (GENIUS Act) — GENIUS Act § 4(a)(3)(A)–(C) (US)

See the pilot Talk to us

What we heard

Two jobs, one deadline

What the opinion covers

Reserves at least equal circulation

Your examining firm already says so each month, at the report dates. That is what the statute asks the firm for, and it is not what we build.

What it does not

How the figure was derived

Supply by chain, mint and burn, tenor and custody location by asset class, and whether the officer signing could recompute the number without the person who built the spreadsheet.

The gap

The certification is a signature on a derivation nobody has written down.

Custodian statements, Treasury positions, repo, bank balances on one side; on-chain supply on the other; a workbook in between. The evidence underneath the signature does not yet exist as a reproducible artifact.

Our core principle

Your data never leaves your warehouse. We bring the logic to it.

Read-only, always

A SELECT-only role you create and can revoke. Nothing is written back, structurally.

Your rows never leave

Only figures at the regulator's grain, and the metadata that explains them, cross to us.

No model computes a number

AI proposes mappings and explains results. Deterministic code produces every figure, reproducibly.

What we will not do. Replace your examining firm, opine on reserve-asset eligibility, or tell you which supervisory regime you sit in — that is a per-issuer fact for counsel. We do not say you are compliant. We show how each figure in the report was derived and which section asks for it.

Step 1 · map once

We map your warehouse to a compliance model

illustrativeYour sources, mapped to what § 4(a)(1)(C) asks for

Your sources (examples)	Mapped to	Used for
custodian statements	Reserve holdings by asset class	amount and composition
treasury positions, repo	Tenor by instrument	average tenor per category
bank balances	Deposits, by institution and location	geographic location of custody
on-chain supply, mint, burn	Outstanding stablecoins	total outstanding, by chain
redemption queue	Redemption requests and timeliness	redemption policy evidence

A different data shape from transaction events — holdings versus supply at points in time. Whether it reuses our existing models is tested in discovery, not assumed.

Step 2 · the flow

From your tables to the figure, every step on the record

Step 01

Discover

Five conversations and your actual tables on a whiteboard, before anything is built.

Step 02

Model on paper

The reserve report as the statute reads it, every section cited, on synthetic data shaped like published attestations.

Step 03

Connect

A SELECT-only role; custodian and on-chain feeds mapped and confirmed by your treasury team.

Step 04

Reconcile

Supply versus ledger versus custodian, daily, in place. Differences are figures with reasons, never silently netted.

Step 05

Evidence

The month-end report with the derivation of every line, for the examining firm and the certifying officers.

Rulebooks and elections

Each figure is judged by the rule that asks for it

The statute is read and recorded. The implementing rules are still proposed; we version the models and treat the final rule as a diff.

cited

1:1 reserves

Identifiable reserves backing outstanding stablecoins on at least a one-to-one basis (§ 4(a)(1)(A)).

U.S. Congress — Pub. L. 119-27 (GENIUS Act) — GENIUS Act § 4(a)(1)(A) (US)

cited

Monthly public composition report

Total outstanding stablecoins, and the amount and composition of reserves including average tenor and geographic location of custody of each category (§ 4(a)(1)(C)).

U.S. Congress — Pub. L. 119-27 (GENIUS Act) — GENIUS Act § 4(a)(1)(C) (US)

cited

Which regulator — a per-issuer fact

OCC for nonbank federal issuers; OCC, FDIC or the Federal Reserve for insured-depository subsidiaries; NCUA for credit-union subsidiaries; a state regulator under $10B where the state regime is substantially similar (§ 2(25), § 4(c)).

U.S. Congress — Pub. L. 119-27 (GENIUS Act) — GENIUS Act § 4(c)(1), § 4(d)(1)–(3) (US)

to be confirmed

OCC, FDIC, FinCEN and Treasury rules

Proposed as of October 2026; the Comptroller has said the OCC aims for a final rule by November 2026.

No regime verified for this item — the first question we ask.

What we look for

Line items, patterns and the traps underneath them

What a certifying officer would ask before signing — each becomes a line with a derivation.

Pattern	What it looks like in the data
Supply by chain	Outstanding tokens per chain, from mint and burn events, reconciled to the issuer's ledger.
Composition by category	Cash, Treasury bills, repo, money-market funds — amount and share, from custodian statements.
Tenor	Average tenor of each category, computed from positions, not typed into a cell.
Custody location	Where each category is held, by institution and jurisdiction.
Coverage	Reserves over outstanding, at each report date, with the two sides' sources shown.

Step 3 · the output

Every line arrives with its trail

Short sentences instead of query output. Every figure links back to the rows in your warehouse that produced it, the rule it maps to, and the person who signed the interpretation.

illustrativeIllustrative · synthetic figures

Outstanding stablecoins — 1,204,500,000 — 4 chains — from mint/burn events reconciled to ledger
Reserves, total — $1,206,912,040 — cash 12%, T-bills 71%, repo 17% — from 3 custodian statements
Average tenor, T-bills — 41 days — computed from 23 positions
Custody — 2 banks (US), 1 custodian (US) — by category
Caveat — implementing rules still proposed; figures computed against the statute as enacted

Step 4 · your team decides

The system drafts. People approve.

General Counsel

Which legal entity issues, and which regulator supervises it?

Treasurer or CFO

Valuation timing and sources for each reserve category

Treasury operations, with data

Which custodian and on-chain feeds are the system of record

CEO and CFO

Who certifies — and who approves the evidence before they do

Nothing reaches a regulator or an authority without human approval. Every release records who asked, what was shared, who approved it, and when.

Security and control

Built for data that cannot move

Read-only, always

A SELECT-only role you create and can revoke. Nothing is written back, structurally.

Your rows never leave

Only figures at the regulator's grain, and the metadata that explains them, cross to us.

No model computes a number

AI proposes mappings and explains results. Deterministic code produces every figure, reproducibly.

A person confirms every mapping

Before a figure is built on it. Nothing reaches a regulator without a named approval.

Where the rules disagree, we say so

The choice is recorded, cited, signed off, and disclosed on the pack. Never silently picked.

Proposed pilot

Discovery first, then eight weeks, measured by hours and traceability

Discovery

five conversations; the reserve report modelled on paper with citations; your tables mapped on a whiteboard — a short paid engagement

Then weeks 1–2

Map: SELECT-only role, custodian and on-chain feeds confirmed

Weeks 3–8

Build and run the month-end report beside your current process; hand the derivation to your examining firm

How we will measure it

· Analyst hours per report or request
· Time from period end, or from request, to an approved pack
· Share of reported figures traced to source rows

Pilot terms: the pilot fee is credited against a first year signed within 30 days. Every pack carries its own caveats on its cover; nothing is suppressed to make a figure look cleaner.

Talk to us

The reserve report underneath the certification

If this is on your desk, tell us what you are dealing with and we will reply within one to two business days.