Custodied assets must be accounted for separately and not commingled
What the document says“Payment stablecoin reserves, payment stablecoins, cash, and other property of a permitted payment stablecoin issuer or customer shall be separately accounted for by a person described in subsection (a) and shall be segregated from and not be commingled with the assets of the person.”
Subsection (c)(1). Four exceptions follow. Property of more than one issuer or customer may be pooled for convenience in an omnibus account at a State chartered depository institution, an insured depository institution, national bank or trust company, and reserves held as a cash deposit are not subject to a separation requirement against the depository institution's own property. A share may be withdrawn and applied to transfer, adjust or settle a transaction, including commissions, taxes, storage and other lawful charges. Property may be commingled in issuer or customer accounts on terms a primary Federal payment stablecoin regulator prescribes. An insured depository institution providing custody may hold reserves as cash on deposit where that is consistent with Federal law.
What the document actually says“Payment stablecoin reserves, payment stablecoins, cash, and other property of a permitted payment stablecoin issuer or customer shall be separately accounted for by a person described in subsection (a) and shall be segregated from and not be commingled with the assets of the person.”
The firm must keep a separate count of what it holds. Those assets must sit apart from its own. It may not mix the two.
There are four ways around this. One lets many customers share one pooled account. One lets the firm take out what a trade costs. A bank may hold cash as a deposit.
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