2025 Supervisors Symposium

Supervisors Symposium

December 10-11 , 2025 Clearwater, Florida

@ www.csbs.org ♦ @csbsnews

CONFERENCE OF STATE BANK SUPERVISORS 1300 I Street NW / Suite 700 / Washington, DC 20005 / (202) 296-2840

CSBS Board Meetings & Supervisors Symposium December 8-11, 2025 | All Times Eastern Time | Clearwater, FL All meetings are on level 2, unless otherwise specified

Monday, December 8 7:30 AM

Breakfast | Belleair Room 7:30 AM - 8:30 AM

7:30 AM

Registration | Aqualea Ballroom Pre-Function 7:30 AM - 5:00 PM

8:30 AM

CSBS Bankers Advisory Board Meeting | Aqualea Ballroom B/C 8:30 AM - 12:30 PM

12:30 PM

CSBS Lunch | Belleair Room 12:30 PM - 1:30 PM

1:30 PM

SRR Board of Managers Meeting | Siesta Key 1:30 PM - 4:00 PM Small Group Dinners (Invitation Only) Meet in hotel lobby at 5:30; Dinners 6:00 - 8:00 PM

5:30 PM

Tuesday, December 9 7:30 AM

Registration | Aqualea Ballroom Pre-Function 7:30 AM - 5:00 PM

8:00 AM

Breakfast | Belleair Room 8:00 AM - 9:00 AM

9:00 AM

CSBS Board of Directors Meeting | Aqualea Grand Ballroom 9:00 AM - 4:00 PM MMC Annual Meeting (Invitation Only) | Siesta Key 9:00 AM - 5:00 PM

9:00 AM

12:00 PM

Lunch | Belleair Room 12:00 PM - 1:15 PM

6:00 PM

Welcome Reception (off-site) | Marina Cantina, 25 Causeway Blvd. 6:00 PM - 8:00 PM

Wednesday, December 10 8:00 AM

Breakfast | Belleair Room 8:00 AM - 9:00 AM

8:00 AM

Registration | Aqualea Ballroom Pre-Function 8:00 AM - 5:00 PM

9:00 AM

CSBS Supervisors Symposium | Aqualea Grand Ballroom 9:00 AM - 4:30 PM

9:00 AM

Welcome Remarks 9:00 AM - 9:15 AM Sebastien Monnet Senior Vice President & Deputy Chief Learning Officer, Conference of State Bank Supervisors Stablecoins v. Tokenized Deposits-Industry Perspectives 9:15 AM - 10:00 AM Larry Pruss Managing Director, Emerging Payment Technologies, Strategic Resource Management, Inc.

9:15 AM

10:00 AM

Break 10:00 AM - 10:15 AM

10:15 AM

The Aftermath of the GENIUS Act & Supervisory Implications 10:15 AM - 11:15 AM Jeremiah Bishop Commissioner, Wyoming Division of Banking

Rich Mumford Managing Member, Richard Mumford Consulting LLC

Polly Klyce Pennoyer Executive Deputy Superintendent, Banking Division, New York Department of Financial Services

Sabrina Bergen (moderator) Chief of Staff, Policy & Supervision, Conference of State Bank Supervisors

11:15 AM

Break 11:15 AM - 11:30 AM

11:30 AM

Visualizing A.I. in the Exam Process 11:30 AM-12:30 PM Rich Mumford Managing Member, Richard Mumford Consulting LLC

Ali Bandukwalla Principal, Deloitte Consulting LLP

Aleks Ontman, Ph.D. Senior Manager, Deloitte Consulting LLP

Avi Sinha Principal, Deloitte Consulting LLP

12:30 PM

Lunch 12:30 PM - 2:00 PM | Belleair Room

12:30 PM

CSBS Legislative Committee, (Invitation Only) 12:30 PM - 2:00 PM | Siesta Key

12:30 PM

CSBS Regulatory Committee, (Invitation Only) 12:30 PM - 2:00 PM | SHOR Private Dining Room

12:30 PM

CSBS State Supervisory Processes Committee, (Invitation Only) 12:30 PM - 2:00 PM | Longboat Key B

12:30 PM

Non-Depository Supervisory Committee, (Invitation Only) 12:30 PM - 2:00 PM | Sand Key

2:00 PM

Cybersecurity and Emerging A.I. Risks 2:00 PM - 3:00 PM Kevin Powers Faculty Director & Lecturer-In-Law, Master of Legal Studies in Cybersecurity, Risk and Governance, Boston College Law School

3:00 PM

Break 3:00 PM - 3:15 PM

3:15 PM

Dialogue with the FDIC 3:15 PM - 4:15 PM Suzanne Clair Acting Deputy Director, Division of Risk Management Supervision Federal Deposit Insurance Corporation Brian Cox Advisor to the Director, Division of Risk Management Supervision Federal Deposit Insurance Corporation

4:15 PM

Open Forum & Adjourn 4:15 PM - 4:30 PM

5:30 PM

Networking Reception | Sky Terrace, 16 th floor 5:30 PM - 7:30 PM

Thursday, December 11 8:00 AM

District Breakfasts and Conversations 8:00 AM - 9:00 AM Please check signs outside of rooms to confirm assignments.

District I |Sand Key District II |Bellair Room (West Side) District III | Bellair Room (East Side) District IV | Siesta Key District V | SHOR Private Dining Room Fundamentals of Effective Crisis Response 9:00 AM - 10:00 AM Mary Meagher President, The Meagher Group Jeff Eller Founder, The Eller Group

9:00 AM

10:00 AM

Break 10:00 AM - 10:15 AM

10:15 AM

Dialogue with the Federal Reserve 10:15 AM - 11:15 AM Todd Vermilyea Senior Advisor, Policy Planning, Federal Reserve Board of Governors

11:15 AM

Break 11:15 AM-11:30 AM

11:30 AM

Policy & Supervision Priorities 11:30 AM-12:30 PM Kevin George Senior Director, Legislative Affairs, Conference of State Bank Supervisors Mary Beth Quist Senior Vice President, Bank Supervision, Conference of State Bank Supervisors

Nathan Ross Vice President, Policy, Conference of State Bank Supervisors

Tony Vasile Senior Vice President, Nonbank Supervision & Enforcement, Conference of State Bank Supervisors

12:30 PM

Lunch & Conclusion 12:30 PM | Belleair Room

December 10-11, 2025 2025 Supervisors Symposium Clearwater, FL

ATTENDEES Alabama State Banking Department Andres, Jason

jason.andres@banking.alabama.gov jay.caver@banking.alabama.gov mike.hill@banking.alabama.gov John.Russell@banking.alabama.gov

Caver, Jay Hill, Mike

Russell, John

Arkansas Securities Department Tierney, Karyn Arkansas State Bank Department Marshall, Susannah

karyn.tierney@arkansas.gov

smarshall@banking.state.ar.us bmoseley@banking.state.ar.us dpatel@banking.state.ar.us jpowell@banking.state.ar.us Jwallace@banking.state.ar.us

Moseley, Baker Patel, Dharmin Powell, Jacklyn Wallace, Jessica

California Department of Financial Protection and Innovation Mohseni, Khalil Colorado Department of Regulatory Agencies Division of Banking Hunter, Kara

KC.Mohseni@dfpi.ca.gov

kara.hunter@state.co.us allison.rothermel@state.co.us

Rothermel, Allison

Connecticut Department of Banking Chambers, Joseph

joseph.chambers@ct.gov

Perez, Jorge

jorge.perez@ct.gov

Delaware Office of the State Bank Commissioner Collison, Lisa

Lisa.Collison@delaware.gov christopherL.Hall@delaware.gov

Hall, Christopher

Georgia Department of Banking & Finance Fears, Bo

BFears@dbf.state.ga.us msneed@dbf.state.ga.us

Sneed, Melissa

Idaho Department Of Finance Quintero, Gabriel

gabriel.quintero@finance.idaho.gov

Illinois Department of Financial and Professional Regulation Jennings, Matt

m.jennings@illinois.gov Susana.Soriano@Illinois.gov

Soriano, Susana

Indiana Department of Financial Institutions Dietz, Christopher

cdietz@Dfi.in.gov

Iowa Division of Banking Christensen, Craig

Craig.Christensen@idob.state.ia.us james.johnson@idob.state.ia.us Shauna.Shields@idob.state.ia.us

Johnson, James Shields, Shauna

*Denotes an attendee who is also a speaker

Kansas Office of the State Bank Commissioner Kemp, Tim

tim.kemp@osbckansas.org Jim.Payne@osbckansas.org Brock.Roehler@osbckansas.org

Payne, Jim

Roehler, Brock

Louisiana Office of Financial Institutions Jolly, Scott

PJolly@ofi.la.gov ckirkland@ofi.la.gov

Kirkland, Christine

Maine Bureau of Financial Institutions LaFountain, Lloyd

lloyd.p.lafountain.iii@maine.gov

Maryland Department of Labor Office of Financial Regulation Hennen, Amy

Amy.Hennen@maryland.gov kat.hyland@maryland.gov tony.salazar@maryland.gov michael.sprouse@maryland.gov

Hyland, Kathleen

Salazar, Tony

Sprouse, Michael

Massachusetts Division of Banks Cuff, Kevin

kevin.cuff@mass.gov

Gallagher, Mary

mary.l.gallagher@mass.gov

Michigan Department of Insurance and Financial Services Luetzow, Aaron

luetzowa@michigan.gov westrinj1@michigan.gov

Westrin, Jim

Minnesota Department of Commerce Barness, Kasie

kasie.barness@state.mn.us mark.hastie@state.mn.us

Hastie, Mark

Mississippi Department of Banking and Consumer Finance Kelly, Rhoshunda

rhoshunda.kelly@dbcf.ms.gov

Montana Department of Administration Division of Banking and Financial Institutions Hall, Melanie

mghall@mt.gov preynolds@mt.gov

Reynolds, Paul

Nebraska Department of Banking and Finance Bailar, Darcy

darcy.bailar@nebraska.gov kelly.lammers@nebraska.gov

Lammers, Kelly

Nevada Department of Business and Industry Financial Institutions Division O'Laughlin, Sandy

solaughlin@fid.state.nv.us

New Hampshire Banking Department Zoracki, Seth

Seth.M.Zoracki@banking.nh.gov

New York State Department of Financial Services *Klyce Pennoyer, Polly North Carolina Office of the Commissioner of Banks Bosken, Katherine

Polly.KlycePennoyer@dfs.ny.gov

kbosken@nccob.gov adeffenbaugh@nccob.gov estandrews@nccob.gov

Deffenbaugh, Annette St. Andrews, Eugene

*Denotes an attendee who is also a speaker

North Dakota Department of Financial Institutions Kruse, I. Lise

lkruse@nd.gov

Ohio Division of Financial Institutions Allard, Kevin

kevin.allard@com.ohio.gov

Prude-Smithers, Pamela

pamela.prude-smithers@com.ohio.gov

White, Ingrid

Ingrid.white@com.ohio.gov

South Dakota Department of Labor and Regulation Division of Banking Afdahl, Bret

bret.afdahl@state.sd.us

Texas Department of Savings and Mortgage Lending Retta, Hector

hretta@sml.texas.gov strotti@sml.texas.gov

Trotti, Stephany

Utah Department of Financial Institutions Berrett, Shaun Vermont Department of Financial Regulation Jandreau, Luke

shaunberrett@utah.gov

luke.jandreau@vermont.gov kelley.reed@vermont.gov

Reed, Kelley

Washington State Department of Financial Institutions Clark, Charles

charles.clark@dfi.wa.gov matthew.harvey@dfi.wa.gov shannon.tushar@dfi.wa.gov

Harvey, Matthew Tushar, Shannon

West Virginia Division of Financial Institutions Holstein, Dawn Wisconsin Department of Financial Institutions Swissdorf, Kim

dholstein@wvdob.org

kim.swissdorf@dfi.wisconsin.gov

Wyoming Division of Banking *Bishop, Jeremiah

jeremiah.bishop@wyo.gov yvonne.shafer-shaw@wyo.gov

Shafer-Shaw, Yvonne

SPEAKERS Boston College Law School Powers, Kevin Deloitte Consulting LLP Bandukwalla, Ali

kevin.powers@bc.edu

abandukwalla@deloitte.com aontman@deloitte.com avisinha@deloitte.com

Ontman, Aleks

Sinha, Avi

Federal Deposit Insurance Corporation Clair, Suzanne

sclair@fdic.gov brcox@fdic.gov

Cox, Brian

Federal Reserve Board of Governors Vermilyea, Todd Richard Mumford Consulting LLC Mumford, Rich

todd.a.vermilyea@frb.gov

rich@richardmumfordconsultingllc.com

*Denotes an attendee who is also a speaker

Strategic Resource Management, Inc. Pruss, Larry

lpruss@srmcorp.com

The Eller Group Eller, Jeff

info@ellergroup.com

The Meagher Group Meagher, Mary

mary@meaghergroup.com

CSBS STAFF Accreditation & Workforce Development Jarmin, Jennifer

jjarmin@csbs.org mmartin@csbs.org smonnet@csbs.org sstrub@csbs.org

Martin, Max

*Monnet, Sebastien

Strub, Sydney

Communications & Brand Strategy Fisher, Laura

lfisher@csbs.org slucernoni@csbs.org

Lucernoni, Shannon

Finance & Office Operations Green, Leila

lgreen@csbs.org

Matsubara, Elise

ematsubara@csbs.org

IT Vu, Ngoc

nvu@csbs.org

Office of the President Milhorn, Brandon

bmilhorn@csbs.org ldove@csbs.org

Dove, Le' Shea

Office of the General Counsel Lambert, Matthew

mlambert@csbs.org

Liu, Margaret McLaughlin, Lisa People Operations Haire, Kelly Policy & Supervision Alcala, Alejandro *Bergen, Sabrina Byers, Kevin *George, Kevin Lawson, Karen *Quist, Mary Beth *Ross, Nathan Szucs, Terrie

mliu@csbs.org

lmclaughlin@csbs.org

khaire@csbs.org tszucs@csbs.org

aalcala@csbs.org sbergen@csbs.org kbyers@csbs.org kgeorge@csbs.org klawson@csbs.org mbquist@csbs.org nross@csbs.org tvasile@csbs.org dbleicken@csbs.org ddwyer@csbs.org rmadison@csbs.org vpeck@csbs.org ephillips@csbs.org

*Vasile, Tony

Products & Solutions Bleicken, David

Dwyer, David Madison, Rich Peck, Vickie Phillips, Emil

*Denotes an attendee who is also a speaker

Stablecoins vs Tokenized Deposits Industry Perspectives

Prepared For:

December 10 th , 2025

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

U.S. Instant Payment Rails Overview

Mastercard Send (Move) Card Network (Mastercard) All Mastercard

Tokenized Deposits Private Blockchain JPM Coin (Kinexys) ~$1 Trillion (Flow) High (Pilot Scaling)

Feature

FedNow

RTP (TCH)

Visa Direct

Stablecoins

Card Network

Primary Rail

(Visa) Private Bank Rail New Federal Rail

Public Blockchain

Participants

~700+ Fis (US) ~1,400+ Fis (US)

Issuers All Visa Issuers

USDC, USDT ~$9 Trillion (Settlement)

~10 Billion (Global)

Not publicly disclosed

~750 Billion Annual Volume

~250 Billion

~2,000% (High growth/low base)

~38% (Steady mature growth)

YoY Growth

~20%

~40%

~50–80%

Global Payments , Remittance Varies (often ~$50k)

Global Payments Gig Economy, Disbursements

Global Payments Cross-Border, Remittance, B2B

Small B2B High Value

Large Corp B2B, High Value

Inst. Liquidity, Intraday

Best For

Very High (Institutional) Unlimited (Liquidity) Varies by Program

Max Limit

$10 Million

$10 Million

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STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Use Cases

Use Case

Value Proposition (Why Faster Payments Win)

Traction and Real-World Examples (2025)

Gig & Earned Wage Access (EWA)

DailyPay, Branch, Uber, Lyft, DoorDash offer instant or same day payout. Roughly 65% of gig workers now expect an instant pay option. Allstate, Geico, Progressive, and others now support instant claims. More than 30% of claim payouts use faster payment rails. Around 40% of RTP volume in 2025 is B2B. Large firms such as Cisco, IBM, and Walmart are using RTP for same day vendor payments. Large corporates move more billions nightly over RTP and FedNow to reduce idle cash drag and improve liquidity management. Zelle remains the best known name, but pure RTP and FedNow bill pay through providers grew about 180% year over year in 2025. The IRS is piloting instant tax refunds, and several states used FedNow for hurricane relief with payouts reaching affected residents within hours. Large platforms such as Amazon, Shopify, Stripe, and Adyen introduced Pay by Bank buttons. Early programs report conversion lifts of 7% to 12%. Platforms enable RfP flows where more than 70% of requests are paid within 60 seconds compared with less than 20% for emailed invoices. Lenders now fund loans over RTP and FedNow so borrowers see funds in less than 10 seconds in many programs.

Workers want pay as soon as a shift ends rather than a week later.

Insurance Claim Payouts

Policyholders expect funds within hours after an accident or storm rather than weeks. Avoid supply chain disruption by paying suppliers the moment goods are delivered or invoices are approved rather than waiting for batch ACH. Corporates sweep idle balances from many accounts into a single yield bearing account in real time. Members pay rent, utilities, and mortgages directly from bank to bank with immediate finality and fewer card or interchange fees. Disaster relief, tax refunds, and other public payments arrive in minutes rather than days, which improves financial resilience.

B2B Urgent & Just in Time Payments Treasury and Cash Concentration A2A Consumer Bill Pay

Emergency & Government Disbursements Pay by Bank for Commerce

Shifts checkout from cards to direct bank payments so merchants save 150 to 300 basis points on fees while still improving checkout.

Request for Payment (RfP)

A structured message triggers an instant payment when the member approves, reducing manual invoices and reconciliation work.

Loan & Credit Disbursements

Personal loans, home equity lines, and BNPL advances fund in seconds rather than one or two business days which boosts satisfaction. Cash moves in real time between checking and brokerage for trading or yield optimization without waiting for traditional ACH settlement.

Wealth & Brokerage Sweeps

Brokerages such as Robinhood, Fidelity, and Schwab support faster payment powered sweeps so investors can deploy funds the same day.

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STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Pricing & Speed Comparison

Payment type

Typical fee

Time to settle / availability

Credit card payment

≈ 2.7–3.5% + $0.05–$0.30

Auth immediate; funds T+1–2 days

Debit card (Durbin-regulated)

0.05% + $0.21 (+$0.01 fraud adj.)

Funds T+1–2 days

Debit card (non-Durbin)

≈ 0.80% + $0.15

Funds T+1–2 days

ACH (standard)

$0.25–$1.50

1–2 days (up to 3–5 held)

International wire transfer

$30–$50

1–5 business days

Remittance service

≈ 6.4% (for $200)

Minutes to days

Peer-to-peer app (consumer)

Free (P2P) / 1.75% instant cash-out

Instant to 1–3 days

FedNow (instant)

$0.045 per transfer; $0.01 RfP

Instant (seconds), 24/7/365

RTP (The Clearing House)

$0.045 per transfer; $0.01 RfP

Immediate finality, 24/7/365

Seconds

Stablecoin transfer (Solana, ETH L2)

< $0.01

4 4

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

A stablecoin is a cryptocurrency designed to maintain a stable value relative to a certain asset, such as the US Dollar. They combine the price stability of traditional money with the speed of crypto.

What are Stablecoins?

Price Stability

Barrier Instrument

Redeemable

Blockchain-Backed

Pegged to a reference asset (e.g., U.S. dollar) and backed by cash or high-quality liquid assets to minimize volatility.

Can serve as an intermediary asset between traditional money and other digital assets, enabling easy conversion.

Holders can exchange stablecoins for an equivalent value in FIAT currency at any time.

Transacts over distributed ledger networks, enabling near-instant, low-cost transfers.

5

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

GENIUS Act Provides a Legal Definition Genius Act n

RESERVES → Only bank deposits, T-bills, and overnight repos SEGREGATION → Assets held for stablecoin holders only (no leverage!) OVERSIGHT → Fed & OCC supervision for big issuers AML/KYC → Issuers are explicitly made “financial institutions” for all purposes under the Bank Secrecy Act.

It’s important to understand that stablecoins are “programable” and global.

6

6

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

How big are stablecoins?

• $315B+ market cap • Worldwide Stablecoin 12-month volume: $50T • $9T represents non-trading activity

7 7

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Stablecoins now rival the world's largest payment networks in transaction volume

Transaction Volume, Last 12 Months

$50T Unadjusted

$87T

$9T Adjusted

$16T

$1.7T

PayPal

Visa

Stablecoins

ACH

8

Source: a16zcrypto State of Crypto 2025

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Stablecoin payments cut out the complex banking networks, demanding regulations, and countless fees found in traditional payment rails.

How Do Stablecoins Work?

Payment Initiated

Send Wallet

Receive Wallet

Stablecoin Conversion

Network Settlement

Stablecoin Conversion

Payment Received

$

$

Initiate a payment or purchase using a wallet or stablecoin enabled payment app

Fiat converted to stablecoins via regulated exchange or provider Conversion fee (on-ramp)

Stablecoins are transferred peer-to peer or merchant to-merchant using a mobile wallet

Payment settles instantly across blockchain network Network transaction fee (“gas”)

Recipient wallet receives stablecoins instantly and can be stored there as a yield bearing asset

Stablecoins optionally converted back to fiat through exchange or bank Conversion fee (off-ramp)

Transaction completed. Funds are now available in the recipient’s end account

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STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Peer-to-peer Payments with no Intermediaries

Transaction fees for stablecoins can be as low as 1-2 basis points (0.01% to 0.02%) depending on the blockchain used.

1010

10

STRATEGIC RESOURCE MANAGEMENT

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Stablecoins are Evolving Rapidly Stablecoins have evolved from early experimentation to a maturing, regulated financial instrument with a clear path to adoption for Financial Institutions

2014

2018

2020

2022

2024

$200MM

$500MM

$25B

$140B

$160B

Tether launches the first fiat-backed and algorithmic stablecoins

Circle and Coinbase launch USDC with full fiat reserves

USDT (Tether) becomes the first stablecoin to surpass $10B in market cap

Tether Crash Wipes out over $40B in value, leading to regulatory crackdowns and market skepticism.

JPM Coin begins settling $1B daily in stablecoin transactions

Today - $315B market cap and >$50T world-wide transactional value

Corporate Adoption Payment Giants Fiserv, FIS, PayPal, Visa, and Mastercard boost stablecoin adoption

GENIUS Act Becomes Law Establishes a framework for fully backed, regulated stablecoins, enabling official adoption by U.S. banks

Circle (USDC) Files IPO on NYSE Major milestone that validates stablecoins as core fintech infrastructure powering trillions in transactions

11

STRATEGIC RESOURCE MANAGEMENT

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Stablecoins are making inroads on established and emerging payment and deposit use-cases

Stablecoin Use-Cases

Agentic & E Commerce

Treasury & Liquidity

Custody & Settlement

P2P Transfers

Remittances

Store of Value

Cross-Border

Consumer

Business

Consumer

Business

Consumer

Business

Consumer

Business

Consumer

Business Consumer

Business

Consumer

Business

• Instant wallet-to wallet transfers across apps and platforms • Enables micropayments and recurring transfers without intermediaries • Strengthens ecosystem effects through interoperable wallets

• Automated

• Direct consumer transfers bypass traditional remittance networks • Lower fees and faster delivery, no bank account required • Expands reach to

• Holding value in a fiat-pegged token for spending or short-term savings. • Used by consumers in high-inflation markets, freelancers, SMEs, Web3 users. • Dollar exposure without bank account; portable, programmable; composable with apps

• 24/7/365 real-time settlement replaces delayed international wires • Reduces reliance on ACH, SWIFT, and correspondent banks • Basis-point fees

• Real-time

• On-chain

payments triggered by AI agents or smart devices

settlement from corporate treasury operations

settlement reduces operational risks

• Streamlines collateral

improves cash positioning and intraday liquidity • Reduces reliance

• Smart contract escrows funds releases on delivery/event • Streamlines subscriptions,

management, clearing, and inter

institution settlement

on cutoff times or batching windows

• Reduces

improve liquidity and FX efficiency

• Enables

marketplaces, and digital commerce flows

underbanked and cross-border users

reconciliation burden through shared ledgers

programmable treasury workflows, better reconciliation

12

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Stablecoins deliver safety, utility, and global accessibility for everyday users Why Use Stablecoins?

•

Stablecoins operate on a full reserve model.

Safer by Design

1

• US law mandates full reserve backing (cash, short-term Treasuries, repos) making stablecoins bankruptcy remote and eliminating the need for FDIC insurance.

• Stablecoins live on the blockchain, accessed through a digital wallet, and function like digital bearer instruments. • Think of it like cash in pocket, except it's accessible anywhere in the world with an internet connection. • While interest payments are prohibited under the GENIUS Act, merchants may offer incentives for stablecoin use. • Users can also earn yield via DeFi smart contracts that often outperform high-yield savings.

Reward Potential

2

Portable & Convenient

3

• Stablecoins enable borrowing. They can be used as loan collateral, similar to borrowing against stock portfolios.

4

Collateral Utility

• Stablecoins provide a hedge against weak currencies. • Outside the US, consumers use stablecoins to protect themselves from inflation or unstable local currencies.

5

Currency Hedge

13

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Stablecoins introduce new paradigms that may redefine how payments are processed and settled

Stablecoin Implications

New Rails = Lower Cost + Faster Settlement • Stablecoins enables 24/7/365 real-time settlement • Reduces reliance on ACH, SWIFT, and card networks • Processing fees drop to basis points vs. 1–3% on cards

Disintermediation Risk

Infrastructure Evolution

New Business Models

Regulatory Shift

• Merchants and consumers may bypass traditional payment intermediaries • Fewer trusted third parties = less economic rent to capture • Potential threat to

• Movement

• Opportunities to offer: − Wallet custody − On/Off ramps − Payment APIs , embedded finance tools − Treasury and liquidity solutions • Growing expectation for programmable, composable financial products

• The GENIUS Act and similar frameworks are defining the playing field • Early movers will help shape standards on reserve quality, consumer protection, and interoperability

toward shared/unified ledgers may put pressure on legacy cores • Large processors (e.g., Fiserv’s FIUSD ) and bank consortiums are investing in tokenization platforms • Institutions must assess participation in clearinghouses or Regulated Liability Networks (RLNs)

interchange income , especially for smaller institutions

14

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

As with any new financial instrument, stablecoins present benefits and risks to stakeholders including the potential for lower transaction costs but with the burden of significant infrastructure changes.

Benefits and Risks of Stablecoins

border payments and remittances ✓ blockchain-based settlement ✓

cards ✓

Lower transaction costs, especially for cross

Lower transaction fees compared to credit

currency conversion ✓

Enhanced transparency and security via

Access to a global consumer base without

Limited recourse in case of transaction errors,

Limited adoption may hinder immediate

refunds, or fraud x

benefits x

Consumer Merchant

Dependence on digital access and technical

Integration complexity with legacy payment

literacy x

systems such as POS terminals x

Increased competitiveness in digital payment innovation and mitigate disintermediation risk ✓ New fee-based revenue opportunities such as custody and tokenization services ✓ Cannibalize traditional payment and deposit products x Additional AML/CFT compliance complexity for on-chain activity x

New product, service, and revenue opportunities ✓ Simplified cross-border processing ✓

Financial Institution

Processor

Requires significant infrastructure upgrades or

new capabilities x

Interoperability challenges across stablecoin

protocols (solved by clearing-houses) x

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STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Stablecoins are maturing with a clear path to adoption for financial institutions

Stablecoin Monetization Opportunities

Economic Impact and Ease of Execution

Degree of fit between revenue stream & the underlying partnership model

Custody & Reserve

Issuance / Co-Issuance

Revenue Stream

Infrastructure

Product

Impact

Execution

Transaction Fee & FX Spread Capture

Custody, Wallet & Account Services

Embedded Payments & APIs

Issuing & Interest from Tokenized Deposits

Treasury & Liquidity Solutions

Regulatory Advisory & CaaS

Note: Impact and east levels are based on a qualitative assessment of revenue potential and implementation feasibility across stablecoin-related use-cases

High

Medium

Low

Core

Optional

Out of scope

16

Source: Payments and Commerce Market Intelligence: How Banks Can Make Money with Stablecoins through Strategic Partnerships

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Stablecoins vs Tokenized Deposits Summary Tokenized Deposits: the Banks’ Answer to Stablecoins

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STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Why Use Tokenized Deposits?

• Represent direct claims on a licensed bank, subject to prudential regulation and supervision. • Benefit from established banking protections and have 1:1 redeemability into traditional deposits.

Regulated and Secure

1

• Tokenized deposits ensure automated payments, settlement rules, and conditional logic via smart-contract platforms. • Reduces operational effort for complex workflows (e.g., escrow, payout rules, supply chain events).

Programmable Money

2

• Near-instant transfer and settlement on shared ledgers – no need for batch, cutoff times, or intermediaries. • Supports always-on transaction environments (e.g., commercial payments, treasury)

Faster Settlement

3

• Can move across institutions and platforms where supported, allowing more flexible treasury and liquidity management. • Digital form factor improves accessibility while preserving ownership within the banking system.

4

Interoperable & Portable

• Can serve an on-chain collateral in controlled financial environments. • Creates opportunity for integrated lending and trade settlement. • Streamlines treasury management with real-time visibility and control.

5

Embedded Financial Utility

18

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Stablecoins vs Tokenized Deposits Summary Stablecoins vs Tokenized Deposits

Stablecoins • Digitally-native tokens pegged to a fiat currency (typically USD)

• Transact on public blockchains (e.g., Ethereum, Solana) • Backed by fully reserved assets such as cash, T-bills, or repos • Examples: USDC (Circle), PYUSD (PayPal), USDT (Tether) • Function like digital bearer instruments , enabling peer-to-peer payments without intermediaries Tokenized Deposits • Bank-issued digital tokens representing commercial bank money • Operate on private, permissioned blockchains • Backed by fractional reserves and often carry deposit insurance • Examples: JPM Coin (J.P. Morgan), USDF (bank consortium), Citi Token Services • Functionally like today’s deposit accounts, but optimized for programmability and atomic settlement Key Distinctions

Stablecoins

Tokenized Deposits Regulated banks Fractional reserves Private, permissioned Institutional, interbank

Issuer

Fintech or non-bank entities Fully reserved (e.g., T-bills) B2B, cross-border, consumer GENIUS Act (U.S. pending) Public, permissionless

Backing

Blockchain Type Use Case Focus

Regulation

Covered by existing banking regs

19

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Strategic Implications

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Let’s compare all of them….

Payment Method

Strength

Weakness

FedNow

• Central Bank Settlement

• Uneven Adoption

RTP

• Mature Ecosystem • Enormous Reach • Global Low Cost • Regulated Clarity

• Prefunding Requirements

Card push Stablecoins

• Variable Fees

• Potential Disintermediation

Tokenized deposits

• Early Ecosystem

21

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Merchant Settlement

Wallets / Embedded

Should I wait?

Use Cases

Retail P2P

Bill Pay / RfP

B2B/Treasury

Cross-border

(via RfP analogs, invoicing) (programmatic, instant)

(programmatic sweeps, intraday)

Stablecoins

(on/off ramp)

(marketplaces, platforms)

Tokenized Deposits

(cash mgmt, DvP/PvP)

(closed networks)

(limited today)

FedNow

(domestic) (domestic)

(RFP, billers)

(domestic payouts) (payroll, biller, B2B)

NA NA

(domestic) (domestic)

(bank apps)

(RTP RfP widely used)

RTP (TCH)

(via partners)

Revenue Opportunity

Total Revenue Opportunity

Direct fees On/off-ramp, issuance/ redemption Platform/ connect fees Modest service fees Modest service/usage fees High (wallets, ramps, chain ops, ledgering) Medium–High (ledger integration, APIs) Medium (gateway, core changes, posting) Medium (gateway, ISO 20022, posting) Tech lift

FX / Spread

B2B / Treasury

Advisory / Data Wallet/Custody

$$$-$$$$

(cross-border)

(programmable cash mgmt) (treasury services tiers) (corporate payouts)

(custody fees)

(risk, analytics, APIs)

Stablecoins Tokenized Deposits

$-$$$

(if cross-border later)

(enterprise wallets)

(data, ERP connectors)

$

—

—

(usage, insights) (billing analytics)

FedNow

$$-$$$

—

(billers, payroll)

—

RTP

Typical first-year costs*

Vendor dependence

Compliance lift

24/7 ops

Costs

High (KYC/AML, travel rule, custody, disclosures)

Stablecoins

Medium–High

Yes

$$$–$$$$

Tokenized Deposits

High (consortium)

Medium

Yes

$$–$$$

Medium (fraud, Reg E workflows)

FedNow

Medium

Yes

$$

RTP

Medium–High

Medium (fraud, disputes)

Yes

$$–$$$

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Financial institutions need a perspective on how stablecoins and tokenized deposits fit into their broader payment and banking strategy or risk further disintermediation

Dimension

Considerations

Stablecoins/tokenized deposits should likely be considered as part of a broader payment method and rail strategy, layering on to capture growth and differentiation. Stablecoins/tokenized deppsoits can be viewed as a complement to domestic faster payment rails (e.g., TCH, FedNow) as enabling those is currently the fastest path to creating member value with manageable risks. Wallet and international-oriented use-cases (stablecoins only) provide a compelling value-add to certain demographics. The technology shift will likely take years, nor will it leapfrog existing schemes; however, testing early and proactively building a governance structure may provide competitive differentiation in the future.

Strategy

Use-Cases

Timing

Partnership is likely best, as direct infrastructure build is too burdensome / costly for all but the biggest institutions or those with a specific B2B focus.

Enablement

Adopt a phased approach that begins with low-risk pilots and internal experimentation. Evaluate internal settlement and test partners. Ensure regulatory alignment is met.

Approach

23

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Questions & Discussion

Presented By: Larry Pruss https://www.linkedin.com/in/lpruss/ Managing Director, Emerging Payment Technologies lpruss@srmcorp.com

STRATEGIC RESOURCE MANAGEMENT | CONFIDENTIAL

Asset Size

Public Supervisory

Conference of State Bank Supervisors December 10,2025

GENIUS Act in a Nutshell

GENIUSAct: Key Elements

WHO CAN BECOME AN ISSUER?

PREEMPTION/PASSPORTS:

Federal issuers : l icensed, regulated, examined, and supervised exclusively by the Comptroller State Issuers : • host State laws, inc. laws relating to consumer protection, only apply to the activities to the extent they would apply to the activities conducted in the host State by an out-of-State Federal qualified payment stablecoin issuer • host State laws governing the chartering, licensure, or other authorization to do business are n/a

Uninsured national bank

IDI subsidiary

July18, 2025

GENIUS Act signed into law

U.S. federal branch of an FBO

Federal Agency deadline to issue final rules ( 1 year after enactment)

State-licensed PSC issuer (<$10B)

July ‘26

Options

Nov ’26 - Jan ‘27

GENIUS Bill takes effect (18 months after enactment)

Federal licensed non-bank entity (e.g., national trust charters)

Sales of PSCs by non-permitted issuers prohibited (3 years after enactment)

Foreign stablecoin issuer

July ’28

KEY AREAS COVERED IN THE GENIUS ACT

Transparency Issuers must regularly publish reports on their stablecoins (e.g., underlying assets).

Foreign Issuers Only comparable regulatory regimes may issue PSCs in the U.S..

Charter and Regulation Clear guidance on regulatory oversightand typesofcharter options.

Reserve Requirements Issuers must Maintain 1:1 reserve backing among multiple assets.

Notable Regulations PSCs issued under this framework areexempt fromsecurities law.

Future Standards Capital, liquidity, interest rate, risk management & AML standards.

.

.

Federal Interaction with State Programs

Federal Certification:

State programs must be certified by the Stablecoin Certification Review Committee (SCRC) as “substantially similar” to the federal framework established by the GENIUS Act within 1 year of the Act’s effective date (no later than Jan. 18, 2028) and recertified annually.

Federal Coordination & Oversight:

States must share information on state

State issuers with $10bn or more in outstanding issuance transition to co-regulation with the state and a federal regulator (either FRB or OCC) unless waived by federal regulator

States can opt into an MOU with the FRB to co-regulate all state issuers

FRB and OCC (for nonbanks) have exigent enforcement authority over state issuers

qualified issuers with the FRB (including application and throughout life of the entity)

GENIUSAct – PermittedActivities…How Big a Fig Leaf? REGULATORY LANDSCAPE

…but with a potentially significant “additional” authority or “loophole”

The GENIUS Act limits the permitted activities of “permitted payment stablecoin issuers” to a short list…

Issuing PSCs Redeeming PSCs

to engage in incidental nonpayment stablecoin activities that are authorized by the primary Federal (or State, if applicable) payment stablecoin regulator ” It remains to be seen how the Federal and State banking regulators will exercise this additional authority, and whether that exercise will be subject to successful legal challenges

Managing related reserves, including purchasing, selling, and holding reserve assets or providing custodial services for reserve assets, consistent with State and federal law Other activities that directly support the activities listed above

Public companies that are not predominantly engaged in 1 or more financial activities are not permitted to issue a payment stablecoin unless the public company obtains a unanimous vote of the Stablecoin Certification ReviewCommittee . This provision does not applyto privatecompanies.

2

So, you want to be a “State Payment Stablecoin Regulator” (SPSR), per GENIUS?

GENIUS Substantive Requirements State Must Meet: • State-level “regulatory regime” must be “ substantially similar ” to the Federal regulatory framework under GENIUS • Process for State certification refers to meeting standards and requirements in Sec 4(a) , which include reserves; no rehypothecation; monthly certification re reserves; capital, liquidity and risk management requirements; BSA/AML; activity limitations; tying; deceptive names; audits; no interest or yield; non-financial company ownership

GENIUS Process Requirements: • Secretary of the Treasury must, through notice and comment rulemaking, establish broad-based principles for determining whether a State-level regulatory regime is “substantially similar” to the Federal regulatory framework • SPSR must submit an initial and then annual certification to the Stablecoin Certification Review Committee (SCRC) that the State-level regulatory regime meets the criteria for “substantial similarity” established by Treasury; SCRC will promulgate certification form • Within 30 days following the initial certification submission, the SCRC will approve the certification if it unanimously determines that the State-level regulatory regime meets or exceeds the standards and requirements described in GENIUS Sec. 4(a), or deny the certification and provide the SPSR with a written explanation of the denial, describing the reasoned basis for the denial with sufficient detail to enable the State payment stablecoin regulator and State level regulatory regime to make any changes necessary to meet or exceed the standards and requirements described in 4(a)

The “GENIUS” framework outlines proposed regulatory protections for PSCs, aiming to enhance safety, transparency, and consumer trust. GENIUS Act Framework

GENIUS “PROTECTIONS”

DESCRIPTION

Requires 1:1reserveassetbacking byshort-termliquid assets like U.S. dollars; demand deposits at insured depositories (vs “insured” deposits); Federal Reserve Deposits; Treasuries with a maturity < 93 days; certain repos backed by T-bills or reverse repos; money market funds invested in approved assets Issuers must hold additional capital beyond 1:1 asset backing, plus liquidity requirements (details to be determined)

Reserve Asset Backing

Capital & Liquidity Requirements

-Issuers are prohibited from pledging or hypothecating of assets (with limited exceptions for liquidity management) - Custodians limitedto regulatedbroker-dealersand U.S.banks

Asset Pledge and Custody

Bankruptcy

Provides PSC holder US bankruptcy preference/priority

Reserve Disclosure

Requires monthly disclosures of reserves (subject to criminal penalties)

Redemption

Requires timely redemption of PSCs

Prohibits misleading marketing about government backing or insurance, restricts the use of consumer transaction data for advertising

Marketing and Data Use Restrictions

Leadership Requirements

Prohibits “bad people” (fraud, financial crimes) from leading PSC issuers

-Prohibits PSC issuer from paying interest or yield ( decreases customer confusion with insured bank deposits?) -Does not prevent payment of rewards/incentives by partners

Yield Payment Prohibition

Restrictions on Issuers

Prohibits direct issuance by public commercial companies (Amazon, Starbucks, Walmart etc.)

Key Payment Stablecoin (“PSC”) Risks

R I SKS

DESCRIPTION

IMPLICATIONS

Customer Misunderstanding

PSCs are not bank deposits, lack FDIC insurance, & are not government guaranteed

Can leadto confusion, lossof trust and regulatory scrutiny.

PSC value depends on reserve assets. If reserves lose value or are concentrated, the token may drop below its intended peg.

De-Pegging Risk

Cantrigger volatilityandundermineconfidence.

Liquidity and Redemption Risk

Mass redemptions may force rapid asset sales, causing delays or losses.

Threatens PSC stability and market trust.

Counterparty depository fails; asset custodian is hacked or has material operational snafu and losses.

Counterparty Risk

Stressestheneedfor reliablepartners.

Issuerincomedependsonreserveyields,andratechanges(e.g., zerorate environment) can reduce earnings or cause losses

Interest Rate Risk

Affects profitability and PSC stability.

Minting/Burning Operational Errors

Operational mistakes can create or destroy incorrect PSC amounts.

Mayresultinfinanciallossorregulatory issues.

Fraud and Misconduct

Risk of theft, misappropriation, or manipulation.

Leads to legal and reputational damage.

FXRisk

Currency fluctuations impact PSC value in international use.

Users and issuers may face unexpected gains or losses.

Network Congestion

High transaction volumes can slow the blockchain.

Reduces efficiency and user experience.

Operational Risks (Cybersecurity & Data Protection) AML/BSA Regulatory Compliance

System breaches or cyberattacks can disrupt PSC operations.

Results in financial loss and regulatory penalties.

Issuers must follow anti-money laundering and Bank Secrecy Act rules

Non-compliance leads to fines and legal action.

18

18

StablecoinState SupervisoryConsiderations

Legal, Regulatory and Enforcement Powers of Federal and State Regulators over PSCs

FEDERAL

STATE

SOURCE

No, except State issuers by home State (< $10B unless federal waiverprovided)

GENIUS Act

Yes

No re PSC Issuer. Per16(d), norefiatmoneytransmissionactivities by State uninsured bank sub PSC issuer

State Money Transmission Licensing

n/a

General anti-fraud enforcement authority

Yes

Yes

Federal UDAAP

???

Maybe?

State UDAP/UDAAP

n/a

Maybe?

RegE Electronic Fund Transfers

???

???

Reg DD Truth in Savings

n/a

n/a

Reg I “NDIP” Disclosure Requirements for Depository Institutions Lacking Federal Deposit Insurance

n/a

n/a

Securities registration laws

No

No

Lending, credit, debt collection, securities laws and regulations generally are not applicable

2

M.L.S. in Cybersecurity, Risk & Governance

Master of Legal Studies (MLS) in Cybersecurity, Risk & Governance

“Cybersecurity and Emerging A.I. Risks” Professor Kevin R. Powers Conference of State Bank Supervisors (CSBS) Supervisors Symposium Clearwater, FL December 10, 2025

1

Artificial Intelligence (AI) Governance & Risk Management

M.L.S. in Cybersecurity, Risk & Governance Master the Law. Mitigate the Risk. Lead in Cybersecurity.

ACADEMIC LEADERSHIP  Founder, Faculty Director & Lecturer-in-Law  Master of Legal Studies (MLS) in Cybersecurity, Risk & Governance Program, BC Law  Professor of the Practice, BC’s Carroll School of Management  Research Affiliate & Senior Lecturer: MIT Sloan School of Management  Former Deputy JAG to the Superintendent, U.S. Naval Academy PROFESSIONAL EXPERTISE  Cybersecurity, Technology (AI), and Privacy Expert Witness and Litigation Consultant (Analysis Group)  Trainer and Consultant: Boards of Directors and Senior Management, Financial Services (e.g., John Hancock, Bank of America)  Board Director (Reading Cooperative Bank), Trustee (former Chair, Boston College High School), and Advisor (HYCU (Backed by BCV), Acium, & CyberSaint) BACKGROUND  Attorney with 25+ years experience in private and government practice, focusing on cybersecurity, technology (AI), and data privacy law, policy, governance; business strategy and litigation; and national security, law enforcement, and military law and policy  U.S. Navy Veteran

Kevin R. Powers Boston College Law School

FFIEC

2

MLS in Cybersecurity, Risk & Governance :