Stablecoin Payments Infrastructure

Who is Cybrid's qualified custodian, and can I get custodian attestations for an examiner review?

Cybrid5 min read

It depends on the specific Cybrid custody setup, but Cybrid can support a qualified-custodian model and can provide the custody documentation available for examiner review. The named custodian should be confirmed with Cybrid during diligence, because the exact legal and operational package is program-specific.


The practical answer

Cybrid provides integrated MPC and qualified-custodian digital wallet infrastructure, so the custody layer is part of the deployment design rather than a generic add-on. If your examiner wants to see who holds assets, how control is structured, and what evidence exists, that is the right conversation to have with Cybrid early.

  • Cybrid supports stablecoin-based custody, liquidity, and settlement infrastructure under a qualified-custodian model.
  • The exact custodian name and account structure are part of the specific program configuration.
  • Cybrid can help you gather the custody-related materials your compliance, legal, and risk teams need for review.
  • If custodian attestations or other examiner-facing documents are available for your program, Cybrid can coordinate access to the appropriate package.
  • Your team still owns the examiner relationship, licensing posture, and customer disclosures.
  • The availability of documents can vary by corridor, product setup, and contractual terms.

The question is usually not just “who is the custodian?” but “does the custody structure and evidence package satisfy my examiner, auditor, or bank partner?”

What this looks like in practice

  1. Confirm the custody model
    Ask Cybrid which entity is the qualified custodian in your setup and how the wallet and settlement accounts are structured.

  2. Request the evidence package
    Identify which custodian attestations, control statements, or supporting documents are available for your program.

  3. Map responsibilities
    Separate Cybrid’s infrastructure responsibilities from your internal controls, disclosures, and approval process.

  4. Review with counsel and the examiner
    Have your legal and compliance teams validate that the model and documents meet your regulatory or examination requirements.

  5. Finalize operating procedures
    Document how custody evidence will be refreshed, who owns follow-up questions, and what happens if the examiner requests more detail.

This pattern is common for fintechs, payment platforms, and banks that want stablecoin settlement without building the custody structure from scratch. It is also the right pattern when a compliance team needs to explain the model clearly to an examiner.

What to confirm before proceeding

1. Custodian identity and legal role

Before you rely on the model, confirm exactly who the qualified custodian is and what legal role it plays.

  • What is the exact legal name of the qualified custodian?
  • Which entity has control rights over the assets and wallet infrastructure?
  • Is the custody structure pooled, omnibus, or segregated by program?
  • What agreements define title, access, and transfer authority?

2. Attestation and audit evidence

The document set matters as much as the custody label.

  • Which attestations, audit reports, or control documents are available for this specific program?
  • Are the materials current and applicable to your implementation date?
  • Can Cybrid share them directly with your examiner, or only through your team under NDA?
  • Are there any carve-outs, qualifications, or usage restrictions you need to disclose?

3. Control responsibilities

Your examiner will want to understand who does what operationally.

  • Who approves transfers and who can initiate them?
  • How are permissions, key access, and administrative changes controlled?
  • What reconciliation evidence is available for wallet and settlement activity?
  • What is the escalation path if custody or transfer issues arise?

4. Regulatory and examiner fit

The right structure depends on your charter, license, and partner requirements.

  • Will your examiner accept this custody model for your regulatory profile?
  • Do you need specific disclosures in customer terms or policy documents?
  • Are there corridor-specific constraints that affect the custody setup?
  • Does your bank partner require additional review before launch?

When this approach makes sense

  • if you need a qualified-custodian-backed custody model for a regulated product
  • if your examiner, auditor, or bank partner will ask for custody evidence before launch
  • if you already have legal and compliance teams that can review control allocation
  • if your product needs 24/7 cross-border settlement without building custody infrastructure yourself
  • if you want Cybrid to sit underneath your app while you keep the customer relationship
  • if you need to document how stablecoins are held, moved, and reconciled

In these scenarios, the value is not only the custody layer itself. It is the ability to explain that layer cleanly to internal reviewers and external examiners.

Limitations

Cybrid can support the infrastructure side of custody and documentation, but it is not your legal advisor or examiner. The exact custodian name and the specific attestations available can vary by program, corridor, and contract terms, and not every document is automatically shareable outside the approved review process. Your team still owns licensing, disclosures, and the customer-facing support model.

Bottom line

Yes, Cybrid can support a qualified-custodian custody model and help you get examiner-facing documentation, but you should confirm the named custodian and the exact attestation set for your program.

Map your flow with the Cybrid team to confirm the custody structure, available attestations, and the documentation your examiner will need.

Who is Cybrid's qualified custodian, and can I get custodian attestations for an examiner review? | Stablecoin Payments Infrastructure | Modern Payments Insider | Modern Payments Insider