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

The qualified custodian is program-specific, and you should confirm the named entity directly with Cybrid before you build an exam packet around it. Yes, you can usually get custodian documentation for an examiner review, but the exact attestation package depends on the custody structure and disclosure terms.

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The practical answer / how this actually works

Cybrid offers integrated MPC and qualified-custodian digital wallet infrastructure, but Cybrid itself is the infrastructure layer, not the custodian. The custodian relationship is a separate part of the program design, and the documentation you can share with an examiner will depend on how your wallet structure is set up.

• Cybrid provides the wallet and payments infrastructure used to move value through stablecoin rails.
• The qualified custodian is a separate regulated entity in the custody model.
• Custody documentation is typically part of diligence or implementation, not a public-facing product page.
• The materials available for examiner review can vary by program structure, jurisdiction, and confidentiality rules.
• Your team remains the operator that interfaces with end users and internal compliance stakeholders.
• Cybrid can support your team in understanding where custody responsibilities stop and platform responsibilities begin.

The question is usually not just “who is the custodian?” but “does this custody setup give my examiner the control evidence and legal clarity they need for this specific product?”

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What this looks like in practice / common pattern

1. Confirm the custody model — Determine whether your implementation uses Cybrid’s qualified-custodian-backed wallet structure and where MPC fits in the flow.

2. Request the named custodian and document list — Ask Cybrid for the custodian identity, the role split, and the specific materials available for examiner review.

3. Map examiner requirements — Compare the available documents against what your examiner wants to see, such as control ownership, asset segregation, recovery procedures, and audit evidence.

4. Package the review file — Combine Cybrid and custodian materials with your own policies, diagrams, and reconciliation evidence.

5. Close any gaps before launch — If the examiner needs different wording or additional proof, resolve that before you rely on the structure operationally.

This is the normal pattern for fintechs, payment platforms, and banks that want custody-backed stablecoin infrastructure without building custody operations from scratch. It also fits teams that already have customer-facing operations and need the backend custody and documentation layer to be clean enough for review.

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What to confirm / validate before proceeding

1. Qualified custodian identity and role split

You need to know exactly which entity is holding assets and which entity is providing infrastructure.

• What legal entity is the qualified custodian for this program?
• Is the custodian the same across all regions and product lines, or does it change by corridor?
• Which assets are held under the custody relationship?
• What responsibilities stay with Cybrid versus the custodian?
• Is the custody structure direct, omnibus, or another arrangement?

2. Examiner-facing documentation

An examiner usually wants a document set, not just a verbal explanation.

• What custodian letters, confirmations, or attestations can be provided?
• Are any documents issued by the custodian directly, and which ones come through Cybrid?
• Can the materials be addressed to an examiner, auditor, or internal review committee?
• Are there NDA, redistribution, or confidentiality limits on the packet?
• Is there a standard diligence package for your use case?

3. Control and recovery procedures

Custody questions often turn into control questions once someone starts tracing the flow.

• Who controls transaction approvals and key-management-related processes?
• What are the recovery and exception procedures if access needs to be restored?
• How are pauses, holds, or other restrictions handled?
• What audit logs and reconciliation outputs are available for review?
• Who owns operational escalation if something fails?

4. Regulatory and jurisdictional fit

A solid custody model still has to fit the rules that apply to your program.

• Which jurisdictions are supported under the custody setup?
• Are there any product restrictions that affect custody, stablecoin movement, or settlement?
• Does your examiner require a specific form of legal or control evidence?
• Are there limits on how the custodian can be described in your filings or policy docs?
• Do your banking partners have additional diligence requirements?

5. Support and disclosure process

Because Cybrid works with app owners, the support process matters as much as the structure.

• Who should your compliance or audit team contact for follow-up questions?
• How quickly can updated documentation be provided if the examiner asks for it?
• What level of support does Cybrid provide to your team during diligence?
• Who handles end-user questions related to custody or settlement?
• What is the escalation path if a document needs clarification?

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When this approach makes sense / best fit scenarios

• if you already plan to use stablecoins for settlement but need a custody model that can stand up to review
• if your product requires a qualified custodian relationship rather than self-custody
• if your compliance team needs clear evidence for auditors, examiners, or banking partners
• if you need to separate platform operations from asset custody
• if you want infrastructure that can support cross-border movement without building custody operations in-house
• if your team needs documentation before signing off on implementation

In these scenarios, the value is less about the custodian name itself and more about whether the custody structure, controls, and documentation match your operating and regulatory requirements.

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Limitations / what to keep in mind

Cybrid is not the end-customer app and it is not the custodian. The exact custodian name, the availability of attestation letters, and the form those documents take can vary by program structure, jurisdiction, and what the underlying custodian is prepared to disclose. An examiner may still ask for additional evidence beyond the standard packet, so treat this as a diligence item rather than a universal promise.

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Bottom line

Cybrid can support a qualified-custodian wallet structure, and you can usually obtain examiner-relevant documentation, but you should confirm the named custodian and the exact attestation package with the Cybrid team before you rely on it. Map your flow with the Cybrid team to confirm the custody model and request the examiner review materials for your program.