Frequently Asked Questions

Background Information on Commercium and SPDI's

Yes - Commercium is a state-chartered bank under Wyoming's special purpose depository institution ("SPDI") law. As a depository institution, Commercium meets the definition of a bank under state and federal law.

A Wyoming-chartered SPDI is a full reserve bank that receives deposits and conducts other activity related to the business of banking, including custody, asset servicing, and fiduciary asset management. SPDIs can handle digital assets, such as virtual currencies, digital securities, and digital consumer assets. SPDIs may deal in traditional assets as well, by serving as a vehicle for business cash management, operational accounts, and any other purpose permitted under applicable law.

A TC is a separate corporate entity owned by a bank or other financial institution, law firm, or independent partnership. Its function is to manage trusts, trust funds, and estates for individuals, businesses, and other entities. A trust is an arrangement that allows a third party or trustee to hold assets or property for a beneficiary or beneficiaries. TCs get their title from the fact that they act in a fiduciary capacity for their clients—as trustees.


SPDIs and TCs are different in multiple ways. Important differences include:

  1. SPDIs are regulated as banks and must comply with banking regulations and special, strict regulations applicable to SPDIs (for example, have their customer deposits of fiat currency at all times backed 100% or more by unencumbered liquid assets, which include U.S. currency and level 1 high-quality liquid assets).
  2. SPDIs advance qualified custody of securities and digital assets. SPDIs may provide custodial services for digital assets and perform authorized transactions for customers. Further, the Wyoming SPDI laws mean that only SPDIs can provide an effective bailment while permitting direct ownership of securities, all provable through the blockchain.
  3. SPDIs may conduct activity under Wyoming regulations tailored to digital assets, which address issues such as technology controls, transaction handling, and custody operations for digital assets.
  4. SPDIs operate under Wyoming law that defines digital assets in conjunction with the Wyoming Uniform Commercial Code and describes, among things, perfection and priority of security interests in digital assets.
  5. SPDIs may resemble custody banks because they will likely be predominantly engaged in custody, safekeeping, and asset servicing activities. A custody bank is focused on safekeeping assets, fiduciary management, transaction processing and settlement, and providing an “on/off” ramp to securities markets, commodities markets, and customer bank accounts.
  6. A SPDI can engage in a wider range of activities than a TC.
  7. A TC is often owned by another entity, such as a bank.

No, deposits with Commercium are not FDIC-insured. However, Commercium must comply with all SPDI reserve requirements, which ensures the safety of customer deposits. Please see the question - "how are customer deposits protected without FDIC insurance?"

Commercium, unlike many banks, does not engage in lending or fractional reserve banking, instead, 100% of customer deposits are held in reserve with additional protective measures. Here is how deposits are safeguarded in the event of bankruptcy:

  • 100% Reserve in Liquid Assets: All customer deposits are held in unencumbered, high-quality liquid assets. Specifically, Commercium's investment policy mandates retaining at least 20% in cash. The remainder is invested in US Treasury bills with a maximum tenure of 3 months. This, combined with constant liquidity management ensures that all customers will be able to access their deposits immediately. In the unlikely event of a very severe run on the bank occurs, 100% of all deposited funds will be available within 3 months. However due to the nature of 100% reserves, the chances of a bank run are much less likely than at a fractional reserve bank.
  • Capital Reserves: Beyond holding 100% of customer deposits, Commercium will maintain a capital reserve of between 2% and 4% (final amount pending) against all assets. For instance, for every $1 billion in customer deposits, a capital reserve of $20 million to $40 million will be required.
  • Legal Framework & Guidelines: Although the Wyoming Banking Division hasn't yet overseen a liquidation, their procedures are outlined in section 12-12-123 of the SPDI Charter under the voluntary dissolution section.
    • Title 13 - Banks, Banking and Finance
  • Capital Requirements: Prior to opening, Commercium is required to retain capital of at least $30 million. As the bank grows its assets, the minimum capital requirement will be either $30 million or 2-4% of assets, whichever is greater.
  • Asset Pledge: In addition, $15 million of bank assets will be legally pledged to the State Banking Division, ensuring they can promptly address potential harm to the SPDI charter during any forced or voluntary liquidation. This pledged amount is accessible immediately, even before any remaining capital post-liquidation.
  1. Our Banking services are traditional banking products:
    • USD checking, savings, escrow accounts, FBO accounts
    • Payment services (ACH, wire, Bill Pay)
  2. Full Reserve Bank versus Fractional Reserve Banking:
    • 100% of Commercium customer deposits are held in reserves.
    • 4% or $30 million capital, whichever is greater, on top of 100% reserves.
    • We cannot leverage our capital.
    • Our Charter prohibits us from engaging in any form of lending.
    • Our Charter prohibits the issuance of credit cards.
  3. We have no immediate plans to enter the crypto space, and will only do so once clear US regulation has been established.
  4. We will only enter the Stablecoin space once full regulatory approvals are received for the industry.
  5. Our tokenization of financial and real-world assets have received US regulatory approval in the marketplace.

Fractional reserve banking is a banking system where only a fraction of their depositors' balances are available for withdrawals, with the rest used to lend out to other customers. For example: if a customer deposits $100 in their bank with a reserve requirement of 10%, $10 is cash and $90 is lent out to other customers. If depositors simultaneously lose confidence, especially if the bank's investments underperform or lose money, and try to withdraw their funds, the bank runs the possibility of not having enough liquid cash on hand to cover all withdrawals, leading to a bank run.

Historically, the choice whether states would require their banks to be insured or federally regulated rested solely with the states, not with Washington, D.C, and until approximately 1990 most state laws were silent on the topic. Banks simply chose to be FDIC insured and federally regulated, and the Fed and FDIC routinely granted them access. But five U.S. states held back, keeping flexibility for themselves and a check on potential overreach by federal bank regulators. The five states - Connecticut, Maine, Nebraska, Vermont and Wyoming - enacted bank charters that neither require insurance nor federal regulation. Such uninsured state banks are prohibited from lending (either explicitly by law or functionally), and therefore hold 100% cash to back customer deposits plus up to 8% of deposits as an additional capital requirement.

Commercium's Business Plan

As part of CFI's core banking implementation, CFI will test and have approval to launch products and services for commercial and retail customers. CFI's plan for day 1 is commercial, but by testing retail products this means CFI can launch at a much quicker pace later on.

The Wyoming Division of Banking has expressed no objections to allowing SPDI's to accept non-US citizen customers or deposits. However, for the initial opening of the Bank we will only be focusing on accounts for US residents.

As part of our core banking implementation (checking accounts, savings accounts, bank services) with NYMBUS, we have secured alongside a back-office capability and a call center capability. These two areas from NYMBUS who already serve many banks, will be linked with the proposed Commercium back-office capabilities.

Regulatory and Compliance

Commercium is a state-chartered U.S. bank, regulated by the Wyoming Division of Banking, and is subject to the same standards that govern all banks, including bank-level capital requirements and bank-level compliance requirements (including the higher standard that applies to banks called the "Customer Due Diligence Rule"). Additionally, as a regulated bank, Commercium will be subject to frequent supervisory examinations that may not apply to non-banks.

Blockchain and Tokenization

We will leverage vendor-provided blockchain technology. As with any software vendor, the security measures will be proven through their documentation and will first demonstrate software compliance through initial testing before being accepted and integrated. User acceptance testing, penetration testing, and deployment testing procedures, etc. will be developed for system approval through both internal and third-party evaluations before we are certified by the Wyoming Division of Banking.

Commercium will ensure the safety and security of customer digital assets through a multi-faceted approach. We will partner with a reputable wallet custody provider known for its robust rules-based security measures, designed to prevent unauthorized actions, even internally. Additionally, Commercium will partner with Chainalysis, a renowned blockchain analytics and Know-Your-Transaction vendor to ensure that all transactions comply with stringent US regulations and anti-money laundering (AML) laws. Furthermore, to enhance security, private keys will be broken up in such a way that no single location or individual can gain full access to them.

With the recent decisions from the Federal Reserve as it pertains to banking, it has become apparent that public blockchains, such as Ethereum, may not be favored or allowed in banking. With this recent development, we are considering a permissioned or private blockchain for our use, just as was presented in our business case to the Wyoming Division of Banking to receive our charter.

Part of our software vendor selection will include the ability to support the integration of multiple blockchain types. This is designed to ensure we can adapt to any regulatory-approved developments. While no one can yet guarantee support of any future US-backed digital currency, we are following the development of the Central Bank Digital Currency (CBDC) to ensure we have the maximum opportunity to complement these developments.

Privacy policy

© 2023 Commercium Financial, Inc.

All Rights Reserved

© 2023 Commercium Financial, Inc.

All Rights Reserved

Deposits with Commercium and investment products and services of Commercium are not FDIC insured. Your funds are subject to loss of value, including the amount deposit and the principal amount invested.

About Commercium: Commercium Financial, Inc. is a Wyoming SPDI Bank formed to serve as a custodian of digital assets and securities that can bridge to the US federal reserve system. Commercium is required to comply with Wyoming law pertaining to digital assets and special purpose depository institutions as amended. Commercium is required to always maintain 100% of its dollar deposits in reserve. Neither this site nor any press releases or statement made by an officer or director of Commercium contained herein, constitute an offer to sell or a solicitation of an offer to purchase any securities, although they may contain “forward-looking statements” within the meaning of the safe harbor provisions of the U.S. Private Securities Litigation Reform Act of 1995. Such forward-looking statements are based on current beliefs, assumptions, expectations, estimates, regulatory frameworks, and business projections and should not be relied upon, and/or may change without notice, as actual results may differ materially from these expectations due to certain risks, uncertainties, and other important factors. You are cautioned future circumstances, events, or results may differ materially from those projected in the forward-looking statements.