No GENIUS Act obligation binds yet; the effective-date backstop is 18 January 2027. Build the reserve record and the examination pack now, because the CEO and CFO certify against whatever record exists then.
A reserve is held at a custodian, and the position is pulled from supported custody, ledger and chain sources.
02
A holding is tested against the closed asset list at GENIUS Act § 4(a)(1)(A), and anything outside it is named.
Reason
03
A Treasury position is re-tested for remaining maturity daily, because the limit is not a purchase-date test.
04
A reserve pool is tied to a single stablecoin brand, and a commingled position is flagged rather than allocated.
05
A coin count is reconciled from the mint-and-burn ledger to on-chain supply, and each difference is described.
Decide
06
A redemption settles, and the reserve movement behind it is matched to the published redemption policy.
07
A reserve use is logged against the § 4(a)(2) exception claimed for it, and an unmatched use stays open.
Out
08
A pack is retained as a dated version, alongside the composition disclosure and what each officer was shown.
09
A write action runs only inside the approval boundaries agreed during implementation.
→Product statement
The agent maintains the record and assembles the pack; a registered public accounting firm examines it, and the CEO and CFO both certify.
Example workflow
One month, custody to certification
AgentHuman
1Month-end positions receivedCustody statements, ledger extracts and on-chain supply reads
2Composition assembledEligibility, residual maturity, average tenor, custody location and coins outstanding
3Pack draftedComposition schedule, exception log, open items and confidence
4Controls appliedEligibility tests, maturity re-tests, brand-segregation checks and confidence threshold
No human action required
Stages 1 to 4 run unaided, and nothing is certified at any of them — the agent is assembling a record, and the treasury lane opens at the confidence gate.
5DecisionBranches at the confidence threshold
High confidence
Goes to the reserve owner to approve.
Low confidence
Adds a controller read first.
Reserve-owner approval
The pack is held with its custodian confirmations, its open items and the confidence.
Approve · Amend · Send to controller review
Approved — released to the accounting firm▼
6Reserve systems updatedOnly where write access and approval policy allow it
7Outcome evaluatedAmendment distance, open-item outcomes, examination findings and post-publication corrections
Amendments
Every reviewer amendment is counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required8 items
Certifying the monthly report — the CEO and the CFO, both.
The monthly examination — a registered public accounting firm.
Deciding that a reserve asset qualifies.
Invoking an exception to the reuse prohibition.
Automation boundaryAgent acts unaided
✓Reconcile reserve positions across custodians to the ledger.
✓Re-test residual maturity and eligibility, day after day.
✓Tie coins outstanding to on-chain supply, and name the difference.
✓Draft the composition disclosure, and hold the pack for its owner.
Writes run only inside the boundaries agreed at implementation, and never ahead of approval.
Publishing the monthly composition to the issuer's website.
Setting or amending the public redemption policy.
Engaging and instructing the accounting firm.
Changes to eligibility, segregation or approval rules.
Example output
One reserve position, annotated
Everything the agent assembles is attached to the position it was drawn from.
Reserve record output · single positionIllustrative example
Custodian
Instrument
Remaining maturity
Source of record
Confidence
Eligibility basis
Primary reserve custodian
Treasury bill · remaining maturity re-tested
61 days
Custodian statement
88%
Named item on the § 4(a)(1)(A) list
As receivedTaken from the custodian statement and the month-end extract — nothing on this side is written by the agent.
Source facts usedCustodian statementMonth-end position fileOn-chain supply read
Why this is eligibleRemaining maturity is re-tested each day, so eligibility reads as a current fact.
ActionApproveAmendSend to controller review
What the score decidesBelow the configured threshold the position picks up a controller read first.
Value
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value landsValue 01 – 04
Every positionFrom the custody record
03Assembly
Test what the statute lists
Eligible assets are a closed list, and the limit runs on remaining maturity — GENIUS Act § 4(a)(1)(A).
01Approved path
Two officers, criminal exposure
A false certification imports the criminal penalties of 18 U.S.C. § 1350(c), by way of § 4(a)(3)(C).
02Human review
Assembly, not attestation
The agent builds what the firm tests; the examination under § 4(a)(3)(A) is the accounting firm's, and its report stays the firm's.
04Build an evidence trail
The reserve, the composition rule it was tested against and the officers who certified stay on the pack.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
Custody and reservesBNY · State Street Anchorage · Fireblocks
Chain and token dataNode and indexer APIs Mint-and-burn ledger
Treasury and general ledgerKyriba · GTreasury Core banking · GL extracts
Agent
Reserve record & examination pack
Reads the positions Assembles the pack Holds for approval
Close and disclosureWorkiva · close tooling Website · disclosure feed
A programme-level reconciliation figure can read as clean while a few reserve classes absorb most of the amendments. Nestack reports the amendment rate by reserve class, not only in total.
Slice performance — reported separately, not only in aggregateIllustrative example
Slice
Failure rate
Lift
Lift vs. threshold
Status
Tokenised money market funds
8.6%
3.7×
Review
Omnibus custody accounts
7.0%
3.0×
Review
Overnight repo positions
4.0%
1.7×
Watch
Direct-held Treasury bills
1.2%
0.5×
Normal
Bar: amendment-rate lift vs. direct-held-bill baseline · scale 0–4.0× · tick marks the 2.0× review threshold2 of 4 slices over threshold
Evidence-linked improvement
A cycle ends where a test begins
A cycle closes when the unreconciled reserve is a case the next release has to catch. That suite is what the next pack assembled is measured against.
Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect
Amendment rate rises in a reserve class.
02Diagnose
The month the composition moved and the pack still said otherwise is read back until the cause narrows to one.
03Improve
Number the correction, and the reserves that surfaced it stay fastened to it.
04Verify
No release while a touched reserve case is outstanding; it reruns first.
05Learn
The case is retained, and the composition rules change in the same commit.
Learn → DetectThe return edge. The next month is detected against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, reserve workflow, evaluation, integration, then production validation and handover.
WorkstreamWeek 1Week 2Week 3Week 4Week 5Week 6
01Reserve workflow discovery and boundary mapping.
02Custody, ledger and chain assessment.
03Eligibility, maturity and segregation rule mapping.
04Position ingestion and reconciliation.
05Pack assembly and source binding.
06Confidence scoring and exception routing.
07Reserve-owner approval workflow.
08Custody and ledger integration.
09Composition and segregation cases.
10Guardrails and attestation controls.
11Reserve-trail instrumentation.
12Deployment, documentation and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallelFinal scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
Capability✓ in scope · — not at this tierPilotOne brand, one monthProductionProduction custody systemsAdvancedMultiple brands / issuers
Introduced at Pilot
Reserve record and reconciliation✓✓✓
Reserve-owner approval✓✓✓
Reconciliation-completeness baseline✓✓✓
Introduced at Production
Reporting by reserve class—✓✓
Exception workflow in your systems—✓✓
Approved write-back—✓✓
Custody and ledger integration—✓✓
Introduced at Advanced
Multi-jurisdiction custody rules——✓
Multi-stage treasury approvals——✓
High reserve volume——✓
Multi-issuer reserve controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build priceConfirmed after discovery based on integrations, workflow complexity, reserve volume, approval controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bringWe build with it
01Your custodian list and reserve policy→Eligibility, maturity and segregation rule mappingWeek 1
02Representative prior month-end packs→Position ingestion, reconciliation and the assembly baselineWeek 2
03Your documented eligible-asset definitions→Reserve-policy mapping and automation-boundary definitionWeek 1
04Access to relevant APIs, feeds or exports→Custody, ledger and chain assessment, then integration setupWeek 2
05Packs you would not want examined→Composition cases and the evaluation suiteWeek 4
06What no certification may rest on→Confidence scoring, exception routing, guardrails and approval controlsWeek 3
07Named reserve owners to review the pack→Reserve-owner approval workflow, then pilot and production validationWeeks 5–6
Nothing else is requiredDeployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
The bands follow the monthly cycle rather than the slide, so the fifth week carries two phases.
PhaseW1W2W3W4W5W6
DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6
Week focusW1Reserve workflow discovery, rule mapping and the automation boundaryW2Source integration and the reconciliation baselineW3Assembly workflow, confidence logic and approval controlsW4Evaluation suite, eligibility checks and failure-mode testingW5Custody integration, a pilot month and targeted correctionsW6One monthly cycle assembled under the chief financial officer, then handover
Reading the bandEach bar covers only the weeks its work is named in. The week 5 overlap is real, not padding.
At the end of W6The last checks clear on a live cycle and Agent Care picks up monitoring.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Banking AI agent
Build the reserve record before the first certification falls due.
Show us your custodians, your eligible-asset policy and who signs. A wrong reserve line, once certified, is a criminal exposure carried by two named officers — not a supervisory finding.