Frequently asked questions

Is Commercium a bank?

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.

Are deposits at Commercium FDIC-insured?

No, deposits with Commercium are not FDIC-insured. However, Commercium must comply with all SPDI reserve requirements, such as holding 100% of deposits in reserve. These requirements ensure the safety of customer deposits.

Is Commercium a "crypto bank"?

The SPDI Charter allows Commercium to hold and take custody of public network-based cryptocurrencies.

What is Fractional Reserve Banking?

Fractional Reserve Banking is a system where only a fraction of their depositors' balances are available for withdrawal, 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 left in reserve while the remaining $90 is lent out to another customer.

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.

Are SPDI's banks?

SPDIs are sometimes described as "bank-like" or "bank-lite". Not the case. SPDIs are banks under state and federal law. The SPDI charter is a bank charter - specifically, a depository institution, which is a distinction that unlocks certain regulatory benefits and obligations.

Why does Commercium NOT present additional risks than a domestic bank?
  1. Our Banking services are traditional banking products:

    • USD checking, savings, escrow accounts

    • Payment services (ACH, wire, Bill Pay)

  2. Full Reserve Bank versus Fractional Reserve Banking:

    • 100% of Commercium customer deposits are held in reserves.

    • $30 million capital

    • Our Charter prohibits us from engaging in any form of lending.

    • Our Charter prohibits the issuance of credit cards, yet we can issue debit cards.

  3. Stablecoins - given the four Large US Banks are already operating in this space, Commercium plan to also enter this market. We will only utilize those tokens that have 100% USD backing of cash and US securities such as USDC from Circle, and the to be shortly launched Wyoming Stable Token

  4. Our tokenization aspirations are already in place by major banks in the US such JPMC (its partnerships with ONYX) and BNY Mellon.

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 minimum capital reserve of $30 million.

  • 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.

  • 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% of assets, whichever is greater.

  • Asset Pledge: $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.

How is Commercium Regulated?

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.

Frequently asked questions

Is Commercium a bank?

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.

Are deposits at Commercium FDIC-insured?

No, deposits with Commercium are not FDIC-insured. However, Commercium must comply with all SPDI reserve requirements, such as holding 100% of deposits in reserve. These requirements ensure the safety of customer deposits.

Is Commercium a "crypto bank"?

The SPDI Charter allows Commercium to hold and take custody of public network-based cryptocurrencies.

What is Fractional Reserve Banking?

Fractional Reserve Banking is a system where only a fraction of their depositors' balances are available for withdrawal, 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 left in reserve while the remaining $90 is lent out to another customer.

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.

Are SPDI's banks?

SPDIs are sometimes described as "bank-like" or "bank-lite". Not the case. SPDIs are banks under state and federal law. The SPDI charter is a bank charter - specifically, a depository institution, which is a distinction that unlocks certain regulatory benefits and obligations.

Why does Commercium NOT present additional risks than a domestic bank?
  1. Our Banking services are traditional banking products:

    • USD checking, savings, escrow accounts

    • Payment services (ACH, wire, Bill Pay)

  2. Full Reserve Bank versus Fractional Reserve Banking:

    • 100% of Commercium customer deposits are held in reserves.

    • $30 million capital

    • Our Charter prohibits us from engaging in any form of lending.

    • Our Charter prohibits the issuance of credit cards, yet we can issue debit cards.

  3. Stablecoins - given the four Large US Banks are already operating in this space, Commercium plan to also enter this market. We will only utilize those tokens that have 100% USD backing of cash and US securities such as USDC from Circle, and the to be shortly launched Wyoming Stable Token

  4. Our tokenization aspirations are already in place by major banks in the US such JPMC (its partnerships with ONYX) and BNY Mellon.

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 minimum capital reserve of $30 million.

  • 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.

  • 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% of assets, whichever is greater.

  • Asset Pledge: $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.

How is Commercium Regulated?

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.

Frequently asked questions

Is Commercium a bank?

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.

Are deposits at Commercium FDIC-insured?

No, deposits with Commercium are not FDIC-insured. However, Commercium must comply with all SPDI reserve requirements, such as holding 100% of deposits in reserve. These requirements ensure the safety of customer deposits.

Is Commercium a "crypto bank"?

The SPDI Charter allows Commercium to hold and take custody of public network-based cryptocurrencies.

What is Fractional Reserve Banking?

Fractional Reserve Banking is a system where only a fraction of their depositors' balances are available for withdrawal, 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 left in reserve while the remaining $90 is lent out to another customer.

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.

Are SPDI's banks?

SPDIs are sometimes described as "bank-like" or "bank-lite". Not the case. SPDIs are banks under state and federal law. The SPDI charter is a bank charter - specifically, a depository institution, which is a distinction that unlocks certain regulatory benefits and obligations.

Why does Commercium NOT present additional risks than a domestic bank?
  1. Our Banking services are traditional banking products:

    • USD checking, savings, escrow accounts

    • Payment services (ACH, wire, Bill Pay)

  2. Full Reserve Bank versus Fractional Reserve Banking:

    • 100% of Commercium customer deposits are held in reserves.

    • $30 million capital

    • Our Charter prohibits us from engaging in any form of lending.

    • Our Charter prohibits the issuance of credit cards, yet we can issue debit cards.

  3. Stablecoins - given the four Large US Banks are already operating in this space, Commercium plan to also enter this market. We will only utilize those tokens that have 100% USD backing of cash and US securities such as USDC from Circle, and the to be shortly launched Wyoming Stable Token

  4. Our tokenization aspirations are already in place by major banks in the US such JPMC (its partnerships with ONYX) and BNY Mellon.

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 minimum capital reserve of $30 million.

  • 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.

  • 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% of assets, whichever is greater.

  • Asset Pledge: $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.

How is Commercium Regulated?

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.