ppsicustody.com & .eth | PPSI Custody Identity

The OCC’s proposed 12 C.F.R. Part 15 establishes a comprehensive framework for stablecoin issuance covering licensing, reserves, prudential standards, custody, capital, reporting, supervisory fees, and enforcement — with Final Rules required by July 18, 2026. arxiv

Of these requirements, custody is the most operationally non-negotiable. A PPSI that cannot demonstrate compliant custody of its covered assets cannot legally operate — regardless of its reserve adequacy, capital sufficiency, or AML compliance. A covered custodian must take appropriate steps to protect the covered assets of customers from the claims of creditors of the covered custodian and any subcustodian, and must maintain possession or control of the covered assets of a customer that are held directly. Legislation.gov.uk

This custody documentation challenge requires simultaneous compliance on two rails. The OCC examiner requires human-readable custody agreements, segregation documentation, and subcustodian arrangements in a legally referenceable Web2 format. The GENIUS Act’s lawful order technological capability requirement demands that custody infrastructure can freeze, seize, and transfer covered assets on-chain at the protocol layer.

ppsicustody.com is the institutional Web2 portal identity for the PPSI custody documentation standard — the legal brand that appears in OCC custody examination submissions, covered custodian agreements, and GENIUS Act compliance documentation wherever PPSI custody infrastructure must be referenced. ppsicustody.eth is the programmable on-chain routing identity — the ENS endpoint that software architects embed directly into PPSI custody protocol logic to attest to covered asset custody compliance on-chain without intermediary DNS dependency.

Together they form the complete Convergence Identity for the PPSI custody standard that every institution subject to 12 C.F.R. Part 15 must establish before the July 18, 2026 Final Rules deadline.

The Regulatory Foundation, The PPSI Custody Architecture, and The Ecosystem

The OCC’s custody requirements apply to “covered custodians” — defined as OCC-supervised institutions including national banks, federal savings associations, federal branches and OCC PPSIs, as well as sub-custodians for OCC-supervised institutions. An OCC PPSI may serve as custodian for covered assets related to the payment stablecoin it issues. Lexology

The proposed rule defines “covered assets” as payment stablecoin reserves, payment stablecoins used as collateral, private keys used to issue payment stablecoins, and any cash or property received in the course of providing custody or safekeeping services for those assets. UK Parliament

Three simultaneous regulatory requirements define the PPSI custody compliance mandate.

A PPSI must not pledge, rehypothecate or reuse any reserve assets either directly or indirectly through a third-party custodian of the reserve assets — with limited exceptions. Reserve assets must at all times have a total fair value that equals or exceeds the outstanding issuance value of the PPSI, and are either held directly by the PPSI or within the custody of an eligible financial institution. STEP

The GENIUS Act requires the OCC to establish capital requirements for PPSIs — primarily focusing on operational risk. The OCC would impose PPSI capital requirements on a case-by-case basis at licensing using factors such as financial projections, expenses, products and services proposed, and discussions with organizers.

The FDIC’s parallel custody framework — Subpart B applies to FDIC-supervised custodians, with comment deadline June 9, 2026 — confirms that custody compliance is a multi-regulator requirement that every PPSI must satisfy across OCC, FDIC, and Federal Reserve standards simultaneously. SCC Times

The PPSI Custody Architecture

The PPSI custody architecture operates through three simultaneous compliance layers that ppsicustody.com documents and ppsicustody.eth routes through.

The covered asset segregation layer establishes that every covered asset is separately accounted for per customer — with no commingling with the custodian’s own funds even if held in an omnibus account. This layer requires continuous documentation of custody arrangements, subcustodian relationships, and asset segregation records that OCC examiners can verify at any time.

The reserve custody documentation layer establishes the 1:1 reserve backing requirement — that covered assets in custody have a total fair value equaling or exceeding the outstanding issuance value at all times. This layer requires real-time custody attestation that connects reserve holdings to outstanding stablecoin issuance — the documentation challenge that ppsicustody.com provides the institutional namespace for.

The lawful order execution layer establishes the technological capability to freeze, seize, and transfer covered assets under lawful order — the Protocol Layer requirement that ppsicustody.eth routes through on-chain. The OCC explains that the independent operational backstop obligation is necessary for providing a liquidity runway to allow the issuer to stabilize operations and evaluate response options during a disruption without resorting to emergency measures. Legislation.gov.uk

ppsicustody.eth is the W3C DID-compliant ENS endpoint for this three-layer custody architecture — the on-chain routing identity that software architects embed directly into PPSI custody infrastructure to attest to covered asset custody compliance without intermediary DNS dependency.

The PPSI Custody Ecosystem

ppsicustody is the custody compliance core of the PillarsX PPSI namespace. It connects directly to ppsisettle.com & .eth as the settlement execution identity whose covered assets ppsicustody governs, and to ppsigateway.com & .eth as the Fed payment access gateway that ppsicustody enables.

Beyond the PPSI cluster, ppsicustody integrates with coveredcustodian.com & .eth as the OCC covered custodian standard that complements PPSI custody requirements, verifiablereserve.com & .eth as the reserve attestation identity that confirms custody backing, and permittedreserves.com & .eth as the reserve eligibility standard that governs what covered assets ppsicustody holds.