Special Purpose Depository Institutions (program page: statute citations, "four SPDI charters" approved)

Bitcoin Research — Law, Regulation, Markets & Origins (2026)

Banking

2026-10-09

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Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.

Division of Banking - Special Purpose Depository Institutions

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Special Purpose Depository Institutions

Wyoming-chartered special purpose depository institutions (“SPDIs”) are fully-reserved banks that receive deposits and conduct other activity incidental to the business of banking, including custody, asset servicing, fiduciary asset management, and related activities. 
SPDIs will likely focus on digital assets, such as virtual currencies, digital securities and digital consumer assets. For example, SPDIs may elect to provide custodial services for digital assets and, in accordance with customer instructions, undertake authorized transactions on behalf of customers. SPDIs may also conduct activity under Wyoming regulations tailored to digital assets, which address issues such as technology controls, transaction handling, and custody operations for digital assets. As a final example, 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. 
SPDIs may focus on traditional assets as well. They also may serve as a vehicle for business cash management, operational accounts, and any other purpose permitted under applicable law. As fully-reserved banks, SPDIs are prohibited from making loans with customer deposits of fiat currency.  SPDIs must also 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. Given this, SPDIs are not required to obtain insurance from the Federal Deposit Insurance Corporation—though they may do so. 
SPDIs may resemble custody banks because they will likely be predominantly engaged in custody, safekeeping, and asset servicing activities. The role of 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.
Wyoming first authorized SPDI charters with the enactment of House Bill 74 in 2019, which created the Special Purpose Depository Institutions Act (“SPDI Act”) at Wyo. Stat. § 13-12-101, et seq. Wyoming also created its digital asset law at Wyo. Stat. § 34-29-101, et seq. with the enactment of Senate File 125 in 2019. Since then, Wyoming amended the SPDI Act in 2020 and amended its digital asset law in 2021, with the latter becoming effective July 1, 2021. The Division of Banking's SPDI regulations became effective in 2020 and were amended in 2021.  The Division of Banking's digital asset custody regulations became effective in 2019 and were amended in 2021.
Wyoming’s statutes, rules, guidance, and other information related to SPDIs and digital assets may be found below. 
The Division has been accepting SPDI applications since October 1, 2019. The Wyoming Banking Board has approved four SPDI charters thus far. Application materials and background information may be found below. If you are considering applying for a SPDI charter, please contact the Division at (307) 777-7797 or at [email protected].  Once a SPDI commences business they file a Call Report with the Division which is publicly available.

Charter Applications- Rules.pdf
Digital Asset Custody Rules (05-21).pdf
Digital Asset Statutes (07-21).pdf
Procedure for Application Hearings- Rules.pdf
SPDI Application Process Overview (05-20).pdf
SPDI Bank Charter Application (11-21).docx
SPDI Biographical & Financial Report (06-20).docx
SPDI Rules (05-21).pdf
SPDI Statutes (7-21).pdf
SPDI Updated Capital Guidance (07-21).pdf
SPDI Examination Manual v1 2021 (pdf)

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