You found this page because the reserve attestation question landed on you. The GENIUS Act requires monthly CPA-attested reconciliation as a condition of legal operation, certified personally by the CEO and CFO, due January 18, 2027. The person who solves it is the person reading this. Here is the package and how it gets built.
| Transaction Hash | Block | Unix TS | DateTime (UTC) | From / To | Token Value |
|---|---|---|---|---|---|
| 0xa3f8c2d1e4b7... | 18841203 | 1704067230 | 2024-01-01 00:00:30 | 0x0000...0000 / 0x55fe...8a21 | 2500000000000 |
| 0x7c2e91a4f63b... | 18841219 | 1704067442 | 2024-01-01 00:03:58 | 0x3f4a...d2c1 / 0x0000...0000 | 850000000000 |
| 0xd1b4a7e2c938... | 18841241 | 1704067698 | 2024-01-01 00:08:18 | 0x0000...0000 / 0x8823...1134 | 5000000000000 |
| 0x4f7b2a8e1d53... | 18841267 | 1704068001 | 2024-01-01 00:13:21 | 0x1c9d...f4e2 / 0x0000...0000 | 1200000000000 |
| 0x9e3c1d7b4a2f... | 18841289 | 1704068244 | 2024-01-01 00:17:24 | 0x0000...0000 / 0xa4c2...7751 | 10000000000000 |
Every mint and burn exists on the blockchain. Your CPA needs that data resolved, normalized, and reconciled against reserves before an examination can begin. Turning raw chain data into a reconciliation package is a separate discipline.
A qualified CPA can perform the examination and sign the attestation. Querying on-chain event logs and normalizing token decimals sit outside their practice. The documentation has to arrive in a form built for examination.
Without a signed attestation, issuance stops. The GENIUS Act treats the attestation as a condition of legal operation. The CPA engagement takes weeks to establish. The first reconciliation cycle takes a full reporting period. Both need to finish before the deadline.
Section 4(a)(3) of the GENIUS Act requires the CEO and CFO to personally certify the accuracy of each monthly report to the regulator. A knowingly false certification carries criminal penalties of up to 20 years imprisonment and a $5 million fine under 18 U.S.C. 1350(c). Two named officers hold that exposure every month. The work that makes the report signable happens well before it reaches their desks. Wherever you sit, if this landed on you, you are the one solving it.
The GENIUS Act requires monthly CPA-attested proof that our reserves equal or exceed circulation, personally certified by our CEO and CFO under criminal penalty for false certification, with a compliance date of January 18, 2027. The attestation requires a documented reconciliation package our CPA can examine under AICPA AT-C Section 205, and the CPA engagement plus the first reporting cycle both take time. The Compliance Bridge produces that package as a service. Deliverable samples: thecompliancebridgellc.com/templates
Every issuer that makes January will trace it back to one person who moved early. That decision is available right now.
Here is what the GENIUS Act requires, who it applies to, and what the examination standard demands from your documentation. Read this before you decide you have more time.
The Guiding and Establishing National Innovation for US Stablecoins Act passed the Senate 66-32 in May 2025. It establishes a federal licensing framework for permitted payment stablecoin issuers and creates a mandatory attestation requirement that is a condition of legal operation.
Every regulated issuer must produce monthly proof that reserve assets equal or exceed coins in circulation. The proof must come from a qualified CPA. The issuer does not self-certify.
The GENIUS Act creates three licensing tracks: OCC-chartered entities (proposed rules February 2026), state-regulated issuers below a circulation threshold, and credit union stablecoin subsidiaries under NCUA jurisdiction (proposed rules 2026, comment period closed April 2026).
State-licensed issuers below $10B in circulation may qualify for a state-law compliance path. The attestation requirement exists at both levels. There is no tier of issuer for whom monthly attestation is not required.
AICPA AT-C Section 205 governs examination engagements. The CPA evaluates whether a subject matter (in this case, the issuer's reserve assertion) conforms to suitable criteria. They issue a conclusion based on documented evidence: on-chain supply figures, reserve confirmation, and reconciliation output.
This is not an audit. The CPA does not issue an opinion on your financial statements. They attest that the reserve assertion is fairly stated based on the evidence examined. For the attestation to be defensible, every figure in the attestation package must be traceable to a documented, reproducible source.
OCC, FDIC, and NCUA rules are all in proposed rulemaking as of 2026. Final rules could publish in late 2026. The window between final rulemaking and the compliance date is narrow. Potentially 120 days.
The data pipeline, CPA relationship, and reporting cadence all need to be operational and tested before that window closes. A first reporting cycle is not the time to discover infrastructure gaps.
Mint and burn events queried directly from the chain. Normalized, decimal-corrected, date-bounded to your reporting period.
Your designated finance contact signs our reserve confirmation template. One document, once per period. No system access required.
Reconciliation exhibit, variance classification, CPA verification parameters. Everything formatted to AICPA AT-C Section 205.
Your CPA reviews the attestation package and delivers a signed attestation. We are not in the attestation chain. They are.
The Compliance Bridge LLC does not provide accounting, audit, legal, or attestation services. Nothing in any engagement should be construed as such.
The reconciliation package has a defined structure. Each component serves a specific purpose and a specific recipient.
Reporting period, On-Chain Supply Change, scope disclosure, reserve position, and CPA attestation reference. Every figure is labeled. Every calculation is traceable. Goes to issuer leadership and the attesting CPA. Formatted for executive review. Totals and conclusions, not chain-level detail. Delivered at every tier.
Preview L1 template →The full working document the CPA uses to perform the examination. Chain-by-chain On-Chain Supply Change, Phase I totals, scope disclosure, and reconciliation against the issuer's published all-chain figure. Every variance is classified. The Section B.1 scope note explains the delta between Phase I scope and issuer-published circulation. This is what makes the attestation reproducible.
Preview L2 template →A permanent reference document sent to your CPA with every attestation package regardless of tier or frequency. Defines data sources, mint and burn event definitions, decimal normalization method, date boundary protocol, chain scope, and compliance threshold. Allows the CPA's attestation to be based on documented, reproducible procedures. Non-depth-gated by design.
Preview Part E →USDC operates on 14 chains. EVM-compatible chains share a common event model and form the Phase I engagement scope. Non-EVM chains require different collection architecture and are Phase II.
EVM chains use the ERC-20 Transfer event model. Mints are Transfer events where from = zero address. Burns are Transfer events where to = zero address. This pattern is consistent across all four Phase I chains and can be queried directly from on-chain event logs.
Solana (Sealevel) and Tron (TRC-20) do not share the ERC-20 Transfer event model. Each requires chain-specific parsing logic. These are the primary contributors to the scope variance between Phase I figures and issuer-published all-chain circulation. That variance is expected, classifiable, and disclosed in every L2 package.
All first clients begin at monthly frequency. No exceptions. This protects your first cycle and ours. After you have seen your first package and understand your own numbers, upgrades are available.
One month, one chain. See the deliverable before committing to a recurring engagement. Applies as credit toward Foundation within 60 days if you convert.
Pricing scales by circulation size and chain configuration. Issuers operating on more than four chains or non-standard blockchain architectures are priced on a custom engagement basis. Contact TCB directly before qualifying.
Issuance stops. The attestation is the compliance artifact that makes issuance legal under the GENIUS Act. Missing it is a shutdown condition.
The CPA engagement takes time to establish. The first reconciliation cycle takes time to run. The documentation needs to exist before the deadline. The issuers that comply will be the ones where somebody acted the day they understood the requirement.
No. Most people who find this page are in that position. They know the requirement exists, they know their CPA needs something, and they do not yet know what that something looks like in practice.
The templates page shows the actual deliverable. The 30-minute call is where we find out whether your chain configuration and circulation size fit the current engagement scope. You do not need to have the answers before you call.
Yes, technically. You would need an on-chain query setup for each EVM chain you operate on, a method to pull Fiat Reserve Balance data from your custodian, a reconciliation process that produces output formatted to AICPA AT-C Section 205 examination engagement standards, and a cadenced delivery system that maintains documentation for CPA review.
The technical components exist and are publicly available. What most issuers are deciding is whether this is an internal function or an external one. The compliance function needs to be operational and tested before the compliance date. Not under construction during the first reporting cycle.
Yes. TCB produces the reconciliation package. Your CPA performs the examination and delivers the signed attestation. We are not in the attestation chain. That relationship is yours to establish.
If you do not have a CPA with AICPA AT-C Section 205 examination engagement experience, we can describe what to look for. The CPA selection is your decision and the engagement relationship is yours.
Variances are expected and classifiable. Every variance is classified under a three-tier system based on magnitude relative to Attested Closing Circulation. Tier 1 covers variances at or below 0.1%. Tier 2 covers explainable variances above 0.1% up to 1.0%. Tier 3 covers anything above 1.0% or any unexplained variance regardless of size. Most variances arise from multi-chain scope, timing differences at period boundaries, or rounding at the decimal normalization step.
Actual reserve shortfalls where Fiat Reserve Balance is genuinely less than Closing On-Chain Supply are a different category. The exhibit discloses and classifies every variance. Your CPA determines materiality. Our job is to make sure nothing is obscured.
Public on-chain transfer data and your signed reserve confirmation. One document per reporting period confirming your Fiat Reserve Balance for that period.
We do not have access to your bank accounts, your custody arrangements, or your internal financial systems beyond the single confirmed figure on the reserve confirmation template. The template is designed to collect exactly what the examination engagement requires. Nothing more.
Phase I: Ethereum, Polygon, Arbitrum, Base. These four EVM-compatible chains cover the majority of USDC circulation. If your issuance is distributed across these chains, an engagement is viable now.
If you operate primarily on Solana or Tron, contact us before qualifying. We will tell you directly whether an engagement makes sense before any scope discussion.
Two reasons. First, monthly is the GENIUS Act minimum. Every issuer needs a working monthly process regardless of what they ultimately want. Second, the first reporting cycle is where we both learn your specific chain configuration, reserve structure, and variance profile.
After cycle one, upgrading to Standard or Enterprise is straightforward. Enterprise adds read-only access to the Perpetual Tracker, a running on-chain supply record fed each business day, for both you and your CPA.
Foundation tier: you receive the L1 Executive Summary. Your CPA receives the L2 Reconciliation Exhibit and Part E: CPA Verification Parameters. Standard and above: you also receive the L2 exhibit directly.
Part E goes to your CPA every cycle, every tier, without exception. It defines our data sources, event definitions, decimal normalization, date boundaries, and chain scope. It is what makes the attestation defensible. We do not gate it by tier because the quality of the attestation should not depend on what the issuer is paying.
You handle things before they become emergencies. This is one of those moments. Bring what you know about your chain configuration and circulation size. If the window is too tight or the scope does not fit, you will hear that in the first call. You leave with an answer.