PYUSD’s issuer, Paxos, is regulated by the NYDFS as a stablecoin issuer. Under the NYDFS’ guidelines, PYUSD is required to comply with the following:

• PYUSD reserves must be segregated from the proprietary assets of Paxos, and must be held in custody with (i) U.S. state or federally chartered depository institutions with deposits insured by the Federal Deposit Insurance Corporation (“FDIC”) and/or (ii) asset custodians, approved in advance in writing by NYDFS.

• Hold reserves in asset classes pre-authorized by the NYDFS and within imposed limits

• Procure monthly attestations of reserves including (i) end of period reporting and (ii) one random day reporting.

• Annual attestation report by a US-licensed CPA pre-vetted by the NYDFS.

• Meet redemption requests from users within prescribed time limits.

• Such other conditions that may be imposed by the NYDFS on a case-to-case basis.