Community Digital Dollar · CDD™ Apply for a readiness assessment
Digital financial infrastructure for community banking

Every dollar deposited in a community bank stays in the community

CDD is a proposed consortium structure under which the reserves behind payment stablecoins would be held as deposits at community banks, CDFIs and MDIs, so that growth in digital dollars funds local lending instead of leaving town. It is a design under legal review, not a live product, and we say so on every page.

StructureProposed consortium,
under legal review
Issuer applicationNone filed
Reserve depositsWould be bank deposits of the issuer
wording pending counsel
PatentProvisional filed Feb 2026,
none granted
Founding-bank assessments3 slots open
Last updated18 Sep 2026
For bank leaders · an assessment scoped separately from the CDD platform

Understand your deposit exposure, test customer demand, and decide whether to act, partner, monitor, or pass

The Founding-Bank Readiness Assessment is a six-week, board-ready study run to a published method and reviewed by an independent community bank finance advisor. It is the first step into a bank, and it is deliberately separate from anything CDD would sell. The assessment may recommend against adopting CDD, and when it does the memo will say so in plain terms.

The sequence

1. Assessment six weeks

Funding exposure, customer demand, options and operating model, and a recommendation. Your data, your customers, your decision meeting.

2. Board decision yours

Act, partner, monitor, or pass, with triggers, an owner, and a review date. Three of the four outcomes do not involve CDD.

3. Optional CDD pilot only if recommended

A small, controlled pilot with an explicit spend cap, proposed only where the memo identifies a sponsored use case, a vetted legal path, and unit economics that work.

4. Optional independent evidence layer any path

A reconciliation and controls layer for instructions, reserve movements, approvals and redemptions, scoped so a bank can adopt it on a path that does not include CDD.

Founding cohort3 slots open
ExpansionTo five, decided after bank three
Professional feeNone for founding banks
ScopeDeposit exposure, customer demand,
options, board memo
SelectionExecutive sponsor, usable data,
customer access, decision meeting
Profiles soughtRural or ag lender; small-business
balances; CDFI or MDI
Independent reviewBank finance advisor challenges
every analysis
Possible outcomesAct · Partner · Monitor · Pass
How CDD would work · the platform

Digital deposits, community lending power

The core idea: when a payment stablecoin is issued, dollars are set aside as reserves. Today those reserves sit mostly at the largest custodians. CDD proposes a consortium of community banks, CDFIs and MDIs whose members would hold those reserves as deposits, keeping the funding in the communities the dollars came from. Everything below is a design under legal review, written in the conditional because it does not yet exist.

1. Consortium formation Proposed design

Community banks and credit unions would join a consortium with shared issuance infrastructure while keeping their own charters, customers and lending decisions. Whether the consortium could operate under one regulatory application, or each member would need its own approvals, is a question for counsel and is not assumed. wording pending counsel

2. Reserve placement at members Proposed design

Reserves behind issued digital dollars would be held as deposits at consortium members rather than in a money market fund or at a single large custodian, distributed by a published priority method that considers each member's capital position and community lending capacity.

3. Lending capacity Proposed design

Stable reserve deposits would support local small business, housing and agricultural lending, subject to each member's own underwriting, liquidity and concentration limits. Whether reserves placed this way count as brokered deposits, and what that means for each bank, is part of the readiness assessment.

4. Evidence and reconciliation layer Proposed design

Every instruction, reserve movement, approval and redemption would be independently reconcilable by the bank and its examiners. Scoped separately so a bank could adopt it on any path, including one that does not involve CDD.

An insured deposit and a stablecoin are different things wording pending counsel

An insured deposit is a bank's obligation to its depositor, covered by the FDIC up to the applicable limit if the bank fails. A payment stablecoin is a claim on its issuer, redeemable for dollars, backed by reserves the issuer holds. Some of those reserves may themselves be insured deposits at a bank, but the insurance protects the issuer's account at that bank, not the person holding the coin. If a community bank held CDD reserves, the bank would have a deposit from the issuer; the customer holding the digital dollar would not have an insured deposit at that bank. Banking counsel will verify this description and the exact structure before it is used in outreach.

Tokenized deposits as a first-class alternative

A bank's own liabilities on new rails, with balances that never leave its balance sheet, is the most serious alternative to reserve routing. The readiness assessment compares both. Where tokenized deposits fit a bank better, the memo will say so.

Financial inclusion pathway Under legal review

The design contemplates a graduated wallet-to-account pathway for customers without conventional credit history. Whether an on-ramp for customers without a Social Security number is legally and operationally viable depends on the institution's customer identification program and current rules, and we will not describe it as available until that is settled.

Intellectual property

A U.S. provisional patent application covering the consortium architecture, reserve distribution method, and related processes was filed in February 2026. No patent has been granted. A filing describes an application, not freedom to operate or a validated control.

Readiness assessment · the decision your board will face

Digital dollars are a funding question before they are a product question

Payment stablecoins may become a useful instrument for some of your customers. Balances that move off your books to hold them may or may not come back. The exposure depends on which customers, which use cases, for how long, and where the reserves behind those dollars are held. Your board needs a quantified answer before anyone needs a token.

Bank problemDecision questionWhat the assessment answers
Deposit migrationWhich balances might leave, for how long, and at what replacement cost?Segmented exposure under a modest and a severe scenario, with replacement funding cost and liquidity effects.
Customer paymentsWhich customers value faster or extended-hours settlement enough to adopt?Interviews with a bank-selected sample of business customers: actual delays, volumes, costs, and reasons to keep balances.
Execution burdenShould the bank act, partner, monitor, or pass?A comparison of existing rails, third-party providers, tokenized deposits, and consortium reserve routing.
AuditabilityCan instructions, reserve movements, approvals and redemptions be independently reconciled?A controls and evidence review scoped to whichever path the bank is considering.
ActA sponsored use case, a named owner, a legal path, and unit economics that work.
PartnerA third-party or consortium path where the economics and oversight hold up.
MonitorExposure is small or conditional. Named triggers, an owner, and a review date.
PassNo customer pull, or the costs outweigh the funding case. A defensible no.
Readiness assessment · open methodology

Published before the first engagement, so you can judge the method before you judge the result

CDD proposes one of the paths the assessment compares. That is a conflict of interest, and we address it in the structure rather than asking you to take our word for it.

1. Funding exposure

Segment deposit balances and concentration. Define a modest and a severe behavior scenario using the definitions published below. Estimate replacement funding and liquidity effects. Identify transfers within and outside the bank.

2. Demand validation

Interview a small, bank-selected sample of business customers about actual payment delays, volumes, current costs, willingness to switch, and reasons to keep balances where they are. The bank controls invitations and consent.

3. Options and operating model

Compare existing rails, a third-party provider, tokenized deposits, and a consortium reserve-routing path. Examine technology, vendor oversight, legal structure, AML and sanctions, operational resilience, reconciliation, and customer disclosures.

4. Board decision

Recommend act, partner, monitor, or pass, with triggering conditions, owner, timing, expected economics, key assumptions and unresolved issues.

Scenarios set per bank, not imposed

A modest and a severe scenario are always reported, but the migration shares behind them are set from each bank's deposit mix, concentration and customer interviews, not from a universal number. The 5% and 25% shown in the calculator below are editable examples. Neither scenario is a forecast. Replacement cost uses the bank's own marginal wholesale funding spread.

Bank-level and consortium-level results, reported separately

Reserve placement that benefits a consortium can leave an originating member worse off. Gross reserve inflow is never presented as net funding benefit.

Independent bank finance review

Joe Kenner, a former community bank CFO and asset-liability management leader, reviews each bank's deposit exposure, replacement funding assumptions, liquidity effects and board recommendation. His role is to challenge the analysis, including cases where CDD would not benefit the bank. The scope of that role, its budget and its conflict rules are set out in the engagement agreement before the first bank starts.

Method now, outcomes later

The method is published now. Aggregate outcomes will be published only once the number of completed assessments and the banks' permissions allow it without revealing any single institution's decision. With three founding banks, reporting how many chose pass could identify one; we will not do that.

Data minimization

Aggregated data wherever it answers the question. No customer identifiers collected when segment totals suffice. Work product ownership, confidentiality, and security controls are covered in a short written agreement.

Sample deliverable

A redacted board memo template will be published here before the first engagement begins. Six pages: exposure range, customer signal, options compared, recommendation, triggers, open issues.

Readiness assessment · deposit exposure calculator

Run the first pass on your own numbers

This is the arithmetic behind workstream one, simplified to illustrate how the pieces relate. It is not a prediction of any bank's result. It runs entirely in your browser and nothing you enter is stored or sent. Defaults show an illustrative $500 million bank with example scenario shares; they are not any bank's data. funding math pending bank CFO review

$M
$M
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bps

Off by default. A reserve inflow counts as a benefit only after its origin, price, stability, concentration and regulatory treatment are assessed for your bank.

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Illustrative funding arithmetic

Not a prediction · before liquidity, capital and behavior adjustments
LineModestSevere
Mobile balances as share of deposits
Gross outflow
Incremental funding cost of replacing it
Gross reserve inflow
Of which originated at this bank (not new money)
Stable, new reserve funding after haircut
Net funding change (outflow, less any included reserve inflow)
Illustrative annual funding effect at the replacement spread

With the reserve inflow excluded, the illustration shows only the deposit migration side. When included, it counts only the stable, new portion of that inflow against gross outflow, and even that is a placeholder. Reserve deposits placed through an issuer or consortium may be classified as brokered, which affects FDIC assessment rates, liquidity ratios and examiner treatment; the haircut is a crude stand-in for that until counsel and your ALCO have a view. The full assessment replaces every input here with your call report segments, your marginal funding curve, and interviewed customer behavior.

Readiness assessment · founding bank program

Three institutions, chosen for what they can teach the method

Who we are looking for

One rural or agricultural lender. One bank with material small business operating balances. One CDFI or MDI with a credible institutional payment or deposit sourcing channel. Preference for at least one institution with banking-as-a-service or fintech partnership experience. Credit unions after the method is adapted to their charter.

What the bank commits

An executive sponsor. Access to aggregated deposit data. Introductions to a small sample of business customers, on the bank's terms. A final decision meeting with the executive team or board. Permission for an anonymized case study is requested; a reference is requested separately, and only after value is demonstrated.

What CDD commits

No professional fee for founding banks. The published methodology, applied as written. A board memo that has been through independent bank finance review. A written agreement covering scope, data minimization, security controls, ownership of work product, confidentiality, conflicts and any follow-on procurement. We expect and welcome your third-party risk review.

Timeline

Six weeks per assessment, subject to data availability. Founding slots are limited to three so that each engagement gets the attention the method requires; whether to expand to five is decided after the third, on delivery effort and bank response. Founding banks receive the assessment without a professional fee. A standard price for later assessments will be published once actual delivery hours and demand from the founding cohort are known; founding banks will be asked what they would have paid.

Regulatory and company status

Where things stand, dated

This table is reviewed by counsel before each update. Nothing on this site should be read as a statement that CDD, or any bank, is authorized to issue payment stablecoins.

ItemStatusAs of
GENIUS Act (Pub. L. 119-27)Enacted 18 July 2025. Takes effect on the earlier of 18 January 2027 or 120 days after primary federal regulators issue final implementing rules.18 Sep 2026
Implementing rulesOCC, FDIC, NCUA and Treasury have issued proposals. No primary regulator had finalized rules as of mid-2026; 18 January 2027 is the working effective date. Federal Reserve rulemaking to be added for state member banks.18 Sep 2026
Issuer-paid yieldProhibited for permitted issuers under the Act. Treatment of rewards paid by affiliates or exchanges was still contested in pending legislation.18 Sep 2026
CDD issuer applicationNone filed.18 Sep 2026
ConsortiumNone formed. Structure under legal review.18 Sep 2026
PatentU.S. provisional application filed February 2026. No patent granted.18 Sep 2026
TrademarkCDD™ mark in use. Registration status under confirmation. pending counsel18 Sep 2026
Founding assessmentsThree slots open. None completed. Aggregate outcomes will be published here once the sample and bank permissions support it.18 Sep 2026
Counsel review of this siteInitial review in progress. Statements tagged "wording pending counsel" are interim and will be replaced or removed on counsel's advice.—
Changelog · 18 Sep 2026 — Site updated: For Bank Leaders section and Founding-Bank Readiness Assessment added; platform description rewritten in the conditional pending counsel review. Removed: "FDIC Insured Deposits" and "GENIUS Act Compliant" badges, "3%+ APY", competitor fee comparisons, "$0 systematic deposit solutions", "single regulatory application", unsourced deposit and cost figures, per-step patent claim annotations, and "Confidential" footer.
People

Who does the work

Bankers, examiners and counsel will want to know who is on the other side of the table.

Chris SmithProgram leadChris leads the Digital Dollar Readiness Assessment program, bringing more than 20 years of experience directing technology, data and financial-services programs. He coordinates bank leadership, finance, risk and payments teams, oversees the assessment method, and delivers a board-ready recommendation grounded in each institution's data.
Joe KennerCommunity bank finance advisorA former community bank CFO and asset-liability management leader. Joe reviews each bank's deposit exposure, replacement funding assumptions, liquidity effects and board recommendation. His role is to challenge the analysis, including cases where CDD would not benefit the bank.
Andrew SteinBanking regulatory and payments counselAndrew advises financial institutions on payment products, third-party arrangements and regulatory approvals. He reviews CDD's proposed issuer and consortium structure, reserve and insurance language, customer disclosures, and the legal assumptions behind any pilot.
Apply

Apply for a Founding-Bank Readiness Assessment

Scope: deposit exposure under two published scenarios, customer demand interviews, an options comparison including paths without CDD, and an independently reviewed board memo. Selection: an executive sponsor, usable aggregated data, access to a small customer sample, and a commitment to a final decision meeting. Three founding banks first; a decision on expanding to five follows the third. We reply to every application, and if your institution is not a fit we will say so and tell you why.

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Sources

Every figure on this site links to where it came from

GENIUS Act, Public Law 119-27, enacted 18 July 2025 — https://www.congress.gov/bill/119th-congress/senate-bill/1582
OCC, GENIUS Act notice of proposed rulemaking, Bulletin 2026-3 — https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-3.html
FDIC, proposed GENIUS Act requirements and standards, 7 April 2026 — https://www.fdic.gov/news/press-releases/2026/fdic-approves-proposal-implement-genius-act-requirements-and-standards
FDIC, remarks on stablecoin insurance treatment, 11 March 2026 — https://www.fdic.gov/news/speeches/2026/update-reforms-regulatory-toolkit
Treasury, proposed regulations on payment stablecoin issuance, offer and sale, 18 August 2026 — https://www.federalregister.gov/documents/2026/08/18/2026-16796/genius-act-regulations-on-payment-stablecoin-issuance-offer-and-sale
OCC, interagency third-party risk management guide for community banks, May 2024 — https://www.occ.gov/news-issuances/bulletins/2024/bulletin-2024-11.html
Calculator scenarios and defaults are illustrative assumptions defined in the published methodology, not observed data.