ESBD_451805_1760636200450_RFI 311-26-090825AK - Responses to questions.pdf

Texas Strategic Bitcoin Reserve RFI No. 311-26-090825AK Page 1 of 8

RFI No. 311-26-090825AK

Official Responses to Questions from Potential Respondents

10/15/2025

1. Are specific licenses (e.g., BitLicense, money transmitter) mandatory for all vendors/subcontractors?

CPA RESPONSE:

Specific licenses are not mandatory for all vendors/subcontractors; however, the Comptroller and the Trust Company strongly believes that appropriate regulatory controls will be helpful, and of course may consider such licenses and their corresponding regulatory regimes when evaluating responses to requests for proposals or requests for offers.

2. Is having a physical presence in Texas a requirement for all vendors and subcontractors?

Having a presence in Texas is not required; however, the Comptroller and the Trust Company may consider a presence in Texas when evaluating responses to requests for proposals or requests for offers. When two or more responses receive the same score after evaluation, priority of the claimed preference may be given to a Texas bidder

3. Are there minimum standards for cold storage, multi-signature wallets, or geographic location of servers?

At this time, neither the Comptroller nor the Trust Company has established minimum standards for cold storage or multi-signature wallets. We are hopeful the responses to this RFI will help establish a more informed and detailed RFP. When two or more responses receive the same score after evaluation, priority may be provided first to servers located in Texas, then within the United States.

4. What level and types of insurance are considered sufficient for custodians and subcontractors?

At this time, neither the Comptroller nor the Trust Company has established minimum standards for insurance requirements for a future RFP/RFO. Please note: Per the Comptroller's procurement guide: It is recommended that any solicitation for goods or services specify that all insurance policies must be obtained from insurance companies licensed in Texas with at least an ""A-"" rating from AM Best Company.

5. SB21 authorizes the Comptroller to contract with a qualified custodian employing secure technologies, including cold storage. The RFI requests detailed explanations of custody practices, including key generation, storage models, proof-of-reserves, and audits. Our intention is to present a standards framework based on recognized best practices across the industry. Could TTSTC confirm that respondents are expected to propose and justify such standards, and that TTSTC has not established separate mandatory technical or compliance thresholds beyond those specified in SB21?

CPA RESPONSE:

Neither the Comptroller nor the Trust Company has established separate mandatory technical or compliance thresholds beyond those specified in SB 21. Should any additional mandatory requirements be included in future procurement efforts, such requirements will be expressly provided in the RFP/RFO documentation.

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6. SB21 establishes the Comptroller as custodian and manager of the Reserve , while TTSTC is designated as the vehicle to contract for custody and administration. Could TTSTC confirm whether respondents should frame proposals and standards primarily to the Comptroller as the decision-maker, or to TTSTC as the implementing entity acting on the Comptroller’s behalf?

CPA RESPONSE:

The Trust Company's Chief Investment Officer or Chief Executive Officer will execute any contracts pertaining to future efforts to procure a custodian/liquidity provider for the Strategic Bitcoin Reserve; however, the Trust Company and the Comptroller of Public Accounts will work closely together throughout the procurement process.

7. In the event of a future contract reward, is there a preference from the TTSTC for a fixed or variable rate fee based on digital assets held in custody?

CPA RESPONSE:

At this time, neither the Comptroller nor the Trust Company has established a preference for a fixed or variable rate fee for digital assets held in custody. In the Trust Company's experience, it would not be atypical to see fees reduced as assets under management expand.

8. Will preference be given to companies with an established presence in Texas?

Having a presence in Texas is not required; however, the Comptroller and the Trust Company may consider a presence in Texas when evaluating responses to requests for proposals or requests for offers. When two or more responses receive the same score after evaluation, priority of the claimed preference may be given to a Texas bidder

9. Is the Trust Company pursuing a best of breed or single vendor solution?

At this time, the Comptroller and the Trust Company are exploring the existing options that may be made available for the country's first Strategic Bitcoin Reserve. We are not ruling out any particular method or approach at this time.

10. What are the long-term goals for the Reserve beyond initial acquisition—e.g., investment growth, hedging, public transparency?

CPA RESPONSE:

At this time, the Comptroller and the Trust Company are exploring the existing options that may be made available for the country's first Strategic Bitcoin Reserve. We are not ruling out any particular method or approach for future procurement efforts.

11. What is the timeline for expanding the Reserve beyond Bitcoin, and which other cryptocurrencies are being considered?

CPA RESPONSE:

Section 403.704, Tex. Gov't Code, provides: Bitcoin or other cryptocurrency purchased using money in the reserve must have an average market capitalization of at least $500 billion over the most recent 24-month period. Presently, Bitcoin is the only cryptocurrency that meets this statutory requirement at this time.

12. Is it required that the custodian offer digital asset trading (purchase/sale) as part of the Reserve product?

No, the custodian need not offer digital asset trading as part of the Reserve product; however, if such services are not included, then the custodian must be capable of efficiently and effectively working with third party liquidity providers to help facilitate such transactions indirectly.

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13. Does the RFI favor qualified custodians over qualified liquidity providers, or is there no preference?

At this time, the Comptroller and the Trust Company are exploring the existing options that may be made available for the country's first Strategic Bitcoin Reserve. We are not ruling out any particular method or approach for future procurement efforts.

14. What investment guidance or strategies are expected from custodians or providers in relation to question 2b?

CPA RESPONSE:

For purposes of this RFI, neither the Trust Company nor the Comptroller has expectations that a custodian or qualified liquidity provider will provide investment advisory services to the State of Texas. However, the intent of the RFI is to explore what options may be made available if the Trust Company or the Comptroller desires to explore options that do include investment advisory services.

15. Beyond secure custody, are there any additional services considered mandatory for this mandate?

For purposes of this RFI, the Trust Company and the Comptroller are seeking information in connection with the custody of digital assets as well as the purchase and exchange of such assets.

16. Does the Texas Comptroller of Public Accounts anticipate seeking additional appropriations in future legislative sessions?

CPA RESPONSE:

The Comptroller will implement any future changes to the Reserve enacted by the Texas Legislature and any additional appropriations would be the subject to the Legislature's discretion.

17. Is there a maximum allocation to cryptocurrency expected, either in dollar terms or as a percentage of investible assets?

CPA RESPONSE:

The enabling legislation for the Reserve (Chapter 403, Subchapter V, Tex. Gov't Code) establishes that the Reserve will be invested under the prudent investor standard and does not mandate any particular maximum allocation. That said, the Comptroller anticipates that substantially all of the Reserve's assets will ultimately be invested in Cryptocurrency, namely Bitcoin.

18. Can you clarify which Texas economic development category the Reserve fits under, as referenced in Plan for Reserve (2), Item c?

CPA RESPONSE:

Respondents should focus on how their solutions align with the RFI requirements and the broader goals of responsible digital asset management, rather than on a specific economic development category.

19. What is the client’s investment strategy for the Reserve?

Cryptocurrency exposure, namely Bitcoin

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20. Will the Reserve be open to earning yield on a portion of the Reserve by using tokenized Bitcoin—such as wrapped Bitcoin tokens—on vetted DeFi platforms?

CPA RESPONSE:

The Comptroller and the Trust Company have not yet made a determination on these types of issues. If this is part of your business practice, please submit more background information, so we can give it due consideration.

21. Will the Reserve be open to low-risk yield opportunities in onchain finance, such as providing liquidity to protocols (e.g. Aave for yield generation)?

CPA RESPONSE:

To be determined at a later date after giving due consideration. If this concept is part of your submission, please explain the context and/or relevancy, so we can learn more about the concept.

22. Would TTSTC consider holding cash deposits in tokenized treasuries or acquiring other digital assets, tokenized securities or other tokenized real world assets as part of the Reserve strategy?

CPA RESPONSE:

Bitcoin or other cryptocurrency purchased using money in the reserve must have an average market capitalization of at least $500 billion over the most recent 24-month period.

23. Is TTSTC interested in potential strategies to generate yield on the assets in the Reserve, or would it prefer to hold spot assets in cold storage?

CPA RESPONSE:

To be determined at a later date after giving due consideration. If this is part of your submission, please explain context or relevancy of the idea.

24. Is TTSTC interested in evaluating other non-traditional methods of digital asset procurement for the reserve such as mining cryptocurrency natively, use of yield on unclaimed digital assets in the state's custody, or staking?

CPA RESPONSE:

To be determined at a later date after giving due consideration. If this is part of your submission, please explain

25. Beyond the market capitalization requirement, does TTSTC have a framework for qualifying other cryptocurrencies that would comprise its strategic reserve, including considerations for the underlying network supporting assets? If not, is that something TTSTC is seeking support in?

CPA RESPONSE:

The agency is bound by the requirements established in statute. Beyond the market capitalization criteria, there is currently no additional framework for qualifying other cryptocurrencies. Respondents may, however, provide information or recommendations in their responses regarding potential considerations for the Reserve.

26. Will this RFI lead to an RFP or RFQ? If so, what is the anticipated timeline?

The agency intends for this RFI to help inform the potential development of a future solicitation. While an RFP is likely, no commitment or specific timeline can be confirmed at this time.

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27. What does “No Award Results” mean in the context of this RFI? Will there be a follow-up RFP, and is pricing required at this stage?

CPA RESPONSE:

This Request for Information was published to help the Comptroller and the Trust Company identify industry best practices to help inform future procurement efforts, likely through the RFP/RFO process. Pricing is not required at this stage, but would be required in those future efforts.

28. Should the Risk Management and Insurance (7), Item A vendor list be limited to custody and liquidity providers only?

We would like to know all the vendors providing material services without limitation.

29. What additional services are included under “acquire, custody, and exchange bitcoin”?

We would be interested in learning about all services relevant to acquisition, custody and exchange of Bitcoin.

30. Will the client expect to exchange Bitcoin for other cryptocurrencies?

At this time we are considering Bitcoin only, but open to learn more about cryptocurrencies that are meeting the requirement of an average market capitalization of at least $500 billion over the most recent 24-month period.

31. How does the client define “exchanging” in the context of digital assets?

For purposes of this RFI, “exchanging” refers to the purchase, sale, or transfer of digital assets between parties, with an emphasis on conducting transactions safely and securely. Respondents should interpret the term in its conventional financial context.

32. Is <vendor> expected to execute orders, act as a qualified liquidity provider, and manage Reserve assets as a managed account?

CPA RESPONSE:

The Comptroller is authorized to contract with third-party entities for the administration or management of the Reserve, including with qualified custodians and liquidity providers. We are open to learn about all methods and business practices to safely acquire, exchange and custody Bitcoin.

33. What is the distinction between withdrawing and transferring Bitcoin?

For purposes of this RFI, “withdrawing” generally refers to moving Bitcoin out of the Reserve for external use, while “transferring” refers to moving Bitcoin within the Reserve or between accounts under the Reserve’s control.

Respondents should interpret these terms in the conventional context of digital asset management.

34. What is the role of the designated contractor in the Reserve initiative?

The designated contractor’s role is to provide services as outlined in the RFI and any subsequent solicitation, in support of the Reserve initiative. Respondents should focus on addressing the RFI requirements and describing how their solutions could fulfill the objectives of the Reserve.

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35. Is <vendor> required to perform an independent audit, or can this be outsourced to a third-party audit firm?

The Comptroller may contract with a certified public accountant to perform an independent audit of the Reserve.

We would generally expect any entity or entities ultimately selected for providing services to the Reserve will undergo their own independent audits.

36. What do you envision <vendor>’s role – if any - in establishing the Reserve?

A vendor is expected to work along with TTSTC in establishing the Reserve by consulting, advising and collaborating with the agency and the Reserve's advisory committee.

37. Would TTSTC prefer to receive responses via email at "Researchcpa@cpa.texas.gov" or "BitcoinReserve@ttstc.texas.gov"?

Please, send your response to Researchcpa@cpa.texas.gov

38. Is TTSTC planning to deploy the $10,000,000 obligated for the Reserve over time or as a one-time purchase? If over time, is TTSTC seeking guidance on allocation strategies?

CPA RESPONSE:

To be determined at a later date after giving due consideration, if this is part of your submission, please explain

39. Would TTSTC consider entertaining a response from a consortium of service providers as part of a unified proposal to support the build out of additional processes for management of digital assets that may go beyond what the scope of the RFI indicates? (i.e. on-chain analytics & monitoring, risk management and internal control design, third party risk assessments, on-going compliance assessments, cybersecurity, etc.)?

CPA RESPONSE:

We would like to learn more about this idea, please make sure to explain context and relevancy along with your vision on what would be the best option to utilize the Reserve's funds.

40. Has TTSTC decided whether they would prefer to utilize a third-party custodian or a self-custodial solution?

CPA RESPONSE:

To be determined at a later date after giving due consideration. If this is part of your submission, please explain

41. Is TTSTC seeking a short-term valuation methodology for digital assets to inform allocation decisions or a long-term valuation methodology to inform price targets?

CPA RESPONSE:

The Comptroller and the Trust Company have not yet made any determinations regarding valuation methodologies.

We would like vendors to provide more information on their long and short term valuation methodologies.

42. There are two emails that are provided to deliver the RFI response, please see below.

Researchcpa@cpa.texas.gov BitcoinReserve@ttstc.texas.gov Which email is the correct email for respondents to use for delivering the RFI?

Please, send your response to Researchcpa@cpa.texas.gov mailto:Researchcpa@cpa.texas.gov

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43. "Each response will be public information and available for public inspection without redaction.

Consequently, a Respondent should not submit any information in its Response that is asserted by Respondent to be confidential or proprietary." The RFI seeks information from respondents that are not public information and considered trade secrets. Would you consider including an addendum to the RFI for all respondents to submit a Certificate of Trade Secret that will provide an exemption from public disclosure?"

CPA RESPONSE:

All responses to this RFI will be considered public information and may be made available for public inspection without redaction. As such, the agency cannot grant exemptions from public disclosure. We strongly encourage respondents to avoid including information that is confidential, proprietary, or considered a trade secret. Please focus your responses on providing general or non-sensitive information that addresses the RFI requirements.

44. What level of technology will be expected to be provided by the custodian in terms of reporting Reserve statuses (e.g., weekly/monthly flat files, sustained APIs with live reporting) for transparency and public assurance?

CPA RESPONSE:

To be determined at a later date after giving due consideration. If this is part of your submission, please explain

45. Will proposals be considered to integrate non-invasive, verifiable data infrastructure to provide public, automated “Proof of Reserves” with onchain attestations to enhance transparency in custody and reporting?

CPA RESPONSE:

Both the Comptroller and the Trust Company aim to provide as much transparency as we can while ensuring the Reserve remains secure at all times. We hope this RFI and potentially an RFP/RFO will help the State of Texas identify such an approach.

46. What are your intentions to weigh innovation (e.g., adoption of advanced cryptographic techniques, real-time proof-of-reserve reporting, or oracle-based risk monitoring) versus traditional financial controls when assessing responses?

CPA RESPONSE:

We would like to learn more about this idea, please make sure to explain context and relevancy along with your vision on what would be the best option.

47. Will the wallet addresses of the Reserve be publicly exposed? Will the wallet addresses have a consistent rotation process provided by the custodian(s)?

CPA RESPONSE:

Both the Comptroller and the Trust Company aim to provide as much transparency as we can while ensuring the Reserve remains secure at all times. We hope this RFI and potentially an RFP/RFO will help the State of Texas

48. What degree of transparency will the Reserve provide to the public in terms of Reserve holding status?

Both the Comptroller and the Trust Company aim to provide as much transparency as we can while ensuring the Reserve remains secure at all times. We hope this RFI and potentially an RFP/RFO will help the State of Texas

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49. Will the sum total of the reserve status be available on a public blockchain for onchain record creation?

Both the Comptroller and the Trust Company aim to provide as much transparency as we can while ensuring the Reserve remains secure at all times. We hope this RFI and potentially an RFP/RFO will help the State of Texas