ESBD_482662_1768333174855_RFI 908-26-031326MS Transactional Payment Systems Using Asset-Backed Currency.pdf

RFI No. 908-26-031326MS

RFI 908-26-031326MS – Transactional Payment Systems Page 1 of 7

CMD# 26-8133VR

KELLY HANCOCK

ACTING TEXAS COMPTROLLER OF PUBLIC ACCOUNTS

Request for Information (RFI) for

Transactional Payment Systems Using

Asset-Backed Currency

January 13, 2026

Schedule of Events

January 13, 2026 Issuance of RFI

February 6, 2026 Deadline for Submission of Questions (2:00 p.m., CT)

February 16, 2026 Release of Answers to Questions

(or as soon thereafter as practical)

March 13, 2026 Deadline for Submission of Responses (2:00 p.m. CT)

Late Responses will not be considered

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A. Summary

1. Type of Document: Request for Information (RFI)

2. Deadline for Responding to RFI: March 13, 2026 @ 2:00 p.m., Central Time (CT)

Respondents are solely responsible for ensuring receipt of their

Responses at the email addresses specified in Section A.4 on or before the specified deadline; late Responses will not be considered.

3. CPA Point of Contact for this RFI: Michelle Shih, CTCD/CTCM

Email: researchcpa@cpa.texas.gov

4. Method of Submitting Responses: Responses must be submitted to:

Email: researchcpa@cpa.texas.gov

5. RFI Addenda: CPA will post any amendments to this RFI as addenda on the Electronic

State Business Daily (ESBD) located at http://www.txsmartbuy.com/esbd. It is the responsibility of an interested party to periodically check the ESBD for updates to the RFI prior to submitting a RFI Response.

6. Questions and Answers: Questions regarding this RFI must be submitted in writing to CPA’s

Point of Contact in Section A.4 no later than February 6, 2026; 2:00 p.m. CT. Telephone inquiries will not be accepted. CPA intends to post answers to questions received on the ESBD on or about February

16, 2026.

7. Respondent Presentations: In CPA’s sole discretion and to assist in additional information gathering, CPA may invite Respondents to give a presentation to explain in further detail the recommendations made or information provided in the RFI Response. Any presentation(s) will be performed at CPA offices located in the LBJ Building, 111 E. 17th Street, Austin, Texas 78774;

presentation date(s) and time(s) to be arranged.

mailto:david.cruz@cpa.texas.gov mailto:david.cruz@cpa.texas.gov http://www.txsmartbuy.com/esbd

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B. Introduction

In response to the enactment of House Bill 1056 by the 89th Texas Legislature (Act) creating Subchapter D of Chapter

2116 of the Texas Government Code, the Texas Comptroller of Public Accounts (“CPA” or “Comptroller”) issues this Request for Information No. 908-26-031326MS (RFI) to gather information regarding implementation and maintenance of an electronic payment system using a digital instrument or currency backed by gold or silver held in the Texas Bullion Depository (Depository). Responses to this RFI will aid the CPA in preparing for the statutory May

2027 effective date for a transactional payment system and add to CPA’s general understanding of the types of offerings which are commercially available in this industry, including but not limited to debit cards and digital wallets.

All references in this RFI to a “depository” mean the Texas Bullion Depository.

Section 2116.104 of the Texas Government Code gives CPA the authority by rule to establish fees that are reasonable and necessary to implement the legislation. Because no appropriations were included for the Depository, the Act appears to envision a private business contracting with CPA to establish and run a transaction payment system using a currency backed by deposits held in the Depository under the supervision of CPA, with the contractor being paid for its services through the collection of service fees.

This RFI seeks input from Respondents interested in partnering with the Depository to establish such a payment system by leveraging existing platforms or implementing an alternative model suggested by Respondents. The Comptroller is also interested in gauging industry interest in partnering with the Depository to create a new, Texas-based digital instrument backed by bullion held in the Depository as the basis for a transactional payment system.

C. Background

The Depository is a Texas state agency within the office of the Comptroller. The Depository was established as the first - and only - state-administered and audited bullion facility currently operating in the United States. Authorized by H.B. 483, 84th R.S., (2015), Chapter 2116 of the Texas Government Code, the Depository serves as the custodian of bullion owned or acquired by the state of Texas (State) or an agency, political subdivision, or another instrumentality of the State. In addition, the Depository is authorized to accept deposits of bullion from, or on behalf of, any person acting in the person’s own right, as trustee, or in another fiduciary capacity.

In this latter role, the Depository in partnership with its vendor, Lonestar Tangible Assets LP (LSTA), currently provides precious metals storage, safekeeping, custody, and accounting to individual investors and other owners of bullion. Direct governmental oversight of the depository operations by the Comptroller ensures adherence to the highest standards of public accountability and transparency.

Located on a purpose-built 10-acre campus in Leander, Texas, just north of Austin, the Depository houses its holdings within the highest-rated Class III vaults and multi-layered physical security. The facility offers COMEX-scale liquidity, all-risk insurance underwritten by Lloyd’s of London, and is explicitly structured to eliminate counterparty risk. Digital infrastructure enforces cybersecurity and privacy through at least 256-bit encryption, encrypted data storage, and a secure customer portal that enables real-time account access (including valuation, photographic verification, and transaction history).

D. Scope

CPA is interested in responses to the questions below to explore models for implementing a transactional payment system that would enable point-of sale or peer-to-peer transactions backed by precious metals stored at the Depository. CPA is interested in learning more about how such transactions could be settled by either liquidating a corresponding amount of bullion in near real-time to settle fiat currency transactions or allowing for peer-to-peer transfers without a central intermediary to facilitate each transaction.

While CPA is particularly interested in input regarding how existing platforms can be used or adapted as part of a transactional payment system as contemplated by the Act, CPA is equally interested in understanding whether other

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CMD# 26-8133VR

innovative models or mechanisms could achieve the same objective of enabling secure, scalable, and widely adopted payments using assets held in the Depository.

Respondents should be aware that as a state agency, the Depository must comply with Section 10, Article I, United States

Constitution which prohibits states from coining money or emitting bills of credit. As such, Respondents should specifically address how their recommended model would be fully compliant with that provision.

Vendors are encouraged to respond to the RFI in full or to the best of their ability. Additional documents, such as copies of a scope of work, are encouraged to be submitted with vendor responses. CPA may request presentations or demonstrations from vendors based on their RFI response.

General

1. Does your company presently have an existing platform or payment technology that could be adapted to comply with the Act for use with bullion held in the Depository? If so, how would your existing platform or payment technology enable payments backed by precious metals held by the Depository.

2. What other alternative models could enable depositors and vendors to make and receive payments using bullion-backed digital instruments? In your response, please describe the relative advantages and disadvantages of your proposed model compared to both the account-based model and asset-backed model.

3. In your view, what are the relative advantages and disadvantages of an account-based model that uses a third-party payment processor (i.e., a debit card) versus using asset-backed digital tokens for implementing a transactional payment system? What are the strengths and weaknesses of your recommended model in achieving adoption, liquidity, and compliance? How does your recommended model achieve these goals?

4. How do you recommend structuring a public-private partnership (P3) to achieve the goal of creating a payment transaction system as contemplated by the Act given the lack of an appropriation of funds? How does your recommended structure best align incentives between the State and a private partner?

System Architecture

5. What platforms or technology standards should be implemented in the creation of a gold and silver-backed payment transaction system that addresses scalability, transaction costs, and user accessibility?

6. How should real-time “proof of reserves” to verify depository holdings be structured and implemented?

7. If your recommended model includes digital tokens, what is your recommended approach for custodial vs. non-custodial wallets (i.e., should users hold their own keys or rely on a managed service)? How would your approach address interoperability with other digital assets, wallets, and payment platforms, both within and outside Texas?

Payment Functionality

8. Please provide a recommendation as to whether the payment system should interface with existing banking and payment networks and, if not, describe how your solution provides an alternative to existing payment networks while also fully complying with U.S. federal and state regulatory requirements. If yes, please describe how your proposed solution could interface with existing banking and payment networks (ACH, FedNow, credit/debit card networks)?

9. How would your recommended model work to support point-of-sale transactions and/or peer-to-peer transactions?

What should a typical workflow for point-of-sale and a peer-to-peer transactions look like?

10. How should we verify the value of the precious metals in real time in order to authorize a transaction?

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11. How would point-of-sale transactions be settled? What processes would you recommend for the near real-time liquidation of the account holder's bullion to settle transaction? Please describe:

a. Whether liquidation should occur through internal netting of trades, an external liquidity provider, or a combination?

b. If an external liquidity provider should be used, what are the required characteristics of such a partner (e.g., regulatory status, creditworthiness, market depth).

c. How price slippage and execution risks should be managed between the point-of-sale and the time of settlement/liquidation?

12. How much working capital would be needed? Detail a proposed strategy for providing and managing the working capital required to bridge any potential settlement lag between the instant authorization of a fiat transaction on a card network and the final settlement of the corresponding bullion sale.

13. How could your recommended model support offline payments or low-connectivity environments?

Bullion Liquidation and Redemption Process

14. Please recommend a redemption process workflow for a depositor to redeem their account balances for physical bullion, U.S. dollars, or a combination of physical bullion and U.S. dollars that will maximize liquidity. This recommendation should detail the process from the initial request in the user interface to the final delivery or in-person pickup, including all necessary user verification, token-burning mechanisms (if applicable), and inventory reconciliation steps required by the Depository.

15. What policies and limits regarding redemption (e.g., minimum/maximum transaction amounts, daily frequency, and required notice periods for large requests) do you recommend for redeeming physical bullion or converting the physical bullion for U.S. dollars?

16. How would your recommended model’s solution interface with the Depository’s existing inventory management and custody systems? Please describe the API or data exchange protocols, key data fields, and the update frequency the

Depository should require to ensure real-time reconciliation between transactions and physical bullion held in custody. If your recommended model is token-based, please elaborate on how the blockchain record and Depository records should be reconciled.

Partnership Ecosystem and Third-Party Roles

17. Please identify the types and qualifications of partners required to implement your recommended model (e.g., FDIC-insured issuing bank, payment card network, payment processor, bullion liquidity provider) and describe the role and responsibility of each.

Risk Management and Regulatory Compliance

18. Please provide a summary of the regulatory challenges (U.S. federal, state, and international laws and restrictions) that your recommended solution faces and how you will comply.

19. If you are recommending a token-based model in which the state, as opposed to a private entity, would create a currency backed by bullion held in the Depository, please specifically address how your recommended model complies with Section 10, Article I, United States Constitution which prohibits states from coining money or emitting bills of credit.

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20. How should KYC/AML requirements be implemented for both individual depositors and commercial vendors? What controls should the Depository require to be put in place to ensure real-time monitoring and reporting of suspicious transactions (AML/CFT compliance) without undermining user privacy?

21. What risk management and consumer protection protocols do you recommend to protect the payment transaction system and its users from fraud, cybersecurity threats, and operational failures (e.g., failure of a third-party partner, price feed disruption). How would these protocols comply with federal regulations such as Regulation E (12 CFR

Part 1005)?

Fee Structures and Revenue Model

22. What fee structures are needed to ensure sustainability while also maintaining affordability for users?

23. What projected transaction volumes and adoption rates would be necessary for financial sustainability using the proposed fee structure?

24. How would fees be collected using your recommended model?

Deposit and Minting Process

25. If your recommended model includes a token, please explain the process for how new physical bullion deposits into the Depository should be verified by the system, trigger the minting of new tokens, and ensure the tokens are correctly credited to the depositor’s digital wallet? What standards could the Depository implement to ensure fraudulent tokens would not be able to be presented within the ecosystem?

Other

26. Please identify any other challenges or concerns not mentioned above that CPA should consider in implementing a transactional payment system.

27. Please describe in general the timeline needed to implement a transactional payment system based on an existing technology or a token backed by gold and silver bullion held in the Depository and how the program should be marketed to encourage broad adoption upon launch. In your response, please estimate the cost of marketing.

E. Required RFI Response Materials

Respondents must email an RFI response titled “RFI #908-26-031326MS Response” to the designated CPA Point of

Contact on or before the deadline for Responses (see Section A.2) and as otherwise required by Section A (Summary).

The RFI Response should include the items listed below and be organized in the following manner:

• Entity name and address.

• Point of contact information for Respondent regarding its RFI Response (i.e., name, title, telephone number and email address of Respondent’s designated personnel).

• Enumerated responses to each item requested in Section D (Scope), in the order listed. If not applicable, please write N/A in your response.

• Any other information that the Respondent deems pertinent or relevant to this RFI (e.g., brochures or other company literature).

F. No Award Results from this RFI

This RFI is issued solely for the purpose of obtaining information that may assist CPA in determining grant activities that may be requested in a future solicitation, and no contract will be awarded in connection with this RFI. CPA is

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under no obligation to issue a solicitation. Respondent’s submission of a Response is voluntary and failure to respond will have no impact on the evaluation of responses to any subsequent solicitation.

G. No Compensation or Cost Recovery

CPA shall pay no costs, expenses, or any other amounts to any entity that are incurred under or related to this RFI.

H. Ownership of Responses, Copyright, Public Nature of Responses

Responses to this RFI will be the property of CPA. CPA, in its sole discretion, may consider or disregard any information submitted in a Response to this RFI. Responses to this RFI will not be returned to Respondents.

Responses 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.

A response with a copyright notice or marked as “Confidential or Proprietary” is not acceptable and will be rejected by CPA as non-responsive to the RFI.