| 1. | VASPs shall, at all times, maintain reserve assets equivalent to one hundred percent (100%) of the liabilities owed to clients with respect to all VA Activities (“Reserve Assets”). |
| 2. | VASPs must hold Reserve Assets on a one-to-one basis in the same Virtual Asset that liabilities are owed to its clients. |
| 3. | Reserve Assets must be reconciled on a daily basis and audited by an independent third-party auditor no less than every six (6) months. VASPs shall include such audit reports as part of the subsequent quarterly report to VARA required in the Compliance and Risk Management Rulebook.
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