(a) The stablecoin issuer is wholly responsible for custody of client’s approved stablecoins and provides this service “in-house” through its own wallet solution. Such an arrangement includes scenarios where a licensee provides its own inhouse proprietary wallet for clients to store any approved stablecoins bought through that licensee or transferred into the wallet from other sources.

(b) The stablecoin issuer is wholly responsible for the custody of client’s approved stablecoins but outsources this service to a third-party custodian. Such an arrangement includes the scenario where a licensee uses a third-party service provider to hold all its clients’ approved stablecoins (e.g., all or part of the clients’ private keys).

(c) The stablecoin issuer wholly allows clients to hold their approved stablecoins in self-custody. Clients are required to source and use their own third-party custodians (which the licensee have no control over or responsibility for). This arrangement also includes the scenario where licensees provide an in-house wallet service for clients but also allow clients to transfer their approved stablecoins out of this wallet to another wallet from a third-party wallet provider chosen by the client (and which the licensee does not control).