Wyoming Special Purpose Depository Institutions Act

The Act creates a state-chartered special purpose depository institution, or SPDI, as a Wyoming corporation formed for a limited banking purpose. Current statutory text authorizes SPDIs to conduct nonlending banking business, provide payment services, apply for Federal Reserve System membership, and engage in commissioner-approved incidental activities.

Those incidental activities may include custody, safekeeping, asset servicing, fiduciary powers, investment adviser or broker-dealer activity, commodities-intermediary functions, and taking deposits related to those services. The statute generally prohibits an SPDI from making loans, with narrow exceptions for purchasing specified debt obligations.

The Wyoming Division of Banking describes Wyoming-chartered SPDIs as fully reserved banks that may receive deposits and conduct incidental activities including custody, asset servicing, and fiduciary asset management. The Division states that SPDIs are likely to focus on digital assets, virtual currencies, digital securities, and digital consumer assets, although the same framework may also support traditional-asset and business-cash-management use cases.

This makes the Act significant for crypto market infrastructure, but it is not solely a crypto statute. Its operative legal structure is a banking charter, with digital-asset activity addressed through custody, asset-servicing, payment, fiduciary, compliance, and supervisory requirements rather than through a standalone token-issuance regime.

The statute requires an SPDI to maintain unencumbered liquid assets valued at not less than 100% of its depository liabilities. Eligible liquid assets include U.S. currency on premises, funds held at a Federal Reserve bank or federally insured financial institution, highly liquid investments, and certain U.S. Treasury or federal agency obligations.

SPDIs must comply with applicable federal law, including anti-money-laundering, customer-identification, and beneficial-ownership requirements. The statute also requires depositor evidence for identity, AML, and beneficial-ownership purposes and imposes disclosure duties when deposits are not insured by the Federal Deposit Insurance Corporation.

Wyoming places SPDIs under the supervision of state banking authorities. The statute covers charter applications, public hearing procedures, reports, examinations, supervisory fees, insurance or bond coverage for operational risks, suspension or revocation of authority, and liquidation or continuing jurisdiction after operations end.

The SPDI framework has been amended since enactment. The Wyoming Division of Banking notes amendments in 2020 and 2021, and the legislature later enacted SF0095 in 2025, which addressed conversion of SPDIs into public trust companies, depositor requirements, and related statutory changes.

In 2026, Wyoming enacted SF0055, which modifies SPDI capital, charter-application, business-commencement, supervision-fee, and resolution-fund provisions. The enrolled act states that most 2026 amendments take effect July 1, 2026, while rulemaking and effective-date sections took effect immediately. Editors should re-check the consolidated statute after July 1, 2026, before treating those amendments as fully operative.