ht.digital: Building the controls behind stablecoin assurance

Monthly attestation sets the baseline for continuous reserve control

Kevin Fitzgerald, CPA, Partner (US) at ht.digital, joined Paula Pettit, VP of Strategy and Growth at Range, to discuss what stablecoin assurance requires in practice. Fitzgerald leads ht.digital's US expansion after a decade in large accounting firms and four years focused on digital assets. He describes the sector as uniquely structured and says practitioners need to work deeply enough in it to understand it.

Fitzgerald describes the GENIUS Act as the first substantive US legislation focused on crypto and a formal recognition of stablecoin activity. For issuers, its immediate accounting consequence is a requirement for monthly attestation reports. Those reports compare the circulating supply of a stablecoin with the assets held to back it. The objective is clear: the value of the backing assets should exceed the value of the outstanding supply, giving holders evidence that redemption obligations are covered. Fitzgerald points to Circle's existing monthly transparency reports, performed by Deloitte, and Tether's work with BDO as examples of issuer reporting already in the market. In his assessment, Circle has provided this transparency consistently for years, while issuer practice more broadly remains uneven.

Monthly publication still leaves a timing gap. The report is issued after the date being examined, and the conclusion applies to the reserves and supply at that point in time. Fitzgerald supports the requirement while identifying the operating constraint: "I think the monthly attestations are fantastic, but they are a bit delayed in terms of when you would see these." ht.digital is already working with issuers on daily checks and, where possible, real-time reserve verification. The blockchain provides current supply data, so the assurance process can move closer to the speed of the underlying asset.

Range's view is that this regulatory change is an operating-model question. Range starts with regulatory and reporting requirements, translates them into operational controls, orchestrates the risk and compliance providers a company already uses, then runs transaction monitoring, reconciliation and reporting from the same record. For stablecoin treasury management, that sequence gives finance teams a direct path from what an examiner expects to the evidence the business can produce, without rebuilding the record for each monthly close.

Reserve assurance starts with reconciliation across every chain

The reporting framework Fitzgerald discussed centers on two tests. The first is complete supply reconciliation. If a stablecoin exists on six blockchains, the issuer needs to account for the supply across all six, including smaller networks, before comparing the total with reserves. A reserve calculation built from only the largest chains is incomplete. Range reads this requirement as making cross-chain monitoring part of the accounting record rather than a secondary analytics exercise.

The second test is the composition of the reserves. A nominal asset value says little without evidence about what the asset is and how readily it can support redemption. Fitzgerald contrasts an NFT used as backing with a Treasury held at a large banking institution. The figures may both appear on a schedule, but they do not offer the same reserve characteristics. For Fitzgerald, "the quality of the assets matters quite a bit". Reconciliation establishes quantity, while asset review establishes what stands behind that quantity.

Control design sits around both tests. Fitzgerald says auditors are increasingly focused on who can access the system, issue new stablecoins, mint tokens and process redemptions. He also points issuers toward controls for private-key access, custody, key generation and recurring reconciliation. The AICPA proposal he discusses is not itself rulemaking, but it gives issuers a practical reference for the environment an auditor will examine. Range's view is that these are the operating facts that make a proof-of-reserves platform dependable. For teams using Range, the record can show who performed an action, what approval applied and how the resulting change reached the reserve and supply records.

Higher-frequency reporting raises the standard further. Controls tested weekly may not support a daily conclusion without additional process and evidence. Fitzgerald says ht.digital helps issuers determine how their controls can support real-time reporting, combining assurance work with advisory support. The firm's work for Falcon Finance provides one example from the conversation: ht.digital checks daily whether reserves exceed circulating supply and signs off on the result shown on the issuer's transparency page. The reporting cadence is therefore connected directly to the cadence of the control environment.

Stablecoin use has outgrown its place on the balance sheet

Accounting treatment creates a separate problem for companies that hold stablecoins. Fitzgerald explains that US guidance effective from 2024 allows qualifying crypto assets to be measured at fair value. Under the older approach, an asset impaired after a price decline could remain recorded below a later market recovery. The fair-value change addressed that issue for crypto assets in scope, but it did not settle where stablecoins belong. Fitzgerald states the current position plainly: "Stablecoins don't fall in there as of today." The reference is to cash and cash equivalents, where many finance teams expect a fiat-backed stablecoin to appear.

Fitzgerald says stablecoins instead remain within intangible assets under the prevailing treatment he described. That can make the balance sheet harder to interpret when a company uses USDC or USDT as an operating cash rail. It also affects the cash flow statement. Payments made through stablecoins do not appear as cash movements when the asset is outside cash and cash equivalents, even when the business uses those tokens as its primary vehicle for moving funds. The accounting presentation can therefore diverge from how the company actually operates.

There is room for judgment. Fitzgerald cites Coinbase and Figure Technologies as companies that publicly determined their stablecoin holdings qualify as cash and cash equivalents, with their auditors signing off on that treatment. His practical qualification is that "as long as you can get your auditors comfortable, there is some room there", while he expects stablecoins to move toward the cash and cash equivalents category as adoption grows. That could include a separate balance-sheet breakout that distinguishes stablecoins from traditional fiat. He avoids presenting that direction as settled policy.

Range's view is that finance teams should prepare for this accounting judgment by maintaining one live record across wallets, exchanges, custodians and bank accounts. The classification decision belongs to the company and its auditor. The operational evidence should already show balances, transaction history, counterparties and reconciliations across stablecoin and fiat rails. That gives the auditor a coherent record to test and gives the finance team a stable foundation for reporting, regardless of where the final line item appears.

Institutional adoption follows evidence and accountable review

The value of an assurance signature rests partly on accountability. Fitzgerald notes that technology companies can verify reserves or displayed yields, but their exposure is different from that of a licensed accounting firm. Fitzgerald says, "There are technology firms that do this, but they do not have the same liability exposure that a CPA firm does." A CPA firm puts its license behind the conclusion. That creates an additional incentive for care in the testing, documentation and language of the report.

Specialized knowledge also changes the engagement. Fitzgerald says clients moving to ht.digital often describe having to teach a previous auditor the mechanics of their business. The recurring complaint is specific: "I had to explain what staking was. I had to explain what bridging was. I had to explain each and every of these transactions." ht.digital concentrates its people and technology budget on digital-asset accounting and audit work. That focus reduces the translation burden for a company whose books include activities that generalist teams may encounter infrequently.

Fitzgerald sees institutional activity in stablecoins, vault products and crypto exchange-traded funds. He characterizes adoption as gradual, which is consistent with how established institutions approach unfamiliar financial products. He says established firms "have been around for hundreds of years because they're not going to risk a lot right away". The practical signs of adoption are therefore found in controlled use cases and familiar product structures, rather than in broad claims that every institution has already moved onchain.

He is more cautious about agent-based payments. The idea that software agents will each hold wallets and trade continuously has received attention, but ht.digital has not yet seen meaningful activity in that category. Fitzgerald places it several years from maturity. By contrast, ht.digital has discussed yield attestations with vault platforms and asset managers, and Fitzgerald expects institutional capital to care whether the displayed yield has been verified and controls are in place. His summary is concise: "They care about having these controls." Adoption grows when finance and risk teams can rely on the evidence behind the product.

Build the record before the attestation

Fitzgerald's advice to issuers preparing for GENIUS is practical: begin audit-firm conversations early, confirm whether the firm meets the registration requirements then under consideration and test the controls around reconciliation, private keys, custody, minting and redemption. Range's view is that the same evidence should run through daily operations, so reporting becomes an output of the control environment rather than a separate reconstruction. See how Range supports stablecoin operations.

About ht.digital

ht.digital is a professional services firm focused on digital assets. It provides audit and assurance, proof-of-reserves attestations, foundation management, crypto accounting and tax services. Learn more at ht.digital.

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