Circle Internet Financial, LLC issues USDC. As of Circle Internet Group’s December 31, 2025 Form 10-K, approximately 88% of USDC reserves was in the Circle Reserve Fund, a Rule 2a-7 government money-market fund managed by BlackRock, with the fund’s assets held in custody at BNY. The remaining 10–20% was typically cash in accounts titled for the benefit of USDC holders (FBO accounts), primarily at global systemically important banks (GSIBs), with a small fraction at additional operational banks.
To verify those roles rather than relying on a summary, use four dated records: Circle’s Transparency & Stability page, the newest Circle SEC filing, the daily fund disclosure referenced by that filing, and the latest independent USDC examination report. The records answer different questions, so checking only one can give an incomplete picture.
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The short answer: issuer, manager, custodian and cash banks are different roles
| Role | What it means for USDC | Evidence identified in Circle’s disclosures |
|---|---|---|
| Issuer | The entity that creates, redeems and administers USDC. | Circle Internet Financial, LLC. Circle has described it as the sole issuer of USDC. |
| Investment manager | The firm that manages the reserve fund’s portfolio. | BlackRock manages the Circle Reserve Fund. |
| Custodian | The institution that holds the assets inside the reserve fund. | BNY holds the assets of the Circle Reserve Fund. Circle also announced BNY as a primary custodian for USDC reserves. |
| Cash banks | Banks holding the reserve portion maintained as cash rather than in the fund. | FBO accounts, mainly at GSIBs, plus a small fraction at additional banks. |
| Assurance provider | An independent accountant that examines management’s assertion about reserves and circulation. | A Big Four accounting firm performs monthly third-party assurance; the June 30, 2025 examination report tested the defined reserve assertion. |
“Custodian” therefore does not mean that BNY issues USDC or that BlackRock owns USDC. Circle remains the issuer. BlackRock manages a fund that contains a large portion of the reserves, while BNY provides custody for that fund’s assets.
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Start with the Transparency & Stability page
Open Circle’s Transparency & Stability page and record its dated as of line before reading the figures. Circle says USDC is redeemable 1:1 for U.S. dollars and publishes reserve composition, circulation, weekly holdings, mint and burn flows, and links to monthly assurance reports. The page’s own wording is: “USDC is always redeemable 1:1 for US dollars, and EURC is always redeemable 1:1 for euros. Always.”
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The date matters because reserve composition and circulation change. A page viewed in 2026 should not be treated as if every number on it describes December 31, 2025, or June 30, 2025. Write down the page date, the circulation number, the reserve categories and the links to the newest assurance report.
Use the page for frequency, not for every custody detail
Circle’s transparency page is the most convenient place to see recurring updates, but it is not the complete legal description of every account or service provider. Weekly holdings and mint/burn data show movement over time; they do not by themselves identify the legal issuer, the investment manager or the custodian for each reserve component. For those roles, move to the corporate announcement and SEC filing.
Confirm who actually issues USDC
Read Circle’s issuer statement
Circle Internet Financial, LLC is the USDC issuer. Circle’s corporate announcement identifies that entity as the sole issuer of USDC. This is the answer to “Who creates and redeems USDC?” It is not BlackRock, BNY or any of the banks that hold cash.
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A wallet, exchange or blockchain explorer may display a USDC balance, but those services do not become the issuer merely because they distribute or store the token. The issuer relationship is established by Circle’s own corporate and regulatory disclosures. When making your notes, record the complete legal name, not only the shorter brand name “Circle.”
Find the investment manager and custodian in the SEC filing
Use the newest dated Form 10-K or other filing
Open the newest Circle Internet Group SEC filing available to you and search within the document for USDC reserves, Circle Reserve Fund, custodian, FBO and BlackRock. The filing is the best source for a dated description of how reserves were allocated and which service providers had which responsibilities.
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What the December 31, 2025 filing reported
Circle’s 2025 Form 10-K, reporting its position at December 31, 2025, said approximately 88% of USDC reserves was held in the Circle Reserve Fund. The fund is a Rule 2a-7 government money-market fund managed by BlackRock. The assets in that fund were held in BNY custody.
The same filing said the remaining 10–20% was typically cash in FBO accounts, primarily at GSIBs, with a small fraction at additional banks. The percentages are approximate and describe that reporting date; they are not a guaranteed 2026 allocation. Because the figures are rounded and the cash range is presented as typical, do not add them as if they were precise components of a single-day balance sheet.
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Interpret the fund relationship correctly
The Circle Reserve Fund is a vehicle holding reserve assets; it is not a second issuer of USDC. BlackRock’s role is investment management. BNY’s role is custody of the fund’s assets. Circle’s role remains issuing and redeeming the token and administering the reserve structure.
Check the fund-level detail through the daily disclosure
Follow the USDXX disclosure named by the filing
Circle’s SEC filing points readers to BlackRock’s USDXX disclosure for daily fund-level information. The filing says that disclosure is updated daily. Use it to inspect the fund’s holdings, maturity profile and net asset information for the date you care about.
Know what the daily file can and cannot prove
Daily USDXX information covers the Circle Reserve Fund, not every USDC reserve. It can show what is inside the fund managed by BlackRock, but it does not replace the issuer disclosure about cash in FBO accounts at other banks. For an all-reserves view, combine it with the SEC filing and Circle’s transparency page.
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When you save a daily record, include the observation date and the document’s update date. A fund portfolio can change after the page is posted, and a daily fund report does not establish the balance of USDC in circulation on the same day unless that figure is separately reported.
Compare circulation with reserve assets in the independent examination
Locate the examination report, not just a press summary
Open the latest independent USDC examination report linked from Circle’s transparency materials. Find the two lines headed USDC In Circulation and Fair Value of Assets Held in USDC Reserve. They are the figures the accountant compares against the defined criteria in the report.
The June 30, 2025 examination
Circle’s June 30, 2025 independent examination reported 61,332,530,506 USDC in circulation and $61,397,784,739 in fair value of reserve assets. The independent accountant concluded that management’s assertion that the fair value of assets held in the USDC reserve was equal to or greater than USDC in circulation, as of the report dates and under the report’s criteria, was fairly stated in all material respects.
This is an examination of a defined assertion at a stated date. It is not a promise that the same amounts exist today, nor is it a guarantee about the future market value of every instrument. The report’s date and criteria must travel with the numbers whenever you quote them.
Understand “attestation” versus “audit”
Circle describes monthly third-party assurance, and the examination report tests management’s reserve assertion against defined criteria. That is different from treating every public page as a full audit of Circle’s entire business. The report addresses the reserve assertion and the specified procedures; read its scope, definitions and report date before drawing a broader conclusion.
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Learn what assets qualify as USDC reserves
Circle’s reserve standard limits eligible reserves to the following categories:
- U.S. Treasury securities with three months or less remaining maturity.
- Cash deposits at global banks.
- Overnight tri-party reverse repos fully collateralized by U.S. Treasuries.
- Government money-market funds.
- Products whose underlying assets are limited to those categories.
This standard explains why a government money-market fund appears in the structure and why the daily fund disclosure matters. It also gives you a checklist for reading a portfolio: an instrument should fit one of the permitted categories or be a product whose underlying assets are restricted to them.
A repeatable verification procedure
- Record the transparency page date. Write down the “as of” date, current USDC circulation, reserve composition and the links to the monthly assurance reports.
- Confirm the legal issuer. In Circle’s corporate materials, verify that Circle Internet Financial, LLC is identified as the sole issuer of USDC.
- Open the newest SEC filing. Search for the reserve section and note its filing date, reporting date, fund percentage, cash range and descriptions of FBO accounts.
- Map the service providers. Enter Circle as issuer, BlackRock as investment manager of the Circle Reserve Fund, BNY as custodian for that fund, and the disclosed GSIBs and additional banks as cash-bank categories where the filing identifies them.
- Inspect the daily fund disclosure. Follow the USDXX reference in the filing and save the observation date and the fund’s holdings. Treat this as fund-level evidence, not an all-reserves total.
- Read the independent examination. Locate the circulation and fair-value lines, copy both with the report date, and read the accountant’s conclusion and scope.
- Compare dates before making a claim. Do not present a June 30, 2025 examination figure as a current 2026 balance, or present the December 31, 2025 88% figure as a permanent allocation.
- Keep the evidence together. Store the page date, filing date, report date and daily fund date in the same verification note so that a reader can see which statement each number supports.
Which source should you trust for which question?
| Question | Best source | Recency | Scope | Authority and role clarity |
|---|---|---|---|---|
| What is the current published reserve composition? | Circle Transparency & Stability page | Weekly holdings and a dated page update | Circle’s published view of all reserve categories | Issuer disclosure; useful for recurring monitoring |
| Who issues USDC? | Circle corporate issuer statement | Dated corporate announcement | Legal issuer relationship | Issuer source; directly identifies Circle Internet Financial, LLC |
| How are reserves divided between the fund and cash? | Circle Internet Group SEC filing | Annual filing; the cited allocation is as of December 31, 2025 | Reserve structure, percentages, FBO accounts and service providers | Regulatory filing; strongest source for role and legal-structure detail |
| What is inside the managed fund today? | USDXX disclosure referenced by the filing | Daily update | Circle Reserve Fund only | Fund-level disclosure; does not cover external FBO cash |
| Did reserves meet circulation at a stated date? | Independent examination report | Monthly report dates; the cited report is June 30, 2025 | Defined reserve assertion and specified criteria | Independent accountant’s examination; not a general audit of every business activity |
Important legal and operational limits
Reserve accounts are described as benefiting USDC holders
Circle’s SEC filing says reserves are held in accounts titled for the benefit of USDC holders and are not lent, borrowed against or encumbered. That description supports operational due diligence: it tells you how Circle says the accounts are structured and restricted.
Bankruptcy treatment is not definitively settled
The same filing says courts have not yet definitively ruled on how reserve assets would be treated if an issuer entered bankruptcy. Custody disclosures therefore reduce uncertainty about who holds assets operationally, but they do not eliminate legal, insolvency or market risk.
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A custodian is not a guarantee against every loss
BNY custody identifies the institution holding assets for the Circle Reserve Fund. It does not make BNY the issuer, guarantee redemption independently of Circle, or remove risks associated with settlement, law, fund operations or the value and liquidity of permitted assets. The same distinction applies to BlackRock’s management role.
How to report your finding accurately
A careful verification note should include four separate sentences rather than one blended claim:
- Issuer: Circle Internet Financial, LLC is identified by Circle as the sole issuer of USDC.
- Fund manager and fund custodian: The December 31, 2025 SEC filing describes BlackRock as manager of the Circle Reserve Fund and BNY as custodian of the fund’s assets.
- Cash portion: The filing describes the remainder as typically held in FBO cash accounts, mainly at GSIBs, with a small fraction at additional banks.
- Reserve test: The June 30, 2025 independent examination compared USDC in circulation with the fair value of reserve assets and found management’s assertion fairly stated in all material respects under the report’s criteria.
This wording preserves the dates and prevents a common error: saying that one custodian holds every dollar of USDC backing when the disclosures describe both a fund and separate cash accounts.
Common mistakes when checking USDC backing
Calling the manager the issuer
BlackRock manages the Circle Reserve Fund; it does not issue USDC. Use the issuer’s legal name when answering who creates and redeems the token.
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One free scan finds every outdated or missing driver and matches the right update for your exact hardware.Free scan · exact hardware matchCalling BNY the custodian of every reserve
BNY is identified as custodian for assets in the Circle Reserve Fund and as a primary custodian in Circle’s announcement. The filing separately describes cash in FBO accounts at multiple banks. Say “custodian of the fund’s assets” unless a newer disclosure explicitly establishes a broader scope.
Using an old percentage as a current percentage
The approximately 88% figure belongs to the December 31, 2025 filing. Reserve allocations can change, so check the newest dated filing and current transparency page before describing today’s mix.
Relying on a single attestation line
An examination conclusion is valuable, but it is tied to a report date and defined criteria. Pair it with the issuer identity, filing, fund disclosure and cash-bank description.
Confusing token circulation with reserve value
USDC in circulation is a token count, while fair value of assets is a dollar valuation. The examination places them side by side for a stated date; do not treat either number as a perpetual balance.
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A compact checklist for future updates
- Have you recorded the Transparency & Stability page’s “as of” date?
- Have you named Circle Internet Financial, LLC as issuer?
- Have you checked the newest SEC filing rather than relying only on a prior article?
- Have you separated BlackRock’s manager role from BNY’s custody role?
- Have you included FBO cash accounts and their bank categories?
- Have you checked the daily USDXX disclosure for fund-level detail?
- Have you copied both circulation and reserve-asset figures from the same examination report date?
- Have you labeled every percentage and amount with its date, scope and qualification?
- Have you noted that bankruptcy treatment of reserve assets remains legally unresolved?
If all nine answers are yes, your check distinguishes the issuer, investment manager, custodian, cash banks and independent assurance provider instead of collapsing them into a single “USDC reserves” label.
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