The common determination of the member financial institutions
The Alkaimi Ecosystem™ member financial institutions have determined, in common, to carry the 100% Whole Reserve™ model from wholesale settlement into consumer banking, at their own branches, under their own names and regulators, carrying the Alkaimi™ mark to identify their ecosystem affiliation.
The statements on this page are statements of that intent. No consumer service has been deployed, and each will be offered, when it is offered, under the member financial institution's own regulator.
How the transition occurs
As the Alkaimi Ecosystem's ledger grows, member financial institutions accumulate national currencies from the conduct of wholesale settlement and from the transactions aligned with it that they conduct on behalf of their clients.
The transition to consumer banking services is to occur under the charters the members already hold, because each member is an operating, chartered financial institution that already takes deposits, already lends, and already holds the central bank accounts and correspondent relationships its currency business requires.
The transition changes what the member financial institution does with what a client holds, not where the client goes or under whose regulator the member operates.
What the 100% Whole Reserve model is in retail operation
In retail operation, a member financial institution conducts two businesses at one desk.
- The value side
- The member holds a client's value in custody on the Alkaimi Ecosystem's ledger, whole, under the client's title: the member places no lien on it, pledges it to no one and creates no claim against it, and settles it with any other member financial institution as a ledger entry, final when the value moves.
- The currency side
- The member continues to take ordinary currency deposits, to exchange settled value for currency on the client's instruction, and to lend. The loans the member writes may be funded by a term advance from the member's own central bank, on collateral that central bank accepts, secured on Digitized Tangible Assets™ (DTAs™) whose owner has agreed to rent them to the member for a term, and not by deposits the member creates by lending.
Every loan the Alkaimi Ecosystem member writes on rented DTAs creates no deposit, and every existing loan that repays retires the deposit that created it. The Alkaimi Ecosystem member's created deposits therefore retire with its old loans, on the member's own timetable, while its new loans stand on rented DTAs. No depositor is asked to leave.
Why a member financial institution in retail operation is not a narrow bank
A narrow bank takes deposits and places all of them at the central bank; it lends nothing. In 2019 the Board of Governors of the Federal Reserve System stated three concerns about such a financial institution.
- Very large balances at the central bank
- That it could attract very large deposits and hold very large balances at the central bank, complicating the implementation of monetary policy.
- Deposits drawn away from lending
- That it could draw deposits away from the financial institutions that lend.
- Stability in stress
- That its balances could harm the stability of the financial system in stress.
On 13 December 2023 the Federal Reserve Bank of New York refused The Narrow Bank an account on grounds of the same kind: undue risk to the stability of the financial system and to the implementation of monetary policy.
Three points of construction
An Alkaimi Ecosystem member financial institution in retail operation is not a narrow bank, on three points of construction, and each point answers one of the concerns.
- Value outside any central bank
- An Alkaimi Ecosystem member financial institution does not place its clients' value at a central bank. Client value is held in custody on the Alkaimi Ecosystem's ledger, in the client's title, outside the member's balance sheet and outside the central bank's. The ecosystem member's balances at its central bank are its ordinary settlement balances, in the ordinary amounts a financial institution of its size holds.
- A lender whose lending grows with the ledger
- An Alkaimi Ecosystem member financial institution lends, and its lending grows as the ledger grows. Each loan may be funded by a central bank advance secured on rented DTAs, under the central bank's existing rules on collateral; whether to fund a loan that way is each member financial institution's own decision, and whether to extend the advance is its central bank's, under that central bank's rules. The supply of credit a member can extend expands with every asset recognized onto the ledger, which is the opposite of a financial institution that lends nothing, and the lending is funded on substance rather than on the deposits of other financial institutions.
- Ordinary deposits, and custody that cannot be run
- An Alkaimi Ecosystem member financial institution continues to take ordinary currency deposits under its own charter and its own deposit insurance regime. The member's clients' value in custody cannot be run in the sense a deposit is run, because the member never owed it; a client who moves value to another member financial institution moves the client's own holding, and nothing on the member's books falls due. In stress, the member need sell nothing to meet a withdrawal of client value, because client value is not the member's liability, and a client's movement of value to another member financial institution is a movement of the client's own holding on the ledger; the deposits the member does owe are funded and insured as they were before the member joined the ecosystem.
- Removal of value from the ledger
- A client who removes recognized value from the ledger does not withdraw anything from any member financial institution; the client unwinds the value recognition under the agreement that created it, clearing the obligations standing against the value, paying the fees the agreement sets, and taking back the rights in the tangible asset the client assigned to obtain recognition. The unwinding reaches only the value the client still holds, and the client gives up the liquidity the recognized value carried. No member financial institution's books are touched by it.
The findings
| The Board's concern | The member's construction | The finding |
|---|---|---|
| Very large balances at the central bank | Client value is held in custody on the ledger, outside the central bank's balance sheet; the member's central bank balances are its ordinary settlement balances. | Does not describe a member's operations. |
| Deposits drawn away from lending | The member is a lender, its lending grows with the ledger, and the lending is funded on substance rather than on the deposits of other financial institutions. | Does not describe a member's operations. |
| Stability in stress | Client value is not the member's liability and cannot be run; the deposits the member does owe are funded and insured as they were before membership; removal of value from the ledger is a contractual unwinding, not a withdrawal. | Does not describe a member's operations. |
Table 4. The Board's three concerns of 2019 against the narrow bank, the member financial institution's construction on each, and the finding.
None of the three concerns the Board stated against the narrow bank describes an Alkaimi Ecosystem member financial institution, and the record is why the model is the better construction.
As the Alkaimi Ecosystem's ledger grows, each of those three points grows with it.
- Custody
- More value in custody outside any central bank.
- Lending
- More lending funded on rented DTAs.
- Deposits
- Fewer created deposits on the member's books.
The question a central bank put to the narrow bank grows smaller with every year of the members' operation, because every year of operation makes the members less like a narrow bank and more like what they are: chartered financial institutions that hold their clients' value whole and lend on substance.
How the public will recognize a member financial institution
A member financial institution will carry the Alkaimi mark: on the sign of its building, on its application, beside its own name. Where the mark is displayed, the financial institution displaying it operates the 100% Whole Reserve model.


How the public will engage
Locally, at a member financial institution in the client's own region, under that financial institution's own name and regulator, as the client engages with a financial institution today.
Nothing changes in where the client goes; what changes is what the financial institution does with what the client holds.
Notice of consumer deployment
Persons who wish to be told when consumer services open in their region may leave their name, their email address and their region.
The address is used for that notice and for nothing else, and is deleted on request.
Leaving an address is not an application for any product or service, and the notice, when it is sent, is not an offer.
Sources
The Alkaimi Financial Ecosystem™ in Function, Granular Value on a Neutral Rail, Pegisai Global Holdings, Inc., released 22 August 2026, published on pegisai.com 5 September 2026: the consumer phase, the rent agreement and the custodial rental account, the retirement of created deposits. Board of Governors of the Federal Reserve System, advance notice of proposed rulemaking on narrow banks, 6 March 2019. Federal Reserve Bank of New York, letter refusing the account application of TNB USA Inc., 13 December 2023. Federal Reserve Board, Regulation A, 12 CFR Part 201.
Compliance statement
This page is an institutional communication published on behalf of the regulated member financial institutions of the Alkaimi Ecosystem. The page is not a solicitation, an offer or an advertisement of banking, investment or other financial services, and it does not offer any product or service to any person. Statements on this page about the member financial institutions' future operations are statements of intent, subject to each member's regulator and to the members' own determination, and are not undertakings to any person.
The member financial institutions and their counsel have reviewed this page for compliance with the financial promotion, consumer protection and advertising rules that apply in the members' jurisdictions, as the members and counsel understand them. The ecosystem's regulatory position is stated in full in the Legal section of this site.