STATE OF COLORADO DEPARTMENT OF REGULATORY AGENCIES DIVISION OF BANKING

In the Matter of:

Etana Custody, Inc., a Colorado State-Chartered Non-Depository Trust Company

LIQUIDATION ORDER

WHEREAS, pursuant to Title 11, Article 109, Colorado Revised Statutes (C.R.S.), the Commissioner of the Division of Banking (the “Commissioner”) has supervisory authority over all state-chartered trust companies; and

WHEREAS, under C.R.S. § 11-109-104(6), the Commissioner is authorized to examine the books and records of every trust company as often as deemed advisable and to the extent required by the Colorado State Banking Board, to make and file a detailed report disclosing the results of such examinations, and to provide a copy of such report to the trust company; and

WHEREAS, in accordance with this authority, the Commissioner reviewed the books and records of Etana Custody, Inc., specifically the June 30, 2025, Report of Condition and Income and the July 31, 2025, unaudited financial statements; and

WHEREAS, the review determined that Etana Custody, Inc. failed to provide sufficient supporting documentation for certain transactions, as required under the July 23, 2025 Capital Restoration Directive and applicable law;

WHEREAS, under C.R.S. § 11-109-104(1)(c), the Colorado State Banking Board (“Banking Board”) is authorized to order any trust company to cease violating any provision of Title 11, Article 109, or any rule promulgated thereunder;

WHEREAS, on August 22, 2025, the Banking Board issued its Cease and Desist Order directed to Etana Custody, Inc. pursuant to the authority granted by C.R.S. § 11-109-104(1)(c) and (6);

WHEREAS, pursuant to C.R.S. § 11-109-702, the Banking Board may take possession of a trust company and appoint a liquidator to conduct a liquidation of the affairs of a trust company;

WHEREAS, grounds exist to place Etana Custody, Inc. into liquidation under applicable law;

NOW, THEREFORE, pursuant to the authority granted by C.R.S. Title 11, Article 109, and after due consideration, the Banking Board hereby ORDERS that

Randel Lewis is hereby appointed as liquidator (the “Liquidator”) for Etana Custody, Inc., pursuant to C.R.S. § 11-109-702(3);

The Liquidator shall be vested by operation of law with all of the Commissioner’s statutory rights and obligations under C.R.S. § 11-109-701 et seq. with respect to Etana Custody, Inc.;

Title to all of the property of Etana Custody, Inc. shall be held by the Liquidator, in custodia legis, pursuant to further orders of the District Court for the City and County of Denver, Colorado. Such property shall include property of any kind or nature, whether real, personal, or mixed, including but not limited to money, funds, cash, stock, bonds, account deposits, statutory deposits, special deposits, digital assets, contents of safe deposit boxes, funds held in share accounts or trust accounts, retainages and retainers, letters of credit, real estate, fixtures, furniture, equipment, books, records, documents and insurance policies, intellectual property, computer software and systems, information technology, internet domain names, patents and intangible assets, whether owned individually, jointly, or severally, wherever located, and all rights, claims or causes of action belonging to Etana Custody, Inc., whether asserted or not, including but not limited to accounts receivable, notes, premiums, subrogation, insurance and reinsurance proceeds, and all licenses held by Etana Custody, Inc. (the “Property”);

The Liquidator shall post a bond in favor of the State of Colorado in an amount no less than $15,000.00;

Etana Custody, Inc. and all of its officers, directors, and employees, shall cooperate with the Liquidator and turnover all of the Property and documents and records related thereto; and

The Liquidator and the Commissioner may seek entry of further orders in the District Court for the City and County of Denver, Colorado to execute the liquidation of Etana Custody, Inc. in accordance with applicable law and principles of equity as deemed necessary and appropriate.

SO ORDERED this 6th day of November, 2025.