The rise and fall of Silvergate Bank: lessons for prudential regulation of crypto-sector banking

Abstract

Silvergate Bank began to “wind down operations and voluntarily liquidate” its bank in March 2023. Whereas Silicon Valley Bank and Signature Bank would be shut down by the Federal Deposit Insurance Corporation in the following days, this “crypto-sector bank” was able to satisfy depositor withdrawals and enter into voluntary liquidation. This paper examines how Silvergate Bank managed its balance sheet in a manner that maintained liquidity and its ability to satisfy substantial and unpredictable outflows from depositor withdrawals by its “crypto-firm” clients. Its approach was consistent with the ethos of the Basel III liquidity requirements to which many banks—though not Silvergate Bank—are subject. Yet the Silvergate model went further by recognising the idiosyncratic depositor dynamics of “crypto-firms”. This paper argues that prudential regulation should apply this model to (i) any bank that sources a substantial proportion of its funding from “crypto-firm” clients, irrespective of that bank’s size, and (ii) all deposits related to crypto-asset market participants at all banks.