Stablecoin Development Corp

Evaluation of Disclosure Controls and Procedures

As of the end of the period covered by this report, we carried out an evaluation, under the supervision and with the participation of our management, including our Chief Executive Officer and Chief Financial Officer, of the effectiveness of our disclosure controls and procedures pursuant to Rules 13a-15 and 15d-15 of the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Based on that evaluation, and because the previously disclosed material weakness in our internal control over financial reporting, which relates to the review of the contractual terms of our outstanding equity-linked financial instruments and the identification of triggering events under those instruments, as described in Part II, Item 9A of Amendment No. 1 to our Annual Report on Form 10-K/A for the year ended December 31, 2025, filed with the SEC on April 29, 2026, had not been remediated as of September 30, 2026, our Chief Executive Officer and Chief Financial Officer concluded that our disclosure controls and procedures were not effective as of September 30, 2026.

A control system, no matter how well conceived and operated, can provide only reasonable, not absolute, assurance that the objectives of the control system are met. Further, the design of a control system must reflect the fact that there are resource constraints, and the benefits of controls must be considered relative to their costs. Assessing the costs and benefits of such controls and procedures necessarily involves the exercise of judgment by management. Because of the inherent limitations in all control systems, no evaluation of controls can provide absolute assurance that all control issues and instances of fraud, if any, have been detected.

Remediation of Material Weakness

Management, with oversight from the Audit Committee of the Board of Directors, continues to implement remediation measures to address the material weakness in our internal control over financial reporting previously described in Amendment No. 1 to our Annual Report on Form 10-K/A for the year ended December 31, 2025. In May 2026, the Company engaged a third-party fund administrator to perform monthly closing procedures, including the reconciliation of the Company’s on-chain digital asset balances and staking rewards to its books and records, independently of management, and in June 2026 the Company hired a Vice President of Finance and Controller to strengthen the Company’s accounting and financial reporting function. The implementation of our remediation measures will require validation and testing of the design and operating effectiveness of internal control over financial reporting over a sustained period. The material weakness will not be considered remediated until the applicable controls are designed, implemented, and operate effectively for a sufficient period of time, and management has concluded, through testing, that the controls are operating effectively. We cannot ensure that the measures taken to date, and actions we may take in the future, will be sufficient to remediate the material weakness or that they will prevent or avoid potential future deficiencies. Until remediation is complete, the Company will continue to perform additional analyses and other procedures to help ensure that its financial statements are prepared in accordance with GAAP.

Changes in Internal Control Over Financial Reporting

Other than noted above, there were no changes in our internal control over financial reporting during the current quarter which have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.

PART II. OTHER INFORMATION