A Call to the SEC: Treat Crypto Assets as if Clients Matter

Given the scarcity of crypto custodial solutions, the SEC could clarify that, in certain circumstances, registered investment advisers (that are not qualified custodians) can use a combination of software and comprehensive internal controls to self-custody crypto. This doesn’t have to result in any relaxation of custodial rules – in fact, we strongly believe the SEC should put in place robust, technology-neutral principles regarding crypto custodianship.