CTF Written Submission
Letter to the Crypto Task Force
May 5, 2025
- Self-custody wallets are not considered custodians under U.S. securities law as users retain exclusive control over their private keys and assets.
- Self-custody wallets do not meet the definition of an exchange under the Securities Exchange Act of 1934, as they do not match orders or facilitate securities trading among multiple participants.
- Self-custody wallets are not brokers under the Exchange Act, as they do not solicit transactions, route orders, match trades, or hold funds in escrow on behalf of clients.
Last Reviewed or Updated: May 6, 2025