CTF Written Submission

Re: Crypto Custody under the Investment Company Act of 1940

June 23, 2025
  • The Commission should provide guidance that state-chartered trust companies and similar institutions qualify as "banks" for purposes of Section 17(f) of the Investment Company Act of 1940.
  • The definition of "custody" under the 1940 Act with respect to crypto assets should mean possession of the private keys associated with such assets.
  • The Commission should propose a custody rule specifically tailored to the unique characteristics of crypto assets, including the use of multi-signature wallets and cold storage solutions.
     

Last Reviewed or Updated: June 24, 2025