CTF Written Submission

The Digital Chamber

May 12, 2025
  • The Digital Chamber (TDC) advocates for a technology-neutral, principles-based approach to broker-dealer custody of crypto assets, emphasizing exclusive control over private keys through secure key management practices.
  • TDC requests the SEC to amend Rule 15c3-3 to allow broker-dealers to establish possession or control of crypto asset securities using various approaches and technologies, including third-party vendors.
  • TDC urges the SEC to confirm that broker-dealers can use Section 3(a)(6) Banks as control locations for crypto asset securities and to amend Rule 15c3-3 to explicitly include crypto asset securities.

Last Reviewed or Updated: May 12, 2025