CTF Written Submission

The Digital Chamber

May 12, 2025
  • The SEC should confirm the scope of existing custody rules with respect to crypto assets, as many crypto assets do not fall within the definition of "securities" or "client funds" under the Advisers Act.
  • The SEC should expand the definition of "qualified custodian" to include state-chartered trust companies and other entities that meet substantially similar standards.
  • RIAs should be permitted to self-custody crypto asset securities when no qualified custodian is available, with appropriate safeguards and disclosures.

Last Reviewed or Updated: May 12, 2025