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.
Treat Crypto Assets as if Clients Matter
