The Proposal (the “Proposal”) would:

• permit registered investment advisers and registered management investment companies and business development companies (BDCs, and together with registered management investment companies, “regulated funds”) to self-custody crypto assets in certain circumstances subject to conditions
• permit advisers and regulated funds to maintain client or fund crypto assets with a state trust company, subject to conditions
• modernize the custody rules under both statutes, and
• update recordkeeping and disclosure requirements.²

Chairman Paul S. Atkins stated the Commission proposed “to close a gap that has left investment advisers and funds guessing how to effect lawful custody of an asset class that their…