The "self-custody" part of the crypto custody rules the SEC proposed on 1 October is about an investment adviser holding the $BTC or $ETH it manages for investors itself, per Commissioner Peirce... it covers advisers and funds and has nothing to do with you keeping your own keys. Even then it only applies where no permitted custodian is available, and the private keys have to sit under joint control of at least two people per transaction.

The other headline piece, state trust companies acting as crypto custodians, is already in place. An SEC staff no-action letter from 30 September 2025 let advisers and registered funds use certain state trust companies on the same conditions, and I don't think the flow followed back then, so I'd read that part as existing relief becoming rule text.

It hasn't hit the Federal Register yet, so there's no end date on the comment period. I'll be watching for that.

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