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Steven Lofchie Commentary by Steven Lofchie

The SEC proposed (i) allowing investment advisers to act as custodians (referred to in the proposal as "self-custody") for the crypto assets of their clients (including clients that are regulated funds) subject to a variety of conditions, (ii) authorizing advisers and regulated funds to determine that a state trust company is a permitted custodian, and (iii) facilitating the legal authority of broker-dealers to act as custodians for regulated funds.