The SEC has proposed changes to the crypto custody framework that would give state-chartered trust companies a permanent place in regulated crypto custody while allowing investment advisers to self-custody assets when no qualified custodian supports them. The proposal, which would formalize staff guidance from September 2025, imposes segregation, control and oversight requirements on state trusts comparable to those applied to traditional banks. It would shift the custody market from competing primarily on regulatory status to competing on asset coverage and service breadth. US custodian banks collectively held over $234 trillion in customer assets globally in 2024, while compliance costs for self-custody are estimated at approximately $433,833 annually per adviser.
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