The SEC has submitted a rewritten crypto custody rule to the White House Office of Information and Regulatory Affairs for review, a required step before finalization. The rule targets investment advisers and registered investment companies, aiming to clarify what constitutes a qualified custodian for digital assets following the withdrawal of the controversial 2023 Staff Accounting Bulletin-adjacent proposal. OIRA review typically takes 90 days but can extend.
Armada's crypto repo desk relies on Fireblocks as its custody partner and has committed to a no-rehypothecation policy, both of which intersect directly with qualified custodian definitions. If the final rule imposes specific technical or operational requirements on custodians holding crypto on behalf of advisers, Armada may need to verify Fireblocks compliance or update client agreements. Legal counsel should begin a gap analysis against the draft rule text as soon as it is publicly available.