Marisa

@mtcoppel

73 Following

187 Followers

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I never knew how much water from a glacier would enhance my life.

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7/ Simply put: custody rules must evolve with technology. Blockchain enables new, safe, and transparent forms of asset custody. The SEC should embrace innovation while preserving strong investor protections.

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6/ The SEC should adopt a principles-based approach: protect client assets from loss, theft, or misuse – but allow flexibility in how that’s achieved. RIAs should be empowered to use their fiduciary judgment to choose the best solution for their clients.

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4/ We propose that RIAs should have a choice. They should be able to choose to self-custody if it better serves their investors and the mechanism of custody follows clear, reasonable guardrails that include things like disclosures, consent, and independent verifications and audits.

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5/ We also urge the SEC to expand the definition of “qualified custodian” to include well-regulated, crypto-native firms and state-licensed entities. Many have developed security practices purpose-built for digital assets – often exceeding those of traditional custodians.

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3/ Today, RIAs can’t self-custody digital assets (even when safer), are restricted from using crypto-native custodians if they aren’t a Qualified Custodian, and face barriers to on-chain activities like staking or governance that may benefit clients. These limitations hurt innovation and client outcomes.

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2/ The custody rules governing registered investment advisers (RIAs) were written in 1962 and last updated in 2009 – before blockchain technology. This outdated framework imposes a one-size-fits-all model that often prevents RIAs from selecting the safest or most cost-effective custody options.

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1/ Blockchain Association submitted a response to the SEC's Crypto Task Force, urging the SEC to modernize custody rules for digital assets. Current rules hinder advisers (e.g., vc funds) from serving clients in the crypto space. Here's a summary of our recommendations. 🧵 https://theblockchainassociation.org/wp-content/uploads/2025/06/BlockchainAssociation-RFI-Response-Re-Custody-Topics.pdf

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end/ Read our full response here: https://theblockchainassociation.org/wp-content/uploads/2025/05/Blockchain-Association-Response-to-Trading-RFIs.pdf

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5/ The SEC should leverage blockchain's inherent transparency through open-source data and exchange APIs for regulatory surveillance, while avoiding unnecessary collection of personal information. I wrote about these privacy risks last June: https://www.coindesk.com/opinion/2024/06/05/cryptos-latest-privacy-battle

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6/ The Commission has successfully adapted its rules for new technologies in the past. We urge a similar approach for crypto that balances innovation with investor protection, ensuring US leadership in digital asset markets.

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4/ We describe the importance of side-by-side trading and also recommend the SEC provide guidance concerning best execution that focuses on "reasonable diligence", with enhanced transparency through disclosure requirements rather than prescriptive order-protection rules.

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3/ We outline the key innovations in crypto trading that the SEC should consider when making key regulatory updates. For instance, the SEC should recognize the benefits of disintermediation, real-time settlement, and reduced costs.

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2/ At a high level, our letter advocates for a flexible and fit-for-purpose approach to regulating crypto asset trading. The Commission should recognize how blockchain technology enables new trading, clearing, settlement, and custody methods that promote greater efficiency and safety.

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1/ Today, we submitted our response to SEC Commissioner Peirce's "There Must Be Some Way Out of Here" request for input on trading-related topics (focusing most of our response on questions 15-19 in the RFI). Here’s Peirce’s post from Feb: https://www.sec.gov/newsroom/speeches-statements/peirce-statement-rfi-022125

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6/ Thank you to the Crypto Task Force and Commissioner Peirce for inviting dialogue on these critical issues. We’re committed to working with policymakers to ensure staking remains accessible, secure, and aligned with U.S. law.

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5/ A regulatory framework that misunderstands staking could harm network security, innovation, and U.S. leadership in blockchain technology. We urge the SEC to publish guidance consistent with the recent statements on memecoins, mining, and stablecoins.

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3/ We emphasized the importance of making staking accessible — individuals should have safe, simple ways to participate in network security without needing to be technical experts.

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4/ We also explained why staking and staking services are not securities transactions under federal law. Bottom line: Staking is fundamentally about network operations, not investment contracts. The staker is engaging in an administrative or ministerial activity to secure the network.

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2/ Staking is critical to blockchain networks. It secures decentralized infrastructure, supports network governance, and ensures the integrity of the systems that power modern digital innovation.

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