Qualified Custodian
A Qualified Custodian is an institution legally authorized to hold client assets on behalf of SEC-registered investment advisers — a requirement that historically excluded most crypto-native firms but is expanding to include digital asset custodians following SAB 121's reversal and OCC charter approvals.
Qualified Custodian Requirements for Tokenized Assets: What Investment Advisers Need to Know
SEC-registered investment advisers must maintain client assets with a 'Qualified Custodian' under Rule 206(4)-2. The 2023 Custody Rule amendments proposed to extend this requirement to crypto assets. This analysis maps the qualified custodian landscape for tokenized assets.