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Responding to the SEC Staff on the Custody of Digital Assets Under the 1940 Act
The Review of Securities & Commodities Regulation

February 15, 2023
Several years ago, the SEC staff requested feedback on whether a registered fund investing in digital assets could satisfy the 1940 Act’s custody requirements. In this article, the author suggests a response to the SEC staff’s custody question that draws heavily from SEC rules and SEC staff no-action letters. Read more...

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