Sharing a useful analysis by @mud2monarch of SAB 121, an interpretive statement from SEC staff on crypto custody.

Sharing a useful analysis by @mud2monarch of SAB 121, an interpretive statement from SEC staff on crypto custody. https://zachrwong.info/a-comprehensive-explanation-of-sab-121-and-how-it-prevents-safe-crypto-custody/

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Our 2 cents: This is yet another instance of policymaking through "guidance" that evades the notice-and-comment process and avoids judicial review. Without a crypto-focused statutory regime, we expect we'll continue to see attempts from some regulators to marginalize crypto by making the industry less safe.