Custody, Account Control & Digital-Asset Safekeeping
v2026.10.21
- Document version
- v1.6
- Effective
- 2026-10-21
- Change
- material — supersedes v2026.10.02
- SHA-256
- 72611953dcd3e038274bfa69d3debd660f957b15e16c4e099fe9d5b170573f54
Note
Key Material: the paragraph stating the firm's position on the Fordefi MPC arrangement is replaced by the Form ADV Part 2A, Item 15.C sentences quoted word for word, in the brochure's first person ("we do not believe this arrangement gives the firm custody"), including that the position is "our own interpretation of a rule written for traditional assets" and that the additional requirements a regulator could apply include "the use of a qualified custodian and an annual surprise examination by an independent public accountant". No other paragraph changed.
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