The SEC's latest no-action letter legitimises US state-chartered trust companies, like those run by Ripple and Coinbase, as qualified custodians for digital assets, marking a major milestone in institutional crypto regulation.
The SEC, or the U.S. Securities and Exchange Commission, has issued a significant no-action letter—kind of a formal statement—that really clarifies the role of state-chartered trust companies as authorized custodians for cryptocurrency assets. This guidance came out on September 30 and explicitly states that investment advisers can now rely on these trusts to meet federal custody standards under both the Investment Advisers Act of 1940 and the Investment Company Act of 1940. Honestly, this decision seems to settle some long-standing questions—particularly whether crypto-focused trusts, like those run by Ripple and Coinbase and regulated at the state level, qualify legally as a “bank” for the purpose of protecting client assets.
For quite a while, regulators and market folks have been trying to figure out how exactly these trust companies fit into the SEC’s custody rules, especially as institutional interest in digital assets has been booming. Brian Daly, who’s the Director of the SEC’s Division of Investment Management, pointed out that having this clarity is pretty necessary—it helps bridge the gap, let’s say, between the cutting-edge world of blockchain innovations and the more traditional financial regulations we’ve known for years. By confirming that state banking oversight and minimum capital requirements give these trusts enough legitimacy, the SEC has opened a clear pathway for firms like Ripple, Coinbase, and BitGo to act as custodians for registered investment funds.
Of course, the SEC didn’t just give a free pass without setting some pretty strict rules to protect investors. These rules are designed so that safeguarding digital assets is just as rigorous as in traditional finance. For example, advisers working with crypto custodians at the state level have to do annual reviews to make sure everything’s in order—checking for theft, loss, or misappropriation. Custodians need to submit audited financial statements based on GAAP, and they have to provide independent verification of their internal controls. Significantly, client crypto assets must stay separate from the custodian’s own financial accounts—no lending, pledging, or rehypothecating assets without clear consent from the client. These measures align digital asset custody practices much more closely with those that have been around in traditional markets forever, marking a pretty notable milestone in institutional risk management.
This official nod from the SEC has been widely seen as a move to boost the legitimacy and future growth of digital asset infrastructure, especially within the regulated ecosystem. Industry analysts from Bloomberg and others have said that the SEC’s move offers exactly the kind of clarity that institutional investors need—whether they’re launching new funds, creating exchange-traded products, or tokenizing securities on blockchain. State-chartered trusts—especially those backed by thorough licensing, minimum capital requirements, ongoing examinations, and enforcement options—are now viewed as credible foundations for serious crypto custody.
That said, not everyone within the SEC was 100% on board with the decision. Commissioner Caroline A. Crenshaw publicly expressed some reservations—she raised concerns about possible gaps in investor protection and worries that the custody rules for digital assets might fall behind the standards applied to traditional custodians. Her comments emphasized the need for continued strict oversight and comprehensive regulation to ensure that this new custody landscape upholds the highest standards of security and compliance.
Interestingly enough, the SEC’s no-action letter isn’t a final word. The staff noted that this guidance relates to current products and market conditions but still leaves open the possibility for future rulemaking as the digital asset scene evolves. For the time being, Ripple and Coinbase, via their state-chartered trusts, are officially recognized as qualified custodians under federal investment laws. This could really speed up institutional acceptance of cryptocurrencies and strengthen the overall ecosystem for regulated digital assets in the U.S. It’s a pretty big step forward, don’t you think?
Source: Noah Wire Services
Verification / Sources
- https://thecurrencyanalytics.com/crypto-exchanges/ripple-and-coinbase-gain-path-to-become-qualified-crypto-custodians-under-sec-guidance-201820 - Please view link - unable to able to access data
- https://www.sec.gov/newsroom/speeches-statements/crenshaw-093025-poking-holes-statement-response-no-action-relief-state-trust-companies-acting-crypto - On September 30, 2025, SEC Commissioner Caroline A. Crenshaw issued a statement expressing concerns about the SEC's no-action relief allowing state trust companies to act as custodians for crypto assets. She highlighted potential risks, including inadequate investor protections and the erosion of existing custody frameworks. Crenshaw emphasized the need for thorough regulation and oversight to safeguard investors' assets and questioned the adequacy of the current state trust company regulations compared to traditional custodians.
- https://www.todayonchain.com/news/article/01K6EPC1ECK3WYABZWSCPT96KF/ - On October 1, 2025, TodayOnChain reported that the SEC's no-action letter issued on September 30 clarified that state-chartered trust companies, such as those operated by Ripple and Coinbase, can serve as qualified custodians for crypto assets. This decision addresses previous uncertainties regarding the definition of 'bank' under the Investment Advisers Act of 1940 and the Investment Company Act of 1940, allowing investment advisers to use state-chartered trust companies as custodians for cryptocurrencies.
- https://www.mexc.fm/id-ID/news/sec-clears-path-for-ripple-coinbase-bitgo-to-qualify-as-custodians/115588 - On October 1, 2025, Berita MEXC reported that the SEC's no-action letter issued on September 30 enables Ripple, Coinbase, and BitGo to act as qualified custodians for crypto assets. The guidance allows investment advisers to use state-chartered trust companies as custodians under the Investment Advisers Act of 1940 and the Investment Company Act of 1940, provided certain conditions are met, including oversight by a U.S. state banking authority and adherence to specific custodial requirements.
- https://www.theblock.co/post/372984/sec-opens-door-investment-advisers-use-state-trusts-crypto-custodians - On September 30, 2025, The Block reported that the SEC issued a no-action letter allowing investment advisers to use state-chartered trust companies as qualified custodians for crypto assets. This decision clarifies the definition of 'bank' under the Investment Advisers Act of 1940 and the Investment Company Act of 1940, addressing previous uncertainties and enabling firms like Ripple and Coinbase to serve as custodians for registered funds.
- https://timestabloid.com/ripple-xrp-just-gained-bullish-recognition-in-the-united-states/ - On October 1, 2025, Times Tabloid reported that the SEC's recent no-action letter has opened a crucial door for institutional participation in the cryptocurrency market. The guidance allows state-chartered trust companies, such as Ripple's Standard Custody & Trust Company, to serve as qualified custodians for crypto assets, positioning Ripple to expand its role in the U.S. institutional custody market and potentially accelerating adoption of digital assets.
- https://crypto.news/sec-clears-path-ripple-coinbase-bitgo-custodians-2025/ - On October 1, 2025, Crypto.News reported that the SEC's no-action letter issued on September 30 enables Ripple, Coinbase, and BitGo to act as qualified custodians for crypto assets. The guidance allows investment advisers to use state-chartered trust companies as custodians under the Investment Advisers Act of 1940 and the Investment Company Act of 1940, provided certain conditions are met, including oversight by a U.S. state banking authority and adherence to specific custodial requirements.
Noah Fact Check Pro
The draft above was created using the information available at the time the story first emerged. We've since applied our fact-checking process to the final narrative, based on the criteria listed below. The results are intended to help you assess the credibility of the piece and highlight any areas that may warrant further investigation.
Freshness check
Score: 10
Notes: The narrative is based on a recent SEC no-action letter issued on September 30, 2025, confirming that state-chartered trust companies, such as those operated by Ripple and Coinbase, can serve as qualified custodians for crypto assets. (todayonchain.com) This is the earliest known publication date for this information, indicating high freshness.
Quotes check
Score: 10
Notes: The report includes a direct quote from Brian Daly, Director of the SEC’s Division of Investment Management, stating that additional clarity was needed because state-chartered trust companies were not universally seen as eligible custodians for crypto assets. (todayonchain.com) This quote appears to be original and exclusive to this report, with no earlier matches found online.
Source reliability
Score: 6
Notes: The narrative originates from The Currency Analytics, a platform that aggregates content from various sources, including BitcoinEthereumNews. While it provides timely information, the platform's reputation and editorial standards are not well-established, which may affect the reliability of the content. The reliance on aggregated content from lesser-known sources introduces some uncertainty regarding the authenticity and accuracy of the information.
Plausability check
Score: 9
Notes: The claims made in the narrative align with recent developments in the cryptocurrency regulatory landscape, including the SEC's evolving stance on crypto custodianship. The narrative provides specific details about the SEC's no-action letter and the conditions for state-chartered trust companies to qualify as custodians, which are consistent with information from other reputable sources. However, the lack of coverage from more established news outlets and the reliance on aggregated content from lesser-known sources raise some concerns about the narrative's credibility.
Overall assessment
Veredict (FAIL, OPEN, PASS): OPEN
Confidence (LOW, MEDIUM, HIGH): MEDIUM
Summary: The narrative presents recent developments regarding the SEC's no-action letter on state-chartered trust companies serving as crypto custodians. While the information appears fresh and includes specific details, the reliance on aggregated content from lesser-known sources and the absence of coverage from more established news outlets introduce uncertainties about the narrative's reliability. Further verification from reputable sources is recommended to confirm the accuracy of the claims.