SEC SAYS BROKER-DEALERS NEED TO MAINTAIN CRYPTO PRIVATE KEYS
The SEC's Division of Trading and Markets indicate that a broker-dealer can treat itself as having possession/control when it has exclusive access to the private keys needed to transfer the token. It also requires written policies and systems to protect keys from theft, loss, or unauthorized use, plus preparedness for operational events like network attacks, blockchain malfunctions, and hard forks, and processes to comply with legal orders to freeze/burn/seize assets. Custodians must monitor protocol/governance developments and reduce exposure if there are material security or operational weaknesses.