Custody, Account Control & Digital-Asset Safekeeping

Note

Custody wording restated in the terms of Form ADV Part 2A, Item 15. Traditional Assets: the sentence on when Protocol Wealth is deemed to have custody now uses Item 15.A and 15.B: the firm is deemed to have custody because it is authorized to deduct its advisory fees from many client accounts, and it is authorized to trade in client accounts at qualified custodians but not to move assets out of them to third parties. Key Material: the Fordefi description now follows Item 15.C (Fordefi holds one key shard and Protocol Wealth holds one; the client holds the ultimate backup; assets can be sent only to addresses the client has approved), and the firm's position that this arrangement does not give it custody is stated with Item 15.C's caveat that a regulator could reach a different conclusion.