Industry Watch
What we’re watching.
The public materials we monitor as digital-asset custody, control, tax, and market-structure guidance evolves.
We track public regulator materials, legislative activity, industry letters, no-action letters, proposals, court decisions, tax guidance, and market-structure developments that may affect how SEC-registered advisers work with traditional and digital assets.
This page is a watchlist — not legal advice, and not a statement that any proposal or industry submission is law.
What this page is. A source register. Each item links to the official or primary source and is labeled by source type and status so the difference between a final rule, a proposal, a staff statement, a no-action letter, and an industry submission is visible at a glance.
What this page is not. Legal, tax, or compliance advice; a representation that any item applies to a specific client; or a statement that a proposal, staff statement, no-action letter, or industry submission is binding law. Industry submissions are third-party input, not regulator guidance. The notes reflect Protocol Wealth’s conservative reading at the date shown, and the area is evolving.
How to read the labels
Final — Binding final regulatory action, subject to its effective date and scope.
Proposed — A pending proposal. Not final law.
Withdrawn — A proposal that was withdrawn or is no longer active.
Staff-level — A staff statement — not a Commission rule unless stated otherwise.
Fact-specific — Relief or guidance limited to specific facts; not a broad rule.
Industry input — A third-party submission. Not regulator guidance and not law.
Monitoring — A development we are tracking; not itself a rule or obligation.
Superseded — Replaced or overtaken by a later development.
Custody & Safeguarding
SEC Safeguarding Advisory Client Assets proposal — withdrawn
The SEC withdrew the proposed Safeguarding Advisory Client Assets rulemaking in 2025. The current anchor remains the Advisers Act Custody Rule, Rule 206(4)-2, unless new rulemaking occurs.
How we read it. We do not describe proposed Rule 223-1 as an active or pending successor rule. The existing Custody Rule remains the reference point; we monitor for any new safeguarding rulemaking.
Self-Custody & Interfaces
SEC staff statement on Covered User Interface Providers
A staff statement addressing Exchange Act Section 15 broker-dealer registration for interfaces that help users transact on blockchain protocols through their own self-custodial wallets.
How we read it. Useful for non-custodial interface framing. It is staff-level, limited to broker-dealer registration under the Exchange Act — it is not custody guidance and not tax guidance.
CFTC staff no-action letter 26-09 (Phantom)
Fact-specific CFTC staff no-action relief related to self-custodial wallet software facilitating trading with registered derivatives market infrastructure.
How we read it. A monitoring item for self-custodial wallet / front-end interface developments. It is fact-specific relief — not a blanket approval for DeFi or for RIA self-custody structures, and it does not apply directly to Protocol Wealth.
Cross-Agency & Harmonization
SEC–CFTC harmonization memorandum of understanding
An agency memorandum of understanding / harmonization initiative between the SEC and CFTC.
How we read it. A possible path toward coordinated digital-asset treatment over time. It is not a custody rule or a tax rule; we track it as a backdrop development.
SEC–CFTC harmonization initiative — written input log
A public log of written submissions to the harmonization initiative, including industry letters. Any AI-generated key points on the log are not staff-reviewed.
How we read it. Submissions on the log — including Veda and Wave — are tracked as industry input, not as official guidance. We read the submissions themselves rather than relying on auto-generated summaries.
SEC interpretation on application of federal securities laws to crypto assets
An official Commission interpretation addressing how the federal securities laws apply to certain crypto asset types and transactions, including wrapping of non-security crypto assets.
How we read it. Relevant securities-law backdrop for how certain digital assets and operations are characterized. It is a securities-law interpretation, not a custody rule or a tax ruling.
Veda Tech Labs / Morrison Cohen vault submission to the SEC and CFTC
A private written submission proposing that non-custodial smart-contract vault architectures can satisfy qualified-custody and segregation requirements when specific structural guardrails are met.
How we read it. A useful guardrail framework for vault custody and segregation analysis. It is an industry submission — not law, not a rule, and not regulator approval.
Wave Digital Assets letter supporting the Veda submission
A private written submission from an SEC-registered adviser supporting the SMA-vault framing in the Veda submission.
How we read it. Supports the separately-managed-account vault framing from an adviser perspective. It is an industry submission — not law and not regulator guidance.
Tax
IRS digital asset broker reporting & Notice 2024-57
Final regulations and related IRS guidance on broker reporting for digital asset sales and exchanges. Notice 2024-57 provides broker reporting relief for certain categories pending further guidance.
How we read it. Notice 2024-57 is a reporting-relief source, not a definitive substantive tax ruling. It does not determine that wrapping, liquidity-pool activity, staking, lending, short sales, or notional principal contracts are non-taxable.
IRS Instructions for Form 8275 (Disclosure Statement)
Official IRS instructions for Form 8275. Adequate disclosure may help avoid certain accuracy-related penalties when a position has reasonable basis and other requirements are met.
How we read it. We frame Form 8275 conservatively: adequate disclosure may help support a reasonable-basis position and may help reduce the risk of certain penalties if requirements are met. It is not automatic penalty elimination and does not replace tax counsel.
AML & Sanctions
FinCEN investment adviser AML rule — effective date postponed
FinCEN issued a final rule postponing the effective date of the investment adviser AML rule to January 1, 2028.
How we read it. A monitoring item for AML and suspicious-activity obligations. We maintain AML, OFAC, and suspicious-activity procedures; we do not overstate the current obligation while the effective date is delayed.
OFAC digital asset sanctions FAQs
Official OFAC FAQs and guidance on digital asset sanctions, including blocked-property and screening expectations.
How we read it. Relevant to sanctions screening, wallet monitoring, and blocked-property controls. We track OFAC guidance updates as part of our compliance program.
Market Structure
SEC proposal to rescind Regulation NMS Rules 611 and 610(e)
A proposed rule to rescind Regulation NMS Rules 611 and 610(e). Proposed, not final.
How we read it. Market-structure backdrop relevant to broader investment implementation. It is a proposed rule, likely not directly custody-relevant; we track it as market structure, not as a custody change.
Vendor & Infrastructure
Paxos acquisition of Fordefi
Paxos announced an acquisition of Fordefi, combining Paxos's regulated infrastructure with Fordefi's MPC wallet architecture, policy engine, and DeFi integrations.
How we read it. A strategic and diligence item. It does not, on its own, make Fordefi a qualified custodian for Protocol Wealth client assets and does not automatically satisfy the Custody Rule. Any change in characterization is subject to agreement, entity, account structure, and counsel review.
Anchorage Digital acquisition of the Securitize for Advisors platform
Anchorage Digital announced an acquisition of the Securitize for Advisors platform to strengthen its wealth-management and RIA capabilities.
How we read it. Relevant to the evolution of Anchorage's wealth/advisor platform and the qualified-custody page. Platform tools are not the same thing as Protocol Wealth taking custody.
BitGo qualified custody materials
BitGo's published materials describing its qualified digital asset custody offering.
How we read it. A qualified digital asset custody option where appropriate. We do not overstate scope, insurance, or status beyond what current agreements and due diligence confirm.
Read next
Related pages
Custody and Control
How assets are held, who controls them, and what the firm can and cannot do.
Qualified Custody
Independent qualified digital asset custody options, where appropriate — and how custody is kept separate from execution.
Self-Custody & Client-Controlled Wallets
Fordefi and Turnkey wallet infrastructure, client recovery, and the limits on the firm's role.
Bailment Framework
The deeper, source-tracked technical and tax-analysis reference — education, not advice.
Change log
Versions
Initial publication of the source register with source-status labels across custody, self-custody and interfaces, cross-agency harmonization, tax, AML and sanctions, market structure, and vendor developments.
Last updated: June 17, 2026. Protocol Wealth, LLC is an SEC-registered investment adviser (CRD #335298). See our Form ADV for authoritative regulatory disclosures. Registration does not imply a particular level of skill or training; advisory services are provided only under a signed advisory agreement.
This page is general information and a monitoring list. It is not legal, tax, accounting, or compliance advice; not a representation that any listed item applies to a specific person; and not a statement that any proposal, staff statement, no-action letter, or industry submission is binding law. Industry submissions are third-party input, not regulator guidance. Links to third-party and government sources are provided for reference; Protocol Wealth is not responsible for their content. The notes reflect a conservative reading as of the dates shown and may change.
All investments involve risk, including the potential loss of principal. Digital assets are highly speculative and volatile. Past performance does not guarantee future results.