On December 17, 2025, the Staff of the Division of Trading and Markets (the “Division”) of the U.S. Securities and Exchange Commission (“SEC”) issued a Statement explaining its views on the application of paragraph (b)(1) of SEC Rule 15c3-3 to broker-dealers seeking to establish custody of crypto asset securities. Rule 15c3‑3, commonly called the Customer Protection Rule, requires broker-dealers to maintain physical possession or control of all fully paid and excess margin securities held for customers. Historically,…

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