U.S. SEC sets five-part framework for broker-dealer custody of crypto asset securities under Rule 15c3-3

On December 18 2025, the U.S. SEC's Division of Trading and Markets issued guidance on how broker-dealers can satisfy Rule 15c3-3's physical possession provisions when holding crypto asset securities. The staff outlined five specific conditions under which they would not object to treating physical custody as compliant, focusing on blockchain access, technical due diligence, and private key security. Commissioner Hester M. Peirce welcomed the additional clarity and urged further work on amending Rule 15c3-3 to better address crypto custody.