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SEC Statement on Wyoming’s No Action Letter

November 17th | 2020



The state of Wyoming’s Division of Banking recently issued a no action letter relating to whether a Wyoming-chartered public trust company can provide custodial services for digital assets. The letter also covered whether such institutions may serve as a “qualified custodian” with respect to digital assets. In answering both questions affirmatively, Wyoming relied on the definition of “bank” in the Advisers Act and the fact that the applicant exercises genuine fiduciary powers as a substantial portion of its business.


While this no-action letter relies on Wyoming’s interpretation of the Advisers act, the letter was careful to state that it “should not be construed to represent the views of the SEC or any other regulatory agency.” Indeed, on the heels of Wyoming’s letter, the SEC’s Division of Investment Management issuing a statement encouraging interested parties to engage with SEC Staff directly on the application of the Custody Rule to digital assets, including with respect to the definition of “qualified custodian” under the rule.

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