The US Securities and Exchange Commission on Oct. 1 proposed a custody framework that would let registered investment advisers and regulated funds hold crypto assets under rules written specifically for the asset class, capping a run of nine federal agency actions since Aug. 18 that now cover most of a crypto asset's life cycle, from fundraising to safekeeping.

The proposal, announced in an SEC press release, would create a bespoke custody regime for registered investment advisers, registered investment companies and other regulated funds. It would permit self-custody in certain circumstances, recognize state trust companies as custodians for client and fund crypto assets, and open a wider range of crypto-related strategies to regulated funds. Chairman Paul Atkins described it as a compliant custody path where none existed before. Comments run 60 days from Federal Register publication, and every provision remains conditional until a final rule.

Two of the nine actions came before the Senate rejected cloture on the CLARITY Act on Sept. 15, a 49-50 vote that required 60 to proceed. Seven have arrived since Sept. 17, as both the SEC and the Commodity Futures Trading Commission have used exemptions, staff positions and registrations to fill the gap left by stalled legislation.

Offering rules and recordkeeping

The SEC's Regulation Crypto Assets proposal, issued Aug. 18 before the Senate vote, would create an offering regime for certain investment contracts involving crypto assets. It includes exemptions for raises of up to $5 million over four years and $75 million in a 12-month period, plus a conditional safe harbor from the investment-contract definition. Comments close Oct. 20.

On Sept. 25, SEC Corporation Finance staff published FAQs covering token functionality, decentralization, staking receipt tokens, marketing, continued network building, buybacks and secondary-market promoters, and updated them Sept. 28. The SEC frames the FAQs as staff views that leave the law as written, but they give projects a detailed map of how staff approaches investment-contract analysis.

A Sept. 1 transfer-agent proposal addresses electronic and blockchain-based recordkeeping and uncertificated securities — a rewrite of the shareholder-record layer beneath tokenized securities. It remains at the proposal stage.

Trading, routing and collateral

On Sept. 17, the SEC granted its Innovation Exemption, a five-year conditional exemption letting qualifying Tokenized Securities Venues trade tokenized NMS stocks through permissioned automated market makers and liquidity pools. Certain liquidity providers receive conditional dealer relief. It is live now, but temporary and limited to tokenized stocks on qualifying venues.

The same day, CFTC staff took a no-action position covering passive software providers that connect users to registered futures firms and markets. Wallets and interfaces gain a clearer route into regulated derivatives when they meet the specified conditions. As a staff position, the relief sits below a Commission rule or a statute in legal weight.

On Sept. 24, CFTC staff updated its crypto and blockchain FAQs to address customer-funded investments in tokenized forms of permitted investments and blockchain-based recordkeeping — moving tokenization from the trade itself into the plumbing of regulated financial firms.

Clearing and custody

On Sept. 28, the CFTC registered Coinbase Clearing LLC as a derivatives clearing organization permitted to clear fully collateralized futures, options on futures and swaps. The registration covers that entity and those product types, and it marks regulated crypto-native infrastructure reaching the clearing layer.

Four pieces of the stack are usable today: the Innovation Exemption, the CFTC passive-software relief, the CFTC FAQ update for covered registrants, and Coinbase Clearing's registration. Regulation Crypto Assets, the transfer-agent proposal and the custody proposal all need final rules before anyone can rely on them, with the SEC FAQs interpreting the interim.

The last piece, a CFTC regulatory action titled "Regulation Crypto Asset Transactions and Regulation Crypto Asset Markets," went to White House review on Sept. 17. The Office of Information and Regulatory Affairs lists it as RIN 3038-AF80, a pre-rule received that day, so its contents remain unpublished. It covers the market perimeter — the layer where the stack ends.

The legislative gap and the Bitcoin thesis

CLARITY would have allocated authority between the SEC and CFTC and set market-wide rules for secondary trading of digital commodities. That job remains with Congress. Atkins said on Aug. 18 that legislation remained "indispensable" for rules that outlast a future regulator, and the Innovation Exemption runs only five years.

The market consequences connect directly to Bitcoin. Citi raised its 12-month Bitcoin forecast to $113,000 from $82,000, citing ETF inflows and gradual adviser and brokerage allocation growth. CoinShares' August survey found digital-asset allocations at 1.2%, the first increase since the October 2025 selloff, with regulation the top concern among invested respondents.

If the custody, transfer-agent and offering proposals reach final rules that align with the CFTC's market framework, issuance, trading, collateral, clearing and custody would run under one set of rules. That alignment would support the adviser-and-brokerage allocation Citi describes, and it fits the upper range of Citi's tokenization forecasts, which run from $2.7 trillion to $8.2 trillion by 2030.

If the proposals slow, draw litigation or get rewritten, and the CFTC framework stays unpublished, firms can rely only on the specific exemptions and no-action positions available today — a market perimeter resting on interpretation and staff positions that a future administration or a court ruling could narrow.

In roughly six weeks, the agencies have moved from how projects raise money to how regulated investors hold the assets. The statute that would fix the line between the SEC and CFTC remains open, and the Oct. 20 comment deadline on Regulation Crypto Assets is the first concrete test of whether the stack holds together.