Tag: security entitlement

Why Blockchain Custody Is So Difficult—Paths Forward?

In the first post on this topic, we provided a simple answer to a question posed by the Director of the SEC’s Division of Investment Management (the “Division”): To the extent a fund plans to hold cryptocurrency directly, how would it satisfy the custody requirements of the 1940 Act and relevant rules?” Our simple answer … Continue Reading

Why Blockchain Custody Is So Difficult—A Hard Part

In our previous post, we provided a simple answer to the following question posed by Director Dalia Blass of the SEC’s Division of Investment Management: To the extent a fund plans to hold cryptocurrency directly, how would it satisfy the custody requirements of the 1940 Act and relevant rules?” Our simple answer was to treat … Continue Reading

Why Blockchain Custody Is So Difficult—The Simple Part

“There are no easy answers, but there are simple answers.”—President Reagan In a January 2018 letter to the ICI and SIFMA, Director Dalia Blass of the SEC’s Division of Investment Management posed the following question, among many others: To the extent a fund plans to hold cryptocurrency directly, how would it satisfy the custody requirements … Continue Reading

Why Intermediaries Can Stop Worrying About Money Fund Liquidity Fees—Part Three

Currently, managers and directors of money market funds are wrestling with the question of how to make certain that every intermediary selling their funds can implement a liquidity fee. Intermediaries, in turn, are worried about implementing different fees for different funds that may change continuously. This series of posts asks a different question: How would … Continue Reading
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