Simpson Thacher Attorneys Author Article on SEC Staff No-Action Letter on State Trust Company Custody for Crypto Assets
Partners David Blass, Justin Browder, Anne Choe and Michael Osnato, and Associate Michael Passalacqua, authored an article titled, “Simpson Thacher Discusses Use of State-Chartered Trust Companies as Custodians of Crypto,” which was published by The Columbia Law School Blue Sky Blog. The article discussed a no-action letter issued to Simpson Thacher by the SEC’s Division of Investment Management in response to the Firm’s request for confirmation that the SEC staff will not recommend enforcement actions against registered investment advisers and certain funds that use state trust companies as custodians for digital assets. It further noted that the letter represents a meaningful development for asset managers—particularly registered funds—that employ or are considering employing crypto asset-related strategies, as it addresses regulatory ambiguity that has historically made such investments more challenging.
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