Mayer Brown·FINANCIAL REGULATION

SEC Proposes Overhaul of Adviser and Fund Custody Rules With Crypto Framework

Mayer Brown reports the SEC has proposed modernizing registered adviser and fund custody rules, including a crypto custody framework; the proposal text, release number and comment deadline are not in the available evidence.

The cluster contains a single Mayer Brown alert, dated 2 November 2026, reporting that the SEC has proposed modernizing the custody rules applicable to registered investment advisers and funds, with the package including a crypto custody framework. No other source in the cluster corroborates the proposal, and the alert material available for review is limited to its title, so the specific rule text, release numbers, comment deadlines, and any safe-harbor or verification mechanics for digital-asset custody cannot be verified from this evidence.

Why it matters: custody rules sit at the intersection of adviser fiduciary obligations, fund governance and — if a crypto framework is included — how advisers or funds hold client digital assets. A modernization that clarifies permissible custody and third-party arrangements, or reworks verification and disclosure obligations, could change how alternative managers, crypto funds and their counterparties structure operations, contracts and disclosures, and it may ripple into state-level and non-US regimes that mirror the US framework.

Next step to watch: the SEC's proposing release and comment docket, the comment period deadline (not stated in the available material), and any final rule's implementation date. Counsel should read the actual proposal text before advising clients and treat the alert's characterization as unverified until the release is published.

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Read the original firm alert → Tuesday, November 3, 2026

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