Natlawreview iconNatlawreviewAug 28, 2026 ~1 min source read

SEC Staff Grants No-Action Relief for Digital Asset Custody

The relief focuses on transfer-agent control over the authoritative ownership record, rather than private-key control alone, and effectively treats a blockchain integrated recordkeeping platform as functionally equivalent to traditional book entry recordkeeping, without having to merely mirror traditional fund shares. The letter may provide a framework for designing control frameworks around blockchain recorded fund shares.

SEC Staff Grants No-Action Relief for Digital Asset Custody

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The letter may provide a framework for designing control frameworks around blockchain recorded fund shares.

Securities and Exchange Commission staff granted Franklin Templeton no-action relief allowing affiliated funds to custody blockchain-recorded money market fund shares without complying with certain...

The relief focuses on transfer-agent control over the authoritative ownership record, rather than private-key control alone, and effectively treats a blockchain integrated recordkeeping platform as...

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The letter may provide a framework for designing control frameworks around blockchain recorded fund shares. Securities and Exchange Commission staff granted Franklin Templeton no-action relief allowing affiliated funds to custody blockchain-recorded money market fund shares without complying with certain provisions of Rule 17f-2 designed for physically certificated securities. The relief focuses on transfer-agent control over the authoritative ownership record, rather than private-key control alone, and effectively treats a blockchain integrated recordkeeping platform as functionally equivalent to traditional book entry recordkeeping, without having to merely mirror traditional fund shares.

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  • The Letter provides useful insight into a transfer agent's design of its control framework around blockchain-recorded money market fund shares and was issued against the backdrop of broader SEC attention to...

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Securities and Exchange Commission staff granted Franklin Templeton no-action relief allowing affiliated funds to custody blockchain-recorded money market fund shares without complying with certain provisions of Rule 17f-2 designed for physically certificated securities. The relief focuses on transfer-agent control over the authoritative ownership record, rather than private-key control alone, and effectively treats a blockchain integrated recordkeeping platform as functionally equivalent to traditional book entry recordkeeping, without having to merely mirror traditional fund shares. On August 12, 2026, the SEC's Division of Investment Management issued a No-Action Letter (the Letter) granting no-action relief to Franklin Templeton under Section 17(f) of the Investment Company Act of 1940 (the 1940 Act) and Rule 17f-2.

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