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The cryptocurrency landscape is rapidly evolving, with regulatory changes playing a pivotal role. The SEC’s shift on Staff Accounting Bulletin (SAB) 121 is a significant development with far-reaching consequences, particularly for M&A activity. We share our thoughts on these impacts and their influence on potential acquisitions.
SAB 121: A Recap
While numerous resources provide in-depth analysis, we’ll add our oversimplified explanation. SAB 121 imposed stringent requirements on public banks and custodians holding crypto assets. It mandated that these entities maintain regulatory capital against custodied crypto, even though these assets weren’t their own.
For example, if Big Global Bank custodied $100 million in Bitcoin for Blackrock’s ETF, the bank was required to set aside an equivalent $100 million of its own capital. This capital requirement, unique to crypto assets, made custody prohibitively expensive, discouraging traditional financial institutions from entering the space.
The rescission of SAB 121 removes this barrier, opening the door for traditional banks to compete in the crypto custody arena. Custody is fundamentally built on trust, and over time, market share will likely gravitate towards the most trusted providers.