This week we submitted our comment letter to the SEC on its proposed safeguarding rule. As the only federally chartered digital asset bank, our goal is to help shape the proposed rule to ensure it enhances the safekeeping of digital assets, while also being practical and prudent for both investors and custodians. This rule proposal seeks to broaden the scope of the existing custody rule to require Registered Investment Advisors (RIAs) to maintain not just client “funds" and “securities,” but all “assets”, including crypto with a qualified custodian. Regarding bankruptcy remoteness: While we supported the proposed rule's bankruptcy remote requirements, we highlighted potential consequences of the rule and SAB 121 on certain banks' ability to offer qualified custody services due to bankruptcy remoteness concerns. For example, the SEC custody proposal from February 2023 includes two references to one of our earlier letters to the Commission , as well as one reference to our application for a national bank charter from the OCC.