Mutual Fund Minute
SEC Staff Guidance: Can State-Chartered Trust Companies Custody Digital Assets?
November 18, 2025
Are state-chartered trust companies "banks" that can custody digital assets for investment advisers and funds? In this episode of Mutual Fund Minute, Sidley Investment Funds partner Chuck Daly and host Jay Baris examine SEC staff guidance interpreting the definition of a "bank" in the Investment Advisers Act and the Investment Company Act. Tune in to find out what the guidance means for registered advisers and investment companies that hold digital assets, and why it matters.
Contacts

Related Resources
Capabilities
Suggested News & Insights
U.S. CFTC Staff Issues No-Action Relief to Simplify Cross-Border Swaps RegulationJanuary 21, 2026Sidley Represents Bonaccord Capital in Increased Minority Investment in Park Square CapitalJanuary 21, 2026Sidley Expands Investment Funds Capabilities With New York Partners Cliff Cone, Michael Sabin, and Dan DrabkinJanuary 20, 2026Fifth Circuit Rejects “Passive Investor” Test for Code Section 1402(a)(13) Limited Partner ExceptionJanuary 16, 2026Sidley Ranked in Chambers Greater China Region 2026January 15, 2026UK Cryptoasset Regulation — Action Points for 2026–27January 13, 2026
- Stay Up To DateSubscribe to Sidley Publications
- Follow Sidley on Social MediaSocial Media Directory
