The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Mon, 05 Oct 2026 13:35:43 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.11 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png Statement by Commissioner Peirce on Proposed Amendments to the Custody Rules – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 Statement by Commissioner Peirce on Proposed Amendments to the Custody Rules https://corpgov.law.harvard.edu/2026/10/03/statement-by-commissioner-peirce-on-proposed-amendments-to-the-custody-rules/?utm_source=rss&utm_medium=rss&utm_campaign=statement-by-commissioner-peirce-on-proposed-amendments-to-the-custody-rules https://corpgov.law.harvard.edu/2026/10/03/statement-by-commissioner-peirce-on-proposed-amendments-to-the-custody-rules/#respond Sat, 03 Oct 2026 11:30:39 +0000 https://corpgov.law.harvard.edu/?p=184178?d=20261002160523EDT Posted by Hester M. Peirce, U.S. Securities and Exchange Commission, on Saturday, October 3, 2026
Editor's Note:

Hester M. Peirce is a Commissioner at the U.S. Securities and Exchange Commission. This post is based on her recent statement. The views expressed in this post are those of Commissioner Peirce and do not necessarily reflect those of the Securities and Exchange Commission or its staff.

Last summer, two friends goaded me into riding a roller coaster for the first time in decades. The terrifying sense of dread that gripped me as we whipped around the curves and dropped down irrationally steep hills on a ride that was totally out of my control made me think, of course, of investment advisers’ wild ride with crypto custody over the years.

Without clear rules about how and where crypto assets could be custodied and often without viable qualified custodians available,[1] investment advisers have been gritting their teeth and holding on for dear life hoping the regulatory roller coaster will soon end in workable custody rules. The Commission’s 2023 custody proposal, rather than offering some respite from the ride, threw these advisers for another loop: compliant crypto custody looked impossible under the proposal, and the accompanying release suggested that many advisers were already on the wrong side of the law [2]. The Commission today approved a proposal to amend the custody rules for registered investment advisers and regulated funds, which I hope foreshadows that a calm end to the regulatory roller coaster ride is imminent.

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