SEC Grants No-Action Relief to Registered Investment Advisers and Certain Registered Investment Companies to Treat a State Trust Company Providing Crypto Asset Custody Services as a “Bank”

On September 30, 2025, the staff of the Division of Investment Management of the U.S. Securities and Exchange Commission granted no-action relief that allows, subject to numerous conditions: (i) investment advisers registered under the Investment Advisers Act of 1940, as amended (the “Advisers Act”); and (ii) investment companies registered under the Investment Company Act of 1940, as amended (the “1940 Act”) and entities that have elected to be regulated as business development companies under the 1940 Act, to treat a State Trust Company as a “bank” as defined in the Advisers Act and the 1940 Act with respect to the placement and maintenance of Crypto Assets and cash and/or cash equivalents reasonably necessary to effect transactions in Crypto Assets.