Trump's SAB 121 Repeal: The $3 Trillion Digital Asset Custody Race

The Next Wave of Institutional Crypto Adoption and Five Companies to Watch

"Confusion about what is legal creates an environment hostile to innovation and conducive to fraud"

SEC Acting Chairman Mark Uyeda

In a decisive move that signals a dramatic shift in U.S. crypto policy, President Donald Trump's administration has rescinded Staff Accounting Bulletin 121 (SAB 121), a controversial SEC guidance that had effectively barred traditional banks from offering crypto custody services. This action, coupled with a sweeping executive order on digital assets, marks a fundamental departure from the previous administration's approach and sets the stage for increased institutional participation in the cryptocurrency sector[1][3].

Understanding SAB 121's Impact

Staff Accounting Bulletin 121, introduced in March 2022, required SEC registrants to record crypto assets held in custody as both an asset and a liability on their balance sheets[2]. This unorthodox accounting treatment effectively made it economically unfeasible for banks to provide crypto custody services, as it significantly impacted their capital requirements and balance sheet structure[9].

The Path to Repeal

The journey to SAB 121's repeal was marked by significant legislative efforts. In 2024, both the House and Senate passed a bipartisan resolution to overturn the bulletin, demonstrating growing recognition of its negative impact on innovation[24]. However, President Biden's veto maintained the restrictive framework until Trump's administration took action[1].

Trump's Executive Order and New Direction

President Trump's executive order, titled "Strengthening American Leadership in Digital Financial Technology," established a comprehensive framework for digital asset regulation[25]. The order created the President's Working Group on Digital Assets Markets and directed it to:

- Evaluate existing crypto regulations

- Propose new regulatory frameworks

- Consider the establishment of a national digital asset stockpile

- Promote dollar-backed stablecoins[27]

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