Custody and Control
How client assets are held, and who controls them.
Protocol Wealth advises, monitors, documents, and implements within the authority a client grants. It holds no client private keys and can transact only to client-pre-approved destinations. Here is how that works in plain English.
Protocol Wealth holds no client private keys, and can transact only to destinations a client has pre-approved.
Client assets are held either with independent custodians or in client-controlled wallets. For qualified custody, client digital assets may be held with an independent qualified custodian — Anchorage is the primary qualified custodian in active use (Anchorage Digital Bank plus the Anchorage-owned RIA/advisor platform); BitGo is onboarded but not currently in use. For self-custody workflows, clients use client-controlled wallet technology — Turnkey for client-sole-root self-custody, and a whitelist-bounded managed sleeve on Fordefi that the client administers — while Protocol Wealth’s role is limited by client-approved permissions, documented strategy parameters, and fiduciary oversight.
In self-custody arrangements, Protocol Wealth does not receive client private keys. Wallet permissions are designed to be specific, documented, and limited to approved activity. Changes that expand or alter those permissions require client approval and compliance review.
Technology helps us research, monitor, document, and review. Human fiduciaries remain responsible for advice, judgment, and client decisions.
What this page is. A plain-English overview of how assets are held, who controls them, and how Protocol Wealth stays in an advisory role. It is written so a client, a prospect, a CPA, an attorney, or a diligence reader can understand the separation between advice, control, custody, and execution.
What this page is not. A personalized recommendation, an offer of any specific arrangement, or a guarantee of any regulatory, tax, or legal outcome. The right custody path depends on the client, the account type, the asset, and the strategy, and is determined under a signed advisory agreement and applicable compliance review.
No custody-rule conclusion. This page states facts about how assets are held and controlled; it takes no position on how the Advisers Act Custody Rule (Rule 206(4)-2) applies to any specific asset or arrangement. As of July 27, 2026, Rule 206(4)-2 remains the anchor and by its terms reaches client “funds or securities”; the 2023 SEC proposal to expand safeguarding to a broader “assets” standard was withdrawn in 2025. How a particular asset or account is treated is a matter for the governing agreements and compliance and legal review.
Section 1
The basic idea
Three sentences capture most of it.
- Assets stay with an independent custodian or in a client-controlled wallet.
- Protocol Wealth is the adviser, not the asset holder.
- Clients keep ownership and the applicable withdrawal and recovery rights.
Everything else on this page explains how the firm works within that structure.
Section 2
Two main paths
Depending on the client, account type, asset type, and strategy, digital assets generally follow one of two paths. Traditional assets are held at independent brokerages and custodians in the usual way.
Qualified custody
Where qualified custody is appropriate, client digital assets may be held with an independent qualified digital asset custodian, such as Anchorage Digital Bank or BitGo. The custodian holds the assets; Protocol Wealth provides advisory services.
Client-controlled wallets
Where a client-controlled wallet is the better fit, the client controls the wallet and the recovery path. Protocol Wealth’s permissions are limited by approved policy rules, documented strategy parameters, and human fiduciary oversight.
Section 3
What Protocol Wealth can do
Within the authority granted by the client and the advisory agreement, the firm’s role is to:
Research
Study assets, regimes, protocols, and risks using the firm’s framework and technology.
Recommend
Make fiduciary recommendations a human adviser stands behind.
Monitor
Watch positions, exposures, and policy compliance on an ongoing basis.
Implement within agreed authority
Act inside the scope set by the advisory agreement, the IPS, and approved wallet permissions.
Document
Keep records of advisory decisions, client approvals, and relevant activity.
Review risk
Assess and disclose the risks that come with traditional and digital assets.
Section 4
What Protocol Wealth cannot do
These limits are what keep advice separate from control. They are designed to separate the firm’s advisory authority from unilateral control of client assets.
Take client private keys
In self-custody arrangements, Protocol Wealth does not receive client private keys.
Move assets to Protocol Wealth wallets
There is no path for the firm to route client assets to a Protocol Wealth–controlled destination.
Expand permissions on its own
Changes that expand or alter wallet permissions require client approval and compliance review.
Override client recovery rights
Where a client controls the wallet and recovery path, that control stays with the client.
Provide tax or legal advice
Protocol Wealth does not provide tax or legal advice; clients consult their own professionals.
This structure is designed to separate advisory authority from unilateral control. It remains subject to client agreements, system configuration, compliance review, and legal analysis.
Section 5
Verify, and read deeper
The details, the deeper technical reference, the regulatory backdrop, and the authoritative filings are all public.
Qualified Custody
Independent qualified digital asset custody options, where appropriate.
Self-Custody & Client-Controlled Wallets
How client-controlled wallet structures work, and the limits on the firm’s role.
Bailment Framework
The deeper, source-tracked technical and tax-analysis reference.
Industry Watch
The public regulatory and industry materials we monitor as this area evolves.
Disclosures
Regulatory disclosures, Form ADV, and Form CRS — the authoritative filings.
Trust Center
The firm’s broader trust surfaces: privacy, subprocessors, vendors, security, and AI.
Questions about custody and control:[email protected]· or start a conversation.
Change log
Versions
Initial publication. Approved custody statement, the basic idea, the two custody paths, what the firm can and cannot do, and links to the deeper reference and authoritative filings.
Last updated: July 27, 2026. Protocol Wealth, LLC is an SEC-registered investment adviser (CRD #335298). See ourForm ADVfor authoritative regulatory disclosures. Registration does not imply a particular level of skill or training; advisory services are provided only under a signed advisory agreement.
This page is general information about how Protocol Wealth operates. It is not a personalized recommendation, an offer, or a guarantee of any regulatory, tax, or legal outcome, and it is not tax or legal advice. Custody arrangements depend on the client, the asset, the account, and the strategy, and are subject to compliance, legal, and tax review.
All investments involve risk, including the potential loss of principal. Digital assets are highly speculative and volatile, and carry additional risks including smart-contract, protocol, bridge, stablecoin, custody, and wallet-policy risk. Past performance does not guarantee future results.