Qualified Custody
Independent custody, where appropriate.
Independent custody options for digital assets where qualified custody is the right fit.
Some client digital assets may be held with independent qualified digital asset custodians. These arrangements are separate from Protocol Wealth. The custodian holds the assets; Protocol Wealth provides advisory services, monitoring, and documentation under the client’s advisory agreement.
In this path the independent qualified custodian holds the assets. Protocol Wealth’s role is advisory, and Protocol Wealth does not hold client private keys.
Whether qualified custody is used, and which custodian is appropriate, depends on the client, the asset, and the strategy. Not all digital assets are held the same way — some clients useclient-controlled walletsinstead, which is a different structure described on its own page.
What this page is. A description of the qualified custody path for digital assets and how custody is kept separate from trading and execution. A qualified custodian is an independent institution that holds the assets; it is a different role from the wallet infrastructure(such as Fordefi or Turnkey) used in client-controlled wallet workflows, and a different role from any trading counterparty.
What this page is not. A personalized recommendation, an offer, a statement that all client digital assets are held with a qualified custodian, or a representation about any custodian’s insurance, attestations, or entity status. Custodian selection is subject to due diligence, client facts, account setup, and compliance review.
No custody-rule conclusion. This page is educational and 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reaches client “funds or securities”; the 2023 SEC proposal to expand safeguarding to a broader “assets” standard was withdrawn in 2025.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 specific asset or account is treated is a matter for the governing agreements and compliance and legal review.
Section 1
Independent qualified custodians
Protocol Wealth may work with qualified digital asset custodians such as Anchorage Digital Bank and BitGo where appropriate for the client, asset, and strategy. These are independent institutions; using them is not the same thing as Protocol Wealth taking custody.
Anchorage Digital — primary qualified custodian, in active use
Anchorage is the primary qualified digital asset custodian Protocol Wealth uses today. That spans Anchorage Digital Bank — an OCC-chartered national trust bank — and the Anchorage-owned RIA/advisor platform (which Anchorage acquired from Securitize, which had earlier acquired OnRamp). Using Anchorage’s bank and advisor tools is not the same thing as Protocol Wealth holding client assets. We track Anchorage platform developments on ourindustry watch page.
BitGo — onboarded, not currently in use
BitGo is onboarded as an additional qualified digital asset custody option but is not currently in use. We do not make specific public claims about insurance, attestations, jurisdiction, or entity status; any such detail is confirmed against current BitGo materials and the governing agreement as part of diligence.
Traditional assets
For traditional assets, client accounts are held at independent brokerages and custodians such as Charles Schwab, Altruist, and Interactive Brokers in the usual way. Protocol Wealth advises; the brokerage or custodian holds the assets.
Section 2
Custody is separate from execution
In some workflows, a separate trading or execution counterparty may be involved while assets remain with the applicable custodian. Trading and execution counterparties are not described as qualified custodians unless the governing agreement and regulatory status support that characterization.
For example, in an Anchorage and FalconX tri-party workflow, Anchorage Digital Bank remains the qualified custodian. FalconX is treated as a trading, execution, settlement, or derivatives counterparty — not the qualified custodian. Keeping these roles distinct is part of how the structure is designed to separate who holds the assets from who executes a trade.
Section 3
Where Protocol Wealth fits
Across every one of these arrangements, Protocol Wealth’s role is advisory. The firm may have discretionary or non-discretionary authority depending on the mandate, and may report assets as regulatory assets under management or assets under advisement when it provides advisory services over them. Reporting assets under management or advisement does not, by itself, mean Protocol Wealth holds those assets.
The custodian holds the assets. Protocol Wealth researches, recommends, monitors, implements within agreed authority, and documents — under a signed advisory agreement and applicable compliance review.
Read next
Related pages
Custody and Control
The plain-English hub: how assets are held, who controls them, and what the firm can and cannot do.
Self-Custody & Client-Controlled Wallets
How client-controlled wallet structures work — Fordefi and Turnkey wallet infrastructure, and client recovery.
Bailment Framework
The deeper, source-tracked technical and tax-analysis reference — education, not advice.
Industry Watch
The public regulatory and industry materials we monitor as custody guidance evolves.
Change log
Versions
Initial publication. Independent qualified custodians (Anchorage Digital Bank, BitGo), the separation of custody from trading and execution counterparties such as FalconX, and where Protocol Wealth’s advisory role fits.
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 qualified custody arrangements. It is not a personalized recommendation, an offer, a representation about any custodian’s insurance, attestations, or status, or a statement that all client digital assets are held with a qualified custodian, and it is not tax or legal advice. Custodian selection depends on the client, the asset, and the account, and is subject to due diligence and compliance review. Third-party custodians and counterparties are independent of Protocol Wealth; naming them is not an endorsement.
All investments involve risk, including the potential loss of principal. Digital assets are highly speculative and volatile. Past performance does not guarantee future results.