Authority: U.S. Securities and Exchange Commission (SEC)
Regulatory instrument: Written industry submission (regulatory input)
Jurisdiction: United States
Submitting entity: Securities Industry and Financial Markets Association (SIFMA)
Subject: Digital asset wallet providers and broker-dealer regulation
Date posted: January 15, 2026
Summary
The SEC Crypto Task Force published a written submission from the Securities Industry and Financial Markets Association addressing how existing U.S. securities laws should apply to digital asset wallet providers. The letter focuses on the regulatory perimeter between non-custodial software-based wallet services and activities that may trigger broker-dealer registration requirements.
Key points
The no-action position is limited to the following conditions:
- SIFMA said that certain wallet-related services may fall outside traditional broker-dealer functions when they do not involve custody, execution, or the handling of customer securities.
- The submission calls for clearer distinctions between software-based wallet tools and intermediated financial services when assessing registration and compliance obligations.
- The letter raises concerns about regulatory uncertainty where firms facilitate access to digital assets without engaging in securities transactions.
- SIFMA urged regulators to pursue durable regulatory clarity through formal rulemaking rather than case-by-case exemptions or no-action relief.
Status
Informational regulatory input only.
No regulatory action, guidance, or rulemaking has been announced by the SEC in connection with this submission.
Context
The letter forms part of the SEC Crypto Task Force’s broader market-structure review, which includes written input from industry groups and market participants on how existing securities laws intersect with evolving digital asset business models.
