From www.investmentlawwatch.com: [US context] On May 15, 2025, the SEC’s Division of Trading and Markets issued new FAQs clarifying the application of broker-dealer and transfer agency rules to crypto asset activities, while also withdrawing previous guidance from July 2019.

The FAQs detail how possession and control rules under Rule 15c3-3 relate to non-security crypto assets and specify that proprietary positions in assets like bitcoin and ether can be treated as readily marketable.

Additionally, they indicate that whether a transfer agent must register with the SEC depends on the type of security and related services provided.