A crypto client questionnaire for financial advisors is a structured intake form that surfaces a client's digital asset holdings, custody arrangements, transaction-record gaps, risk concentration, and estate planning needs. Used at discovery, it helps an advisor spot held-away crypto and coordinate the tax, custody, and legal follow-up the answers call for.
What a Crypto Client Questionnaire Is
The questionnaire is a discovery tool, not a substitute for legal, tax, or compliance review. Its job is to make sure a conversation about digital assets actually happens, and to capture enough detail that an advisor knows whether to pull in a crypto specialist, tax counsel, or estate counsel. Because clients often hold crypto on exchanges or in self-custody wallets the firm never sees, asking directly is usually the only way the holdings come to light. For the wider context of advising on these assets, see the Crypto Services for RIAs Hub.
Core Questions
Group the intake around six areas. The questions below are a starting point to adapt with compliance counsel, not a finished form.
| Area | Sample questions |
|---|---|
| Holdings | Do you currently own crypto or digital assets? Which assets, and roughly what share of your net worth? |
| Custody | Where are the assets held, an exchange, a Cryptocurrency qualified custodians have emerged to serve institutional requirements. Qualified custody may be required for register">qualified custodian, or a self-custody wallet? Are any assets self-custodied? |
| Ownership structure | Do any trusts, LLCs, or retirement accounts own crypto? |
| Tax records | Do you have complete transaction records (cost basis, dates, transfers)? Have you received staking rewards, airdrops, or mining income? |
| Risk and liquidity | Are any holdings pledged as collateral? Are any assets locked, vested, or restricted? |
| Estate and access | Do you have a plan for heirs or fiduciaries to access assets if you become incapacitated or die? |
Custody answers matter most for an SEC-registered adviser, because the custody rule generally turns on whether assets sit with a qualified custodian versus a wallet only the client controls. Self-custody answers shape what the firm can do; see Can RIAs Advise on Self-Custodied Crypto?. Held-away answers shape how, or whether, the firm can bill; see Can RIAs Bill on Held-Away Crypto?.
Advisor Follow-Up
Depending on the answers, the advisor may need to coordinate with tax professionals, estate counsel, compliance counsel, custodians, or a crypto specialist. Common triggers:
- Incomplete transaction records or undocumented staking, airdrop, or mining income, which the IRS generally treats as property and as taxable events, route to a tax professional.
- Self-custody or an unfamiliar custodian, run custody diligence (SOC 1/SOC 2 reports, insurance, key management) before relying on it.
- Crypto owned inside a trust, LLC, or IRA, confirm the structure actually holds title and that fiduciary access is documented.
Whatever the questionnaire surfaces should be written into the client file. For how to memorialize the recommendation that follows, see How Should RIAs Document Crypto Recommendations?.
Why This Helps
Many clients own crypto outside the advisor's platform. A questionnaire surfaces held-away assets before they turn into tax, risk, or estate planning problems, an unreported airdrop, a single exchange holding a quarter of net worth, or a wallet no heir can open. Surfacing the asset does not remove market, custody, or tax risk; it only gives the advisor the facts needed to manage it.
Related Questions
Should advisors ask every client about crypto?
Generally, asking a consistent screening question of every client is more defensible than guessing who holds digital assets, since ownership is hard to predict from a profile. The approach you take should be set with compliance counsel.
What should an advisor do when a client owns crypto held away from the firm?
It depends on the facts, but the usual path is to document the holding, assess custody and tax exposure, and decide whether the firm can advise on or bill for the asset. Coordinate with compliance and tax professionals before acting.
Does a crypto questionnaire replace tax or legal advice?
No. The questionnaire is a discovery tool that flags issues; it does not resolve them. Tax treatment, custody arrangements, and estate documents should be confirmed with qualified professionals.
Sources
Compliance Note
This article is educational and does not provide legal, tax, compliance, investment, fiduciary, or custody advice. Advisors should adapt questionnaires with compliance counsel. Registration does not imply a certain level of skill or training.