Reviewing held-away crypto for advisory clients means identifying digital assets the advisor does not custody or directly manage, then determining how those assets affect advice, reporting, risk, billing, and compliance.
The advisor should define the scope before giving recommendations.
Step 1: Inventory the Assets
Ask where assets are held, who controls them, whether they are self-custodied, and whether trusts, LLCs, or retirement accounts are involved.
Step 2: Define Advisory Scope
Clarify whether the firm will provide education, reporting, financial planning, investment advice, billing, or management related to the held-away crypto.
Step 3: Review Custody and Access
Advisors should be careful not to take possession of private keys, seed phrases, or account credentials unless the firm has intentionally designed and approved that custody model.
Step 4: Coordinate Tax and Estate Issues
Held-away crypto may affect cost basis, liquidity, estate access, trust planning, and risk concentration.
Sources
Compliance Note
This article is educational and does not provide legal, compliance, tax, investment, fiduciary, or custody advice. RIAs should consult compliance counsel before reviewing held-away crypto. Registration does not imply a certain level of skill or training.