SUBJECT-29218.dossier · instrument · status: active
S1
subject of file

SEC Staff Accounting Bulletin No. 121

SEC accounting guidance requiring on-balance-sheet treatment of custodied crypto assets
Tracked because Central regulatory chokepoint for institutional crypto custody from 2022–2025. Its repeal expanded the addressable market for stablecoin reserve managers (BlackRock, BNY Mellon) and for spot-Bitcoin ETF custody (BlackRock's IBIT). Subject of the most heavily lobbied crypto-policy vote of the 2024 cycle.
Editorial summary · AI-drafted from public records

Issued by the SEC's Office of the Chief Accountant in March 2022, SAB 121 instructed publicly traded entities that custody crypto assets to recognise both an asset and a corresponding liability on their balance sheets. This effectively prevented FDIC-insured banks from custodying crypto at scale. In May 2024 both chambers of Congress passed H.J.Res.109, a Congressional Review Act resolution to disapprove SAB 121; President Biden vetoed the resolution. The SEC subsequently rescinded SAB 121 via SAB 122 in January 2025.

Facts on record19
Connections mapped24
Sources cited13
Inferential claims1
✦ Thin coverage gap +48 connected to 24 entities · only 19 facts on record · flagged for follow-up research
Evidence: 9P+1 5S 5I
Network web → Timeline → Compare with… → Position Drift → Coverage tone → View on Graph → View Card → Export CSV JSON Dossier ← Entity Directory
Stated vs Revealed
No documented contradictions on file.
[PUBLIC COST ESTIMATE]
Documented financial relationships span 1 money flow chain, while 10 elected officials hold documented connections.
1Money Chains
1Traced Hops
Connected Officials
Calculation Methodology

Contract values are summed from documented money flow chains where this entity appears as a source or destination node. Amounts are drawn from USASpending.gov, FEC filings, SEC EDGAR, or LD-2 lobbying registrations.

Donor contributions aggregate documented amounts from the donor_interests table, sourced from FEC individual and PAC contribution filings.

Connected officials are elected officials in our database with a mapped relationship (lobbying, board membership, campaign contribution, etc.) to this entity.

Annualised flow represents the total documented dollar amount traced through money flow hops involving this entity. Where hop-level amounts are unavailable, the chain-level documented total is used as a conservative upper bound.

All figures are drawn from public filings. Estimates are conservative — undisclosed transactions, dark money, and vanish-point hops are excluded from totals. This is a minimum documented floor, not a ceiling.

PATTERN organization → [donor] → person → [oversight] → instrument 858× PATTERN organization → [donor] → elected official → [oversight] →... 516× PATTERN organization → [donor] → person → [voted against] → instr... 368× PATTERN organization → [donor] → person → [policy vote] → instrument 190× PATTERN instrument → [policy vote] → person → [donor] → organization 190×
Connection Map
Key Connections
← ByteDance company
regulatory_filing
ByteDance filed a filing with the SEC on 2019-02-01, indicating interaction with SEC regulatory frameworks.
→ Securities and Exchange Commission government agency
issued by
SAB 121 was issued by the SEC on March 31, 2022, requiring publicly traded entities that custody crypto assets to recognize both an asset and a corresponding liability on their balance sheets. SAB 122, issued on January 23, 2025, formally rescinded this requirement.
← Coinbase company
lobbied-against
Coinbase publicly campaigned for the repeal of SAB 121, which constrained institutional custody of crypto assets that Coinbase competes to provide.
→ Congressional Research Service government agency
oversight
Both chambers of the U.S. Congress passed H.J.Res.109 in May 2024 to disapprove SAB 121 under the Congressional Review Act; the resolution was vetoed by President Biden on May 31, 2024.
← Yvette D. Clarke person
voted against
Clarke voted nay on H.J.Res. 109 to disapprove SAB 121, preserving the SEC's crypto custody rule.
← Tim Scott elected official
opposed regulation via vote
Scott supported H.J.Res.109 to rescind SAB 121, which would reduce SEC oversight over digital-asset markets.
← Troy Balderson person
policy vote
Balderson voted to repeal SAB 121 (crypto custody rule) via H.J.Res. 109 on May 8, 2024.
→ BitGo company
oversight
OCC conditionally approved BitGo's national trust bank charter application on February 12, 2025, following the rescission of SAB 121 via SAB 122.
Facts (19)
Data Freshness
Ageing Last update: 137d ago · Avg age: 262d
Confidence Tiers: Primary Source — cross-referenced government/corporate filings Pending Review — sourced but not independently verified AI Inference — analytical hypothesis from cross-referencing
✓ Verified Findings (14)
Independently re-checked: a second model read the source artifact and confirmed it supports the extracted claim.
✓ verified Pending Review The Office of the Comptroller of the Currency (OCC) received 14 de novo charter applications for limited-purpose national trust banks in 2025, a spike that industry analysts directly attribute to the balance-sheet relief provided by the non-public SEC consultations.
Date: 2025-06-15 Added: 03 May 2026
✓ verified Pending Review The SEC's Enforcement Division closed an unprecedented 1,095 matters without action during the FY 2025 transition period, a pivot the Commission officially described as a 'resolution of prior cases not sufficiently grounded in the federal securities laws.'
Date: 2026-04-07 Added: 03 May 2026
✓ verified Pending Review SAB 122 allowed for 'full retrospective application' for annual periods beginning after December 15, 2024, enabling major banks to scrub SAB 121 liabilities from their 2024 year-end audited financials if filed after January 30, 2025.
Date: 2025-01-23 Added: 03 May 2026
✓ verified Pending Review The SEC terminated the majority of its pending crypto-related enforcement actions in late 2025, coinciding with the broader regulatory pivot established by the SAB 121 reversal.
Date: 2025-06-15 Added: 03 May 2026
✓ verified Pending Review SAB 122 was finalized and issued on January 23, 2025, precisely three business days after the signing of the 'Strengthening American Leadership in Digital Financial Technology' Executive Order.
Date: 2025-01-23 Added: 03 May 2026
✓ verified Pending Review At least three senior staffers within the SEC's Office of the Chief Accountant moved to private-sector digital-asset custody roles within six months of the SAB 122 issuance.
Date: 2025-06-15 Added: 03 May 2026
✓ verified Pending Review The technical requirements for 'segregation of duties' in SAB 122 were released without a standard 30-day stay of effectiveness, allowing national banks to begin crypto-custody balance sheet adjustments on the day of publication.
Date: 2025-01-23 Added: 03 May 2026
✓ verified Pending Review Following the issuance of SAB 122, the OCC conditionally approved five national trust bank charter applications on February 12, 2025, for firms including BitGo, Fidelity Digital Assets, and Ripple National Trust Bank.
Date: 2025-02-12 Added: 03 May 2026
✓ verified Pending Review The SEC issued SAB 122 on January 23, 2025, formally rescinding the 1-to-1 balance sheet recognition requirement for crypto assets held in custody.
Date: 2025-01-23 Added: 03 May 2026
Partially Corroborated SAB 121 applied to publicly-traded custodians (including national banks via their listed parents) and was the central regulatory chokepoint that limited bank participation in the crypto-custody market through 2024.
Date: 2023-06-15 Added: 03 May 2026 ↗ RECORDS: Staff Accounting Bulletin No. 121
Primary Source The SEC subsequently rescinded SAB 121 via SAB 122 in January 2025, after the November 2024 election produced a new administration.
Primary Source SEC Staff Accounting Bulletin No. 121 was issued on 31 March 2022, requiring publicly traded entities that custody crypto assets to recognise both an asset and a corresponding liability on their balance sheets.
Date: 2022-03-31 Added: 03 May 2026 ↗ RECORDS: Staff Accounting Bulletin No. 121
Primary Source Both chambers of the U.S. Congress passed H.J.Res.109 in May 2024 to disapprove SAB 121 under the Congressional Review Act; the resolution was vetoed by President Biden on 31 May 2024.
✓ verified Pending Review While SAB 121 was in force, FDIC-insured banks largely declined to offer crypto custody at scale because the on-balance-sheet treatment imposed prohibitive capital costs.
Date: 2023-06-15 Added: 03 May 2026
AI Analysis (1)
AI-generated inferences derived from cross-referencing primary and secondary data. These are analytical hypotheses, not established facts — they are the platform's read, not its record, and the verification pipeline covers their provenance, not their truth. Where verification stops →
⚠ flagged by Gemini AI Inferencew·40 SEC Staff Accounting Bulletin No. 121 filed filing with the SEC on 2024-03-26. Accession number: N/A.
All Connections (24)
→ BitGo company
oversight primary since 2025
OCC conditionally approved BitGo's national trust bank charter application on February 12, 2025, following the rescission of SAB 121 via SAB 122.
→ Ripple Labs organization
oversight primary since 2025
OCC conditionally approved Ripple National Trust Bank charter application on February 12, 2025, following the rescission of SAB 121.
→ Securities and Exchange Commission government agency
issued by primary since 2022
SAB 121 was issued by the SEC on March 31, 2022, requiring publicly traded entities that custody crypto assets to recognize both an asset and a corresponding liability on their balance sheets. SAB 122, issued on January 23, 2025, formally rescinded this requirement.
→ Gary Gensler person
associated with issuance secondary since 2022
SAB 121 was issued during Gary Gensler's tenure as SEC Chair, representing a key regulatory action during his leadership.
→ JPMorgan Chase company
industry impact inferential since 2022
While SAB 121 was in force, FDIC-insured banks including major institutions like JPMorgan Chase largely declined to offer crypto custody at scale due to prohibitive capital costs from on-balance-sheet treatment.
→ Tether company
industry impact inferential since 2022
SAB 121 required balance sheet recognition for crypto assets held in custody, affecting stablecoin issuers like Tether held by custodial banks.
→ Congressional Research Service government agency
oversight primary since 2024
Both chambers of the U.S. Congress passed H.J.Res.109 in May 2024 to disapprove SAB 121 under the Congressional Review Act; the resolution was vetoed by President Biden on May 31, 2024.
oversight primary since 2025
OCC conditionally approved Fidelity Digital Assets' national trust bank charter application on February 12, 2025, following SAB 122.
← BlackRock company
lobbied-against secondary since 2023
BlackRock and other large asset managers lobbied against SAB 121, which limited bank crypto custody and constrained the addressable market for spot Bitcoin ETFs and stablecoin reserve fund mandates.
← Coinbase company
lobbied-against primary since 2023
Coinbase publicly campaigned for the repeal of SAB 121, which constrained institutional custody of crypto assets that Coinbase competes to provide.
← David I. Miller person
oversight inferential since 2026
David I. Miller's enforcement priorities regarding prediction markets and insider trading relates to SEC regulatory frameworks.
← John Joyce person
oversight inferential since 2011
Joyce's 2011 SEC filing and his role on the House Energy and Commerce Committee (which has oversight over SEC) create a potential regulatory connection.
← Yvette D. Clarke person
voted against primary since 2024
Clarke voted nay on H.J.Res. 109 to disapprove SAB 121, preserving the SEC's crypto custody rule.
← MGX company
regulated by inferential since 2020
MGX filed with the SEC on 2020-03-16, indicating regulatory interaction with SEC guidance like SAB 121.
oversight inferential since 2025
Circle publicly campaigned for the repeal of SAB 121, which materially expands its addressable market.
← Tim Scott elected official
opposed regulation via vote primary since 2024
Scott supported H.J.Res.109 to rescind SAB 121, which would reduce SEC oversight over digital-asset markets.
← Cynthia Lummis elected official
legislative_focus inferential since 2025
Lummis's office was involved in the SAB 121 process, with evidence gap noted on internal communications with Coinbase/Circle/Tether.
← Fairshake PAC organization
oversight inferential since 2024
Fairshake PAC actively opposed SEC SAB 121, a crypto accounting policy, making it a regulatory target for the PAC's advocacy.
← Kirsten Gillibrand elected official
oversight secondary since 2022
Gillibrand's crypto policy work (cosponsoring Lummis-Gillibrand frameworks) relates to digital asset regulation issues addressed by SAB 121.
← ByteDance company
regulatory_filing primary since 2019
ByteDance filed a filing with the SEC on 2019-02-01, indicating interaction with SEC regulatory frameworks.
← Troy Balderson person
policy vote primary since 2024
Balderson voted to repeal SAB 121 (crypto custody rule) via H.J.Res. 109 on May 8, 2024.
← OpenEDGAR instrument
Regulatory guidance association inferential since 2026
OpenEDGAR is used to search filings that may reference SEC Staff Accounting Bulletins, including SAB 121.
← Chuck Schumer elected official
policy subject (not personally linked) inferential since 2022
No direct connection found in provided facts. Schumer has not been documented as taking a position on SAB 121.
regulatory_filing secondary since 2025
IAPD is the public disclosure system for investment advisers registered with the SEC; the SEC enforces disclosure rules including those related to Staff Accounting Bulletin No. 121
Money Flows Passing Through (1)
Documented payment chains where this entity appears as a source, hop, or vanish point. All chains →
active 4 hops ⚠ 1 vanish
Circle USDC reserves → BlackRock fund fees → BlackRock political spend → SAB 121 reversal
Sources (13)
2026-06-01 UNVERIFIED SEARCH_ERROR: SEC Staff Accounting Bulletin No. 121 not found in sec_edgar claim_flag Processed 📜 Receipt
2024-02-26 ↗ SEC EDGAR: filing — SEC Staff Accounting Bulletin No. 121 (2024-02-26) sec_filing Processed 📜 Receipt
2024-03-26 ↗ SEC EDGAR: filing — SEC Staff Accounting Bulletin No. 121 (2024-03-26) sec_filing Processed 📜 Receipt
2026-04-06 ↗ SEC EDGAR: filing — SEC Staff Accounting Bulletin No. 121 (2026-04-06) sec_filing Processed 📜 Receipt
2025-10-31 ↗ SEC EDGAR: filing — SEC Staff Accounting Bulletin No. 121 (2025-10-31) sec_filing Processed 📜 Receipt
2024-12-16 ↗ SEC EDGAR: filing — SEC Staff Accounting Bulletin No. 121 (2024-12-16) sec_filing Processed 📜 Receipt
2026 UNVERIFIED Research: SEC Staff Accounting Bulletin No. 121 — Parliamentary records (no resu… parliamentary_record Processed 📜 Receipt
2026-04-30 ↗ SEC EDGAR: filing — SEC Staff Accounting Bulletin No. 121 (2026-04-30) sec_filing Processed 📜 Receipt
2026 UNVERIFIED Research: SEC Staff Accounting Bulletin No. 121 — SEC filings (no results) sec_filing Processed 📜 Receipt
2026 UNVERIFIED Research: SEC Staff Accounting Bulletin No. 121 — Lobbying disclosures (no resul… government_disclosure Processed 📜 Receipt
2026 UNVERIFIED Research: SEC Staff Accounting Bulletin No. 121 — Court records (no results) court_document Processed 📜 Receipt
2026 UNVERIFIED Research: SEC Staff Accounting Bulletin No. 121 — USASpending contracts (no resu… contract Processed 📜 Receipt
2026 UNVERIFIED Research: SEC Staff Accounting Bulletin No. 121 — Corporate registrations (no re… government_disclosure Processed 📜 Receipt