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[ENTITY FILE] SUBJECT-29218 INSTRUMENT ACTIVE
S1
// Subject

SEC Staff Accounting Bulletin No. 121​​‍‍‌‌‌​‍‌‌​‌‌​‌‍‍​‍‍‌‍‍‌​

SEC accounting guidance requiring on-balance-sheet treatment of custodied crypto assets
Tracked 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-generated 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 The SEC subsequently rescinded SAB 121 via SAB 122 in January 2025.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 record18
Connections mapped2
Sources cited0
Stated vs Revealed
No documented contradictions on file.
[PUBLIC COST ESTIMATE]
Documented financial relationships span 1 money flow chain.
1Money Chains
1Traced Hops
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.

Connection Map
Key Connections
Entity #29188
lobbied-against
Coinbase publicly campaigned for the repeal of SAB 121, which constrained institutional custody of crypto assets that Coinbase competes to provide.
Facts (18)
Data Freshness
Fresh Last update: 4d ago · Avg age: 4d
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 (2)
These facts have been cross-referenced and confirmed against their source material.
Verified Pending Review Evidence gap: The specific drafting input from regulated financial institutions during the Office of the Chief Accountant's January 2025 reversal of​​‍‍‌‌‌​‍‌‌​‌‌​‌‍‍​‍‍‌‍‍‌​ SAB 121 (via SAB 122) is not catalogued in any public rulemaking docket, as staff accounting bulletins are not subject to formal notice-and-comment.
Added: 03 May 2026
Verified Pending Review Evidence gap: The cost-benefit analysis the SEC relied upon when rescinding SAB 1​​‍‍‌‌‌​‍‌‌​‌‌​‌‍‍​‍‍‌‍‍‌​21 has not been released in the form of a published economic-analysis memorandum.
Added: 03 May 2026
Raw Filing Records (16) — unsourced metadata
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 Added: 03 May 2026
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
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
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 Added: 03 May 2026
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
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 Added: 03 May 2026
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
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
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
Pending Review Evidence gap: The internal SEC staff record of dissents and concurrences during the SAB 121 → SAB 122 transition has not been published.
Added: 03 May 2026
Pending Review 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 Added: 03 May 2026
Pending Review 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
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 Added: 03 May 2026
Pending Review 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.
Date: 2024-05-31 Added: 03 May 2026
Pending Review The SEC subsequently rescinded SAB 121 via SAB 122 in January 2025, after the November 2024 election produced a new administration.
Date: 2025-01 Added: 03 May 2026
Pending Review Evidence gap: The full set of industry communications to the SEC requesting rescission of SAB 121 — and the specific contents of the consultations preceding SAB 122 — have not been comprehensively released.
Added: 03 May 2026
All Connections (2)
Entity #25
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.
Entity #29188
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.
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 (0)
No sources.