Recent events
2026-04-07
Other facts
PRIMARY
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…
2025-06-15
Other facts
SECONDARY
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…
2025-06-15
Other facts
SECONDARY
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.
2025-06-15
Other facts
SECONDARY
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.
2025-02-12
Other facts
PRIMARY
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.
2025-01-23
Other facts
PRIMARY
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.
2025-01-23
Other facts
PRIMARY
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.
2025-01-23
Other facts
PRIMARY
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…
2025-01-23
Other facts
PRIMARY
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…
2025-01-15
Other facts
PRIMARY
The SEC subsequently rescinded SAB 121 via SAB 122 in January 2025, after the November 2024 election produced a new administration.
2024-05-31
Other facts
PRIMARY
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.
2024-03-26
Other facts
INFERENTIAL
SEC Staff Accounting Bulletin No. 121 filed filing with the SEC on 2024-03-26. Accession number: N/A.
2023-06-15
Other facts
SECONDARY
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.
2023-06-15
Other facts
SECONDARY
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.
2022-03-31
Other facts
PRIMARY
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.
