The newly created Crypto Task Force has been holding roundtable discussions on the regulatory treatment of digital assets. An April 25, 2025, roundtable on custody by investment advisers and investment companies focused on the challenges of complying with current Rule 206(4)‑2 – the Custody Rule – under the Investment Advisers Act of 1940. This second article in our two-part series covers potential digital asset custody models, as well as state trust companies and other entities as qualified custodians, with additional commentary from Justin L. Browder, partner at Simpson Thacher & Bartlett LLP, who also participated in the roundtable. The first article summarized the Commissioners’ remarks and reviewed the practical custody challenges discussed. See “SEC Commissioner Examines Regulatory Approach to Digital Assets” (May 6, 2021).