# SEC accounting staff rescinds SAB 121 through Staff Accounting Bulletin 122

> SEC accounting staff rescinded SAB 121’s staff view that an entity safeguarding customer crypto assets should recognize a safeguarding liability and corresponding asset. The rescission does not eliminate generally applicable accounting, loss-contingency, or risk-disclosure requirements.

- URL: https://riadefi.com/regulation/2025-01-23-sec-sab-121-rescission-sab-122/
- Posture: Guidance
- Authorities: SEC Office of the Chief Accountant; SEC Division of Corporation Finance
- Event date: 2025-01-23
- Effective: 2025-01-30
- Version: 1, published 2026-08-07 (first published 2026-08-07)
- Advisor-relevant: yes

## What changed

SEC accounting staff rescinded SAB 121’s staff view that an entity safeguarding customer crypto assets should recognize a safeguarding liability and corresponding asset. The rescission does not eliminate generally applicable accounting, loss-contingency, or risk-disclosure requirements.

## Who it affects

- Public companies and financial institutions safeguarding crypto assets
- Advisers assessing the financial condition and operational resilience of crypto custodians

## What is still open

- How individual custodians will revise financial statements and controls
- Whether custody capacity and pricing will change in response

## What it means for an advisor

- Refresh custodian financial-condition diligence using post-rescission statements
- Do not describe the bulletin as an SEC custody exemption or qualified-custodian determination

## Previous interpretation

SAB 121 stated that safeguarding entities should recognize a liability and corresponding asset for customer crypto assets held.

## Sources

1. [Staff Accounting Bulletin No. 122](https://www.sec.gov/rules-regulations/staff-guidance/staff-accounting-bulletins/staff-accounting-bulletin-122) · U.S. Securities and Exchange Commission staff · 2025-01-23 · effective 2025-01-30


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Published by Ketju Research on RIADeFi (https://riadefi.com). Educational research for financial professionals; not investment, legal, tax, or compliance advice.