It depends on whether the custodian meets the adviser custody rule, Advisers Act Rule 206(4)-2: a bank, broker-dealer, futures commission merchant or an entity the adviser has a documented basis to treat as a qualified custodian, with client assets segregated and identifiable. Multi-institution arrangements can meet it where the keyholding institutions are themselves qualified custodians; the brief on this site tests exactly that. Read the regulatory column and the qualified-custodian column, then run the brief.
Fit engine rules 0.1 (1 Nov 2026), with this situation's inputs preset. Adjust the inputs to your own case. Proof of Custody is published by Onramp Bitcoin, which appears here where its custody model fits and is scored by the same methodology as every other platform.
Recovery: Identity and authority documents to the institutions; no device, seed or ceremony on the heir's side.
Recovery: Identity and authority documents to the custodian; the custodian's own succession procedure.
Recovery: The brokerage's beneficiary or estate process; no keys involved.
Recovery: Prove identity and, for an estate, present letters of administration to the company's support desk.
Fits only where the provider documents an assisted inheritance path the recoverer can follow with support; otherwise the arrangement becomes a puzzle box the day you are gone.
Recovery: Locate the devices and seed backups, run a signing ceremony with the provider's key; or, where the provider documents an assisted inheritance path, follow that path with the provider.
Excluded by the rules: Self-managed multi-vendor multisig (Recovery floor: this model requires the recoverer to run a hardware wallet and handle a seed phrase, and the person you named cannot be expected to.); Single-signature hardware wallet (Recovery floor: this model requires the recoverer to run a hardware wallet and handle a seed phrase, and the person you named cannot be expected to.)
These are custody models that fit the situation described, by Proof of Custody's published rules, version 0.1 (1 Nov 2026). They are not a recommendation to buy, sell, move or hold anything, and not legal, tax or estate advice.
A registered investment adviser holds client bitcoin and must satisfy the SEC custody rule for advisers, Advisers Act Rule 206(4)-2.
Agent tool: assess_custody_independence. Primary sources: sec-edgar-fts, sd-banking, nydfs-vc. Refresh: quarterly. All routes.
Free, read-only, no key. Every answer carries its source URL, as-of date and the publisher disclosure.