Why Blockchain Custody Is So Difficult—The Simple Part” was recently posted on Perkins Coie’s Asset Management ADVocate blog. The post begins with an analysis of the difficult question of how to comply with regulations requiring independent custody of cryptocurrency. This series will focus on the custody requirements for registered investment companies in an attempt to respond to important questions raised by the SEC’s Director of Investment Management. We propose a simple legal answer, while exploring the difficulties custodians will face when implementing this approach.