Evidence who controls keys or control instruments and how assets, withdrawals, records and incidents are managed.
Why this workstream matters
Review hot, warm and cold arrangements, segregation, approvals, address controls, recovery, vendor roles, audit logs and customer asset records. “Non-custodial” is a functional conclusion, not a marketing label.
Model-specific questions
- Key and wallet architecture
- Asset and customer-record segregation
- Withdrawal and address controls
- Approval, recovery and incident processes
- Provider and sub-custodian due diligence
- Logs, reconciliation and system demonstration
How it connects to the application
Outputs must be consistent with the ownership structure, product and information flows, providers, business plan, staffing assumptions, policies and system behaviour. Any inconsistency should be resolved before filing or implementation.
Client inputs and dependencies
We confirm required founders, group records, product documentation, vendor information, system access, markets, transaction assumptions and responsible client personnel during scoping. The proposal separates adviser work, client responsibilities and third-party costs.