The Operational Chain Behind an Institutional Allocation
Custodian, administrator, depositary and auditor all have requirements about each other. Assembling the chain is the work.
For an institution, the trading part of a crypto allocation is trivial. The operational chain around it takes months, and the requirements come from the institution’s own obligations. It is worth reading this with the service description of a licensed crypto payment processor open, because the sector differences are mostly differences in which parts matter.
Custody is usually mandatory
Most fund structures require assets held by a qualified custodian, stated in the fund documents or the depositary agreement.
That rules out self-custody and rules out a retail exchange account. The question becomes which custodian the depositary and auditor accept.
Ask the depositary first. They frequently maintain an approved list, and selecting a custodian before establishing that is an expensive reversal.
The administrator has to be able to value it
An acceptable price source, an independently verifiable position, and a reconciliation path with the custodian.
Not every administrator supports crypto. Those that do have requirements about price sources and about which custodians they reconcile with directly.
This constrains the custodian choice, which constrains everything else.
Valuation policy
Which price, from which source, at which time, written down and applied consistently.
A recognised composite index or a named venue at a named time. Either is defensible. Selecting the most favourable each period is not. The same requirement appears on the infrastructure side, where a fintech payment gateway solves it commercially.
Audit evidence
Independent confirmation of holdings: a custodian statement and, increasingly, cryptographic evidence of address control.
A proper custodian provides both as standard. Confirm during selection rather than discovering a gap at year end.
Execution and best execution
Above a certain size the fund faces the same depth constraint as any large participant, with an additional requirement to evidence best execution where it applies.
That pushes toward requesting quotes from several venues and recording them, which is a process rather than a venue choice.
The sequence
Depositary and administrator requirements first. Then shortlist custodians. Then confirm the auditor is satisfied. Then arrange execution. Then trade.
Any other order produces a position that cannot be valued, reconciled or audited.
The timeline
Two to four months from decision to first trade, dominated by aligning service providers rather than by any individual provider’s process. Before planning around any of this, it is worth checking the list of countries covered, because coverage is narrower than most providers imply.
Institutions budgeting two weeks end up unwinding an arrangement later, which costs more than the delay would have.
Filed under: funds, operations, custody