The biggest untapped on-ramp for crypto is opening.

On Sept 22, House Republicans pressed SEC Chair Paul Atkins to fast-track rules letting 401(k)s invest in Bitcoin, Ethereum, private equity, and VC. This builds on Trump’s Aug 7 executive order directing regulators to clear the path. [NEWS]

it matters: $9T sits in U.S. 401(k)s. Even a 1% allocation to crypto = ~$90B of new demand. For context, all U.S. spot BTC ETFs combined have ~$140B AUM today. This isn’t about retail traders, it’s about creating the largest long-term, dollar-cost-averaging inflow Bitcoin has ever seen.

Let’s dig in.

What’s happening

The U.S. 401(k) system, governed by ERISA, has long constrained savers to low-risk assets under strict fiduciary standards. Previous guidance, like the Biden administration’s 2022 caution on crypto, allowed plan sponsors to deny digital asset exposure without justification.

What we’re watching:

• The Department of Labor (DOL) has 180 days to create safe harbors for plan sponsors, so they can add alternatives without ERISA litigation risk.
• The SEC will revisit “accredited investor” definitions, expanding access to managed crypto funds.
• Together, this gives fiduciaries a legally defensible pathway to offer crypto inside retirement accounts.

It is a concerted push to fundamentally redefine what "retirement saving" means for 90M Americans.

What changes:

• DOL safe harbors (180 days): Plan sponsors can offer alternatives (crypto, PE, VC) without ERISA litigation risk.
• SEC accredited investor reform: Expands who can access professionally managed crypto funds inside retirement accounts.
• Fiduciary shield: Shifts due diligence to fund managers, giving employers a clear legal path to add crypto exposure.

The backdrop: For decades, retirement savers were confined to stocks, bonds, and fiat-denominated funds. Crypto allocations were blocked by fiduciary “caution” guidance, most recently under Biden in 2022. Trump’s EO flips the script, reframing Bitcoin/Ethereum as legitimate long-term assets — akin to gold or real estate — while democratizing access to private markets.

Punchline: This is the biggest new capital channel since spot ETFs. You now have a six-month runway before the DOL and SEC finalize rules. The firms that build compliant retirement vehicles first will own the distribution to 90M Americans.

Investor implications

• Asset managers: Retirement products are the next ETF trade. Build compliant multi-asset funds tailored to cautious fiduciaries.
• Public proxy stocks (MSTR, MARA, COIN): Position as retirement-eligible exposure to capture sticky flows.
• Crypto treasuries: NAV premiums gain support from predictable, regulated inflows.

Our take

The push to put Bitcoin in 401(k)s has never had more political backing. SEC Chair Paul Atkins — architect of “Project Crypto” — is openly saying most digital assets aren’t securities, a sharp break from the last administration. Translation: the SEC is shifting from enforcement to building clear rules of the road.

But turning Trump’s executive order into real retirement products won’t happen overnight. It means new DOL and SEC guidance, new fund structures, integration with 401(k) recordkeepers, and educating both employers and savers. The political will is there. The execution will take heavy lifting.

What’s Next

Executive Order 14330 marks a watershed moment for retirement investing and creates a massive new market opportunity, opening access to private equity, real estate, and digital assets like Bitcoin. The industry will likely see a proliferation of new investment vehicles designed to fit the EO’s “actively managed” criteria, such as closed-end funds and multi-asset funds.

Market Signals of Today

• Deusche Bank: “Bitcoin to coexist with gold on central bank balance sheets by 2030”. Link
• HSBC starts tokenized deposits to move currencies across borders. Link
• Forward Industries to tokenise stock, expanding Solana treasury and DeFi use. Link
• World Liberty Financial to launch debit card and trading app soon. Link
• Kraken and Legion launch Yield Basis BTC protocol with merit-based sale. Link
• Plasma launched neobank, Plasma One which offers global, permissionless stablecoin savings, spending, earning. Link
• Vitalik on L2s. Link

That’s all for today’s CEO Briefing.

Best,

Marc & Team

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