For many Registered Investment Advisers (RIAs), digital assets have shifted from “interesting” to “mandatory.”
Client demand is no longer theoretical. Industry surveys show that over 90% of advisors have been asked about crypto by their clients, and allocations to digital assets made by RIAs have risen sharply in recent years. At the same time, a majority of advisors cite regulation, custody, and security as their primary reasons for hesitating to engage.
That tension creates a familiar business dilemma:
- Ignore the asset class and risk losing relevance with younger, digitally native clients.
- Build an in-house solution, with all the cost, liability, and distraction that entails.
- Partner with a specialist, but only if the model is truly fiduciary-aligned and operationally seamless.
This article looks at the real cost of building in-house, what a turnkey sub-advisory solution actually absorbs on your behalf, and how a structure like Keychain Access is designed to let your firm adopt digital assets without re-architecting your practice.
What “Digital Assets” Really Mean for an RIA
For a typical RIA, adding digital assets is not just “one more sleeve.” It touches nearly every control point in the business:
- Custody & the Safeguarding Rule – The SEC’s existing Custody Rule and proposed Safeguarding Rule raise new questions about qualified custodians, audits, and whether traditional trust banks can support certain crypto assets at all.
- Security & Key Management – Unlike traditional assets, crypto introduces private keys, cold storage, and on-chain transaction risk.
- Books & Records – Blockchains settle differently than broker-dealers. Performance, tax lots, and corporate actions behave differently.
- Compliance & Supervision – Policies and procedures must be rewritten to address new risks: forks, airdrops, DeFi exposure, “held-away” wallets, and more.
- Client Communication – You must explain volatility, custody, and security in a way that is consistent with your fiduciary duty and risk-profile frameworks.
This is why many principals instinctively feel that “adding a crypto sleeve” means rebuilding the plane while flying it.
The True Cost of Building In-House
On paper, a firm might imagine hiring “one crypto person” and wiring them into existing systems. In practice, even a modest in-house build-out typically requires:
- Infrastructure & Custody
Selecting and onboarding a qualified crypto custodian that meets SEC expectations under the Custody Rule or proposed Safeguarding Rule.
Designing workflows for:- Account opening and KYC/AML
- Address whitelisting and withdrawal controls
- Multi-signature policies and key-access rules
- Integrating the custodian’s API into your portfolio accounting and reporting (PMR) system so that positions, prices, and transactions reconcile correctly.
- Typical hard costs: Custody integration fees, consulting, and development work can easily reach five figures before a single account is funded—especially if you must customize PMR or CRM systems around a new data model.
- Compliance & Risk
Your CCO and compliance team must:- Rewrite policies and procedures to reflect digital asset risk.
- Update Form ADV, CRS, and disclosures to address custody, conflicts, and risk.
- Coordinate audits related to the crypto custodian and on-chain activity.
- Train advisors on suitability, concentration limits, and communications around inherently volatile assets.
- Even without adding headcount, this represents dozens of hours of high-value CCO and legal time, plus potential ongoing costs for specialist compliance counsel with crypto experience.
- Operations & Reporting
Operational staff must now:- Reconcile on-chain transactions and fees (gas, staking rewards, protocol airdrops).
- Map new asset types, tickers, and pricing feeds into performance reports.
- Handle corporate actions that don’t look like traditional splits or dividends.
- If your team is already lean, absorbing this work can require at least one additional operations FTE or significant overtime.
- Talent & Specialization
Digital assets are still a specialized domain. To do this credibly in-house, many firms feel compelled to:- Hire or train a dedicated digital asset portfolio manager.
- Sponsor certifications in blockchain and digital assets for advisors and compliance (e.g., DACFP CBDA).
- Between salary, benefits, training, and opportunity cost, it is easy for total soft and hard costs to exceed $100,000 in year one for a mid-size firm—before your firm has earned a sustainable fee stream on those assets.
Why Many RIAs Are Turning to Specialist Sub-Advisers
Given those realities, it is not surprising that a growing number of RIAs are partnering with specialist digital asset sub-advisers rather than trying to become crypto firms themselves.
The logic is straightforward:
- You retain the client relationship and the holistic planning role.
- A specialist sub-adviser handles the digital asset research, portfolio construction, trading, and operational complexity.
- Your firm gains a new capability without adding a new business line.
Keychain Asset Management’s Keychain Access platform is built around exactly this model: a turnkey, fiduciary-aligned sub-advisory solution for the digital asset sleeve of your clients’ portfolios.
How the Keychain Access Sub-Advisory Model Works
At a high level, the sub-advisory relationship is straightforward:
- You remain the primary adviser. You manage the broader financial plan, traditional portfolios, and the client relationship.
- Keychain becomes the digital asset specialist. Via a sub-advisory agreement, the digital asset sleeve is delegated to Keychain, which manages day-to-day investment decisions, trading, and strategy implementation in line with your firm’s risk preferences and client objectives.
- A qualified institutional custodian holds the assets. Digital assets are custodied with institutional-grade providers, typically in cold storage, aligning with emerging expectations under the SEC’s custody and safeguarding framework.
- Data flows back into your PMR and reporting stack. Trade, position, and performance data is integrated into your existing reporting system, so digital assets appear alongside traditional assets in household-level reporting.
In practical terms, this structure converts what would have been a capital-intensive build-out into a variable, revenue-linked cost.
Turning Operational Expense Into a Scalable Revenue Line
For most RIAs, the digital asset opportunity is not just about adding a new asset class; it’s about solving three business problems:
- Retaining next-generation clients. Younger investors, especially those receiving inheritances, show a higher affinity for crypto and expect their advisor to have a point of view.
- Consolidating held-away assets. Many clients already own crypto in self-custodied wallets or on exchanges. A compliant, institutional-grade solution gives you a way to bring some of those assets under your fiduciary umbrella and into your AUM.
- Differentiating in a crowded RIA market. A disciplined digital asset capability—integrated into planning and risk management—can be a meaningful competitive edge without turning your firm into a trading shop.
Because Keychain Access is delivered as a turnkey, white-labeled solution, your advisors can talk to clients about digital assets within a familiar framework—risk profiling, allocation sizing, and long-term planning—while the complexity of custody, trading, and security is handled behind the scenes.
A Practical Implementation Timeline
To make this more concrete, consider a typical mid-size RIA that decides to partner rather than build:
- Month 1: Governance & Setup
- Update IMA language to include a digital asset sub-advised sleeve.
- Execute the sub-advisory agreement with Keychain.
- Add disclosures to ADV and CRS.
- Month 1–2: Integration & Training
- Enable the custodial relationship for digital assets.
- Map data feeds into the PMR.
- Train advisors on positioning, suitability, and client conversation frameworks.
- Month 3–4: Initial roll-out
- Identify existing clients with held-away crypto or high interest in digital assets.
- Implement model portfolios for early adopters.
- Begin including digital assets in review meetings where appropriate.
- Month 5+ : Scale & Optimize
- Track adoption, AUM growth in digital sleeves, and retention metrics.
- Refine internal playbooks based on real-world client interactions.
Compared to a full in-house build, this approach focuses your leadership team on governance and client strategy, rather than infrastructure and technical integration.
Questions Every RIA Should Ask a Digital Asset Partner
Even if you are still exploring options, it can be useful to have a due-diligence framework. Key questions to ask any digital asset sub-adviser include:
- Custody & Security
- Which qualified custodians do you use?
- Are assets held in segregated accounts and cold storage?
- How do you handle key management, withdrawal controls, and incident response?
- Compliance & Fiduciary Alignment
- How is the sub-advisory relationship documented and supervised?
- How do you ensure strategies are suitable and fit within each client’s IPS?
- How do you support updates to ADV, CRS, and other disclosures?
- Operations & Reporting
- How do you integrate with our existing PMR/CRM systems?
- How will our team see positions, transactions, and performance alongside traditional assets?
- Investment Process
- What is your framework for asset selection (e.g., Bitcoin-only, majors, broader digital assets)?
- How do you think about risk, position sizing, and rebalancing?
- Education & Support
- What materials, training, and ongoing insights do you provide to our advisors and clients?
Keychain’s sub-advisory model is built with these questions in mind, but the framework is deliberately general: it’s the same checklist you can use to evaluate any potential partner in this space.
Conclusion: Own the Relationship, Delegate the Complexity
Digital assets no longer sit on the fringe of client conversations. They’re increasingly part of the core dialogue around diversification, inflation, monetary policy, and long-term growth.
For RIAs, the strategic decision is not whether crypto exists—it’s how you want to manage it:
- Rebuild your firm to become a digital asset specialist, or
- Partner with a specialist so you can stay focused on planning, relationships, and holistic portfolio design.
A turnkey sub-advisory approach like Keychain Access is designed to let you do the latter: retain the relationship, expand your capabilities, and avoid taking on unnecessary operational and regulatory risk.
If your firm is evaluating digital assets as a business initiative, the next step is not a technology sprint. It’s a governance, risk, and partner-selection conversation.
And that’s a conversation worth having before your clients decide to have it with someone else.
About the Author
Brent Pearson is the Principal, Chief Compliance Officer, and Investment Adviser Representative at Keychain Asset Management. With over a decade of hands‑on experience in the cryptocurrency market and a background in FinTech software development, Brent brings a rare combination of technological acumen and financial insight to his work. He is the author of ‘Understanding Bitcoin and Protecting Your Assets with Crypto: How to Secure Your Wealth in Any Financial Climate‘, reflecting his deep commitment to educating and empowering investors. Brent founded Keychain Asset Management to bridge the gap between traditional wealth management and the evolving digital economy, and he upholds a fiduciary standard to ensure every piece of advice is unbiased and in the client’s best interest.
