Morgan Stanley’s amended SEC registration for its proposed spot Bitcoin ETF now names Bank of New York Mellon as cash custodian and both BNY Mellon and Coinbase Custody Trust Company as bitcoin custodians, according to an updated S-1/A filing dated March 4, 2026.
Morgan Stanley’s amended filing names BNY and Coinbase for custody
The amended Form S-1 for the Morgan Stanley Bitcoin Trust, filed with the SEC on March 4, 2026, lays out a dual-custodian structure for the proposed fund. BNY Mellon and Coinbase Custody Trust Company will serve as the trust’s bitcoin custodians, while BNY separately handles custody of cash and cash equivalents.
The distinction matters. Cash custody covers fiat held during share creation and redemption, while bitcoin custody involves securing the actual BTC holdings that back the fund’s shares. Splitting those roles across two established custodians mirrors a pattern seen in other institutional Bitcoin products already trading in the U.S.
Morgan Stanley originally filed its S-1 registration statement on January 6, 2026. The March 4 amendment updated the trust’s operational infrastructure, including the custodian disclosures that signal the firm is actively building out the product’s back-end requirements.
Why the custodian setup matters for ETF approval
For a new U.S. spot Bitcoin ETF to reach market, the issuer must clear two regulatory gates: the Securities Act registration statement (the S-1) must become effective, and the exchange where shares will trade must receive separate SEC action on a Rule 19b-4 proposal. Naming custodians is a core part of the first gate.
Custodian disclosure tells the SEC who holds investor assets and under what safeguards. Without credible, regulated custodians, a registration statement is unlikely to advance. BNY Mellon, the world’s largest custodian bank, and Coinbase Custody, already used by multiple approved spot Bitcoin ETF issuers, represent an institutional-grade pairing.
Amy Oldenburg, speaking in the context of Morgan Stanley’s broader crypto ambitions, said the firm would “absolutely” offer Bitcoin custody, trading, yield, and lending services in time. The amended filing aligns with that trajectory, positioning Morgan Stanley alongside asset managers that have already secured spot crypto product approvals.
SEC approval remains pending
Despite the updated filing, the Morgan Stanley Bitcoin Trust has not been approved for trading. No SEC order greenlighting an exchange listing for the fund’s shares has been published as of the filing date.
Some early coverage characterized the March 4 document as a “second amendment” to the registration. However, the SEC record shows the original S-1 filed on January 6, 2026, and one subsequent S-1/A on March 4. No additional amended filing has been confirmed beyond that single amendment.
What remains ahead: the S-1 must become effective, which typically requires SEC staff review and possible additional amendments. Separately, the exchange seeking to list the shares must file and receive approval on its own 19b-4 rule change proposal. Neither milestone has been reached based on the public record.
Disclaimer: This article is for informational purposes only and does not constitute financial or investment advice. Cryptocurrency and digital asset markets carry significant risk. Always do your own research before making decisions.
