A KEY from proposed changes to SEC Custody Rule: account must protect customer assets in event of custodian insolvency. This prob means qualified custodians must be under statutory receivership regime to protect segregation in insolvency & state-chartered trust cos in crosshairs 
Yep, here's more. Gensler was clear abt this in his prepared remarks & here it is in writing: Assets passing OUTSIDE OF THE BANK'S INSOLVENCY is key. Translation: SEC wants all qualified custodians to be subject to special receivership regime, ie not subject to US Bankruptcy Code
More: lookin' good so far for state-chartered special purpose depository institutions under statutory receivership regimes that keep assets outside of bank's estate (ie, #Wyoming SPDI banks). SEC asks for comment on whether to do away w/ dual banking system but doesn't propose it
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