Regulations on Cryptocurrency in the Mortgage Sector Should Acknowledge the Reality of Self-Custody

The Federal Housing Finance Agency's new directive to include cryptocurrency in mortgage risk assessments signals a significant shift in the integration of digital assets into mainstream finance, potentially allowing crypto investors to secure mortgages using their digital holdings without liquidation. This move underscores the need for regulatory frameworks that accurately reflect the nuances of cryptocurrency operations, particularly self-custody practices, to ensure both consumer protection and the encouragement of innovation in financial technology.

Arjun Renapurkar

July 19, 2025

The Federal Housing Finance Agency's (FHFA) directive to incorporate cryptocurrency into mortgage risk assessments marks a pivotal shift toward recognizing digital assets in traditional finance. This move could enable long-term crypto holders to leverage their investments in securing mortgages, potentially without needing to liquidate their holdings first. The critical challenge now is crafting regulations that genuinely reflect the operational realities of cryptocurrency, especially the practice of self-custody.

Contrary to some interpretations of the directive, which suggest that only crypto stored on U.S.-regulated exchanges would count towards mortgage eligibility, the actual language of the directive merely emphasizes the capability for such assets to be stored and verified through regulated channels. It does not, as some fear, mandate custody on these platforms exclusively. In fact, as the CoinTelegraph discusses, a nuanced understanding here is crucial to avoid misguided regulatory measures that could stifle innovation.

The practice of self-custody, where individuals control their crypto wallets without an intermediary, represents a foundational principle of the blockchain ethos-decentralization and security. Self-custodied assets, if properly documented, can offer superior security, transparency, and auditability than those held by centralized entities. The historical failures and collapses of some major centralized exchanges underscore the risks of counterparty exposure - risks mitigated by the self-custody model.

A regulatory framework that acknowledges the legitimacy of both custodial and self-custodial crypto holdings, subject to verifiability and liquidity requirements, seems most prudent. Such a framework should also involve valuation discounts to account for the inherent volatility in cryptocurrency markets, similar to how more volatile assets like stocks or foreign currencies are treated. The recent significant movements in the Bitcoin market underscore the importance of having robust mechanisms to assess and manage these kinds of risks.

Moreover, the current dialogue around crypto in mortgage applications is emblematic of a broader requirement for more sophisticated regulatory approaches to emerging financial technologies. Future regulations should avoid forcing innovative models to conform to outdated frameworks merely to facilitate understanding among regulators. Instead, the focus should be on enhancing the technical understanding of decentralized technologies among policymakers.

The path forward for integrating cryptocurrency into traditional sectors like housing finance is not just about accommodating a new asset class but about fostering a regulatory environment that can adapt to and harness the potential of technological advancements. By crafting policies that respect the unique characteristics of decentralized technologies, regulators can both protect consumers and encourage innovation, ensuring that the evolution of finance continues to align with the evolving capacities of technology.

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