The Adviser’s Brief
Welcome {{first_name | fellow crypto curious and trusted fiduciary}}!
March brought a defining test for cryptoasset markets and the advisers navigating them. Bitcoin consolidated in the high $60K to $70K range after retracing roughly 50% from its late 2025 peak, while altcoin markets continued their prolonged distribution phase. The macro backdrop, including tariff volatility, rate uncertainty, and risk off episodes across traditional markets, reinforced a theme we flagged last month. The assets that survive this cycle will be the ones with institutional infrastructure, not speculative narratives.
For fiduciaries, March was less about price and more about plumbing. Gemini delayed 1099 DA delivery, creating a tax season gap that advisers must navigate. Kraken advanced its institutional custody positioning. The regulatory picture also continued to evolve at both the federal and state level. The advisers who are building operational processes now, including custody documentation, tax workflow automation, and compliance manual updates, are the ones who will be positioned when capital rotates back.
STRATEGIC PERSPECTIVE
The tokenization land grab we described last month is accelerating, but a parallel shift deserves equal attention. The emergence of AI agents as autonomous financial operators.
This month, the World Economic Forum published guidance on AI agent governance, explicitly acknowledging that agentic AI systems, those capable of planning tasks, accessing tools, and executing across digital environments, create new categories of risk that existing frameworks do not address. For wealth management, this is not theoretical. Altruist's Hazel is live. Autonomous portfolio rebalancing tools are in production. AI agents are monitoring wallets, interpreting flows, and executing tax loss harvesting strategies without human intervention.
The compliance question is no longer "should advisers use AI?" but "when an AI agent executes a trade at 2 AM on behalf of a client, who documents the fiduciary rationale?" Every autonomous transaction still creates a tax event, requires cost basis tracking, and must fit within an auditable ownership chain. The infrastructure layer that answers these questions, identity, cost basis, lot accounting, and tax implications, is what separates compliant agentic finance from unauditable automation.
Kraken's institutional push this month reinforced another theme. Exchanges are racing to become the custody standard for advisers. Our deep technical review of Kraken's API uncovered 14 significant limitations that matter specifically to fiduciaries, including no historical price endpoint, trade duplication across endpoints, and no USD value on ledger entries. These are not edge cases. They are the gaps that produce incorrect Form 8949s. We are working directly with Kraken's partnership team to address the ones that matter most to advisers.
MARKET PULSE
Form 1099 DA: First Filing Season Underway
The February 17 delivery deadline has passed, and the first real world test of 1099 DA compliance is now in progress. Gemini notably delayed delivery, creating reconciliation challenges for advisers whose clients hold assets on the platform. If your clients use Gemini, proactively verify that 1099 DA forms have been received and cross reference against internal transaction records. CP2000 notices from the IRS will be system generated where mismatches exist.
State Level Licensing Continues to Expand
California's DFAL enforcement deadline approaches mid 2026. Multi state advisory practices should audit whether any service providers in their cryptoasset workflow, including custodians, data aggregators, and tax software providers, require state level licensing in jurisdictions where clients reside.
AI Agent Governance Emerging
The WEF's March guidance on AI agent governance signals that regulators are beginning to think about autonomous financial systems as a distinct category. While no specific rules have been proposed, the framing around accountability, auditability, and oversight of autonomous decision making aligns directly with fiduciary obligations advisers already carry.
ADVISER PLAYBOOK
Tax Season Triage: What to Do Right Now
With 1099 DA forms hitting mailboxes, or not in Gemini's case, here is the immediate action list:
Verify delivery. Confirm every client has received 1099 DAs from every exchange and custodian they used in 2025. Do not assume delivery happened.
Cross reference against internal records. 1099 DA proceeds should match your transaction records. Common discrepancies include staking rewards classified differently, forks and airdrops omitted, and transfers between wallets misreported as sales.
Document cost basis methodology. FIFO, LIFO, or specific identification. Ensure your methodology is documented in writing and consistently applied. The IRS does not care which method you use. They care that you can defend it.
Flag zero basis transactions. Some exchanges report sales without cost basis, particularly for assets transferred in from external wallets. These will appear to the IRS as 100 percent gain unless corrected.
Prepare for CP2000 notices. If a client's tax return does not match the 1099 DA, expect an automated notice. Build a response workflow now rather than scrambling later.
QEYS TO ADVISER SUCCESS
Audit Your AI Tool Governance
If your firm uses AI tools for client work such as portfolio analysis, tax optimization, research, communication you need to document the governance framework. Which tools are approved? What data can they access? How are outputs verified before client delivery? Regulators haven't written specific rules yet, but they will, and the firms with documented processes will be ahead.
Prepare for Kraken Institutional Custody
Kraken is actively positioning as an institutional-grade custodian. If it's on your shortlist, start the operational due diligence now with API access, reconciliation workflows, reporting capabilities. Early movers will have smoother integrations.
Review Your Technology Stack for SOC 2 Readiness
Whether you're a solo RIA or a multi-adviser firm, the technology providers in your stack should be moving toward SOC 2 certification. Ask the question. Document the answers. This is becoming table stakes for institutional credibility.
PRODUCT WATCH
TAIP™, Qeychain™, and Turnqey Institute™ launched on February 19th and have been live for nearly a month. Here's what's been shipped since:
TAIP- Kraken exchange integration now fully live alongside Coinbase and Gemini. Unified cross-exchange MWRR/TWRR performance reporting means clients with assets across multiple custodians now get a single, accurate performance calculation. Robinhood integration is in testing. Holdings tab now displays exchange provider labels per asset.
Qeychain - exchange segregation added to the holdings section, showing which exchange each asset belongs to. Server-side transaction filtering with spam detection deployed. 10 users, 18 wallets tracked, over 16,000 transactions processed.
Turnqey Institute is platform stable with continuous education content for advisers. Market regime monitoring and fiduciary posture recommendations active.
Interested in a demo? Visit our website.
Closing Thoughts
The firms that will thrive in this market aren't the ones chasing the next rally. They're the ones building the operational infrastructure, custody documentation, tax workflows, compliance processes, AI governance that makes cryptoasset integration defensible, auditable, and scalable. The market will turn. The question is whether your practice will be ready when it does.
Educate before you allocate. Make it Turnqey.
With gratitude,
The Turnqey Team
A pebble a day moves a mountain.
P.S. What topics should we cover next week? Reply to this email, we read every response.