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Custody-as-a-Service Is Becoming Financial Infrastructure
November 6, 2026

On October 6, 2026, Alto announced plans to acquire Forge Trust from Charles Schwab. The combined platform would hold more than $20 billion in assets under custody and administration, with over 60,000 self-directed IRA accounts holding private-market investments and more than 3 million Custody-as-a-Service accounts. The transaction is proposed, but the scale it describes is already informative. It shows how much of today’s investment activity rests on institutional custody infrastructure that most investors never see.

The development reflects a broader evolution in financial services. Investment platforms increasingly control product distribution, investor relationships, and digital experiences without necessarily performing every regulated function that supports the assets themselves. Custody, account administration, and fiduciary services can operate as specialized institutional capabilities integrated into those platforms.

This separation has important implications for how financial products are built. A platform may provide access to alternative investments, retirement accounts, or other financial assets, but the legal and operational responsibilities associated with holding those assets require an appropriate institutional structure. Access is a product decision. Holding, segregating, recording, and administering the assets is a regulated one. Integrating custody into the platform’s operating model lets product development and distribution remain distinct from the regulated functions of safeguarding and administration.

For platforms building on custody infrastructure, a few questions define whether the structure is sound:

  • Who holds the assets, and in what legal capacity
  • How client assets are segregated from the platform’s own funds and from one another
  • Who maintains the independent record of ownership for each account
  • How account administration is handled for each asset type, including alternatives and retirement accounts
  • Where fiduciary responsibility sits across the platform and the institution

At the scale this transaction illustrates, those answers are no longer internal details. Tens of thousands of retirement accounts holding private-market assets, and millions of accounts served through third-party platforms, depend every day on the custodian’s records, controls, and fiduciary standards, whether or not the investor ever sees them.

This is the role ACTC’s regulated trust infrastructure plays. ACTC provides custody, account segregation, independent recordkeeping, and fiduciary services that allow financial platforms to incorporate institutional asset administration into their offerings without establishing every regulated function internally. The platform keeps control of its technology, products, and distribution. The regulated functions sit with an institution built to perform them.

As financial services become more embedded in digital platforms, custody is increasingly becoming part of the infrastructure that enables those products to exist, rather than a service arranged after distribution. For platforms moving into alternatives and retirement, that points to a practical conclusion: the custody structure is best decided when the product is designed, not after it has reached customers.