Trust & Custody Services — impact tolerance ≤ 1 business day — ITOL

Impact tolerance: ≤ 1 business day — any missed scheduled distribution, corporate-action deadline, or DTCC settlement obligation. Year-end carve-out: in late December, queued required-minimum-distribution (RMD) payments harden the clock — a distribution missed past December 31 becomes the beneficiary's tax problem (IRC 401(a)(9), 4974) (illustrative default — trace the derivation, then replace with your own harm analysis)

Definition: Fiduciary account administration, custody of client securities, corporate-trust services, and periodic income/principal distributions. Digital-asset custody is out of scope for the base archetype. The crypto-custody scenario applies only if the bank adds that optional line (OCC IL 1170/1184; the Fed's SR 22-6 notification expectation was rescinded April 2025).

Why it is designated: Fiduciary duties impose legal standards of care distinct from other banking services — for a national bank they are codified at 12 CFR pt. 9. Missed corporate actions (elections, redemptions) can cause direct measurable client harm. A missed corporate-trust distribution exposes the bank to indenture-trustee liability.