Vanguard crossed the operational line in December 2025 when it opened brokerage access to third-party crypto ETFs; this hire is the risk stack catching up with distribution. A Vanguard-branded BTC fund is still the wrong bet until an SEC filing appears, but model-portfolio access, custody diligence, and tokenized-cash plumbing are now the pressure points because BlackRock has IBIT above $66B and BUIDL around $2.8B.

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