Class M, O, R, I, S explained in plain English
Class M is generally used for a broker-dealer style model in virtual assets. In practice, this is often relevant for an OTC desk, dealing service, or intermediary that buys, sells, or arranges transactions in virtual assets. The key regulatory question is whether the firm is acting as principal, agent, or both, and how conflicts, pricing, and best execution-type issues are managed.
Class O covers wallet services. This is typically relevant where the provider offers hosted or administered wallet functionality and retains a meaningful control layer over transfers, access, or user asset administration. The legal analysis becomes more complex if the product markets itself as non-custodial but still controls transaction routing, recovery, whitelisting, or policy enforcement.
Class R is the custodian class. It is usually the right starting point where the business controls private keys or otherwise safeguards client virtual assets. Custody applicants should expect deeper scrutiny of segregation, reconciliation, key management, insolvency treatment, and incident response than almost any other class.
Class I covers advisory services. This may fit research, strategy, and investment recommendation models focused on virtual assets. The main boundary issue is whether the firm remains advisory-only or also crosses into arranging, dealing, placement, or token sale intermediation.
Class S is the virtual asset marketplace class. This is the most obvious fit for an exchange or platform operating an order book, matching engine, or other marketplace logic. It usually requires the strongest governance around market integrity, surveillance, system resilience, and operational continuity.
A useful founder test is simple: if your product can hold, move, match, or advise on client virtual assets, you should map each function separately before choosing the license class.