Customer property must be treated as the customer's and shielded from creditors
What the document says“treat and deal with the payment stablecoins, private keys, cash, and other property of a person for whom or on whose behalf the person described in that subsection receives, acquires, or holds payment stablecoins, private keys, cash, and other property (hereinafter referred to in this section as the "customer") as belonging to such customer and not as the property of such person”
Subsection (b). Two duties run together: treat the property as the customer's rather than the custodian's, and take such steps as are appropriate to protect it from the claims of the custodian's creditors. The paragraph is where the section's use of the word customer is defined.
What the document actually says“treat and deal with the payment stablecoins, private keys, cash, and other property of a person for whom or on whose behalf the person described in that subsection receives, acquires, or holds payment stablecoins, private keys, cash, and other property (hereinafter referred to in this section as the "customer") as belonging to such customer and not as the property of such person”
What the firm holds belongs to the customer. The firm may not treat it as its own. That covers coins, keys, cash and more.
The firm must also guard those assets. If the firm owes money, its lenders should not reach them. Part 11 deals with a firm that fails.
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