I think I get your point at the autistic level but doesn't that leave a vagueness to the definition of custodial?
Wouldn't giving my money to Tom to hold for me be a riskier endeavor than giving it to a local board that now has reputational risk spread across it's members? Maybe Tom is a dick but probabilistically wouldn't there be a lower chance that the consensus of Tom, Peter, Frank, George and Lisa are all dicks since it increases the total reputation on the line across all members?