"gaming out" is just casting a wide net to gain interested parties. You find out about the limitations afterwards. That did happen to me with the IRA. I assumed that a company that really stresses "not your keys, not your coin" would understand I'd want to hold the keys for the IRA (which would tend to be the larger sum since it is retirement funds).

I grudgingly understand why they do not allow it - because of the McNulty case and a lack of "regulatory clarity" (did I sound like an exchange, there). But I feel multi-sig makes it a whole new animal since that 3rd key holder (Swan, in this case) would know when the coin moved...thus becoming a potential taxable event unless moving to another qualified retirement plan.

And Swan *does* now support the Checkbook IRA setup - meaning, they will get you setup to take custody, but they tell you the risk and then leave it to you should the IRS come a'calllin' for capital gains and early withdrawal penalties.