Subject: File No. S7-04-23
From: Adam Chalmers

As an individual deeply involved in the cryptocurrency and digital asset space, I am deeply concerned about the proposed legislation by the SEC regarding the safeguarding of advisory client assets. While I understand the need for regulatory oversight in this rapidly evolving industry, I believe that the SEC's approach in this particular proposal is an overreach that could stifle innovation and hinder the growth of this promising sector. First and foremost, it is important to note that existing laws already provide a framework for the regulation of digital assets. The SEC has the authority to regulate securities, and it has been actively doing so in the cryptocurrency space. However, the proposed legislation goes beyond the scope of securities regulation and seeks to impose burdensome requirements on all digital asset transactions, regardless of whether they involve securities or not. This is a clear overreach of the SEC's authority and undermines the principles of regulatory proportionality. Furthermore, the proposed legislation fails to take into account the unique characteristics of digital assets. Unlike traditional financial instruments, digital assets are decentralized and operate on blockchain technology. They are designed to be secure and resistant to fraud. Imposing stringent custody requirements on digital asset transactions would not only be impractical but also unnecessary. Existing laws, such as the Electronic Signatures in Global and National Commerce