Mr. Charles Curtis Secretary Securities and Exchange Commission 100 F Street NE Washington, DC 20549 Subject: Public Comment on Safeguarding Advisory Client Assets Proposal Dear Mr. Curtis, I am writing to submit a public comment on the proposed rule "Safeguarding Advisory Client Assets" from the Securities and Exchange Commission (SEC). This rule aims to enhance investor protections and address gaps in the custody rule. While I understand the importance of safeguarding client assets, I have concerns regarding the inadequate consideration of the unique properties of cryptocurrency. As the world shifts towards a digital era, digital assets like cryptocurrencies have emerged as a transformative force in the financial industry. Blockchain technology, the backbone of cryptocurrencies, has brought forth unprecedented opportunities for efficiency, transparency, and security. However, it is essential to adapt regulatory frameworks to these emerging technologies, and the current proposal fails to do so. One specific area of concern is the requirement for an independent public accountant to perform surprise examinations for advisers with custody of client assets. This approach reflects pre-blockchain thinking and does not take into account the decentralized nature and technological complexities of cryptocurrency. The proposal should recognize that the immutability and cryptographic assertions of blockchain technology eliminate the need for human involvement in verification processes. Instead of relying on traditional accountants, the SEC should explore the use of provable software programs utilizing immutable blockchain records as an alternative solution. These programs, based on cryptographic algorithms, can provide indisputable evidence of asset custody and reduce the risk of errors or potential biases that may arise with human involvement. By embracing these new technological advancements, the SEC can enhance investor protection while promoting efficiency and accuracy in safeguarding client assets. Furthermore, the proposed rule fails to address the specific requirements and challenges faced in the custody and compliance of digital assets. Cryptocurrency custody involves unique considerations, such as private key management and secure storage protocols. A comprehensive approach should be taken to define clear requirements for record-keeping and compliance that leverage the primitives of blockchain technology. While custodians may still be necessary in certain cases, it is crucial to distinguish between custodial arrangements and transactions carried out on the blockchain. By acknowledging and adapting to the nuances of digital asset custody, the SEC can ensure that its regulatory framework aligns with the technological advancements and intricacies of digital transactions. In conclusion, I implore the SEC to reflect on the missed opportunity presented by the current proposal for "Safeguarding Advisory Client Assets." Failure to consider and leverage the unique properties of cryptocurrency and blockchain technology would result in a limited approach that may hinder innovation and the development of robust safeguards. Let us seize this crucial moment to embrace the power of decentralized ledgers and provable software programs to enhance investor protection and transform the landscape of asset safeguarding. Thank you for considering my comments on this matter. I appreciate the opportunity to express my concerns and contribute to the discussion on safeguarding advisory client assets. If there are any additional areas of concern you would like me to address or if there are any questions about the proposal I could assist with, please let me know. Sincerely, Frank Mettle