Subject: File No. S7-04-23
From: Derek Blaakman

Dear Securities and Exchange Commission, I am writing to express my concern regarding the proposed rule "Safeguarding Advisory Client Assets" (REG-122793-19). While I acknowledge the SEC's intention to enhance investor protections and address gaps in the custody rule, I have a different perspective on the potential impact this rule could have on local investments. Contrary to the concerns raised by some, I believe that the proposed rule would actually enhance the protection of local investments. By expanding the coverage to include a broader range of investments held in a client's account, the proposed rule ensures that investment advisers are held accountable for the proper custody and safeguarding of these assets. This is especially important in today's rapidly evolving investment landscape, where new and diverse assets are increasingly being offered to clients. Furthermore, the proposed rule's emphasis on requiring qualified custodians to provide protections for client assets, including crypto assets, is a necessary step towards establishing a secure framework for these emerging investment vehicles. It is crucial to ensure that investors have confidence in the custody arrangements for these assets, and the proposed rule provides clarity and accountability in this regard. While it is true that the amendments to the surprise examination requirement may result in increased compliance costs for investment advisers, I believe that this is a small price to pay for the enhanced investor protection it provides. The examination requirement serves as an important safeguard against potential misappropriation or misuse of client assets, and the benefits of this assurance outweigh the associated costs. Additionally, the changes to Form ADV and the associated paperwork requirements may initially seem burdensome for investment advisers. However, these changes are necessary to enhance transparency and provide regulators with the information they need to effectively oversee the industry. The long-term benefits of improved regulatory oversight and investor confidence far outweigh any short-term inconvenience or cost. In conclusion, I support the proposed rule and believe that it strikes the right balance between investor protection and regulatory burden. By ensuring proper custody and safeguarding of client assets, the proposed rule enhances the integrity of the investment advisory industry and protects the interests of investors, including those with local investments. It is my belief that the potential benefits of this rule far outweigh any potential negative consequences. Thank you for considering my viewpoint and for providing the opportunity to express my views on this important matter. Sincerely, Derek Blaakman