Subject: File No. S7-04-23
From: Jim Gio

Chatbot Dear Securities and Exchange Commission, I am writing to provide a public comment on the proposed rule "Safeguarding Advisory Client Assets" (File Number S7-10-17), which aims to enhance investor protections and address gaps in the custody rule. While I appreciate the SEC's commitment to ensuring the safeguarding of client assets, I have certain concerns regarding the proposed rule. First and foremost, I find that the proposal fails to adequately consider the unique characteristics and challenges associated with smart contracts. Smart contracts present a novel method of executing and automating transactions, and their inclusion in the investment advisory industry cannot be overlooked. However, the proposal does not address the regulatory challenges and potential legal uncertainties surrounding smart contracts. It is crucial for the SEC to provide clear guidelines and regulations specifically tailored to smart contracts to ensure investor protection and legal certainty in this developing field. Furthermore, I would like to express my concerns regarding the impact of the proposed reporting requirements on small businesses. The additional burden and costs associated with implementing these reporting requirements will disproportionately affect small businesses and start-ups that may not otherwise be required to track personally identifiable information. This could create a significant disadvantage for these businesses and potentially stifle innovation in the advisory industry. It is essential for the SEC to carefully consider the economic impact on small entities and explore alternatives that minimize the compliance burden while still achieving the overarching goal of investor protection. I believe it is essential to strike the right balance between safeguarding client assets and allowing for innovation and growth within the investment advisory industry. While I commend the SEC's efforts to enhance investor protections, I urge the Commission to consider the potential unintended consequences, especially on small businesses and start-ups. It is crucial for the SEC to foster an environment that encourages innovation and entrepreneurial endeavors, particularly in a rapidly evolving industry like investment advisory. I appreciate the opportunity to provide my input on the proposed rule, and I strongly encourage the SEC to carefully consider these concerns. By striking the right balance and addressing the issues that have been raised, the Commission can ensure a regulatory framework that enhances investor protection while promoting innovation and growth within the industry. Thank you for your attention to this matter. Sincerely, Jim Gio