Dear Secretary, I am writing to submit a public comment regarding the proposed rule "Safeguarding Advisory Client Assets" by the Securities and Exchange Commission (SEC). This rule aims to enhance investor protections and address gaps in the custody rule. I have several concerns and issues regarding the proposed rule that I would like to bring to your attention. Firstly, I would like to address the unequal treatment of different types of digital assets. The SEC's proposed rules treat different types of digital assets inconsistently, leading to confusion and potential regulatory arbitrage. Digital assets, such as cryptocurrencies, have emerged as transformative instruments in the field of finance. However, due to regulatory uncertainties surrounding these assets, investors and advisers alike are uncertain about how to navigate the landscape effectively. The proposed rule fails to provide clear guidance on classifying and safeguarding different types of digital assets, which can result in the misapplication of regulatory requirements and hinder market growth and innovation. Furthermore, the proposed rule should seek to strike a balance between investor protections and the promotion of innovation in the digital asset space. While it is crucial to prioritize investor protection and minimize the risk of asset loss, overly burdensome or inconsistent regulations can stifle innovation and hinder the growth of the industry. Instead, the SEC should work towards developing comprehensive guidelines that address the unique characteristics and risks associated with digital assets, ensuring that investor protections are in place while encouraging continued innovation and market development. In addition to the issues surrounding digital assets, I have concerns regarding the economic analysis conducted by the SEC. While the SEC acknowledges the challenge of estimating economic effects due to varying practices among investment advisers, it is essential to thoroughly assess the potential benefits and costs of the proposed rule. Transparency in conducting economic analysis is vital to ensuring that the rule's impact on investment advisers, investors, and the overall market is adequately assessed. Furthermore, the SEC should consider the potential impact of the proposed rule on small entities. Investment advisers, particularly smaller firms, may face significant compliance burdens and costs. It is crucial to strike a balance between enhancing investor protections and minimizing the regulatory burdens on smaller entities. The SEC should actively seek feedback from small entities and consider potential alternatives to alleviate any undue compliance burden. Lastly, I would like to commend the SEC's efforts in enhancing client and investor protections. It is essential to address conflicts of interest between investment advisers and clients, promoting transparency, and facilitating oversight and verification of adviser conduct. However, to ensure the successful implementation of the proposed rule, I urge the SEC to provide additional clarity, especially in the rapidly evolving landscape of digital assets. Thank you for considering my comments regarding the proposed rule "Safeguarding Advisory Client Assets." I appreciate the opportunity to contribute to the public consultation process. Should you have any further questions or require additional information, please do not hesitate to contact me. Sincerely, Philip Zeisler