Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Safeguarding Advisory Client Assets - File Number S7-09-12 Dear Sir/Madam, I am writing to provide a public comment on the proposed rule published by the Securities and Exchange Commission (SEC) regarding the safeguarding of advisory client assets. While I appreciate the SEC's dedication to enhancing investor protections and addressing gaps in the custody rule, I have concerns regarding certain aspects of the proposed rule that I believe may have adverse effects on the competitiveness of US companies and impact abroad. Firstly, I am concerned that the proposed rules may put US companies at a competitive disadvantage compared to their international counterparts, potentially leading to capital flight and a loss of market share. The proposed expansions in the coverage of assets held in a client's account, and the inclusion of discretionary authority in custody, could create an additional regulatory burden for US companies. These requirements may not be imposed on international advisory firms, resulting in an uneven playing field. Furthermore, the proposed regulations do not sufficiently limit reporting requirements for protocols run outside the US and for users outside the US. This lack of regulation may create loopholes that could be exploited by unscrupulous individuals or entities, potentially jeopardizing the integrity of the market. It is essential for the SEC to clarify and strengthen these reporting requirements to ensure consistent oversight and protection for all investors, both domestic and international. In considering the potential negative impact on the competitiveness of US companies and the need for global oversight, it is crucial to strike a balance that allows for effective investor protection while not unduly burdening domestic firms and deterring foreign investments. I would also like to offer a general question regarding the proposal. Will the SEC provide further guidance on how it plans to harmonize these proposed regulations with existing rules and regulations at the international level? Harmonization is crucial to maintain a level playing field for US advisory firms in a global market, and I believe clarity on this issue would be beneficial for both the industry and investors. In conclusion, while I commend the SEC's efforts to enhance investor protections under the proposed safeguarding rule for advisory client assets, I urge the commission to carefully consider the potential negative impact on US companies' competitiveness, as well as the need for coherence in global oversight. It is essential to strike a balance between robust investor protections and regulations that do not hinder the growth and global competitiveness of the US advisory industry. Thank you for considering my comment. I appreciate the commission's commitment to public input and your attention to these concerns. Sincerely