Subject: File No. S7-04-23
From: Brad Federer

Dear Sir/Madam, I am writing to provide my public comment on the proposed rule "Safeguarding Advisory Client Assets" from the Securities and Exchange Commission (SEC). As an investor and concerned citizen, I believe that the proposed rule has notable gaps and inadequacies that need to be addressed in order to truly enhance investor protections and safeguard client assets. Absence of Regulatory Clarity for Security Tokens: One of the glaring issues with the proposed rule is the lack of clear regulatory guidelines for security tokens. Given the increasing prominence of digital assets in the investment landscape, it is imperative that the SEC provides explicit directives on how investment advisers should handle and safeguard these assets. Failure to do so creates ambiguity and puts investors at risk. Security tokens, being digital representations of traditional assets, require robust custodial measures to protect investor holdings. Unfortunately, the proposed rule does not adequately address the unique considerations and challenges associated with security tokens. By neglecting to provide clear regulatory clarity, the SEC not only hampers innovation, but it also exposes investors to potential vulnerabilities and fraud. In order to ensure investor protection and promote confidence in the emerging digital asset market, the SEC should collaborate with relevant stakeholders to establish comprehensive guidelines specifically tailored to security tokens. These guidelines should address custody, recordkeeping, and compliance requirements while taking into account the nuances associated with the use of blockchain technology. I urge the SEC to revise the proposed rule to explicitly account for security tokens and provide clear and comprehensive guidelines that safeguard investor assets in this emerging asset class. Furthermore, as it stands today, the regulatory uncertainty surrounding security tokens creates a chilling effect on innovation and investment. Without clarity on how investment advisers can safely and compliantly handle these assets, potential market participants are deterred from entering the space, leading to a suboptimal allocation of capital and an impediment to economic growth. I implore the SEC to promptly address this issue by providing the needed regulatory stability for security tokens. The Securities Act of 1933 and the Securities Exchange Act of 1934 have long served as cornerstones of investor protection. It is essential that these laws are updated and expanded to account for advancements in technology, such as security tokens, to ensure that the scope of investor protections remains robust. I thank the SEC for considering my comments and respectfully request that the proposed rule be amended to address the concern raised regarding security tokens. By providing regulatory clarity and comprehensive guidelines, the SEC can effectively enhance investor protection and enable the growth and development of this nascent asset class. Should you require further information or clarification on any of the mentioned points, please do not hesitate to reach out to me. I appreciate your attention to this matter and look forward to the SEC's continued commitment to investor protection and regulatory improvement. Sincerely, Brad Federer