Dear SEC, I am writing to offer my public comment on the proposed rule titled "Safeguarding Advisory Client Assets". As an investor and active participant in the crypto asset space, I would like to express my concerns regarding the insufficient consideration of token standards in the proposed rules. This oversight may hinder interoperability and asset portability, ultimately limiting the effectiveness of the rule in enhancing investor protections. The SEC's proposed rule aims to address gaps in the custody rule and enhance the safeguarding of client assets by investment advisers. While I acknowledge the importance of protecting investor interests, it is crucial to recognize the significant role that token standards play in the realm of crypto assets. Tokens are not mere traditional financial instruments; they represent unique digital assets with their own distinct properties, uses, and interoperability mechanisms. As the industry evolves, token standards, specifically those compliant with common interoperability protocols like ERC20 and ERC721, enable the seamless transfer and management of assets across different applications and platforms. These standards facilitate the efficient movement of tokens between user wallets, smart contracts, and decentralized exchanges. However, the proposed rule does not adequately consider these standards, potentially leading to unnecessary barriers and limitations. By disregarding token standards, the proposed rule risks stifling the innovation and the potential of digital assets by failing to recognize their underlying functionality and unique characteristics. This not only limits the ability of investment advisers to effectively safeguard client assets but also impedes investors' ability to exercise their ownership rights and transfer their assets in a manner that aligns with the evolving crypto ecosystem. To address this concern, I urge the SEC to consult and collaborate with industry experts and stakeholders in the development of the final rule. By actively engaging with the crypto asset community and considering token standards within the regulatory framework, the SEC can facilitate asset portability, interoperability, and effective safeguarding practices in this emerging space. Moreover, it is important to address the challenge of demonstrating exclusive control over crypto assets, as highlighted in the proposed rule. The unique nature of digital assets, such as cryptographic keys and multi-signature wallets, requires nuanced considerations when applying custody requirements. Efforts should be made to provide guidance that reflects the reality and complexity of managing crypto assets, while still ensuring the protection of investor funds. In conclusion, I urge the SEC to thoroughly evaluate the implications of the proposed rule on token standards and their potential impact on interoperability and asset portability. By collaborating with industry participants and seeking their insights, the SEC can strike a balance between safeguarding investor assets and facilitating innovation in the crypto asset ecosystem. I believe that a well-informed and inclusive approach will lead to a regulatory framework that not only enhances investor protections but also supports the growth and development of this transformative industry. Thank you for considering my comments. Sincerely, Brad Federer