Subject: File No. S7-04-23
From: Jared Robbins

Dear Securities and Exchange Commission, I am writing to express my concerns regarding the proposed rule "Safeguarding Advisory Client Assets." While I appreciate the aim to enhance investor protections and address gaps in the custody rule, there are certain aspects of the proposal that require further clarification and consideration. Specifically, I would like to highlight the lack of clarity on custody requirements for digital assets. In an increasingly digital age, where cryptocurrencies and other digital assets have gained prominence, it is crucial to have clear guidelines on how investment advisers should safeguard these assets. However, the proposal fails to provide comprehensive and specific requirements for custody of digital assets, leading to uncertainty for market participants. This could potentially hinder the growth and development of the digital asset industry. Furthermore, I am concerned about the confusing reporting requirements that the proposed rule imposes on participants in decentralized finance (DeFi). With the rapid rise of DeFi platforms and their growing popularity, it is important to find a balance between investor protection and regulatory burdens. The proposed regulations create reporting requirements for multiple participants in DeFi, which may lead to inconsistent and redundant reports being generated for the same transaction. This not only increases compliance costs for market participants but also introduces unnecessary complexity and confusion into the system. It is imperative that the SEC provides clearer guidelines on custody requirements for digital assets and ensures that reporting requirements in the decentralized finance sector are streamlined and consistent. By doing so, the SEC can strike a balance between robust investor protections and fostering innovation in the digital asset and DeFi space. I urge the SEC to consider these concerns and take appropriate action to provide enhanced clarity and consistency in the proposed rule. By listening to the voices of market participants and addressing these issues, the SEC can contribute to the development of a strong regulatory framework that supports both investor protections and innovation. Thank you for considering my comments. Sincerely, Jared Robbins