Dear Securities and Exchange Commission, I am writing to submit a public comment on the proposed rule titled "Safeguarding Advisory Client Assets." As an individual deeply interested in investor protection and the regulation of the advisory industry, I have reviewed the proposed amendments and would like to offer my perspective on certain areas of concern. Introduction: While I appreciate the SEC's efforts to enhance investor protections and address gaps in the custody rule, I believe it is crucial to ensure that the proposed rule strikes the right balance between safeguarding client assets and not imposing excessive compliance burdens on investment advisers. Regulatory measures should aim to promote a fair, efficient, and transparent marketplace for investors and advisers alike. Scope of Rule: I have reservations about the expanded coverage proposed for this rule. While it is important to include a broader range of investments in the definition of assets held in a client's account, we must be cautious not to overburden investment advisers with unnecessary regulatory requirements. A balanced approach is necessary to protect investors without stifling investment opportunities. Qualified Custodian Protections: In analyzing how investment advisers safeguard client assets, it is essential to address the complexities associated with activities involving crypto assets. Given the unique characteristics and challenges surrounding these assets, the proposed rule should provide clear guidelines on how to demonstrate exclusive control, ensuring adequate protection for investors involved in crypto investments. Certain Assets Unable to be Maintained with a Qualified Custodian: I support the enhanced recordkeeping, separation of duties, and regular review requirements outlined in the proposed rule for safeguarding assets that cannot be maintained with a qualified custodian. However, it is important that such requirements do not become overly burdensome for investment advisers, particularly smaller firms, without commensurate investor protection benefits. Segregation of Client Assets: The proposed rule's aim to ensure that client assets are segregated from an adviser's assets is commendable. However, it is crucial to provide clear guidance and examples of exceptions to this requirement. When exceptions exist, utmost priority should be given to safeguarding client assets and mitigating any potential conflicts of interest. Form ADV: I appreciate the changes to Form ADV, which enhance transparency and regulatory oversight. However, it is important to consider streamlining the reporting requirements and minimizing duplication to alleviate the burden on investment advisers. The collection of information should be optimized to provide necessary insights without unduly hindering the efficient functioning of advisory firms. Congressional Oversight: It is essential to call for greater congressional involvement or oversight in the rulemaking process. Legislative input can contribute to a more balanced, transparent, and effective regulatory environment. Increased congressional engagement ensures that the perspectives of various stakeholders are considered, resulting in regulations that better serve investors' interests and account for the practical challenges faced by market participants. Overall, the proposed rule contains important provisions aimed at enhancing investor protections, improving recordkeeping, and increasing transparency. However, continual evaluation and refinement are necessary to strike a prudent balance between safeguarding client assets and enabling investment advisers to serve their clients effectively without undue regulatory burden. I would like to take this opportunity to highlight the need for ongoing dialogue and collaboration between the SEC, industry participants, and the public to ensure that regulations are effective, clear, and efficient. By working together, we can achieve a regulatory framework that encourages capital formation, fosters investor confidence, and supports innovation within the advisory industry. Thank you for considering my comments. I appreciate the opportunity to contribute to this important discussion. Sincerely, Brad Federer