Subject: File No. S7-04-23
From: Luke Stanley

Public Comment on "Safeguarding Advisory Client Assets" Proposal Luke I am writing to express my concerns regarding the proposed rule on the safeguarding of advisory client assets by the Securities and Exchange Commission (SEC). While I recognize the importance of enhancing investor protections and addressing gaps in the custody rule, I believe that the proposal falls short in adequately addressing privacy and security concerns associated with the custody of digital assets, which could potentially put investors' assets at risk. Privacy is a fundamental right that should be safeguarded in any regulatory framework. However, the proposed rule appears to overlook the potential privacy risks associated with the extensive disclosure of sensitive financial data and personal information, such as social security numbers, to multiple third parties involved in the custody process. The SEC should consider implementing stricter privacy protections to ensure the confidentiality and security of investors' information. Furthermore, the proposal does not provide sufficient guidance or requirements for the secure storage and transfer of digital assets, such as cryptocurrencies. As digital assets become more prevalent in investment portfolios, it is crucial for the SEC to address the unique privacy and security challenges associated with these assets. Failure to do so may expose investors to significant risks, including hacking, identity theft, and unauthorized access to their assets. In order to effectively safeguard client assets, it is essential for the SEC to develop robust regulations that prioritize privacy and security. This could include requiring investment advisers to implement rigorous cybersecurity measures, such as encryption, multi-factor authentication, and regular security audits. Additionally, the SEC should consider promoting the use of qualified custodians who have demonstrated expertise in securely storing digital assets. Moreover, the proposal should take into account the need for investor education and awareness regarding the privacy and security implications of digital asset custody. Enhanced transparency and communication from investment advisers about the measures in place to protect clients' privacy and assets would empower investors to make informed decisions about their financial portfolios. As the SEC moves forward with this proposal, I strongly urge the agency to thoroughly consider and address the privacy and security concerns associated with the custody of digital assets. Adequate measures must be put in place to safeguard investor information and assets from potential breaches or unauthorized access. By prioritizing privacy and security, the SEC will not only enhance investor protections but also foster trust and confidence in the advisory industry. Thank you for considering my concerns. I hope that you will take them into account as you review and finalize the proposed rule on safeguarding advisory client assets. Sincerely, Luke