Subject: File No. S7-04-23
From: Stephan Wild

Dear Securities and Exchange Commission, I am writing to submit my public comment regarding the proposed rule on "Safeguarding Advisory Client Assets." As an investor and concerned citizen, I have several reservations and issues with the rule proposal, particularly in relation to potential overreach of regulatory authority and concerns over privacy. Firstly, I would like to express my concern that the SEC's proposed rule may exceed its regulatory authority, potentially encroaching on areas that should be regulated by other agencies. The safeguarding of client assets is undoubtedly important, but it is crucial that the SEC remains within its appropriate jurisdiction and respects the roles of other regulatory bodies. It is essential to ensure that the rule proposal does not undermine the regulatory landscape by creating unnecessary overlaps or conflicts. Additionally, I am deeply worried about the privacy implications of the proposed rule. While I understand the need for increased client protection, the requirement to provide sensitive financial data and social security numbers to multiple third parties raises significant concerns about privacy and data security. The potential risks associated with the disclosure of such personal and confidential information outweigh the proposed benefits of enhanced investor protection. The SEC should consider alternative means of achieving its objectives while minimizing the exposure of investors' private data. Furthermore, I urge the SEC to carefully consider the potential burden that the proposed rule may impose on investment advisers, particularly small entities. Compliance with extensive recordkeeping, reporting, and verification requirements can be prohibitively costly for small advisers, potentially limiting their ability to effectively serve their clients. The SEC should explore alternative approaches that strike a balance between investor protection and the ability of small advisers to remain viable contributors to the investment industry. Lastly, while not directly related to potential overreach or privacy concerns, I request clarification regarding the transition period and compliance dates outlined in the proposal. A one-year transition period seems reasonable, but it would be helpful to better understand the specific deadlines applicable based on assets under management. Clarity in this regard would assist advisers in planning for and meeting the requirements of the new rule. In conclusion, I believe that the SEC's proposed rule on "Safeguarding Advisory Client Assets" requires careful reconsideration to address potential regulatory overreach and privacy concerns. I trust that the SEC will take into account the comments and concerns of stakeholders to ensure that any final rule strikes an appropriate balance between protecting investors and respecting individual privacy rights. Thank you for considering my public comment. Sincerely, Stephan Wild