Subject: File No. S7-04-23
From: Anonymous

While I acknowledge the aim of enhancing investor protections and addressing gaps in the custody rule, I have concerns regarding certain aspects of the proposed rule and its impact on the digital asset landscape. Specifically, my primary concern lies in the lack of clarity on the definition of digital assets. The proposal fails to provide clear guidance on what constitutes a digital asset, leading to confusion and potential misinterpretation. In an industry that is rapidly evolving, it is crucial to have precise definitions in order to accurately assess regulatory requirements and obligations. Furthermore, the proposal introduces reporting requirements for various participants in decentralized finance (DeFi), which could potentially create a confusing and convoluted reporting process. With the nature of DeFi being decentralized and involving numerous stakeholders, it is important to ensure that reporting requirements are streamlined and consistent. An excessively complex reporting system could lead to an unnecessary burden on market participants and hinder the growth and innovation within the DeFi space. I urge the SEC to consider a more streamlined and cohesive approach to reporting requirements in relation to digital assets and DeFi. This could be achieved through clear definitions and standards that provide clarity and consistency across the industry. A harmonized framework would reduce the potential for multiple, inconsistent reports to be generated for the same transaction and mitigate confusion among market participants. Additionally, I believe it is essential for the SEC to engage with industry experts and stakeholders in an ongoing dialogue to gain a better understanding of the evolving digital asset landscape and its unique characteristics. This collaborative approach would facilitate the development of more effective regulatory frameworks that encourage innovation while maintaining the necessary investor protections. As the digital asset industry continues to grow and evolve, it is imperative that regulatory bodies adapt to these changes in a thoughtful and nuanced manner. The proposed rule should take into account the complexities and nuances of the digital asset space, rather than potentially hindering its development through unclear definitions and reporting requirements. Thank you for considering my comments and for your commitment to safeguarding advisory client assets. I hope that these concerns will be taken into account as the SEC moves forward with the rulemaking process.