Subject: File No. S7-04-23
From: Jack Joneson

Dear Securities and Exchange Commission, I am writing to express my concerns regarding the proposed rule "Safeguarding Advisory Client Assets" and the lack of clarity on the definition of digital assets. The proposal does not provide clear guidance on what constitutes a digital asset, leading to confusion and potential misinterpretation. This lack of clarity raises significant legal challenges and may not pass judicial scrutiny. One of the key issues with the proposed rule is its potential negative impact on the economy. It is important to acknowledge that digital assets, like cryptocurrency, are transforming the finance industry. However, regulatory uncertainties pose challenges. The proposed rule, as it stands, would amplify these challenges and hinder innovation in this rapidly evolving sector. This would have substantial economic implications, jeopardizing businesses, investors, and the overall economy. Furthermore, the practical implementation of the proposed rule raises concerns. The ambiguous language, unclear requirements, and overly complex compliance measures make it difficult for investment advisers to understand and comply with the rule. This could lead to unintended noncompliance and deter market participants from engaging in digital asset investments. It is crucial to offer more practical approaches or simpler alternatives that would still achieve the desired objectives without burdensome measures. Moreover, the proposed rule may have unintended consequences that undermine its intended goals. It could potentially discourage innovation, reduce transparency, and create new risks in the financial system. It is essential to evaluate the potential negative side effects and weigh them against the benefits to ensure a balanced approach that effectively protects investors without hindering growth and development. In addition, the proposed rule should consider aligning with global best practices and coordinating with international standards. Failure to do so may create conflicts and put U.S. firms at a competitive disadvantage relative to foreign counterparts. This could result in a loss of market share and hinder the ability of U.S. companies to compete globally. I urge that alternative proposals are thoroughly considered. These proposals should address the same issue of safeguarding client assets while minimizing adverse effects on stakeholders. By exploring alternative solutions, we can strike a balance between investor protection and nurturing an environment conducive to economic growth and innovation. It is crucial to advocate for the public interest in the financial sector. We must ensure that any regulation supports access to financial services, mitigates costs for consumers, and fosters capital formation. These considerations will contribute to the overall well-being of the public and the stability of the financial system. Finally, I request an extension of the comment period to allow for a comprehensive analysis of the proposed rule. Additional time is necessary to ensure that all stakeholders can fully evaluate the rule and present thoughtful and well-supported comments. Thank you for considering my concerns. I urge the Securities and Exchange Commission to carefully review and address these issues to ensure a fair and balanced regulatory framework that supports innovation, protects investors, and fosters the growth of the financial sector. Sincerely,