Subject: File No. S7-04-23
From: Josh Mauer

Dear SEC, I am writing to provide public comment on the proposed rule "Safeguarding Advisory Client Assets" by the Securities and Exchange Commission. As a concerned CPA and advocate of investor protection, I have several issues in relation to the proposed rule that I would like to address. First and foremost, I am deeply concerned about the lack of consideration given to privacy and security concerns surrounding the custody of digital assets. While the proposed rule aims to enhance investor protections, it fails to adequately address the inherent risks associated with the storage and transfer of sensitive financial data in digital form. As we have witnessed in recent years, cyber attacks and data breaches have become increasingly common, putting confidential client information at risk. Without robust safeguards in place, investors' assets could be compromised, leading to significant financial loss and reputational damage. Furthermore, the proposal appears to overlook the privacy implications of requiring investment advisers to share client information with multiple third parties, such as custodians and accountants. As a result, investors' personal and financial data would be exposed to an expanded network of entities, increasing the potential for unauthorized access and misuse. Given the sensitive nature of this information, it is imperative that the SEC ensures the highest level of privacy protection throughout the custody process. Additionally, there is a need for clearer guidance on how investment advisers should address privacy concerns related to the sharing of social security numbers, account details, and other personal information. These identifiers are particularly vulnerable to identity theft and fraudulent activities, and the proposal should include specific provisions to mitigate these risks. By mandating enhanced security protocols and encryption standards, the SEC can help safeguard investors' private information and instill confidence in the advisory industry. In conclusion, as the safeguarding of client assets in today's digital landscape becomes increasingly crucial, it is imperative for the SEC to prioritize privacy and security concerns in the proposed rule. This should include comprehensive provisions to address the risks associated with the custody of digital assets, stronger protocols for the protection of client information, and clearer guidance on mitigating privacy risks related to the sharing of personal identifiers. I urge the SEC to revise and strengthen the proposed rule to provide investors with the level of privacy and security they deserve. Thank you for considering my comments on this matter. Sincerely, Josh Mauer, CPA