Subject: File No. S7-04-23
From: Jeremy Littleton

Dear Securities and Exchange Commission, I am writing to express my concerns regarding the "Safeguarding Advisory Client Assets" proposal. While I appreciate the SEC's efforts to enhance investor protections and address gaps in the custody rule, I have several key concerns that I believe need to be addressed. Firstly, the expansion of the coverage to include a broader range of investments held in a client's account raises privacy concerns. Allowing so many third parties to know my sensitive financial data and social security number compromises my privacy and safety. I believe it's crucial for the SEC to ensure that adequate measures are in place to protect the personal information of investors. Furthermore, the proposed rule places a burden on exchanges to monitor and report suspicious activities, particularly in relation to crypto assets. Given the pseudonymous nature of blockchain transactions, it may be challenging for exchanges to effectively identify and report such activities. The SEC should work closely with exchanges to develop practical and viable solutions, taking into consideration the unique characteristics of cryptocurrencies. Additionally, the economic analysis provided by the SEC acknowledges compliance costs for advisers. It is crucial that these costs do not disproportionately burden small entities, which might lack the resources to implement the proposed safeguards. The SEC should provide resources and support to help small entities, particularly in understanding the compliance requirements and establishing effective control systems. In conclusion, while the "Safeguarding Advisory Client Assets" proposal aims to enhance investor protections, it is important to address the privacy concerns associated with allowing multiple third parties to access personal financial information. Moreover, the burden placed on exchanges to monitor suspicious activities in crypto assets should be re-evaluated, considering the challenges posed by the pseudonymous nature of blockchain transactions. Lastly, it is imperative that the SEC ensures that the proposed rule does not unduly burden small entities. Thank you for considering my concerns. I appreciate the opportunity to provide feedback on this important proposal. Sincerely, Jeremy Littleton