Dear Securities and Exchange Commission, I am writing to share my concerns regarding your proposed rule on the safeguarding of advisory client assets. While I appreciate the aim to enhance investor protections and address gaps in the custody rule, there are certain aspects of the proposal that require further consideration and clarification. Firstly, I would like to address the scope of the rule. The proposed expansion of coverage to include a broader range of investments held in a client's account is commendable. However, there seems to be an inconsistency in the regulatory treatment of stablecoins. The rules do not provide consistent guidance on how these assets should be safeguarded, potentially creating uncertainty and disrupting stablecoin markets. It is imperative for the SEC to address this issue and establish a clear regulatory framework for the treatment of stablecoins within the proposed rule. Furthermore, the proposed rule discusses the application of safeguarding measures to crypto assets. Given the unique aspects of these digital assets, it is important that the rule establishes clear guidelines on how investment advisers can demonstrate exclusive control over these assets. Without such clarity, there may be challenges in safeguarding client assets effectively, leaving investors exposed to unnecessary risks. Additionally, I have concerns regarding the provisions for certain assets that are unable to be maintained with a qualified custodian. While enhanced recordkeeping, separation of duties, and regular reviews are required, it would be beneficial for the SEC to provide more detailed guidance on how advisers can effectively safeguard such assets. The lack of specific instructions may lead to inconsistent practices, thereby jeopardizing the protection of client assets. Another area of concern is the segregation of client assets. Although exceptions are provided in the rule, it is crucial that the SEC prioritizes the protection of client assets and ensures that safeguards are in place to prevent any commingling of client and adviser assets. Clear guidelines and stringent enforcement will help establish trust in the investment advisory industry. With regards to the amendments to the surprise examination requirement, the requirement for advisers to implement a written agreement with an independent public accountant is a step in the right direction. This will undoubtedly help safeguard client assets and reduce the risk of loss. However, it would be prudent for the SEC to provide further clarity on the selection process and qualifications of the independent public accountants to ensure their independence and expertise. Moving on to the economic analysis of the proposed rule, it is evident that the SEC has considered the costs and benefits of the amendments. However, there is a need to delve deeper into the potential economic effects, particularly in relation to competition and compliance costs for qualified custodians. While the proposed rule aims to enhance investor protections, it does not address the potential challenges faced by custodians and the impact on their ability to provide efficient advisory services. A thorough analysis of these factors would help strike a better balance between investor protection and operational feasibility. In conclusion, while I appreciate the SEC's efforts to enhance investor protections and address gaps in the custody rule, I strongly believe that further deliberation and clarification are necessary. The inconsistent regulatory treatment of stablecoins, the need for clearer guidelines on safeguarding crypto assets, and the potential challenges in safeguarding assets that cannot be maintained with a qualified custodian must be addressed. I would also like to take this opportunity to enquire if there are any other areas of concern that I can further comment on, or if there are any general questions I can answer regarding the proposal. I appreciate the opportunity to provide input and encourage the SEC to seek input from a diverse range of stakeholders to ensure the final rule strikes the right balance between investor protection and industry feasibility. Thank you for considering my public comment on this crucial matter. Sincerely, Phil Lawrence