Subject: File No. S7-04-23
From: Ahmed Kallel

Thank you for the opportunity to provide a public comment on the proposed rule "Safeguarding Advisory Client Assets" by the Securities and Exchange Commission (SEC). My name is Ahmed Kallel, and I am writing to express deep concerns and frustration regarding the potential negative impact that these regulations will have on small business owners like myself. It is evident that these regulations have been designed to disproportionately burden small businesses, while allowing larger players with more resources to navigate the regulations unscathed. Firstly, I must stress the potential devastating consequences for small business owners operating in the emerging decentralized finance (DeFi) sector. The proposed rules, under the guise of enhancing investor protections, will severely hinder the growth and development of decentralized finance projects. It is clear that the SEC fails to appreciate the innovative nature of the DeFi sector, which heavily relies on technological advancements such as blockchain and smart contracts to provide secure and transparent financial services. Rather than nurturing and encouraging this promising sector, the proposed rules impose onerous custody requirements and burdensome recordkeeping obligations on DeFi projects. The limited financial and operational resources of small businesses within the DeFi space make it impractical, if not impossible, to comply with the stringent regulatory framework envisioned by the SEC. This discrepancy in the regulatory burden imposed on small businesses versus large players is both unjust and discriminatory. Secondly, I must emphasize the immeasurable burden that these reporting requirements will place on small businesses. Start-up protocols and small businesses operating in the DeFi sector typically do not possess the necessary infrastructure or capital to effectively track and comply with the proposed rules. By imposing such complex tracking mechanisms, the SEC is directly penalizing small businesses, stifling their growth and hindering their ability to compete with their larger counterparts. These reporting requirements will not only deter potential new entrants, but they will also create insurmountable barriers for existing small businesses within the DeFi sector. The exorbitant costs associated with compliance measures will undoubtedly suffocate innovation and hinder the overall growth of the sector, constituting a severe setback to the principle of fair competition. It is evident that the SEC is disregarding the plight of small business owners, instead favoring large players who possess the financial means to navigate these burdensome regulations. In light of these egregious discrepancies, I strongly urge the SEC to rectify this clear bias against small businesses and the DeFi sector. It is imperative that a more equitable and balanced regulatory framework is established, one that accounts for the limited resources and innovative nature of small businesses. By doing so, the SEC can foster a climate that promotes entrepreneurship, encourages technological advancement, and ensures a level playing field for all market participants. Additionally, I would like to reiterate my willingness to address any general questions related to the proposal or provide further input on any other areas of concern. Small business owners like myself are eager to contribute to a vibrant and competitive economy, but we require a regulatory environment that supports rather than obstructs our growth and development. Thank you for considering my impassioned plea to rectify the inequities within the proposed rule. Sincerely, Ahmed Kallel