Dear Securities and Exchange Commission, I am writing to express my concerns about the proposed rule on "Safeguarding Advisory Client Assets." While I appreciate the SEC's efforts to enhance investor protections and address gaps in the custody rule, I fear that the proposed rule may exceed the SEC's regulatory authority and may be a violation of separation of powers, going against legal precedent regarding the "Major Questions" doctrine. Recently (June 30, 2022), the EPA v West Virginia ruling showed that Chevron deference does not apply to executive agencies when dealing with so called "major questions." Certainly, the downstream economic impact of the "internet of money," qualifies as a "major question," as getting it wrong would be detrimental to the growth of the US economy (and thereby our standing as a world superpower). My concern is two-fold: First, the Commission doesn't seem to understand how impossible it would be for newly (and arbitrarily) decreed "brokers," to comply with the rule proposal in question (especially already operating decentralized contracts that basically behave as a vending machine [input unit A, receive unit B], and many similar products which have immutable code with renounced ownership. Anyone can interact with on-chain contracts, regardless of front-ends for said contract(s) being hosted on the internet or not), should the proposed change be finalized. And second, the Commission would be inviting a proverbial tsunami of legal challenges that would ultimately result in LESS clarity, and more confusion (not to mention, become a waste of taxpayer dollars in legal defense). Besides, some of these DLT products behave more like commodities than actual securities (think of the orange grove analogy in the original Howey test), and would fall under the purview of the CTFC in such cases. I am of the opinion that it would better for everyone if the Commission slowed down, waited for Congress to catch up in their understanding of all the nascent technologies involved, got an actual update to existing securities law the proper way, and proceeded from there. Simply changing the definition of "assets," and calling it a day is not good enough here; not to mention, people have a right to custody their own property if they so choose. It is imperative for the future of the United States that we do not fumble this!