Dear Securities and Exchange Commission, I am writing to provide my public comment on the proposal "Safeguarding Advisory Client Assets." While I appreciate the SEC's effort to enhance investor protections and address gaps in the custody rule, I have noticed certain errors and inconsistencies in the proposed rule text that need to be rectified. In order to ensure clarity, understanding, and effective implementation of the rule, it is crucial that these issues be addressed. One area of concern is the presence of careless mistakes or contradictions in the proposed rule. In any regulatory document, it is essential to maintain accuracy and consistency throughout the text. Regrettably, errors or inconsistent language in a proposed rule can lead to confusion and uncertainty, making it difficult for stakeholders to comprehend and adhere to the rule. This can potentially result in conflicting interpretations and unclear instructions, ultimately undermining the intended goals of the rule. To demonstrate this concern, let me cite an example. The proposed rule includes definitions of various terms used throughout the document. However, it is important to ensure that these definitions are error-free and consistent with each other. In case there are mistakes or inconsistencies in the definitions, it could create confusion and ambiguity. Investors, investment advisers, and other stakeholders rely on accurate and consistent definitions to understand their obligations and responsibilities under the rule. To avoid any unintended consequences, it is crucial for the SEC to carefully review and correct any errors or inconsistencies in the proposed definitions. Furthermore, another aspect that deserves attention is the need for clarity in the language used in the proposed rule. Complex or unclear wording can impede stakeholders' understanding of their obligations under the rule. It is essential that the language used is concise, comprehensive, and unambiguous. This will ensure that individuals subject to the rule are able to interpret and implement it correctly, reducing the risk of inadvertent non-compliance. By incorporating clearer language, the SEC can provide greater certainty and confidence to investors and their advisers. In order to uphold the integrity of the regulatory process, it is imperative for the SEC to address these concerns related to errors and inconsistencies in the proposed rule. It is crucial that regulators take the responsibility to correct any mistakes, clarify confusing language, and ensure there is sustainable compliance with the rule. By doing so, the SEC will promote transparency, fairness, and accountability within the industry, ultimately enhancing investor protections and fostering trust. Thank you for considering my comment. I urge the SEC to thoroughly review and rectify any errors or inconsistencies in the proposed rule. This will pave the way for clearer and more effective implementation, benefiting both investors and the advisory community. Sincerely, Brad Federer