Dear Securities and Exchange Commission, I am writing to provide my public comment on the proposal "Safeguarding Advisory Client Assets" from the agency. While I appreciate the SEC's efforts to enhance investor protections and address gaps in the custody rule, I have concerns regarding certain aspects of the proposed rule that I believe could hinder access to appeals for investment advisers and their clients. First and foremost, the proposed rule expands the coverage to include a broader range of investments held in a client's account. While this aims to provide greater protection for investors, it also increases the burden on investment advisers and their ability to efficiently manage their clients' assets. This could potentially result in higher costs for advisers and, in turn, the clients they serve. Moreover, the broad scope of the rule may lead to confusion and unintended consequences, needing clarification and additional guidance from the SEC. Additionally, the requirement for investment advisers to deliver notice to clients when opening an account with a custodian is indeed crucial for transparency and accountability. However, the proposed rule does not adequately address the potential challenge of timely delivery and receipt of such notices, especially in cases where clients may be difficult to reach or have multiple communication preferences. A more flexible approach to notification, such as electronic delivery options, could better accommodate the modernized ways in which clients prefer to interact with their investment advisers. Furthermore, the amendments to the surprise examination requirement introduce a written agreement with an independent public accountant. While I appreciate the intent behind this change to safeguard client assets and reduce the risk of loss, the proposed rule does not specify the criteria for selecting such an accountant. Without clear guidelines, it can lead to additional costs and potential conflicts of interest between investment advisers and the appointed accountants. Establishing a transparent and objective process for selecting qualified accountants could address this concern. In terms of the economic analysis presented by the SEC, it is essential to recognize that the proposed rule will impose significant compliance costs on investment advisers. While the aim is to enhance investor protections, the burden of these costs may ultimately be passed on to the clients themselves. As we strive to strike a balance between investor safeguards and regulatory efficiency, it is crucial to carefully consider the potential impact of these compliance costs on the broader economy. Furthermore, the SEC's consideration of reasonable alternatives to the proposed rule is commendable. However, I believe there is an opportunity to explore further flexibility, especially for small entities, in terms of compliance requirements. Simplifying and streamlining the reporting, compliance, and recordkeeping obligations for small advisers would significantly alleviate the economic burden they may face while still maintaining sufficient investor protections. Lastly, I would like to address my concern about the potential hindrance to access appeals. The proposed rule and its amendments seem to lack clarity and guidance on how investment advisers and their clients can navigate the appeals process. Access to a fair and transparent appeals process is vital to ensure that investment advisers and their clients have avenues to address any disputes or grievances that may arise. By providing clear procedures and guidelines for the appeals process, the SEC can strengthen investor protections and maintain trust in the regulatory framework. In conclusion, while I support the SEC's efforts to enhance investor protections in the proposed rule, I urge consideration of the concerns I have outlined. By addressing the potential hindrance to access appeals, providing flexibility for small entities, and ensuring effective communication and implementation of the amendments, we can achieve a balanced regulatory framework that protects investors while fostering a thriving investment advisory industry. Thank you for considering my feedback, and I encourage the SEC to carefully evaluate all public comments and concerns on this important proposal. Sincerely, Brad Federer