Dear Securities and Exchange Commission, I am writing in response to the proposed rule "Safeguarding Advisory Client Assets" and would like to provide my comments and concerns. As a concerned investor, I believe it is crucial to ensure the protection of client assets while also maintaining fairness and accessibility within the investment industry. One area of concern I have relates to the scope of the proposed rule. While I appreciate the aim to broaden the coverage of investments held in a client's account, I worry about potential barriers that may hinder access to justice for investors. The expansion of the rule should not disproportionately burden smaller investors or advisory firms, as they may lack the resources and expertise to comply with extensive requirements. It is vital that any regulatory measures strike the right balance between protecting investors and ensuring an open and inclusive market for all participants. Additionally, I strongly support the need to enhance the protection of client assets through qualified custodian protections. However, it is essential to consider the unique challenges that may arise when addressing crypto assets. While these digital assets have gained significant attention in recent years, their regulatory framework is still evolving. Any rules relating to crypto assets should be flexible enough to accommodate innovation while still safeguarding the interests of investors. Furthermore, I appreciate the attention given to address the challenges associated with assets that cannot be maintained with a qualified custodian. The proposed requirements for enhanced recordkeeping, separation of duties, and regular reviews can contribute to greater accountability and transparency in safeguarding these assets. It is crucial, however, that the rules remain reasonable and proportionate to the risks involved. Striking an appropriate balance will prevent undue burden on investment advisers without compromising investor protections. Regarding the segregation of client assets, I agree that their separation from adviser assets is of utmost importance. Exceptions should be made sparingly and only for situations where stringent safeguards are already in place. It is essential to prioritize the protection of client assets to prevent any potential mismanagement or mishandling that could jeopardize investor trust. The proposed amendment regarding the delivery of notice to clients when opening a custodial account is a positive step toward ensuring transparency and awareness. By providing clients with detailed information about their custodian, the proposed rule promotes a more informed and empowered investor base. However, it is crucial to strike a balance between providing necessary information while also minimizing unnecessary paperwork and administrative burdens on investment advisers. Concerning the amendments to the surprise examination requirement, I believe that implementing a written agreement with an independent public accountant is a sensible measure to safeguard client assets and minimize the risk of loss. However, I emphasize the need for careful consideration of any exceptions to this requirement. While exceptions can address specific situations, it is crucial to ensure that proper controls are in place to prevent abuse or circumvention of the examination process. I also support the proposed amendments to the Investment Adviser Recordkeeping Rule. Robust recordkeeping requirements are essential for effective oversight and the protection of investor interests. Maintaining records related to client notifications, custodian information, and transactions will improve transparency and accountability, ultimately benefiting investors and the industry as a whole. The changes to Form ADV, particularly the reporting of custody of client assets and information about custodians and accountants involved in safeguarding assets, are steps in the right direction. This increased transparency will enable more comprehensive regulatory oversight and help identify potential risks or misconduct promptly. It is crucial that the reporting requirements are clear and well-defined to avoid additional administrative burdens and confusion. In regard to the economic analysis, I believe it is vital to maintain a cost-effective regulatory framework that protects investors without disproportionately burdening investment advisers. The estimated compliance costs for advisers should be carefully evaluated to ensure they remain reasonable, especially for small advisers who may have limited resources. Any additional expenses should be justified by the corresponding benefits and weighed against the potential impacts on competition and capital formation within the industry. I am encouraged by the SEC's efforts to solicit comments on the economic analysis, benefits, costs, efficiency, and competition related to the proposed rule. This inclusive approach allows for a well-rounded evaluation of the rule's potential impacts and helps address any potential unintended consequences. It is crucial that the SEC remains receptive to public input and critically evaluates all reasonable alternatives suggested during the comment period. Lastly, I appreciate the consideration of the impact on small entities and the acknowledgement that smaller advisers registered with state authorities may not be heavily affected by the proposed rule. It is essential to strike a fair balance between investor protection and the regulatory burden imposed on small advisers. In conclusion, I commend the Securities and Exchange Commission for addressing the safeguarding of advisory client assets through the proposed rule. While recognizing the need for investor protections, it is vital to ensure that these regulations do not hinder access to justice, burden small advisers disproportionately, or stifle competition and innovation within the investment industry. I urge the SEC to carefully consider the points raised in this public comment to ensure an effective and balanced regulatory framework. Thank you for your attention to these concerns and for providing an opportunity for public input on this matter. Sincerely, Brad Federer