Thanks SEC for the opportunity to comment, mandated by the APA. I have some concerns regarding S7-04-23 that you need to consider. I'm presenting it to you in a list so that it's easier for you to understand, than if I didn't use line breaks and just put one after another in paragraphs. The rule would put investors at greater risk. The sec has not assessed impacts on efficiency, competition, and capital formation. The rule would reduce availability of financing for businesses. The rule would undermine attorney-client privilege and work product protections. The rule lacks balance between costs and benefits. The rule conflicts with state privacy laws. The costs of compliance outweigh any benefits. The rule penalizes entities without wrongdoing. The rule lacks authority under the statutes cited. The rule relies on outdated assumptions and statistics. The rule would reduce market liquidity. The rule would undermine privacy and data security. The timeline for implementation is unrealistic. The rule would negatively impact capital formation. Less costly alternatives have not been adequately considered. The rule would enable anti-competitive behavior. The rule duplicates existing regulations. The rule lacks proportionality. The rule ignores foreign conflicts. The rule ignores reliance on existing regulatory frameworks. The rule lacks sufficient flexibility to adapt to changing market conditions. The costs are not justified based on the limited benefits. The rule conflicts with other federal and state laws. The rule would reduce market transparency and price discovery. The rule exceeds international standards without cause. The rule makes arbitrary judgements of risks and benefits. The rule conflicts with other federal regulations. The rule contradicts congressional intent. The economic analysis does not meet OMB standards. The rule exceeds international standards without evidence. The rule conflicts with foreign regulatory regimes. The rule improperly allocates regulatory burdens. The rule would limit access to capital. The rule exceeds the sec's statutory authority. The rule lacks proportionality between costs and benefits. The rule would reduce availability of products that meet investor needs. The sec has failed to make a compelling case that this rule is truly needed. The rule exceeds the sec's expertise. The rule would violate attorney-client privilege. The rule violates the regulatory flexibility act by ignoring small business impacts. The rule incorrectly assumes that more regulation is always better. The rule fails to address actual market failures with surgical precision. The sec does not have the resources to effectively enforce this rule. The rule would undermine capital formation and economic growth. The rule usurps proper congressional authority. The rule is predicated on unproven hypothetical risks. The sec has not justified the need for such an expansive rule. The rule usurps the authority of prudential regulators. The rule fails to differentiate between business models and activities. The data cited by the sec do not support the need for this rule. The rule exceeds the intent of congress. The disclosure requirements are excessive and unnecessary. The rule would reduce market efficiency and transparency. the rule lacks a clear justification and defined purpose. The rule was proposed without proper public notice and comment. The rule imposes a one-size-fits-all approach that is ill-suited to this issue. The rule is arbitrarily restrictive given the actual risks involved. The rule imposes vague and subjective standards. The rule exceeds the sec's expertise on this complex issue. The rule duplicates existing regulations. There are less restrictive alternatives that would achieve the same goals. The rule would reduce access to professional financial advice. The rule would concentrate rather than diversify risk. The rule fails to distinguish between large and small entities. The rule contradicts guidance from other federal regulators. The rule conflicts with international standards. The rule would chill innovation and experimentation. The rule would reduce access to products investors demand. The rule incorrectly assumes that more regulation is always better. The rule conflicts with foreign regulatory regimes. The rule may put us companies at a competitive disadvantage globally. The rule ignores unintended consequences. The rule is based on unproven theories not facts. The rule exceeds sec expertise. The rule exceeds international norms without justification. The rule subverts the proper legislative process. The rule lacks clarity and will be difficult for regulators to consistently enforce. The rule ignores state regulatory jurisdiction. The rule would limit access to financial products for consumers. The sec has not assessed the impact on retail investors. The rule would reduce access to financial advice. The rule reduces access to advice. The rule infringes on the fiduciary duties of financial professionals. The rule improperly allocates regulatory burdens. The rule is misaligned with actual risks. The rule relies on insufficient and inadequate data. The rule exceeds the sec's consumer protection mandate. The rule would discourage market participation. The rule would undermine corporate governance standards. The rule disregards well-established industry standards. The rule would limit investor access to products and services. The rule contradicts guidance from other regulators. The rule lacks empirical support. The rule would undermine investor confidence in markets. The rule disregards established standards. The sec has failed to do a robust cost-benefit analysis. The rule violates cost-benefit analysis requirements. The sec has not conducted an adequate cost-benefit analysis. The rule ignores reliance interests. The rule fails to differentiate based on size, complexity, and business model. The rule would reduce product availability. The rule ignores reasonable reliance on current regulations. The rule relies on flawed assumptions not supported by data. The rule would restrict access to products and services. The rule exceeds congressional intent. The rule would reveal sensitive proprietary information. The rule ignores market impacts. The rule ignores viable alternatives. The rule would reduce access to products that investors demand. The rule would undermine us leadership in financial markets. The rule would undermine corporate governance and accountability. The rule would impose undue reputational risk. The rule infringes on contractual rights and business judgements. The rule lacks clarity on scope and definitions. The sec underestimates transition costs and market disruptions. The compliance costs for small businesses are disproportionately high. The rule relies on flawed economic assumptions. Here are 100 more possible ethical, non-sexual comments against a proposed sec rule: The implementation timeframe is unrealistically short. The rule exceeds the sec's investor protection mandate. The rule exceeds the intent of the authorizing legislation. The rule lacks key definitions needed to implement it effectively. The rule exceeds the sec's congressional mandate. The rule is improperly retroactive. The rule infringes on issues traditionally left to state regulators. The rule ignores modern financial system realities. The rule disrupts contractual expectations. The rule would reduce market transparency. The rule lacks clarity on scope, definitions, and requirements. The rule ignores potential conflicts with other regulations. The rule does not properly weigh systemic risks. The rule exceeds the sec's institutional expertise. The rule would increase concentration of risks. The rule is overly prescriptive and inhibits reasonable business judgement. The rule penalizes prudent business judgement. The rule would deter participation in financial markets. The rule fails to consider reliance interests. The costs of implementing this rule outweigh the benefits. The rule would limit investor choice. The sec has not adequately consulted industry experts and stakeholders. The rule exceeds the sec's investor protection mandate. The rule is overly broad and exceeds the sec's authority. The sec has not assessed impacts on investors and market integrity. The rule goes beyond the sec's authority. The rule conflicts with state regulatory regimes. The rule relies on inadequate data, research, and economic analysis. The rule would undermine principles-based regulation. The rule makes unproven assumptions. The rule is predicated on unproven theories. The rule contradicts other regulators. The rule contravenes the administrative procedures act. The rule makes arbitrary judgements. The rule does not account for first amendment considerations. The rule lacks clarity in implementation. The rule disregards well-established industry standards and norms. The rule was proposed without following proper administrative procedures. The rule exceeds the sec's expertise and mandate. The rule is improperly retroactive. The regulatory impact analysis is inadequate. The rule exceeds congressional intent in the authorizing legislation. The rule is overly complex and burdensome. The rule ignores first amendment issues regarding compelled speech. The rule disregards reasonable judgements of experienced professionals. The rule would require disclosure of immaterial information. The sec has not sufficiently considered the unintended consequences. The rule may stifle innovation in the industry. The rule lacks clarity and may be difficult to interpret. The rule is not tailored to the size and complexity of the institution. The rule penalizes entities without sufficient evidence of wrongdoing. The rule was proposed without adequate public notice and comment. The rule ignores reasonable alternative approaches. The rule lacks safeguards against abuse. The rule disregards well-established industry standards without basis. The rule ignores viable alternatives that are less burdensome. The rule is based on speculation rather than empirical evidence. The rule would concentrate risk rather than spread it. The rule would impose undue burdens not required by legislation. The rule fails to do an adequate cost-benefit analysis as required by law. The rule imposes vague and subjective standards. The rule conflicts with state contract law. The rule would deter participation in us markets. The rule ignores viable alternatives. The rule ignores viable alternatives. The rule would restrict access to investment opportunities. The rule conflicts with foreign laws without justification. The rule disregards established market practices without cause. The rule penalizes entities without evidence they contributed to problems. The rule would limit investor choice. The sec should defer to prudential regulators on this issue. The rule ignores unintended consequences. The rule would undermine corporate governance and accountability. The rule is based on unsound economic assumptions. The rule exceeds investor protection authority. The rule exceeds the sec's statutory authority. The rule lacks clarity in scope, definitions and requirements. The rule would compel unethical business practices. The rule ignores modern financial practices. The rule makes unsubstantiated claims of benefits. The rule is trying to fix a problem that does not exist. The rule would discourage socially beneficial activities. The rule lacks safeguards against abuse. I look forward to you publishing your analysis so that I might comment using better data. No one has time to do things twice, so you might as well get it right the first time.