Subject: File No. S7-04-23
From: garrett-thayer: crouch

Dear Securities and Exchange Commission, I am writing to provide my public comment on the proposed rule "Safeguarding Advisory Client Assets." While I appreciate the SEC's efforts to enhance investor protections and address gaps in the custody rule, I have significant concerns regarding the lack of clarity on the definition of digital assets. The proposed rule fails to provide clear guidance on what constitutes a digital asset, leaving investment advisers in a state of confusion and potential misinterpretation. Given the rapid rise of digital assets like cryptocurrencies, it is crucial that regulatory frameworks keep pace with technological advancements to ensure investor protection without stifling innovation. Digital assets, particularly cryptocurrencies, have transformed the financial landscape and have the potential to empower individuals across the globe. However, regulatory uncertainties surrounding these assets not only hinder adoption but also expose investors to risks. The lack of clarity in the proposed rule exacerbates this issue and fails to provide adequate guidance to investment advisers navigating the complexities of the digital asset landscape. To address this concern, it is imperative for the SEC to provide a clear definition of digital assets that encompasses the various types and use cases. Clarity in the regulatory framework will foster greater transparency and allow investment advisers to effectively comply with safeguarding requirements while facilitating the growth and innovation surrounding digital assets. Additionally, the SEC should consider engaging with industry experts and stakeholders to gain a nuanced understanding of the digital asset ecosystem. This collaborative approach would help ensure that the regulatory framework strikes the right balance between investor protection and fostering innovation. Furthermore, the SEC should carefully evaluate the impact of the proposed rule on the competitiveness of the United States in the global digital asset market. While it is crucial to protect investors, it is equally important to create an enabling environment that encourages investment, attracts innovative projects, and promotes economic growth. Striking this balance will position the United States as a leader in the digital asset space while safeguarding investor interests. In conclusion, while I commend the SEC's efforts to enhance investor protections through the proposed rule, the lack of clarity on the definition of digital assets is a significant concern. To address this issue, I urge the SEC to provide a clear definition of digital assets, engage with industry experts, and carefully assess the impact of the proposed rule on the competitiveness of the United States in the digital asset market. Thank you for considering my comments. Should you require any further information or would like to engage in a constructive discussion on this matter, please do not hesitate to contact me. Sincerely, Garrett Crouch