Public Comment for Safeguarding Advisory Client Assets Proposal Dear Securities and Exchange Commission, I am writing to express my concerns regarding the proposed rule, "Safeguarding Advisory Client Assets," and the potential impact it may have on the safeguarding of client assets in the advisory industry. While I understand the aim to enhance investor protections and address gaps in the custody rule, I believe that the rule falls short in adequately considering the unique properties of cryptocurrency and the challenges it poses for regulation. One key issue I would like to address is the inadequate consideration of the unique properties of cryptocurrency. The proposed rule does not take into account the decentralized nature and technological complexities of cryptocurrency, leading to impractical regulatory requirements. The use of undefined terms, such as "platform," "software," and "ledger," creates ambiguity and leaves room for different interpretations. Furthermore, the definition of terms like "wallet" and "validator" do not align with their technical meaning within cryptocurrency networks, leading to confusion and lack of clarity in compliance. In order to effectively regulate cryptocurrency assets, it is essential that the SEC develops a comprehensive understanding of the technology and its underlying infrastructure. This understanding should inform the regulatory framework and ensure that the proposed rules are both practical and effective. Failure to do so may result in unintended consequences, hinder technological innovation, and stifle the growth of the cryptocurrency industry. Additionally, I have concerns about the rule's definition and scope of certain terms. Poorly defined terms within the proposed regulations, such as "assets," "discretionary authority," and "exceptions," leave room for interpretation and create uncertainty for investment advisers. A lack of clear definitions can lead to inconsistent implementation and enforcement, undermining the objectives of the rule. To address these concerns, the SEC should provide clearer definitions for key terms and consult industry experts to better understand the unique challenges posed by cryptocurrency. Collaboration with professionals who possess technical knowledge and experience with cryptocurrency networks would greatly enhance the regulatory framework, ensuring that it is based on sound understanding and capable of accommodating technological advancements. Furthermore, I urge the SEC to acknowledge the importance of effectively regulating cryptocurrency assets while fostering innovation and competition. The SEC plays a crucial role in promoting capital formation and efficient investment markets. As the cryptocurrency industry continues to evolve, it is essential that regulatory measures strike a balance between investor protections and the facilitation of technological innovation. Imposing overly burdensome requirements without adequate consideration of the unique characteristics of cryptocurrency may deter investment and stifle economic growth. In conclusion, I respectfully urge the SEC to reconsider the proposed rule, "Safeguarding Advisory Client Assets," and undertake a more robust assessment of the unique properties of cryptocurrency. By working closely with industry experts, clarifying key terms, and ensuring practical and effective regulations, the SEC can achieve its objectives of enhancing investor protections while fostering innovation and competition within the advisory industry. Thank you for considering my comments. I appreciate the opportunity to provide input, and I look forward to the SEC's thoughtful consideration of these issues. Sincerely, Brandon