Dear Securities and Exchange Commission, I am writing to express my concerns regarding the proposed rule on "Safeguarding Advisory Client Assets." While I appreciate the SEC's efforts to enhance investor protection and address gaps in the custody rule, I believe there are potential areas of unintended consequences and concerns about the scope of regulatory authority. Firstly, I would like to address the potential overreach of regulatory authority. It is crucial to ensure that the SEC's rule does not extend beyond its intended boundaries and encroach upon areas that should be regulated by other agencies or industry best practices. Overregulation can stifle innovation and impose unnecessary burdens on investment advisers, hindering their ability to effectively serve their clients. It is essential to strike a balance between investor protection and maintaining a competitive and innovative advisory industry. Moreover, I am concerned about the potential unintended consequences of the proposed rule. While the intention is to enhance transparency and safeguard client assets, certain provisions may inadvertently discourage innovation and limit investment strategies that could benefit clients. Innovation plays a crucial role in driving forward the investment industry and providing clients with new options for wealth generation. Therefore, any rule should carefully consider potential negative side effects that may undermine the intended goals. Additionally, I believe there is a need to ensure that the proposed rule does not reduce transparency or create new risks. While it is paramount to protect client assets, excessive disclosure requirements may overwhelm clients with unnecessary information, resulting in confusion and potential misinterpretation. Striking the right balance in disclosure will ensure that clients are well-informed without unnecessary burdens on investment advisers. Furthermore, it is important to carefully evaluate the potential risks that may emerge as a result of the proposed rule, including unintended consequences that could negatively impact market participants or introduce new vulnerabilities in the advisory industry. In conclusion, while I appreciate the SEC's efforts to address the safeguarding of advisory client assets, I urge the agency to carefully consider the potential unintended consequences and assess the scope of its regulatory authority in the proposed rule. It is imperative to strike a balance between investor protection, maintaining a competitive and innovative advisory industry, and minimizing any potential negative impact on market participants or risks arising from these proposed changes. Thank you for considering my concerns. I believe that thoughtful consideration of these issues will help create effective regulations that achieve the goals of investor protection while supporting a vibrant and innovative investment industry. Sincerely, James C. Miller