Subject: File No. S7-04-23
From: Cesar Candelario

Dear Securities and Exchange Commission, I am writing to express my concerns regarding the proposed rule on "Safeguarding Advisory Client Assets." While I understand the need to enhance investor protections and ensure the safeguarding of client assets, I believe that certain aspects of the rule may impose significant burdens on small businesses and startups, particularly those operating in the digital asset industry. One of my primary concerns is the impact on small businesses. The reporting requirements outlined in the proposed rule will necessitate the tracking of personal identifiable information by small businesses and startups that would not otherwise be required to do so. This will impose additional costs and administrative burdens on these entities, which often operate with limited resources and budgets. As a result, these additional compliance costs could prove detrimental to the growth and innovation of small businesses and startups. Moreover, the burden imposed by the proposed rule could hinder growth in the digital asset industry, ultimately stifling innovation. Startups in the digital asset space often face unique challenges due to the rapidly evolving nature of the industry. The proposed reporting requirements may impede their ability to focus on product development and market expansion, diverting scarce resources towards compliance efforts instead. This could lead to a competitive disadvantage and deter investment in this promising sector. Additionally, I am concerned about the potential impact abroad. As the global digital asset market continues to evolve, it is crucial to consider the international implications of regulatory requirements. The proposed rule may create barriers for small businesses and startups operating in the digital asset industry seeking to expand their services outside the United States. This could curtail their ability to compete globally and could have detrimental consequences for the overall growth and success of these businesses. In light of these concerns, I urge the SEC to carefully consider the burden placed on small businesses and startups when finalizing the rule. It is essential to strike a balance between investor protection and maintaining an environment conducive to innovation and growth. This could be achieved through adopting regulatory measures that are proportionate and tailored to the specific needs and capabilities of small businesses. I appreciate the SEC's focus on investor protection and the safeguarding of client assets, but I encourage you to take into account the potential negative consequences on small businesses, startups, and innovation. To ensure a vibrant and competitive digital asset industry, it is crucial to adopt regulations that both protect investors and foster an environment that encourages growth and innovation. Thank you for considering my concerns. I look forward to the SEC's continued efforts to strike the right balance between regulatory oversight and supporting the growth of small businesses and startups in the digital asset industry. Sincerely, Cesar Candelario