Dear Securities and Exchange Commission, I am writing to express my concerns regarding 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 believe there are certain areas that require careful reconsideration. Firstly, the lack of clarity surrounding the definition of digital assets is concerning. The proposal does not provide clear guidance on what constitutes a digital asset, which may lead to confusion and potential misinterpretation among investment advisers. It is crucial that a precise and comprehensive definition is established to ensure consistent understanding and application of the rule. This is especially the case because many of the digital ‘assets’ have many differing intrinsic properties and qualities and can’t be grouped as a network protocol when they have much more utility beyond just the network they exist on. Furthermore, I am deeply concerned about the implications of this rule on privacy and security. As an investor, the safeguarding of my sensitive financial data and personal information is of utmost importance. The proposal suggests allowing multiple third parties to access and handle such information, increasing the risk of privacy breaches and identity theft. It is essential that the SEC carefully considers the potential privacy and security risks associated with this rule and implements robust measures to mitigate them. The reason this technology exists is to subvert the needless passing of private information across many parties for no benefit of the user. In addition to the specific concerns mentioned above, I believe it is crucial for the SEC to provide more clarity and guidance regarding the obligations and responsibilities of investment advisers in safeguarding client assets. A comprehensive and well-defined framework is necessary to ensure that investment advisers understand their obligations and are adequately equipped to protect client assets from loss or misappropriation. Furthermore, the proposed amendments to the surprise examination requirement raise some concerns. While the goal of safeguarding client assets is commendable, the imposition of additional examination requirements may place a significant burden on investment advisers. The SEC should carefully consider the potential impact on compliance costs and the overall efficiency of investment advisory services. Finally, the proposed rule's potential impact on smaller advisory firms must be taken into account. While the SEC acknowledges that most small entities registered with state authorities will not be affected, it is essential to ensure that the rule does not disproportionately burden smaller firms that may lack the resources to comply with extensive regulatory requirements. The SEC should consider providing additional support and guidance to small advisers to facilitate their compliance with the rule. In conclusion, while the SEC's proposed rule aims to enhance investor protections and address gaps in the custody rule, certain aspects raise significant concerns. Clarity on the definition of digital assets, adequate consideration of privacy and security concerns, and a comprehensive framework for safeguarding client assets are essential. Furthermore, it is crucial to carefully evaluate the impact on compliance costs for investment advisers, especially smaller firms. I urge the SEC to address these concerns and ensure that any final rule strikes the right balance between investor protection and regulatory burden. Thank you for considering my comments. I believe that transparent and balanced regulations are crucial for the health and stability of the financial industry. I hope that my concerns, along with those of other concerned investors, will be carefully considered and addressed. Sincerely, Joshua M. Miller