Subject: File No. S7-04-23
From: Matt Frazier

Dear Securities and Exchange Commission, I am writing to express my concerns regarding the "Safeguarding Advisory Client Assets" proposal. While I understand the importance of protecting investor assets, I believe that the proposed rule places a disproportionate burden on small businesses and startups, particularly in the digital asset industry. The additional compliance requirements and reporting obligations outlined in this proposal could stifle innovation and hinder the growth of these businesses. One major concern is the impact this proposal will have on small businesses. The reporting requirements outlined in the rule will require small businesses and startups to track personal identifiable information that they would not otherwise be required to monitor. Implementing such tracking protocols comes with significant expenses and administrative burdens. For many of these businesses, already operating on tight budgets, these additional costs will put them at a disadvantage in the market and curtail their ability to innovate. Furthermore, the proposal fails to consider the unique characteristics of the digital asset industry. It is well-known that the digital asset market operates differently from traditional markets. The proposed rule fails to adequately address the nuances and challenges associated with safeguarding digital assets. Instead, it imposes a one-size-fits-all approach that does not account for the diverse range of assets and custodial practices within the digital asset industry. As a result, these businesses will be subjected to unnecessary compliance requirements that may not be suitable for their specific assets and business models. The burden placed on small businesses and startups by this proposed rule creates an unlevel playing field and inhibits their ability to compete in the market. Not only does this stifle innovation, but it also hampers economic growth and job creation within the digital asset industry. Instead of fostering an environment that encourages entrepreneurship and the development of cutting-edge technologies, this proposal hinders progress and restricts market participation. In the interest of promoting a fair and inclusive regulatory framework, I urge the Securities and Exchange Commission to reconsider the burden that this proposal places on small businesses and startups. It is crucial to strike a balance between investor protection and providing an environment conducive to innovation. I implore the agency to take into account the unique challenges faced by small businesses and startups in the digital asset industry and work towards crafting a more tailored and flexible regulatory approach. Thank you for considering my comments. I hope that you take into account the concerns raised by stakeholders in the digital asset industry to ensure a regulatory framework that encourages innovation and growth for small businesses and startups. Sincerely, Matt