Dear Securities and Exchange Commission, I am writing to share my concerns regarding the proposal titled "Safeguarding Advisory Client Assets." While I understand the objective of enhancing investor protections and addressing gaps in the current custody rule, there are aspects of the proposed rule that raise potential issues of overreach and disproportionate impact. Additionally, there are areas where the proposed rule lacks clarity and may lead to unintended consequences. One area that requires careful consideration is the treatment of digital assets, particularly cryptocurrencies built on blockchain technology. While these digital assets have the potential to transform the financial industry, their regulatory landscape is still uncertain. Imposing strict custody requirements on these assets without sufficient consultation and monitoring could hinder innovation and place disproportionate burdens on investment advisers. The lack of clear standards and guidelines may also result in regulatory inefficiency and ambiguity. Furthermore, the proposed rule introduces unreasonable deadlines and imposes impractical requirements, which could create difficulties for investment advisers in implementing the necessary safeguards. The ambiguity in definitions and requirements may lead to inconsistency in enforcement and confusion among market participants. This could result in unfair market advantages for some and create a disadvantage for others, particularly small businesses. It is also worth noting that the proposal may have a detrimental impact on taxpayer rights and privacy. The rules appear to ignore important considerations such as due process, administrative practicability, and past policy precedents. By imposing burdensome recordkeeping and reporting obligations, the proposal could impose undue hardship on taxpayers and infringe upon their rights. Additionally, the lack of online services and the absence of clear procedures and guidelines hinder access to justice and appeals. Moreover, the economic analysis accompanying the proposal raises concerns about its basis and impact. The analysis seems to lack empirical support and fails to adequately consider the economic realities and potential consequences. The proposed rule may create a windfall for the IRS while shifting costs onto taxpayers, small businesses, and minority investors. This could undermine domestic investment and harm struggling families who rely on investment advisers for financial guidance. I also find it essential to emphasize that there appears to be insufficient stakeholder input, including businesses and investors in the advisory industry. Effective regulation should take into account diverse perspectives, and a lack of consultation may lead to regulatory fragmentation and ineffective communication. Additionally, the complexity of the proposed rules raises serious concerns. The rules appear too convoluted and burdensome, hindering compliance and impairing access to important legal protections and appeals. This complexity also leads to increased compliance costs, particularly for small businesses, without proportional benefits or clear objectives. In conclusion, while I acknowledge the intentions behind the proposed rule, I am concerned about potential overreach, a lack of clarity, and disproportionate impact. The proposal should be reconsidered to avoid impeding innovation, harming taxpayers and investors, and disproportionately burdening small businesses. I urge the Securities and Exchange Commission to take these concerns into consideration and to seek a regulatory approach that balances investor protections with a reasonable and effective framework. Thank you for considering my comments and for the opportunity to contribute to the ongoing discussion on this important matter. Sincerely,