Feb. 15, 2023
February 15, 2023 I'm a believer in qualified custody, and believe RIAs should utilize trusted regulated entities to secure assets on behalf of clients. If the SEC were to expand the requirement of the custody rule, I believe it is also imperative to ensure there are viable and affordable qualified custodians which have regulatory approval to allow advisors to utilize their services. Specifically private securities, which are in high demand by clients of RIAs and will expand greatly over the next decade. Most major qualified custodians struggle to manage private securities given their complexities, which alone has created a shadow industry of private exempt managers. If the SEC were to improve, streamline, and simplify the process in which qualified custodians can service private securities, I believe this would have a great benefit to the greater investor audience. As per Crypto, I also agree that qualified custodians are essential to protect investors - and thus there needs to be clear rules and gu idelines for how a QC can support crypto assets (or crypto securities). These rules again need to be streamlined and not cost prohibitive, as investors will ultimately suffer if the costs are too high and not servicable. I believe with clear rules and guidelines, which are not draconian and costly, for how QCs can support private securities and crypto will lead to FAR better client security and benefit investors greatly. As the SEC and protector of investors, clarity and support for how QCs can comply is essential here - as the current landscape breeds more questions than answers, leading to regulatory purgatory and putting investor protection in the balance. I encourage the SEC to NOT pass this rule without first providing clear guidelines for how qualified custodians can meet these requirements, and allowing current custodians to comment on the feasibility of meeting these requirements in a reasonable timeframe.