Mar. 2, 2023
Dear SEC, I am writing to comment on the proposal regarding “Safeguarding Advisory Client Assets.” If discretionary trading authority—alone—would be enough to trigger “custody,” according to this new rule, PLEASE RECONSIDER THIS PROPOSAL! In an industry that is already filled with regulations and paperwork, this would add an unnecessary and unproductive burden. As RIAs and CFPs, we are already acting as fiduciaries for our clients. Additional forms and legalese only slow down the process of helping clients and offer no actual benefit to them. Please do NOT make a rule for it to be “custody” for advisors merely to have discretionary trading authority. Thanks, John D. Lee, CFP®, MBA Managing Partner, Financial Advisor