Oct. 14, 2023
Dear whomever it may concern at the SEC, Warning: An impending comedy with real concerns intertwined: I'm putting pen to paper, but not for a love letter. No, I'm writing to express my inner turmoil, which, by the way, is as profound as a cat trying to understand quantum physics while chasing a laser pointer. It's all about the U.S. Securities and Exchange Commission's (yes, the Commission, the folks with all the rules) latest hit sensation, the "Safeguarding Advisory Client Assets" rule. I grabbed some popcorn and dissected this thing from all angles, and let me tell you, it's like trying to read Shakespeare after too much coffee - confusing as heck! But I'll say this... We love the idea of protecting investors, but this rule? It could end up limiting their access to all the good stuff - services, assets, and well-established markets. They're changing custody rules without a clear plan. This rule threatens to mess with futures commission merchants, trading advisors, and other market whizzes who are already following strict rules. It's like giving a kid three scoops of ice cream when they're perfectly content with one. Plus, your average Joe might find it harder to get into those swap contracts they love so much. We've had a decade of coordination on this stuff, and now it's all up in the air. The SEC seems to think it's a good idea to make every commodity transaction go through a ridiculous verification process. It's like saying, "Hey, let's put a marathon finish line at the end of a tightrope!" That could seriously mess with the economy. This proposal seems to think the economy is made of Monopoly money. It's a game-changer for custodial services, and the SEC is reaching out its arm to places it shouldn't. The SEC doesn't even know how much this will cost! It's like trying to buy a car when you have no idea what's in your wallet. They want to flip the script on traditional custody, even though custodians have been doing just fine. It just doesn't make sense, and I question if it's even possible for the SEC to not know that... actually it's impossible. I mean no disrespect, I just don't know why?? In short, this proposal is like juggling flaming swords in a room full of helium balloons – it's dangerous, and we're all gonna get hurt. So, do us a favor and scrap it, pronto! We believe in the CFTC's magic touch in the market, and any shenanigans that mess with liquidity and customer protection are not cool. Plus, here's a tip: Next time you want to make rules, check your piggy bank and, oh, I don't know, maybe talk to the experts first? Thanks for letting me vent. I'm 100% certain the community can help you brainstorm some genius alternatives that actually protect investors without turning the financial world into a circus. -another human being