Oct. 14, 2023
Hey there, Chair Gensler, I tell ya what, I got some real deep concerns about that there Proposed Rule - Safeguarding Advisory Client Assets, Release No. IA-6240, dated February 15, 2023, by the U.S. Securities and Exchange Commission. I'm all riled up 'cause when I look at it, I see some problems, man. Now, here's the thing, this proposal could accidentally start meddlin' with them CFTC-regulated folks. Y'see, that could throw the whole U.S. derivatives and commodities markets into a real tizzy, and that ain't good for our farmers and producers, man. We're talkin' 'bout a lack of cooperation with the CFTC, the big dogs of the U.S. derivatives markets, which is mighty concerning 'cause those markets are crucial to our economy and all that risk management and price discovery stuff. This here proposal could go messin' around with futures commission merchants, commodity trading advisors, commodity pool operators, and swap dealers, and they already got rules they gotta follow under the CFTC. It might mess with advisory clients tryin' to get into them swaps contracts, and that don't make no sense, 'cause there's been a decade of decision-makin' and coordination with regulators, both here and abroad. Now, this proposal's talkin' 'bout messin' up commodity markets, from agriculture to energy to them digital commodities. They want a verification process for every transaction, and that could cause some major damage to the U.S. economy, you hear me? Protectin' investors is a noble goal, but this proposal looks like it might do the opposite. It's makin' big changes to custody rules without a good reason, and that could hurt investors' access to services and markets with rules that've been working just fine. We gotta think this through. Economically speakin', this proposal's takin' a sharp turn from the usual custody practices, and it's gonna jack up the cost of custodial services big time. And they're usin' the SEC's power over registered investment advisors to mess with stuff outside their usual jurisdiction. No proper economic analysis, and they're sayin' they don't even know the costs? That sounds kinda reckless, man. This here proposal wants to shake up the way we do traditional custody, even though custodians been modernizing for a long time. And they're talkin' asset-neutral and all that, which could mess up banks and the digital assets too. It ain't good. All these problems got me worked up, and I reckon the Commission should scrap this proposal. The CFTC's way of handlin' things works for our agriculture folks and American businesses, and any proposal messin' with liquidity and customer protection in them markets ain't right. I'm also sayin', if they wanna come up with new rules, they gotta do a good economic analysis, focus on the places where the current rules ain't doin' their job, and talk to the folks who know what's goin' on in them markets and products. I'm appreciatin' the chance to share my thoughts, and I'm ready to talk some more 'bout findin' a better way to protect investors without messin' up things like this proposal might. You take care now, y'hear?