Oct. 14, 2023
As a concerned citizen and advocate for the cryptocurrency and digital asset community, I strongly oppose the proposal "Safeguarding Advisory Client Assets; Reopening of Comment Period" by the Securities and Exchange Commission (SEC). While I recognize the importance of investor protection, I believe that the SEC's approach to regulating cryptocurrency and digital assets is excessive and could have detrimental effects on innovation and economic growth. Firstly, it is crucial to acknowledge that cryptocurrencies and digital assets operate on decentralized networks, which inherently provide a level of security and transparency. The SEC's attempt to impose custodial requirements, as outlined in the current custody rule (17 CFR 275.206(4)–2), fails to consider the unique nature of these assets. Cryptocurrencies are designed to be held and transacted by individuals directly, without the need for intermediaries. Imposing traditional custodial requirements on these assets would not only be impractical but also hinder the growth and adoption of this technology. Furthermore, the SEC's proposal overlooks existing laws and regulations that already provide oversight for cryptocurrencies and digital assets. For example, the Financial Crimes Enforcement Network (FinCEN) has implemented robust anti-money laundering (AML) and know-your-customer (KYC) regulations for virtual Tervitades/ Best regards, Lorenz Juhanson Tel: 5354 1212