Subject: File Number S7–04–23
From: Dan Pollock
Affiliation:

Oct. 15, 2023

The introduction of this proposed rule raises concerns about potentially higher regulatory costs for cryptocurrency users like myself, which could act as a deterrent for newcomers and pose challenges for existing participants. Additionally, this heightened regulation could potentially compromise our privacy. 

The implementation of these new requirements, such as the demand for third-party custodians and surprise audits, could introduce operational complexities for cryptocurrency users. Not only might this create an administrative burden, but it also raises concerns about how our private financial data and cryptocurrency holdings may be handled and accessed. 

It's concerning how this rule could limit the flexibility cryptocurrency users have in managing their digital assets. The mandate for third-party custodians and surprise examinations might reduce our ability to control and transact with digital assets as we see fit, further impacting our privacy in the crypto space. 

The increased regulatory demands could significantly raise our administrative workload and may necessitate sharing more private information, which raises additional privacy concerns. 

I'm worried that this proposal might lean toward overregulation, introducing an unnecessary set of rules that could stifle innovation in the cryptocurrency space and even discourage us from using certain crypto services or assets, exacerbating privacy issues. 

As a cryptocurrency user, it's clear to me that this proposed rule doesn't adequately acknowledge the diversity among crypto participants. Applying the same rules to all users, regardless of their level of involvement or specific use cases, seems shortsighted and could lead to unintended consequences, including privacy risks. 



- Dan Pollock