Oct. 10, 2023
Dear Securities and Exchange Commission, I am writing to address the proposal regarding the safeguarding of advisory client assets. It’s imperative that the conceptual foundation of regulations be accurate to ensure fairness and effectiveness. Cryptocurrencies are often misconceived as possessable assets. However, they fundamentally represent knowledge, specifically, the knowledge of private keys, rather than tangible, possessable goods. A private key is akin to a piece of information; its loss does not equate to the loss of possession. This distinction should be the cornerstone of any regulatory framework around cryptocurrencies, ensuring that laws are based on the nature of blockchain as a technology of knowledge and verification of truth. I advocate for a regulatory approach that acknowledges the inherent nature of cryptocurrencies, treating them as units of knowledge, and focusing on the management and dissemination of information rather than possession and custody. It is crucial that regulatory structures are adapted to embrace the potential of blockchain technology in fostering a new era of progress and transparency. Thank you for considering this perspective, and I urge you to integrate this understanding in the development of future regulations. Sincerely, Nia Toliver