Oct. 21, 2023
Adrian Wdowiak Sansome street 16 apartment 5 Worcester WR11UH UK kryptosfera1@gmail.com 21.10.2023 Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Safeguarding Advisory Client Assets (File No. [Insert File Number]) To Whom It May Concern, I am writing to provide public comment on the proposed rule titled "Safeguarding Advisory Client Assets," filed by the Securities and Exchange Commission (SEC). I appreciate the opportunity to express my concerns and provide feedback on this important matter. Privacy and data security are of utmost importance in today's digital environment, particularly when it comes to sensitive financial information and personal data such as social security numbers. While I understand the need to protect client assets and enhance investor protections, I have concerns regarding the privacy implications of the proposed rule. Under this rule, investment advisers would be required to provide custodian information and custodial account numbers to clients when opening an account. While this information is vital for transparency and investor trust, it raises concerns about the privacy and safety of sensitive client data. The increased disclosure of this information to multiple parties poses potential risks of data breaches, identity theft, and unauthorized access to personal financial information. I urge the SEC to carefully consider the privacy implications of the proposed rule and take necessary steps to ensure that appropriate safeguards are in place to protect client data. This can be achieved through stringent data protection measures, including encryption, secure communication protocols, and robust cybersecurity frameworks. Additionally, I would like to express my concerns regarding potential overreach of the SEC's regulatory authority. It is essential that regulatory agencies operate within their designated areas of expertise and authority. While the SEC has a crucial role in safeguarding investor interests, there exist other agencies and regulatory frameworks that focus specifically on privacy and data protection. The proposed rule may inadvertently encroach upon the authority and expertise of these other agencies. It is crucial that the SEC collaborates and coordinates with other relevant agencies, such as the Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (CFPB), to ensure a comprehensive and cohesive regulatory framework that addresses both investor protection and data privacy issues. In addressing the privacy concerns associated with the proposed rule, the SEC can benefit from the expertise and resources of these agencies, which have extensive experience in regulating data privacy and security. This collaboration would prevent regulatory overlap and ensure that the appropriate agency is responsible for overseeing and enforcing data protection standards. Furthermore, I emphasize the need for clear guidelines and limitations on how third parties can access, handle, and store the sensitive financial and personal data supplied by clients. Robust contractual agreements and data governance practices should be established to protect client privacy and establish accountability throughout the entire ecosystem of providers involved in safeguarding client assets. In conclusion, while I acknowledge the importance of enhancing investor protections and addressing gaps in the custody rule, I urge the SEC to carefully consider the privacy implications of the proposed rule. Collaboration with relevant agencies and the implementation of robust privacy safeguards can strike a balance between protecting investor interests and ensuring the privacy and security of client data. Thank you for considering my concerns and feedback on this matter. I trust that the SEC will take into account the importance of privacy in conjunction with investor protection and act accordingly. Should you require any further information or clarification, please do not hesitate to contact me. Sincerely, Adrian Wdowiak [Your Signature] (Note: The signature is optional if submitting the comment electronically)