Subject: S7-04-23: Webform Comments from Cecilia Contreras Villarreal
From: Cecilia Contreras Villarreal
Affiliation: Young Entrepreneurs Commission Former President, COPARMEX Laguna

Oct. 22, 2023

As an individual who is deeply involved in the
cryptocurrency and digital asset space, I am deeply concerned about
the proposed legislation by the SEC regarding the safeguarding of
advisory client assets. While I understand the need for regulatory
oversight in this rapidly evolving industry, I believe that the
SEC's approach in this particular proposal is an overreach that
could stifle innovation and hinder the growth of this promising
technology.

First and foremost, it is important to recognize that cryptocurrencies
and digital assets are fundamentally different from traditional
securities. They operate on decentralized networks and are not subject
to the same rules and regulations as traditional financial
instruments. Therefore, applying the same regulatory framework to
these assets is not only impractical but also counterproductive.

Furthermore, the SEC's proposal fails to take into account the
existing laws and regulations that already govern the cryptocurrency
industry. For example, the Financial Crimes Enforcement Network
(FinCEN) has already established robust anti-money laundering (AML)
and know-your-customer (KYC) requirements for cryptocurrency exchanges
and other virtual asset service providers. These regulations ensure
that illicit activities are minimized and that investors are
protected.

Additionally, the SEC's proposal could have a chilling effect on
innovation in the cryptocurrency space. By imposing burdensome
regulatory requirements on advisory firms that deal with digital
assets, the United States loses a competitive edge against the rest of
the world.