Oct. 22, 2023
Public Comment on Proposal "Safeguarding Advisory Client Assets" Dear Securities and Exchange Commission, I am writing to provide my comments and concerns regarding the proposed rule on "Safeguarding Advisory Client Assets". While I appreciate the Securities and Exchange Commission's efforts to enhance investor protections and address gaps in the custody rule, I have several reservations regarding the proposed regulations. Unequal Treatment of Different Types of Digital Assets One of the key concerns that I would like to address is the unequal treatment of different types of digital assets in the proposed rules. It is crucial to recognize that digital assets are a diverse category, and treating them inconsistently could create confusion and potentially lead to regulatory arbitrage. The proposed regulations do not provide clear guidance on how to handle various forms of digital assets, leading to uncertainty and hampering the growth and innovation in this space. Too Sudden Implementation Moreover, I am concerned about the timeline for implementing these proposed regulations. The proposed rules will come into effect before companies and protocols have had adequate time to adjust and accommodate the new requirements. An abrupt implementation could result in unintended consequences, additional compliance burdens, and could hinder the ability of market participants to effectively comply with the new regulations. Impact on the Global Market It is also important to consider the potential impact of these proposed regulations on the global market. Given the global nature of the digital asset industry, any regulations put forth by the Securities and Exchange Commission will have implications beyond the United States. It is essential to align the proposed rules with international standards and engage in meaningful dialogue with global stakeholders to ensure an appropriate and harmonized regulatory framework. In conclusion, while I believe that investor protection is of paramount importance, I have concerns regarding the unequal treatment of different types of digital assets in the proposed rules. Additionally, the abrupt implementation and potential impact on the global market warrant careful reconsideration and further discussions. I urge the Securities and Exchange Commission to consider these concerns and engage in a transparent and collaborative process with industry participants. Thank you for the opportunity to provide feedback on this important matter. I trust that my comments will be taken into consideration during the rule-making process. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Sincerely,