Oct. 22, 2023
Dear Securities and Exchange Commission, I am writing to share my concerns regarding the proposed rule, "Safeguarding Advisory Client Assets." While I understand the aim to enhance investor protections and address gaps in the custody rule, I believe there are certain aspects of the proposal that may have negative consequences. Specifically, I would like to address the potential negative impact on financial inclusion, the timing of implementation, and the impact on the international market. Firstly, the proposed rules may inadvertently limit the ability of underserved populations to access digital assets and participate fully in the financial system. As the digital assets market continues to evolve, it is important to ensure that regulatory measures do not disproportionately hinder marginalized communities from accessing financial services. Any new regulations should be carefully balanced to promote both market integrity and inclusivity. Furthermore, I am concerned about the timeline for implementation. The proposed rule seems to be too sudden, especially considering that companies and protocols may need additional time to ensure compliance. Rushing the implementation before market participants are adequately prepared may lead to unintended disruptions and hinder responsible innovation in the financial sector. It is essential to provide sufficient lead time for market participants to adapt their systems and processes accordingly. Additionally, the proposed rule may have implications beyond domestic markets. In the increasingly interconnected global economy, regulations implemented by the SEC can have ripple effects across borders. It is crucial to assess and consider the impact on the international market, specifically with regards to differing regulatory frameworks and potential conflicts. Collaboration and coordination with international regulatory bodies would be beneficial to ensure consistency and minimize unintended consequences on cross-border investments and business activities. In conclusion, while I acknowledge the SEC's efforts to enhance investor protections, I urge the Commission to carefully consider the potential negative impact on financial inclusion, provide sufficient time for implementation, and consider the international implications of the proposed rule. Striking the right balance between safeguarding investor assets and fostering innovation is essential for the future health and growth of the financial industry. Thank you for the opportunity to comment on the proposed rule. Sincerely, Mark Borham Sent from Yahoo Mail on Android