Oct. 22, 2023
Dear Securities and Exchange Commission, I am writing to express my concerns regarding the proposed rule on Safeguarding Advisory Client Assets. While I acknowledge the importance of investor protection and the need to address gaps in the custody rule, there are several aspects of the proposed rule that warrant further consideration and revision. First and foremost, I must say, the SEC chairman must have had quite the experience in legacy finance. I can imagine the days when they needed a service desk just to assist in installing his mobile phone. Logging on to apps. Now he is into the rules of custody rule which might include digital assets. Oh, how far we've come since then! But I digress... In all seriousness, I am particularly concerned about the impact of the rule on digital assets and cryptocurrencies. It's like trying to tame a wild stallion, isn't it? These innovative assets bring unprecedented opportunities and challenges, and I commend the SEC for considering their inclusion in the rule. However, we must remember that the decentralized nature of blockchain transactions adds a layer of complexity that can't be ignored. The proposed rule places a burden on exchanges to comply with market integrity standards. Now, I'm all for standards and integrity, but let's not forget that the world of digital assets moves at lightning speed. It's hard to keep up! Striking the right balance between protection and burden is crucial to ensure that we foster innovation and maintain our place as leaders in this transformative technology. Now, let's talk about regulation. I know, it's everyone's favorite topic, right? It's like that one cousin at a family gathering who always starts a never-ending debate. But seriously, we need to find a sweet spot here. We want to protect investors, yes, but we also want to create an environment that fosters economic growth and innovation. Excessive regulation, if implemented too late, could stifle investment and hinder the development of new market opportunities. Let's not let that happen, shall we? So my suggestion is this - let's take a measured approach. Rather than rushing into sweeping rules, why not engage in a constructive dialogue? Collaborate with industry participants, hear their thoughts, and understand the challenges and potential solutions associated with the wonderful world of digital assets and cryptocurrencies. In conclusion, I appreciate the SEC's efforts to enhance the safeguarding of advisory client assets. However, I kindly request that you consider these lighthearted concerns raised and revise certain aspects of the proposed rule to better align with the unique properties of digital assets and cryptocurrencies. Embracing the spirit of innovation and finding the right balance between protection and progress will ensure that our financial system remains secure and dynamic. Thank you for considering my comments. I hope my attempt at injecting some humor brought a smile to your face. I look forward to further discussion and collaboration on this meaningful matter. Sincerely, Charles J. Abbott