Oct. 22, 2023
Dear Securities and Exchange Commission, I am writing to express my significant concerns regarding the proposed rule "Safeguarding Advisory Client Assets" and its potential encroachment on privacy rights. As an investor, I firmly believe that any regulation in the financial industry should prioritize both the protection of client assets and the safeguarding of individual privacy. First and foremost, I am deeply troubled by the lack of consideration for privacy implications associated with the proposed rule. The rule requires investment advisers to provide detailed custodian information, including sensitive financial data and social security numbers, to clients. While investor protection is of utmost importance, it is equally vital to prioritize the privacy and security of personal information. Exposing such sensitive information to numerous third parties significantly increases the risk of identity theft, fraud, and unauthorized use. I implore the SEC to thoroughly evaluate the privacy implications of the proposed requirements and implement robust safeguards to protect investors' personal information. Additionally, it is crucial that the SEC provides clear and comprehensive guidelines for blockchain governance within the proposed rule. Blockchain technology has the potential to revolutionize the financial industry by introducing decentralized decision-making processes and enhancing transparency. However, the lack of regulatory clarity surrounding the adoption and governance of blockchain solutions hinders innovation and limits the industry's ability to fully leverage the benefits of this emerging technology. The SEC must establish clear regulatory frameworks to ensure the proper and secure governance of blockchain solutions within the proposed rule. Furthermore, the economic analysis provided by the SEC must thoroughly consider the potential costs and burdens imposed on investment advisers by the proposed rule. Compliance costs can particularly burden smaller entities, limiting their ability to provide high-quality advisory services. It is vital to strike a balance between protecting investors and imposing cumbersome requirements that disproportionately affect smaller firms. The SEC should carefully assess the economic impact of the proposed rule on both advisers and investors, ensuring fair regulatory frameworks that are both feasible and effective. In conclusion, I urge the SEC to address the lack of regulatory clarity surrounding blockchain governance and place a far greater emphasis on safeguarding individual privacy rights within the proposed rule. It is essential that any regulatory framework in the financial industry not only ensures the protection of client assets but also upholds the privacy and security of personal information. I appreciate the opportunity to provide this public comment, and I trust that the SEC will give serious consideration to these concerns during the finalization of the rule. Sincerely, Daniel Gibbs