Subject: S7-04-23: Webform Comments from Jeremy Donovan
From: Jeremy Donovan
Affiliation:

Oct. 22, 2023

Dear SEC,

I am writing to provide my public comment on the proposed rule,
"Safeguarding Advisory Client Assets," issued by the
Securities and Exchange Commission (SEC). While I understand the
objective of enhancing investor protections and addressing gaps in the
custody rule, I have concerns regarding the potential negative impact
on decentralized finance (DeFi) and the risk of identity theft
associated with the proposed regulations.

Firstly, I would like to express my concerns about the potential
hindrance to the growth and development of DeFi projects. DeFi has
emerged as an innovative and decentralized financial system that
promotes financial inclusion, removes intermediaries, and provides
opportunities for individuals who are underserved by traditional
financial institutions. By imposing stringent regulations,
particularly when it comes to collecting user information, we risk
stifling this promising sector and limiting its potential benefits.
Striking a balance between investor protection and encouraging
innovation should be a priority for the SEC.

Additionally, I am troubled by the requirement for DeFi participants
to collect sensitive taxpayer information under the guise of tax
reporting. This raises serious concerns about the security and
protection of user data. DeFi platforms are built on trust and
security, but by mandating the storage of such information without
proper safeguards, we open the door to potential data breaches and
identity theft. We must be mindful of the unintended consequences that
could result from these requirements and ensure that proper measures
are in place to protect users' confidential information.

Moreover, I believe that the proposed regulations may inadvertently
encourage the creation of honey pots for identity theft. The
accumulation of vast amounts of sensitive taxpayer information in the
custody of DeFi participants creates a tempting target for malicious
actors seeking to exploit vulnerabilities in the system. We need to
carefully consider the potential risks associated with the proposed
regulations and find alternative ways to safeguard client assets
without jeopardizing user privacy and security.

It is important to recognize that DeFi projects have shown immense
potential in providing financial services to underserved individuals
and communities. By embracing decentralized finance and striving to
understand its unique characteristics, we can foster innovation and
promote financial inclusion. The proposed regulations, as they
currently stand, have the potential to hinder the growth of this
promising sector and limit its ability to deliver on its promises.

In conclusion, I urge the SEC to reevaluate certain aspects of the
proposed rule that may have a negative impact on decentralized
finance. Specifically, I recommend the commission carefully consider
the potential risks of identity theft and the accumulation of
sensitive taxpayer information. Let us work together to strike a
balance between investor protection and innovation, ensuring that we
build a regulatory framework that fosters growth, inclusivity, and
security in the decentralized finance space.

Thank you for considering my concerns. I appreciate the opportunity to
provide my input on this matter.

Sincerely,

Jeremy Donovan