Oct. 23, 2023
Thank you for your interest in the proposed rule "Safeguarding Advisory Client Assets" by the Securities and Exchange Commission. I appreciate the opportunity to provide public comment on this important matter. I would like to express my concerns regarding the potential negative impact of the proposed rule on investor access to digital assets, specifically cryptocurrencies. The emergence of digital assets, built on blockchain technology, has transformed the financial landscape and opened up new investment opportunities. However, regulatory uncertainties around these assets pose significant challenges. While the proposed rule aims to enhance investor protections and safeguard client assets, it may inadvertently restrict investor access to digital assets. Cryptocurrencies, in particular, have gained popularity due to their decentralized nature and ability to provide financial inclusion to underserved communities. Restricting access to these emerging asset classes could limit investors' opportunities for wealth creation and participation in the global digital economy. The proposed rule should carefully consider the unique characteristics of digital assets and their role in motivating innovation, economic growth, and financial inclusion. Rather than imposing burdensome regulations that stifle investor access, the SEC should seek ways to balance investor protection with the ability to support the growth of emerging asset classes. A nuanced approach is necessary to address the concerns surrounding cryptocurrencies without hindering investor access. Rather than being overly prescriptive, the SEC should focus on providing clear guidelines that encourage responsible practices and ensure adequate safeguards, while still allowing for the natural evolution and innovation within the digital asset space. Additionally, it is essential that the SEC coordinates efforts with other regulatory bodies both domestically and internationally to establish consistent frameworks for digital asset regulation. This will help promote investor confidence, foster innovation, and prevent regulatory arbitrage. Furthermore, the SEC should consider consulting with industry experts, technologists, and investors actively involved in the digital asset space to ensure that any regulations are informed and reflective of the unique characteristics and challenges of these assets. In conclusion, while investor protection is of paramount importance, it is crucial that the SEC takes into account the potential negative impact of the proposed rule on investor access to digital assets. Balancing regulation with innovation will allow for responsible growth and ensure that investors can participate in this evolving asset class. I encourage the SEC to adopt measures that promote investor protection without unnecessarily impeding the dynamic and transformative potential of digital assets. Thank you for considering my comments on the proposed rule. I look forward to the SEC's thoughtful consideration of the concerns raised by various stakeholders during this comment period. Sincerely, Peter Juiris