Subject: S7-04-23: Webform Comments from Individual
From: JP
Affiliation: None

Oct. 24, 2023

[Your Address]
[City, State, ZIP Code]
[Date]

Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Subject: Safeguarding Advisory Client Assets - Proposed Rule and
Amendments

Dear Sir/Madam,

I write regarding the proposed rule and amendments on the safeguarding
of advisory client assets, as published by the Securities and Exchange
Commission (SEC) on [proposal publication date]. While I appreciate
the SEC's efforts to enhance investor protections and address the
gaps in the custody rule, I believe there are certain aspects of the
proposed rules that require further clarity and consideration.

Specifically, I would like to express my concerns regarding the lack
of clarity in the definition and treatment of digital assets within
the proposed rule. The rapid evolution of digital assets, such as
cryptocurrencies, has transformed the financial landscape, and it is
crucial to provide clear guidance on how these assets should be
treated and safeguarded by investment advisers.

By failing to define what constitutes a digital asset, the proposed
rule introduces confusion and potential misinterpretation. Given the
increasing prevalence of digital assets in investment strategies and
their unique nature, it is essential for the SEC to provide clear
guidelines to ensure investor protection and regulatory compliance.

Digital assets present inherent challenges for custody and control due
to their decentralized and distributed nature. Without clear guidance,
investment advisers may struggle to implement adequate safeguards for
these assets, exposing clients to increased risk. By defining digital
assets within the proposed rule, the SEC can provide the industry with
the necessary framework to ensure investor protections while fostering
innovation in the emerging asset class.

I commend the SEC for recognizing the need to address the safeguarding
of client assets in the advisory industry. However, it is crucial to
squarely tackle the issues around digital assets to ensure effective
investor protections within this evolving landscape. I strongly urge
the SEC to incorporate a comprehensive and unambiguous definition of
digital assets in the final rule, considering input from industry
experts and stakeholders.

I appreciate the opportunity to provide feedback on this proposal. As
a concerned individual with a vested interest, I believe it is crucial
for the SEC to consider the potential ramifications and ensure that
the final rule effectively addresses the challenges posed by digital
assets.

Thank you for your attention to this matter. I stand ready to provide
any further input or clarification to assist the SEC in crafting a
robust and effective rule that upholds investor protections in the
advisory industry.

Sincerely,
JP