Oct. 25, 2023
Ramses Ful [REDACTED] 10/24/23 Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Subject: Public Comment on "Safeguarding Advisory Client Assets" Proposal Dear Sir/Madam, I am writing to submit my public comment on the "Safeguarding Advisory Client Assets" proposal (File Number S7-15-20) by the Securities and Exchange Commission. I appreciate the opportunity to provide feedback on these important rule amendments that aim to enhance investor protections. While I acknowledge the need for safeguarding client assets, I have concerns regarding the burden imposed on small businesses and startups, particularly in the digital asset industry. The proposed rules, as outlined in the discussion section of the proposal, introduce reporting requirements that would necessitate small businesses and startups to track personal identifiable information. This places a considerable burden on these entities that would not otherwise be required to implement such tracking protocols. These additional compliance costs could potentially hinder the growth and innovation of small businesses and startups in the digital asset industry, creating an unnecessary disadvantage compared to their larger counterparts. Furthermore, burdensome requirements may have unintended consequences by deterring small businesses and startups from entering the digital asset industry or exploring new technologies. Other countries have demonstrated success in rapidly iterating and harnessing new technologies without overreaching regulatory measures that stifle growth and innovation. It is important for the Commission to consider the global competitive landscape and strike a balance between investor protections and fostering technological advancements in the United States. As the digital asset industry continues to evolve, it is crucial for regulatory frameworks to adapt and embrace innovation rather than stifling it. Instead of imposing excessive costs and administrative burdens on small businesses and startups, the Commission should explore alternative approaches that balance investor protections while allowing for entrepreneurial activity in this emerging field. This could involve providing flexibility in compliance requirements for small businesses and startups, ensuring that investor protections are upheld without impeding their growth potential. I urge the Commission to reevaluate the proposed reporting requirements and consider the impact they will have on small businesses and startups in the digital asset industry. By promoting an environment that fosters innovation and growth, the Commission can position the United States as a global leader in the digital asset industry while maintaining necessary safeguards for investor protection. Thank you for considering my comments on this important matter. I trust that you will carefully review and take into account the concerns raised, ensuring that the final rules strike an appropriate balance that encourages innovation, protects investors, and allows small businesses and startups to thrive in the digital asset industry. Sincerely, Ramses Ful