Subject: S7-04-23: Webform Comments from Darnel Ottoman
From: Darnel Ottoman
Affiliation:

Oct. 28, 2023

To Whom it May Concern,

I am writing to express my concerns regarding the proposed rule
"Enhancing Safeguards for Advisory Client Assets" (File No.
S7-04-23) recently introduced by the SEC. While I acknowledge the
efforts to enhance investor protection and address gaps in the custody
rule, there is a need for clearer guidance, especially concerning the
treatment and definition of digital assets, such as cryptocurrencies.

In the rapidly evolving landscape of digital assets, it is crucial to
establish a regulatory framework that acknowledges their unique
features while ensuring investor protection. I recommend providing
explicit definitions and guidelines for the treatment of digital
assets within the proposed rule.

Additionally, considering the dynamic nature of the digital asset
market, continuous monitoring and periodic updates are essential to
maintain the effectiveness of regulatory measures. It is vital to
assess the costs and benefits comprehensively, particularly for
qualified custodians and smaller market participants.

I urge the SEC to strike a balance between encouraging innovation,
fostering competition, and supporting capital formation while
safeguarding investor interests. Thank you for providing a platform
for open dialogue.

Sincerely,
Mr. Ottoman