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