Oct. 28, 2023
Dear Securities and Exchange Commission (SEC), Regarding the proposed rule "Safeguarding Advisory Client Assets", as a concerned U.S. citizen, I would like to submit my public comment for your careful consideration. While the Securities and Exchange Commission (SEC) is taking crucial steps to enhance investor protections, I have several concerns about the proposed rule, particularly regarding the inadequate consideration of self-custody solutions and the challenges posed by digital assets. Firstly, I am concerned that the proposed rule does not adequately consider self-custody solutions, which can hinder the development of user-controlled asset management. Self-custody provides investors with the ability to maintain control and possession of their own assets, reducing the reliance on third-party custodians. The importance of self-custody in the asset management landscape cannot be overstated, especially as advancements in decentralized technologies such as blockchain are revolutionizing the financial industry. Digital assets, including cryptocurrencies, have emerged as a promising alternative investment class, built on the foundation of blockchain technology. However, the regulatory landscape surrounding these emerging digital assets remains uncertain. By limiting the consideration of self-custody solutions, the proposed rule could impede the growth and development of user-controlled management in digital asset investments. This poses a disservice to investors looking to engage in these innovative markets while maintaining control over their assets. To address these concerns, I urge the SEC to take a balanced approach in recognizing the benefits and risks associated with self-custody solutions. By doing so, the SEC can promote innovation in the asset management space, offering investors a broader range of options that align with their risk tolerance and preferences. Rather than imposing strict limitations, the SEC should foster an environment that encourages the development of user-controlled asset management within the boundaries of investor protection. Furthermore, I recommend that the SEC takes proactive steps to provide regulatory clarity for digital assets, specifically cryptocurrencies. Given their increasing prominence in financial markets, it is imperative that regulators act swiftly and decisively to establish a clear framework that protects investors while allowing for continued innovation. By doing so, the SEC can ensure that digital asset transactions occur in a transparent and regulated manner, mitigating risks associated with fraud, market manipulation, and other illicit activities. In conclusion, as a concerned U.S. citizen, I respectfully urge the SEC to reevaluate the proposed rule "Safeguarding Advisory Client Assets" to better consider the potential of self-custody solutions in asset management. Additionally, the SEC should take proactive steps to provide regulatory clarity for digital assets, ensuring that investors can confidently participate in these emerging markets. By striking a balance between investor protection and the fostering of innovation, the SEC can enhance the overall integrity and efficiency of the financial industry. Thank you for considering my comments. I trust that the Securities and Exchange Commission will carefully assess the concerns raised by concerned citizens like myself. I appreciate the opportunity to provide feedback and contribute to the policymaking process. Sincerely, A Concerned U.S. Citizen