Oct. 28, 2023
As a small business owner based in New York City with three young children, I am acutely aware of the daily pressures of balancing professional obligations with familial commitments. In light of the recently proposed SEC Release No. IA-6240; File No. S7-04-23, I am worried that complying with its provisions will exacerbate these existing strains rather than alleviating any perceived threats. Initially, the increased red tape associated with custody matters would necessitate additional staff hours devoted to recording each individual customer's account activity separately. As someone running a modest operation, hiring more full-time employees isn't feasible, so this requirement could force me to prioritize spending precious time on manual data entry instead of focusing on delivering sound advice and service to my clients. Additionally, the costs involved in purchasing and installing advanced software solutions designed to streamline bookkeeping tasks and eliminate redundancies could pose significant obstacles to growth opportunities due to their prohibitive expense tags. Moreover, the strict stipulations regarding preemployment vetting procedures put forth by the draft regulation appear unnecessarily stringent. With limited resources available, finding qualified individuals capable of meeting rigorous security clearance thresholds while simultaneously fitting into the culture and values of a family-owned outfit can be quite tricky. It stands to reason that investing scarce funds towards recruiting and training candidates under the current circumstances would likely mean less money being channeled into other essential areas requiring attention. By contrast, larger multinational conglomerates can afford to bear the overheads entailed by recruitment processes far more easily than those working independently. Lastly, keeping abreast of novel security developments, staying apprised of emerging trends in digital fraud prevention strategies, and adhering scrupulously to best practices mandated by the proposed rules could lead to considerable organizational headaches. Balancing the need to remain vigilant against cybercriminals alongside the imperative of serving customers diligently may prove increasingly challenging when trying to juggle multiple priorities simultaneously. This scenario could translate into rising prices charged to clients seeking protection against malicious actors or compromising internal protocols geared toward preserving confidential data. In summary, while I applaud efforts aimed at safeguarding investor interests, implementing such sweeping reforms without recognizing the unique constraints faced by smaller independent enterprises risks disenfranchisement and dampened productivity levels across the board. Instead, regulators ought to consider offering customized exemptions or mitigation schemes targeted explicitly at smaller ventures, enabling entrepreneurs like myself to continue growing our operations sustainably while still promoting fairness and transparency throughout the broader industry ecosystem. Consider the negative impact.