Subject: S7-04-23: Webform Comments from Anonymous
From: Anonymous
Affiliation:

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.