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

Oct. 29, 2023

Dear Securities and Exchange Commission,

I am writing to express my concerns regarding the proposed rule on
"Safeguarding Advisory Client Assets." While I appreciate
the SEC's efforts to enhance investor protections and address
gaps in the custody rule, I believe that certain aspects of the
proposal may exceed the SEC's regulatory authority and fail to
protect the public interest, particularly in relation to its inclusion
of crypto assets.

One major area of concern is the poorly defined terms used in the
proposed regulations. Terms like "platform,"
"software," and "ledger" are left undefined,
making them susceptible to various interpretations. Additionally, the
definition of terms such as "wallet" and
"validator" do not accurately reflect their technical
meaning in the cryptocurrency industry. This lack of clarity will
undoubtedly lead to confusion and challenges when it comes to
complying with the regulations.

Furthermore, while I understand the need to safeguard client assets,
the proposed rule seems to be disregarding the intention and benefits
of cryptocurrencies. Cryptocurrencies have gained popularity due to
their decentralized nature, which allows individuals to have greater
control over their assets. By imposing stringent regulations on crypto
assets, the SEC is undermining the very essence of this innovation,
limiting individuals' ability to participate and benefit from the
cryptocurrency market.

Additionally, it is crucial to consider the overreach of regulatory
authority in this proposal. The SEC's role should be to regulate
securities and maintain the integrity of the capital markets. However,
the proposed rule seems to extend beyond this mandate, encroaching on
areas that are better regulated by other agencies. It is important to
maintain the appropriate balance of regulatory oversight while
avoiding unnecessary interference in the development of emerging
technologies.

In conclusion, I urge the SEC to reconsider certain aspects of the
proposed rule on "Safeguarding Advisory Client Assets."
Clarifying and refining the definitions and provisions related to
crypto assets is essential to ensure effective regulation without
stifling innovation. It is pivotal that the SEC upholds its duty to
protect the public interest while embracing the potential benefits
that cryptocurrencies can bring to investors and the financial
industry as a whole.

Thank you for considering my comment and the concerns I have raised. I
trust that all public comments received on this proposal will be
carefully evaluated, and any necessary adjustments will be made to
ensure a balanced and effective regulatory framework. Thank you.