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 understand the objective of enhancing investor protections and addressing gaps in the custody rule, I believe that certain aspects of the proposed rule may have unintended negative consequences. Firstly, I am concerned about the potential negative impact on the competitiveness of US companies. The proposed rules may put US companies at a disadvantage compared to their international counterparts. This could lead to capital flight and loss of market share, ultimately impacting the economy as a whole. As Oliver Reed, I strongly urge the SEC to carefully consider the potential consequences on the international competitiveness of US firms before finalizing the rule. Furthermore, I am deeply concerned about the impact on small businesses. The reporting requirements outlined in the proposal will impose a significant burden on small businesses and start-ups. These entities, which may not have previously been required to track personally identifiable information, will now have to implement systems to do so. This would result in additional costs and administrative burden. It is essential to recognize that these additional costs pose a significant challenge for small businesses and could potentially stifle innovation and entrepreneurship. In light of these concerns, I implore the SEC to reconsider the reporting requirements and their potential impact on small entities. It is crucial to strike a balance between investor protections and the preservation of small businesses and start-up protocols. Failure to do so may inadvertently hinder economic growth and hinder the competitive spirit that drives innovation in the US. I appreciate the SEC's efforts in promoting investor protections and improving oversight of client assets. However, I urge the Commission to carefully assess the potential unintended consequences of the proposed rule. As Oliver Reed, I am confident that with further consideration and refinement, a balanced approach can be achieved that addresses investor concerns while nurturing a vibrant and competitive economic landscape. Thank you for considering my concerns. I trust that the Commission will give serious thought to the issues raised and act in the best interest of both investors and the economy. Sincerely, Oliver Reed