Oct. 29, 2023
Public Comment - Safeguarding Advisory Client Assets To Whom It May Concern, I am writing to provide my public comment on the Securities and Exchange Commission's proposed rule regarding the "Safeguarding Advisory Client Assets." As an individual investor who is deeply concerned about the protection of my assets, I would like to express my thoughts and raise certain concerns about the rule proposals. First and foremost, I would like to draw attention to the lack of clarity surrounding the definition of digital assets within the proposed rule. Digital assets have become an increasingly important part of the investment landscape, and it is crucial that regulations adapt to these new forms of investment. However, the proposal fails to provide clear guidance on what exactly constitutes a digital asset, which could lead to confusion and potential misinterpretation. Without a clear definition, investors and advisers alike may struggle to fully understand their obligations and responsibilities in safeguarding these assets. Furthermore, as an individual investor, I am deeply concerned about the privacy implications of the proposed rule. While the aim of enhancing investor protections is commendable, the rule requires the disclosure of sensitive financial data and personal information to various third parties. This raises significant privacy and safety concerns, as it exposes individuals like myself to potential risks associated with unauthorized access and misuse of this information. I believe it is paramount to strike a balance between investor protection and privacy, ensuring that our sensitive data is safeguarded from any potential malfeasance. Moreover, I believe it is crucial to address the potential burden placed on advisers and qualified custodians resulting from the proposed rule. The extensive recordkeeping requirements and additional compliance measures could impose substantial costs and administrative burdens on these entities. These costs could ultimately be passed on to investors, limiting access to advisory services and hindering the growth of the investment market. It is important to carefully consider the economic impact and ensure that the benefits of the proposed rule in terms of investor protection outweigh the potential costs and burdens placed on market participants. In summary, I urge the Securities and Exchange Commission to carefully consider the concerns I have raised regarding the lack of clarity surrounding the definition of digital assets, the privacy implications of the rule, and the potential burden placed on advisers and custodians. It is essential to strike a balance between protecting investor assets and safeguarding their privacy, while also promoting a robust and efficient investment market through reasonable and proportionate regulation. Thank you for considering my comments on this important matter. I appreciate the opportunity to contribute to the discussion and look forward to seeing how my concerns and those of other stakeholders are addressed in the final rule. Sincerely, Lance Buttars -- ~Lance