Oct. 30, 2023
Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Attn: File No. S7–04–23 Subject: Public Comment on the "Safeguarding Advisory Client Assets" Proposal Dear Securities and Exchange Commission, I am writing to express my concerns and reservations regarding the proposed rule titled "Safeguarding Advisory Client Assets." I appreciate the efforts of the Securities and Exchange Commission (SEC) to enhance investor protection and address gaps in the custody rule. However, I believe there are several aspects of the proposal that require further consideration and revision. One area of concern is the treatment of cryptocurrency in the proposed rule. The SEC needs to consider the unique properties and technological complexities of cryptocurrency when formulating regulatory requirements. The current proposal lacks clarity and guidance regarding cryptocurrency, potentially placing additional burdens on investment advisers without offering sufficient support. It is crucial to provide a regulatory framework that is not only practical but also encourages innovation and growth in the cryptocurrency market. Another issue I want to highlight is the use of poorly defined terms in the proposed regulations. Terms such as "platform," "software," and "ledger" need clear definitions to avoid confusion and ambiguity in compliance efforts. The definitions of "wallet" and "validator" should also align with their technical meanings to ensure accurate interpretation. Clarity and precise definitions are integral to effective regulation, and I urge the SEC to refine these terms for better regulatory compliance. Moreover, I would like to express my concern about the impact of SEC speculation on asset valuations and the general apprehension surrounding the regulatory stance on cryptocurrency. The lack of clarity and certainty from the SEC has created an atmosphere of uncertainty, which hampers investor confidence and inhibits the development of the cryptocurrency industry. Other countries are advancing with clear regulatory frameworks, and the United States risks falling behind in global cryptocurrency adoption. Therefore, I strongly urge the SEC to provide clear guidelines to address these concerns and foster a supportive environment for innovation and investment in the cryptocurrency ecosystem. In conclusion, I support the objective of enhancing investor protections in the proposed "Safeguarding Advisory Client Assets" rule. However, the issues I have raised regarding the treatment of cryptocurrency, poorly defined terms, and regulatory certainty must be addressed for effective implementation. Failure to do so may hinder the growth of our emerging digital economy and place the United States at a disadvantage in the global cryptocurrency landscape. Thank you for considering my perspective. I value the opportunity to contribute to this discussion through a public comment. Sincerely, Anonymous US Citizen