Oct. 29, 2023
Dear Securities and Exchange Commission, I am writing to express my concerns regarding the proposed rule "Safeguarding Advisory Client Assets." While I acknowledge the SEC's intention to enhance investor protections and address the gaps in the custody rule, there are certain areas that require further consideration and attention. Specifically, I would like to address the inadequate consideration of self-custody solutions and the privacy concerns associated with third-party involvement. Firstly, the SEC's proposed rules do not adequately consider self-custody solutions. By failing to explore and accommodate user-controlled asset management, the proposed rules hinder the advancement of innovative and secure methods of safeguarding client assets. Self-custody solutions offer individuals the ability to maintain control over their personal data and assets, mitigating the need to rely on potentially vulnerable third-party custodians. It is essential that the SEC fosters an environment that encourages the development and implementation of such solutions. Furthermore, I am concerned about the privacy implications involved in allowing numerous third parties to access my sensitive financial data and Social Security number. With the proposed rule placing clients in a mandatory relationship with custodians, there will be an increased exposure of personal information to multiple entities. This not only raises privacy concerns but also creates the potential for data breaches and misuse of confidential data. It is imperative for the SEC to prioritize the protection of clients' privacy rights when formulating these rules. In conclusion, I urge the SEC to reconsider its approach by giving due consideration to self-custody solutions and addressing the privacy concerns associated with third-party involvement. By doing so, the SEC can strike a balance between enhancing investor protections and promoting innovation, while also safeguarding clients'privacy and control over their personal financial information. Thank you for considering my concerns. I appreciate the opportunity to provide input on this important matter. Sincerely, anonymous