Oct. 29, 2023
Dear Securities and Exchange Commission, I wanted to take a moment to share my thoughts and concerns on the proposed rule "Safeguarding Advisory Client Assets," as outlined by the Securities and Exchange Commission. As an investor and advocate for strong investor protections, I believe it is important to provide constructive feedback on this matter. Firstly, I would like to express my appreciation for the SEC's efforts in addressing gaps in the custody rule and enhancing investor safeguards. The proposed amendments to the current rule, including expanded asset coverage and increased recordkeeping requirements, demonstrate a commitment to protecting the interests of investors. That being said, I do have concerns about the treatment of tokenized gaming assets within the proposed rule. The current proposal lacks clarity on regulatory guidelines for these assets, which creates uncertainty for both investment advisers and investors. Given the significant value that tokenized gaming assets, such as in-game currencies and virtual items, have gained in recent years, it is crucial that explicit guidelines are established to ensure the proper safeguarding of these unique assets. Furthermore, regulatory clarity is essential for fostering innovation and economic growth within the gaming industry. Without clear regulations, advisers may hesitate to invest in this sector, potentially hindering its development and limiting opportunities for both investors and entrepreneurs. I strongly urge the Securities and Exchange Commission to provide explicit rules and guidelines for the treatment of tokenized gaming assets. By doing so, the SEC can ensure that investment advisers have clear instructions on how to comply with the law and provide a secure platform for investors to participate in this growing market. In addition to my concerns about tokenized gaming assets, I would like to commend the SEC for its commitment to balancing investor protections with the burden of compliance. The proposed amendments have the potential to significantly enhance investor safeguards, but it is crucial that the economic impact of these changes is carefully evaluated. Striking the right balance between protecting investors and minimizing unnecessary compliance burdens will be paramount to the success of this rule. I commend the SEC for inviting comment on alternatives to the proposed rule and overlooked benefits and costs. This open and inclusive approach ensures that stakeholders have the opportunity to provide valuable insights and improvements to the regulatory framework. In closing, I would like to emphasize the importance of providing clear regulatory guidelines for the treatment of tokenized gaming assets within the proposed rule "Safeguarding Advisory Client Assets." By doing so, the SEC can demonstrate its commitment to protecting investors, fostering innovation, and creating a stable and secure investment environment. Thank you for considering my input and suggestions. I trust that the Securities and Exchange Commission will consider the perspectives of all stakeholders as it finalizes the rule. I look forward to witnessing the implementation of a robust and comprehensive final rule that promotes investor protection and strengthens the integrity of our financial markets. Thank you for your consideration.