Subject: S7-04-23"
From: Jeffrey Neil Juarez
Affiliation:

Oct. 30, 2023

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Dear Sir/Mam 


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"I strongly oppose the SEC's proposal, 'Safeguarding Advisory Client Assets; Reopening of Comment Period.' While I value investor protections and asset safeguarding, I believe the SEC's approach to cryptocurrency and digital assets is problematic. 


Cryptocurrencies operate in a unique, rapidly evolving space. Applying traditional financial regulations to these innovative technologies is misguided. Cryptocurrencies have distinct characteristics and risks that necessitate a more nuanced approach. Broad regulations without considering these nuances could stifle innovation and growth in this emerging industry. 


Additionally, the SEC's proposal appears to extend its jurisdiction beyond its existing authority, potentially conflicting with other regulatory bodies like the CFTC and IRS. This creates uncertainty and compliance challenges. 


The proposal's burdensome requirements on investment advisers may deter them from offering digital assets, limiting investor choice and hindering a promising industry with economic potential. 


Furthermore, the proposal overlooks the inherent security of blockchain technology, which underlies many digital assets. Blockchain's transparency and immutability reduce fraud risk, potentially rendering additional custody requirements redundant. 


Finally, the proposal might restrict retail investors' access to digital assets by imposing stringent custody rules. This inequality between retail and institutional investors could deprive many of the opportunity to participate. 


In conclusion, I urge the SEC to reconsider this proposal, taking into account the unique nature of cryptocurrencies and digital assets to foster responsible innovation and protect investors."