Oct. 30, 2023
Dear Securities and Exchange Commission, I am writing to express my concern regarding the lack of clarity in the proposed rule "Safeguarding Advisory Client Assets" in relation to the definition of digital assets. As the proposal addresses the safeguarding of client assets by investment advisers, it is crucial to have a clear understanding of what constitutes a digital asset in order to effectively regulate and protect investors in this emerging field. Digital assets, particularly cryptocurrencies, have rapidly transformed the financial landscape through the use of blockchain technology. However, the regulatory uncertainties surrounding these digital assets have created significant challenges for both investors and investment advisers. By failing to provide clear guidance on the definition of digital assets, the proposed rule leaves room for confusion and potential misinterpretation. This lack of clarity could hinder the development of a robust regulatory framework for digital assets, impeding investor protection efforts and stifling innovation in the industry. Moreover, it appears that the proposed rule may have unintended consequences, which could potentially harm investors rather than safeguard their assets. It is crucial for regulatory bodies such as the SEC to ensure that they are acting in the best interests of investors and facilitating the growth and adoption of digital assets within the bounds of a well-defined regulatory framework. In light of these concerns, I urge the SEC to provide clear and comprehensive guidelines on the definition of digital assets as part of this proposed rule. This will promote transparency, increase investor confidence, and create a level playing field for investment advisers operating in the digital asset space. Thank you for considering my comments. I hope that the SEC takes into account the potential impact this lack of clarity could have on the evolving world of digital assets and acts in the best interests of investors. Sincerely, Donnie