Oct. 30, 2023
Dear SEC, I regret to inform you that I am submitting this comment on the proposed rule "Safeguarding Advisory Client Assets" (File Number S7-09-20) with a heavy heart. It is disheartening to see the lack of attention to certain crucial aspects of the proposed rule and the disregard for the concerns of individual investors like myself. One cannot help but notice the glaring ambiguity and confusion caused by the lack of clarity in defining digital assets within the proposed rule. It is distressing to see the SEC's failure to provide clear guidance on what exactly constitutes a digital asset. This oversight reflects a lack of diligence and attention to detail, which is deeply concerning considering the potential consequences for investors. Furthermore, the disregard for the privacy and safety implications associated with the proposed rule is deeply troubling. Requiring investment advisers to provide sensitive financial information and social security numbers to multiple third-party custodians without adequate safeguards raises serious privacy concerns. The lack of consideration for the potential misuse or unauthorized access to this information demonstrates a disregard for the well-being and protection of investors. The overreach displayed by the SEC in certain aspects of the proposed rule is both disappointing and alarming. While investor protection is undoubtedly crucial, it is equally important to ensure that the proposed rule does not impose unnecessary burdens on investment advisers or stifle innovation in the industry. It is disheartening to witness an organization entrusted with regulatory responsibilities display such a lack of understanding of market dynamics and its potential negative consequences. While I appreciate the economic analysis presented in the proposal, it is apparent that the SEC has failed to fully comprehend the diverse practices among investment advisers. The estimate of compliance costs faced by these advisers, particularly small businesses, illustrates a lack of understanding of the real-world implications and burdens such businesses are likely to face. It is profoundly disappointing to witness a regulatory body overlook the concerns and challenges faced by small businesses. In conclusion, it is disheartening to witness the lack of attention to critical issues, the disregard for privacy and safety concerns, and the display of overreach in certain aspects of the proposed rule. I implore the SEC to rectify these shortcomings and show a genuine commitment to addressing the concerns of individual investors and ensuring a fair and balanced regulatory environment. It is my sincere hope that the SEC will carefully consider the impact and consequences of its decisions in the final rulemaking process. Yours sincerely, Edvaldo Kassie