Oct. 30, 2023
Dear Securities and Exchange Commission, I'm writing to express my concerns regarding the proposed rule on "Safeguarding Advisory Client Assets." As a resident of rural Mississippi, I believe that the proposed rule may have unintended consequences that could disproportionately affect small investment advisers in this region. I understand the need to enhance investor protections and address gaps in the current custody rule, but it's also essential to consider the unique challenges faced by investment advisers in rural areas like ours. The proposed rule may impose greater compliance costs and burden smaller firms that already have to deal with limited resources and access to specialized services. The proposed rule's amendments to the surprise examination requirement may also pose challenges for investment advisers in our region. The requirement to engage an independent public accountant for surprise examinations can be particularly burdensome for small firms, which may have difficulty finding affordable options in our rural communities. It's essential to consider the availability and accessibility of such services in different areas of the country. I believe that it's crucial for the SEC to strike a balance between investor protections and the economic realities faced by small investment advisers, especially those in rural areas. The impact of these proposed rule changes on small businesses should be carefully evaluated to prevent any unintended consequences that may stifle economic growth in our region. Thank you for considering these concerns and for providing an opportunity to voice my opinion on this matter. I hope the SEC takes into account the unique challenges faced by small investment advisers in the southern states and will carefully evaluate the potential impact of the proposed rule. Sincerely, Joelle Marine