Oct. 30, 2023
Dear Securities and Exchange Commission, I felt obligated to take a moment out of my oh-so-busy schedule to express some concerns I have about the proposed rule on "Safeguarding Advisory Client Assets." Now, don't get me wrong, I do appreciate the SEC's efforts to enhance investor protections. But, I simply cannot let certain aspects of this rule slide without a bit of critique. So, here goes. Let's start with the SEC's approach to cryptocurrency. Oh, how it warms my heart to see a regulatory body tackle a subject it clearly understands so well. I mean, who needs to fully grasp the decentralized nature and technological complexities of cryptocurrencies when you can just impose regulatory requirements without any consideration? It's as though the SEC is saying, "Hey, investment advisers, figure it out on your own! We're too busy to comprehend this tech stuff." Now, I get it. Regulating cryptocurrencies is a challenging task. But maybe, just maybe, taking a little extra time to consult with industry experts and stakeholders could result in a more sensible and effective approach. Instead, we're left with a blanket regulation that underestimates the technical constraints faced by investment advisers and adds unnecessary compliance burdens. Bravo, SEC, bravo. And let's not forget about the potential privacy risks. In the pursuit of transparency and regulatory oversight, the SEC wants investment advisers to provide detailed information about custodians and custodial account numbers to their clients. But who cares about privacy, right? Let's just overlook the fact that this kind of sensitive financial data and personal information could easily fall into the wrong hands, leading to identity theft, fraud, and who knows what else. I guess we can all sleep soundly knowing our personal info is out there for everyone to see. Thanks, SEC. But wait, there's more! The SEC should definitely take a moment to conduct a robust cost-benefit analysis of this proposed rule. Because, you know, we wouldn't want to consider the economic impact on investment advisers and qualified custodians. It's not like compliance with this rule would result in significant costs or anything. Nope, not at all. Let's just ignore the fact that small entities will be hit particularly hard by these burdensome requirements. After all, who needs business growth and innovation when we can have more regulations? In conclusion, dear SEC, I just want to say thank you. Thank you for your rushed and unreasoned approach to regulating cryptocurrency assets. Thank you for disregarding privacy concerns in your quest for oversight. And thank you for your failure to thoroughly assess the economic effects of this rule. Your proactive disregard for practicality and common sense is truly remarkable. Sincerely, A concerned citizen who hopes you'll take a moment to get your priorities straight