Oct. 30, 2023
Kevin Phua 221 Tampines Street 24 Singapore 521221 31 October 2023 Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Public Comment on Proposal for Safeguarding Advisory Client Assets (File Number: S7-01-19) Dear Securities and Exchange Commission, Could I BE any more thrilled to share my public comment regarding the proposed rule for the Safeguarding Advisory Client Assets? I want to provide some feedback on this proposal that will make you laugh harder than a Friends rerun. So, here's the deal: while I do appreciate that you guys are trying to enhance investor protections and close gaps in the current custody rule, there are a few concerns I have that may put a little sarcasm in this regulatory comedy. In particular, I'm a bit worried about the potential overreach of regulatory authority when it comes to digital assets or cryptocurrencies. So, listen, I understand why you want to clear up any confusion and protect investors in this fast-paced digital asset world. But here's the thing: the proposed rule may be a little too controlling, like Ross to Rachel. Digital assets, like cryptocurrencies, are shaking things up in finance, and they need a fresh approach to regulation that doesn't feel like you're on a break from reality. Let's talk about the practicality and feasibility of applying the proposed rule to digital assets, shall we? Cryptocurrencies are like that wild, elusive Marcel. They're all over the place, moving from wallet to wallet, and the whole idea of exclusive control that's central to the current custody rule may not exactly fit. We don't want to discourage regulated investment advisers from jumping into this new asset class, leaving investors without a pivot option. Instead of trying to fit these digital assets into a box, I think it's time for a "we were on a break!" moment. We need a more principles-based approach that gives investment advisers the flexibility to navigate the challenges of digital assets while keeping investors safe and secure. In conclusion, you guys are doing great work in enhancing investor protections, but let's keep it real and avoid being too monica about regulating digital assets. We're living in a time of rapid change, and it's important to adapt the regulatory framework to promote innovation while still taking care of our investors. How you doin'? Thank you for taking the time to laugh through my comments. I hope my humor makes a little bit of a shusher do. Sincerely, Kevin Phua