Oct. 30, 2023
Dear Securities and Exchange Commission, I am writing to express my concerns regarding the proposed rule on "Safeguarding Advisory Client Assets," particularly in relation to the lack of clarity on the definition of digital assets. While the proposal aims to enhance investor protections, the absence of clear guidance in this area could potentially lead to confusion and misinterpretation. Digital assets, particularly cryptocurrencies, have become an integral part of the modern financial landscape, leveraging blockchain technology to transform traditional financial transactions. However, the regulatory landscape surrounding these assets remains uncertain, posing challenges for both investors and investment advisers. One particular concern is the protection of privacy. Decentralized finance (De-Fi) platforms, which are built on blockchain technology, offer a higher degree of privacy by reducing the reliance on intermediaries and minimizing the collection and storage of user data. This is in stark contrast to the traditional financial system, where the risk of brokers losing user information or identity theft remains prevalent. In order to truly safeguard client assets and ensure investor protection, it is crucial to address privacy concerns in the context of digital assets. Encouraging investment advisers to adopt De-Fi platforms that prioritize privacy, or implementing regulations that promote the secure handling of user data, could greatly enhance investor confidence and protection. Therefore, I urge the SEC to consider providing clear guidance on the definition of digital assets and to address the privacy concerns associated with their custody. By doing so, the SEC can promote innovative financial technologies while still maintaining the highest standards of investor protection. Thank you for considering my concerns. I believe that by addressing these issues, the SEC can foster a regulatory environment that encourages responsible innovation and safeguards client assets in the digital asset space. Sincerely, Jared Robins Jr.