Subject: S7-04-23: Webform Comments from Scott L
From: Scott L
Affiliation:

Oct. 30, 2023

Dear SEC,

I am writing to express my concerns regarding the proposed rule on
Safeguarding Advisory Client Assets. While I commend the SEC's
efforts to enhance investor protections and address gaps in the
custody rule, there are certain aspects of the proposal that require
further clarity and consideration.

Specifically, I am concerned about the lack of clarity in the
definition of digital assets. In today's rapidly evolving
financial landscape, digital assets, especially cryptocurrencies, are
playing an increasingly significant role in investment portfolios.
However, the proposal fails to provide clear guidance on what
qualifies as a digital asset, leading to confusion and potential
misinterpretation.

Furthermore, I am troubled by the privacy concerns and identity theft
risks associated with centralized exchanges. The proposal does not
adequately address these issues, which are of utmost importance when
dealing with digital assets. True decentralized finance (De-Fi)
platforms provide a safer alternative, as they eliminate the reliance
on intermediaries and reduce the risk of brokers losing all user
information.

Additionally, it is disconcerting to witness what many perceive as
overreach by the SEC in the crypto space. Congressman Emmer, McHenry,
and Davidson have been vocal in their support for everyday Americans
in navigating the complexities of this emerging market. Moreover,
Judge Netburn called out the agency's "hypocrisy" in
its approach, while Judge Neomi Rao criticized the SEC's actions
as "arbitrary and capricious."

In conclusion, I urge the SEC to address these concerns and provide
further clarification on the definition of digital assets.
Additionally, I encourage the agency to prioritize privacy and
security measures in the proposed rule, specifically focusing on the
risks associated with centralized exchanges. It is crucial that the
SEC maintains a faithful allegiance to the law, embraces the potential
of digital assets, and ensures a regulatory framework that fosters
innovation while protecting investors.

Thank you for considering my comments. I appreciate the opportunity to
provide input on this important matter.

Sincerely,

Scott L