October 2, 2023 Re: File Number S7-13-23 Concerns Regarding the Proposed Elimination of the De Minimis Non-Internet Client Exception I commend the SEC’s ongoing efforts to modernize the rules for internet investment advisers and to address observed issues. However, I am concerned about the proposed elimination of the De Minimis Non-Internet Client Exception. It appears the Commission's proposal may overlook the critical role this exception can play in enhancing the value of internet-based advisory services and mitigating operational risks. Under the current rule, an internet investment adviser can provide advisory services to a limited number of clients temporarily before integrating these services into their fully automated system. The Commission's proposal doesn't seem to recognize this particular use of the exception and the potential benefits to clients. IMPROVING THE VALUE OF INTERNET-BASED ADVISORY SERVICES Eliminating the exception could constrain the growth potential, quality, and usefulness of internet-based services. By introducing a new service or improving an existing one with human interactions, advisers can discern which offerings resonate most with clients. This hands-on approach also allows them to gauge clients' understanding of the services and whether they address clients' needs. Through this direct feedback, internet investment advisers can focus their resources to integrate the most beneficial services, strategies, and features into their internet advisory systems. While tools like surveys can provide insights, they cannot replicate the invaluable feedback obtained during the actual delivery of investment services. Genuine client engagement can be vital for refining services. Therefore, without the exception, internet investment advisors might struggle to refine their platforms in ways that best align with client needs. REDUCING OPERATIONAL RISKS OF INTERNET-BASED ADVISORY SERVICES I'm also concerned that eliminating the exception could increase operational risks for advisers, and their clients, when they innovate or improve their services. The development or enhancement of an internet-based advisory service often involves creating new software components that implement new algorithms, incorporate new sources of data, or generate new client reporting. Even with rigorous pre-deployment testing, some errors might only become apparent when these components are operating in production. By applying these components within human-provided services before integrating them fully, advisers can ensure a higher degree of reliability when the components are incorporated into the internet-based system. THE EXCEPTION SHOULD NOT BE ELIMINATED The rules for internet investment advisers should ideally provide flexibility for the use of human interaction when the purpose of such human interaction is to enhance the quality and reliability of fully automated, internet-based services. While I recognize the Commission has numerous factors to consider with regard to this exception, the unique benefits described herein should be taken into account. Entirely prohibiting investment advice that involves human interaction could significantly hinder advisers' ability to tailor their fully automated, internet-based services to best meet the needs of their clients. Additionally, such a prohibition could increase operational risks. I appreciate your attention to this matter, and thank you for considering these concerns.