Subject: S7-13-23: Webform Comments from Robert Martin
From: Robert Martin
Affiliation:

Aug. 22, 2023

I disagree that the proposed rule would be of a benefit to
investors, pertaining to operational interactive websites
as it would make it harder for smaller entities to conduct business
solely based on the amount of clients they may have and if their
website may not be up to the standards of the SEC or state regulators,
if a website is the only way an entity provides its clients with
investment advice then requiring the operational interactive
website proposed rule could harm that entity even if that entity
has clients in other states, the SEC and congress should readdress the
entire rule and make it easier for investment advisers to conduct such
activities as long as they keep up to date records, registration
requirements etc. especially for form ADV which is already a lengthy
and time consuming requirement, obviously the SEC should use it
resources to investigate fraud more so than trying to make it harder
for legitimate investment advisers to conduct business. there's
plenty of fraud and particularly securities fraud in regards to stock
market manipulation that the SEC should be more concerned with instead
of making rule changes to internet investment advisers who rely on the
exemptions that are already very limited.