Jan. 07, 2021
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Securities and Exchange Commission – Regarding Release No.34-90788; File No. S7-25-20, I would like to suggest that broker-dealers engaged in the digital asset securities business should not be precluded from the traditional private placement and M&A advisory business lines which do not involve the custody or clearing of customer assets. The Customer Protection Rule does not directly apply to these business lines and as such, broker-dealers engaged in the digital asset securities business should not be precluded from engaging in them. The removal of the private placement and M&A advisory business lines from the definition of “traditional securities” business will accomplish this goal. I would be happy to discuss the above in more detail or answer any questions. Please feel free to contact me, my contact details are below. Best regards, Zachary Marans Chief Executive Officer Manorhaven Capital LLC