Subject: S7-04-22
Form Type A

Dear Secretary Countryman,

Re: File No. S7-04-22; File No. S7-25-22; File No. S7-04-23; File No. S7-05-23; Rulemaking Petition File No. 4-811

The SEC has issued a large volume of major rule proposals that would impose significant new requirements on investment advisory firms like mine. The predictive data analytics, custody, cybersecurity, outsourcing, and other proposals would have a negative impact on our operations, infrastructure, relationships with service providers, and clients, without corresponding benefit.

For example, the SEC’s predictive analytics proposal would needlessly replace advisers’ fiduciary framework with a new regulatory regime, cover virtually any technology, impact our ability to communicate effectively with our clients, and pose substantial operational and compliance challenges for our business.

Similarly, the SEC has proposed a sweeping expansion of the safeguarding/custody rule that would disrupt relationships between our clients and their custodians. The rule’s prescriptive requirements will result in unworkable obligations and ultimately harm investors.

Therefore, we support the Investment Adviser Association’s call on the SEC to slow down, consider the implications of its rulemakings cohesively, and undertake a more accurate and quantifiable assessment of cumulative costs, burdens, and economic effects.

The SEC needs to consider the impact of its regulations on smaller advisory firms like mine, which make up the core of the investment advisory community. To that end, we also support the IAA’s petition to the SEC to amend its definition of small adviser, which would require it to assess the economic impact of regulations on smaller advisers more realistically and consider less onerous alternatives.

Thank you for considering my views.

Sincerely,