Dear Securities and Exchange Commission, I am writing to express my concerns regarding the proposed rule "Safeguarding Advisory Client Assets." While I appreciate the SEC's efforts to enhance investor protections and address gaps in the custody rule, there are several issues that need to be addressed in the current proposal. First and foremost, the scope of the rule seems to lack clarity and contains poorly defined terms. Terms such as "platform," "software," and "ledger" are open to multiple interpretations, making it difficult for investment advisers to ensure compliance. Furthermore, the definition of "wallet" and "validator" does not align with their technical meaning, which could lead to confusion and potential misinterpretation in practice. Additionally, the proposed rule places a burden on exchanges to comply with market integrity standards. However, given the decentralized nature of blockchain transactions, it may be challenging for exchanges to meet these requirements effectively. It is essential to consider the practical implications and potential limitations of implementing these standards in a rapidly evolving landscape. Furthermore, the economic analysis provided in the proposal acknowledges varying practices among investment advisers, making it challenging to estimate the economic effects accurately. It is crucial for the SEC to conduct a comprehensive assessment of both qualitative and quantified impacts to ensure that the rule amendments strike the right balance between investor protections and compliance costs. Moreover, while the proposed rule aims to enhance investor protections, the compliance burden on investment advisers, particularly small entities, needs careful consideration. It is essential to evaluate the potential impact on small advisers and provide clarity regarding compliance requirements to avoid undue hardships. In conclusion, I urge the SEC to address the concerns raised regarding poorly defined terms, burdens on exchanges, economic analysis, and compliance burden. The protection of client assets is vital, but it must be achieved through clear regulations that consider the rapidly evolving nature of the industry. I appreciate the opportunity to provide feedback and hope that these concerns are taken into account during the rulemaking process. Sincerely, Bradley Grayson