Dear Securities and Exchange Commission, I'm writing to express my grave concerns regarding the proposed rule via the proposed amendment under the "Safeguarding Advisory Client Assets" regulation under IAA of 1940. While I appreciate the SEC's efforts to enhance investor protections, I believe that the proposed rule, in its current form, would have a stifling effect on the burgeoning field of decentralized finance (DeFi). Specifically, I'm concerned about the following: The proposed rule's broad definition of "custody" could encompass a wide range of DeFi protocols and applications. This could lead to increased regulatory scrutiny and compliance costs for DeFi developers and participants. The proposed rule's requirement for investment advisers to obtain and maintain possession or control of client assets could be difficult or impossible to meet for DeFi protocols. This is because DeFi protocols are typically designed to be non-custodial, meaning that users retain control of their own private keys. The proposed rule's requirement for investment advisers to conduct surprise examinations of their custodians could be disruptive to DeFi protocols. This is because DeFi protocols are often global in nature and may not be subject to traditional audit and inspection procedures. I believe that the proposed rule, as currently drafted, is not well-suited to the unique characteristics of DeFi. The application of the rule to DeFi could have a chilling effect on innovation and could prevent investors from accessing the benefits of this emerging technology. I urge the SEC to carefully consider the potential impact of the proposed rule on DeFi before finalizing it. I believe that the SEC should work with DeFi developers and participants to develop a regulatory framework that is both protective of investors and supportive of innovation. Thank you for your time and consideration. Sincerely, Rich