Dear Securities and Exchange Commission, I am writing to express my concerns regarding the proposed rule on "Safeguarding Advisory Client Assets" and offer my public comment on the matter. While the objective of enhancing investor protections and addressing gaps in the custody rule is commendable, I would like to raise some issues and suggest improvements to the proposed rule. Scope of Rule - Digital Assets: The proposed rule includes a broad definition of assets and acknowledges the inclusion of digital assets. Given the unique nature of digital assets, such as cryptocurrencies, it is crucial to develop a separate framework that adequately addresses the custody and safeguarding requirements specific to these assets. The SEC should work towards creating a tailored rule that focuses solely on digital assets to ensure investor protection and promote innovation in the rapidly evolving cryptocurrency market. Display of Exclusive Control: The proposed rule acknowledges the challenge of demonstrating exclusive control over digital assets. We urge the SEC to provide clarification on how investment advisers can effectively show exclusive control over digital assets, taking into consideration the decentralized and borderless nature of many cryptocurrencies. This clarification is essential to avoid burdensome and impractical requirements that could stifle the growth and development of digital assets. Effective Safeguarding of Digital Assets: As digital assets become increasingly mainstream, it is crucial to ensure proper safeguards are in place to protect investor interests. The proposed rule should mandate investment advisers to adopt robust cybersecurity measures to safeguard digital assets against hacking, theft, and other malicious activities. Furthermore, the rule should encourage the use of reputable and secure custodians for digital assets to minimize the risks associated with self-custody. Balancing Investor Protection and Innovation: While strong investor protection is paramount, it is important to strike a balance between safeguarding assets and fostering innovation in the digital asset space. Overly burdensome regulations may discourage investment advisers from engaging in the digital asset market, hindering the growth of this sector. The SEC should carefully consider the potential impact of the rule on innovation and ensure that any regulatory requirements are flexible and adaptable to support innovation and growth. In addition to these concerns, I also have a few general questions regarding the proposal: Are there any provisions within the proposed rule that outline the required qualifications or standards for qualified custodians of digital assets? How does the SEC plan to ensure that custodians meet these standards and maintain the necessary infrastructure to safeguard digital assets? Has the SEC considered the potential economic impact of the proposed rule on businesses operating in the digital asset industry, particularly small and medium-sized enterprises? What measures are in place to minimize any negative consequences on these businesses while still achieving the desired investor protection goals? Lastly, I appreciate the thorough economic analysis provided in the proposal and the consideration given to the costs and benefits. I highly encourage the SEC to continue seeking public input on the economic analysis, including potential overlooked benefits and costs. By incorporating diverse perspectives, the SEC can ensure a holistic and well-informed decision-making process. Thank you for considering my comments on the proposed rule. I believe that by addressing the concerns I have raised and pursuing a balanced and nuanced approach, the SEC can develop a rule that effectively safeguards client assets while fostering innovation in the digital asset market. Sincerely, Thomas Schypior