Subject: File No. S7-04-23
From: John Ritter

ALCON, I am writing to submit a public comment on the Securities and Exchange Commission's (SEC) proposed rule on "Safeguarding Advisory Client Assets." While I appreciate the SEC's efforts to enhance investor protections and address gaps in the custody rule, I have several concerns that I believe deserve consideration. I. Privacy and Safety Concerns: One significant concern I have relates to privacy and the safety of my sensitive financial data. The proposed rule introduces a requirement for investment advisers to provide custodian information to clients, including account numbers. In an era of increasing cybersecurity threats, the potential risks associated with disclosing this information to a large number of intermediaries is deeply concerning. It is vital that appropriate safeguards and protections are implemented to secure the clients' sensitive financial data and Social Security numbers. There must be a balance between investor protections and privacy considerations when it comes to sharing information with third parties. II. Burden on Exchanges to Verify Ownership of Digital Assets: Another concern I would like to raise is the burden placed on exchanges to verify ownership of digital assets, particularly considering the complexities and unique characteristics of certain types of assets. While the SEC's intention to safeguard client assets is commendable, it is crucial to ensure that the regulatory requirements do not create unintended hurdles for exchanges and other market participants. Specific provisions should be introduced to address the challenges associated with verifying ownership of digital assets. Furthermore, I urge the SEC to engage in meaningful dialogue with industry stakeholders to develop practical and efficient mechanisms that strike a balance between investor protections and the ability of market participants to comply with the proposed rule. A collaborative approach would allow for a comprehensive understanding of the operational intricacies of exchanges and digital asset custodians, leading to the identification of workable solutions that prioritize both investor safety and market efficiency. III. Concerns Regarding Clarity and Understanding: Lastly, I would like to express concerns about the clarity and comprehensibility of the proposed rule. The language used in the rule may be overly complex and difficult for individuals, particularly retail investors, to understand. Transparency is essential when it comes to regulatory frameworks, as it fosters public trust and enables robust investor participation. Therefore, I encourage the SEC to ensure that the final rule includes clear and concise language, maintaining transparency and facilitating broad comprehension. In conclusion, I appreciate the SEC's initiative to enhance investor protections through the "Safeguarding Advisory Client Assets" proposal. However, I strongly urge the SEC to address the concerns I have outlined, specifically pertaining to privacy and safety considerations as well as the burden on exchanges to verify ownership of digital assets. Additionally, I emphasize the need for clarity in the final rule to ensure its effective implementation and understanding by all stakeholders. Thank you for considering my comments. I trust that you will take into account the various perspectives received during this comment period.