Subject: File No. S7-04-23
From: Christian

Dear Securities and Exchange Commission, I am writing in response to the proposed rule "Safeguarding Advisory Client Assets," which aims to enhance investor protections in the advisory industry. While I understand the need to address the safeguarding of client assets, I have concerns regarding the burden placed on exchanges to conduct due diligence on digital asset issuers. Digital assets, such as cryptocurrencies, are a rapidly growing investment class built on blockchain technology. They offer unique opportunities for investors, but also present challenges due to regulatory uncertainties. It is essential to strike a balance between investor protection and innovation within this evolving space. The proposed rule's requirement for exchanges to conduct due diligence on digital asset issuers may create undue burden and challenges for certain types of assets. Digital assets operate in a decentralized and global ecosystem, and issuers vary widely in terms of their size, jurisdiction, and resources. Implementing thorough due diligence processes for every issuer could be impractical and may hinder the growth and accessibility of these assets for investors. Furthermore, it is important to consider existing regulations and frameworks specific to digital assets. Many jurisdictions have already established comprehensive regulatory frameworks for digital assets, which include requirements for issuers and exchanges. Adopting a collaborative approach that leverages these existing regulatory frameworks would be more efficient and effective than placing the entire burden on exchanges. While investor protection is of paramount importance, it is crucial that regulatory actions do not stifle innovation or hinder access to digital assets for investors. The SEC should carefully review the proposed rule's impact on exchanges and consider alternative approaches that strike a balance between investor protection, innovation, and the complexity of the digital asset ecosystem. Thank you for considering my comments. Sincerely, Christian