Dear Securities and Exchange Commission, I hope this letter finds you well. I am writing to provide a public comment on the proposed rule titled "Safeguarding Advisory Client Assets." As someone deeply concerned about investor protection and fair competition in the advisory industry, I have taken the time to carefully review the content of the proposal and have some significant concerns regarding certain aspects of the rule. First and foremost, I would like to express my appreciation for the efforts put forth by the SEC in addressing the safeguarding of client assets and enhancing investor protections. The proposed rule reflects the SEC's commitment to maintaining the integrity of the advisory industry and ensuring the safety of client assets. However, in my review of the proposal, I have identified some areas where I believe there could be room for improvement to ensure fair and equal treatment for all market participants. Specifically, I would like to draw attention to the potential for unequal treatment outlined in the proposal, which may inadvertently result in unfair competition and market distortions. The expansion of the coverage of client assets to include a broader range of investments is undoubtedly a positive step towards enhancing investor protection. However, it is crucial to ensure that all market participants are subject to consistent and equal treatment. This will help maintain a level playing field and prevent any perceived advantages or disadvantages that could disrupt fair competition and potentially distort market dynamics. Another point of concern is the application of custody rules to crypto assets. Given the unique nature of digital assets, it is essential to treat all market participants equally when it comes to safeguarding these assets. Any deviation from fair treatment could create disparities and favor certain participants in the rapidly evolving world of digital assets. It is vital for the SEC to establish clear guidelines that ensure a level playing field while considering the unique characteristics and challenges associated with digital assets. Additionally, the proposed exceptions to the requirement of maintaining client assets with a qualified custodian raise concerns. While there may be legitimate reasons for advisers to safeguard certain assets in-house, it is imperative to establish clear guidelines and safeguards to prevent potential misconduct. Any exceptions provided should not lead to an uneven playing field or an opportunity for abuse. It is crucial to protect investors by ensuring that adequate internal controls, regular reviews, and independent audits are in place for assets that cannot be maintained with a qualified custodian. Moreover, the proposed amendments to the surprise examination requirement also raise concerns regarding unequal treatment. While exceptions are provided for specific circumstances, it is essential to ensure that regulatory oversight remains consistent and thorough. The SEC should carefully assess the potential impact of these exceptions on competition and investor protection to avoid any unintended consequences. Additionally, I want to express my concerns about the potential increased compliance costs imposed by the proposed rule. While investor protection is undoubtedly of utmost importance, it is crucial to strike a balance and avoid placing an excessive burden on market participants. The impact of these costs, particularly on smaller advisers, should be carefully considered to ensure fairness and equitable application of the rule. In conclusion, I appreciate the SEC's efforts in addressing the safeguarding of client assets and enhancing investor protections through the proposed rule. However, I urge the SEC to carefully consider the potential unequal treatment of market participants, as well as the feasibility and proportionality of compliance costs. By doing so, the SEC can continue to uphold investor protection while fostering a fair and competitive advisory industry. Thank you for taking the time to consider my comments. Sincerely, Phil Lawrence