This is in comment to the proposed changes for those who manage "client" assets. Personally, I think this broad and sweeping rule changes in regards to how managers inform, control, and allocate customers' "assets" is a bit of a loaded back door approach to bring decentralized cryptographic products under the control of the SEC. There is no doubt challenges particularly for those affiliated with government institutions to feel like there is some sort of oversight on such a new frontier. There are examples where the productive base of a nation has shown a preference for a new technology and governments decided it was better to maintain the status quo. A case in point is when the auto mobile was first produced. England decided it would be better to tax car manufacturers and users because there were many who were in the horse business and had a lot to lose. Car entrepreneurs instead traveled to the United States to set up shop. This contributed to the wealth of Detroit in the early 1900s and was much of what enabled the Detroit Art Museum to have a world-class art collection comparable to those found in Europe and New York. The early days of cryptographic assets are not that much different than the car industry. Many fly-by-night companies got a garage, and some tools, and made prototypes with the hope of attracting more investors. Hundreds of companies came into existence and quickly went bankrupt with their investors not making a return. Of course, cryptographic assets do not correlate perfectly, but to jump to the conclusion that all cryptos are Ponzi fraud schemes would be in error. Not much different than stable owners who would scoff every time a rudimentary car would drive by. The most obvious obtrusion of the SEC from the general public point of view is that it is acting as a fox guarding the hen house (the hens being the rank-and-file citizens). It is the first time in the existence of humanity that technology is transcending the dimension of traditional finance. Currency as a technology has always been implemented from a top-down approach from a position of military power. This is the paradigm that has continued century after century. For some, it is a scientific law. On the long arch of evolutionary and consciousness development, it is merely a period in history whose time is coming to an end. The dilemma that rule-makers have is that an ignorant populace will believe that these rulings are created to protect the consumer and armchair investors. When in effect what they do, in regards to the financial system, is protect market share for those who have the most to benefit from the system maintaining its status quo. Also unfortunately the populace is becoming less and less ignorant of such simple explanations. Now I believe that the United States government is the best organizational structure that the world has ever experienced. I'm proud of the nation I live in. Yet as a young entrepreneur, there are more and more nations around the world that look like places with better opportunities. Places where I am more able to retain the product of my labor. What the future holds for the youth of this nation lays more in your hands than it does my own. No one allocates resources to crypto without understanding there is substantial risk. Anyone who plays the victim is either naive about many other things in life or plain lying. Many of the mainstream narratives simply fall on deaf ears. For the SEC to stay in the game there must be comprehensive, non-biased, fair, and nonfluctuating expectations for businesses who decide that they would like to be in the business of managing as custodian crypto assets. These should have a rule and governance model that is not entwined with the traditional securities market. Crypto assets are a new asset class and do not work, interrelate, or their users care about how they "fit" with the traditional asset paradigm. Until the SEC provides the above for centralized exchanges such as Coinbase, Binance, and Kraken, it is reminiscent of yelling fire in a crowded theater and then only letting the attendees who can pay a fee at the door the ability to leave. The reason is that the users do not care. Is not because they are careless people. It is because they have no reason to. Decentralized finance goes around the SEC, there are thousands of nodes around the world, many running on a virtual private network. Therefore, the most pragmatic and wise approach to take is to provide a comprehensive framework for custodial businesses disconnected from the traditional securities market to follow and comply too. This requires some self-responsibility on the part of the SEC. Some of the biggest defrauding of investors (by your terms) was done under your watch. All while procrastinating at providing clear guidance for custodial managers opening huge temptations for missallocating customer assets. Instead of taking ownership of the lack of clarity, a prosecutory approach has been adopted. By shooting into a barrel of fish enough times eventually a big one will float to the surface. It would be advisable to refer to organizations such as https://www.coincenter.org/ for logical and practical recommendations on custodial cryptocurrency regulation Secondly, private ownership and management of cryptographic keys (true defi) are not of the government's purview. A case in point. If a person is up to date on taxes, and insurance, and is not breaking any laws in their car; does the government have any legal standing to require them to disclose where they keep their keys at night? To determine where their keys are in correlation with the law, would require probable cause and a search warrant by an appointed judge. In short, I appreciate the opportunity to share my perspective and anticipate that the SEC will take a step back and rethink what they are doing and how. My Regards, Randolph Schreiner