Feb. 28, 2023
February 28, 2023 The proposed safeguarding rule puts too much burden on the investment adviser who is employed to provide investment advise. Sometimes we are asked to also implement that advise. In our firm, we custody funds with a registered and qualified broker-dealer. We should be able to rely on the broker-dealer to have done the correct verifications and confirmations with client account data. To now have to verify data that I do not have direct access to or control of does not make sense and puts unduly burden on our resources. I ask that the SEC reconsider the new rule 223-1, particularly as it pertains to registered investment advisers. The SEC should vote DOWN and NOT implement this new rule.