Subject: S7-04-23: Webform Comments from Individual
From: Anonymous
Affiliation:

Sep. 1, 2023

I work at a registered investment adviser (RIA). The
premise that trading in client accounts is custody is not valid.
Clients have control over their funds, can withdraw and add funds as
they please. The increased burden of conducting a custody audit for
all discretionary accounts will be too great for a small RIA in terms
of cost and time spent.