Oct. 13, 2023
Dear SEC, I am writing to express my concerns about the proposed implementation of the new rule on safeguarding advisory client assets. I believe that the rule is too complex and burdensome, and that it is not clear enough about what is required. I also believe that the rule will have a negative impact on the market, and that it is not necessary or fair to certain groups of investors. Specifically, I am concerned about the following aspects of the proposed rule: The rule requires investment advisers to use qualified custodians for all client assets, regardless of the type of asset or the size of the account. This requirement is too broad and will be burdensome for small investment advisers and their clients. The rule does not provide clear guidance on how to comply with certain of its requirements. For example, the rule requires investment advisers to "take all reasonable steps" to ensure that their clients' assets are properly safeguarded. However, the rule does not define what constitutes "reasonable steps." The rule will have a negative impact on the market by making it more difficult for investors to access certain investments and by increasing costs for investors. For example, the rule will make it more difficult for investors to access private funds and other alternative investments. The rule is not necessary, as there is no evidence of a widespread problem with the current safeguarding rules. The rule is unfair to certain groups of investors, such as those who invest in alternative assets or who have small accounts. I urge you to withdraw the proposed rule and to work with stakeholders to develop a better approach. Sincerely, Mark Wild Author of Second 'Crypto Revolution' www.secondcryptorevolution.com mark@secondcryptorevolution.com