Oct. 22, 2023
Dear Securities and Exchange Commission, I am writing to share my concerns and offer my public comment on the proposed rule "Safeguarding Advisory Client Assets." While I appreciate the SEC's efforts to enhance investor protections and address gaps in the custody rule, I would like to express my concerns regarding the lack of clarity on the definition of digital assets. As the proposal aims to address the safeguards for client assets, it is imperative to provide clear guidance on what constitutes a digital asset. In today's rapidly evolving technological landscape, digital assets, such as cryptocurrencies, have emerged as a transformative force in the financial industry. However, regulatory uncertainties surrounding these assets have hindered their widespread adoption and investor confidence. Without a clear and comprehensive definition of digital assets, there is a risk of confusion and potential misinterpretation. This lack of clarity can impede investment advisers in understanding their obligations and implementing appropriate safeguards for client assets involving digital assets. Moreover, investors may be left in a state of uncertainty, unsure of whether their investments fall within the purview of the proposed rule and the provided protections. To address this issue, I urge the SEC to collaborate with industry experts, stakeholders, and policymakers to develop a clear and concise definition of digital assets. This definition should account for the unique characteristics, technological advancements, and evolving nature of digital assets to ensure that investor protections are effectively implemented. Furthermore, it is crucial for the SEC to actively engage in ongoing dialogue and collaboration with other regulatory bodies, both domestically and internationally, to establish a unified approach towards regulating digital assets. By fostering coordination, regulators can minimize regulatory arbitrage, promote uniformity, and provide clarity for investment advisers and investors alike. In conclusion, I appreciate the SEC's efforts to enhance investor protections through the proposed rule. However, I urge the commission to prioritize and provide clear guidance on the definition of digital assets to address the regulatory uncertainties surrounding these transformative financial instruments. By doing so, the SEC can foster a more secure and transparent investment environment that embraces the opportunities presented by digital assets while safeguarding investor interests. Thank you for considering my comment. Sincerely, Christopher Carrie Sent from my Galaxy