Subject: S7-04-23
From: Philipp Ruess
Affiliation:

Oct. 22, 2023

Dear Securities and Exchange Commission,


I am writing to express my concerns regarding the proposed rule on the safeguarding of advisory client assets. While I understand the goal of enhancing investor protections is paramount, it is crucial to address the potential negative implications of certain aspects of the proposal, particularly in the context of cryptocurrency regulation.


One key concern I have is the potential impact on equal opportunities for individuals within the decentralized finance (DeFi) space. As regulations surrounding cryptocurrencies tighten, there is a risk of exacerbating existing financial imbalances. Restrictions on decentralized platforms and the imposition of onerous compliance requirements could limit access to financial services for individuals who are unbanked or underbanked. It may also impede the ability of innovative start-ups and small businesses to enter the market, stifling competition and hindering economic growth.


Furthermore, these regulations may have unintended consequences for economic development and educational opportunities. As the burden of compliance increases, financial institutions may redirect resources towards fulfilling regulatory requirements, potentially neglecting investments in educational programs and community initiatives. This could lead to a decline in educational standards and a reduction in the human potential of our society.


To address these concerns, I urge the Securities and Exchange Commission to carefully consider the potential negative effects of the proposed rules on equal access, financial innovation, and educational development. It is essential to strike a balance between investor protection and fostering an environment that encourages economic growth and inclusivity.


Additionally, I would like to raise a general question regarding the potential impact of these regulations on the broader proposal. How does the SEC plan to collaborate with industry experts and stakeholders to ensure that the proposed rule on safeguarding advisory client assets takes into account the rapidly evolving landscape of blockchain technology and cryptocurrencies?


Thank you for considering my concerns and questions. I appreciate your commitment to public input and meaningful dialogue on this important matter.


Sincerely,


Philipp Ruess





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