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

Oct. 28, 2023

Please consider my comments on the proposed rule. S7-04-23
Safeguarding Advisory Client Assets. I believe:
The rules fail to appropriately balance prescriptiveness and
flexibility.
The rules lack justification for regulatory approach.
The rules lack practical implementation plans.
The rules lack data-driven analysis to justify requirements.
The rules are inconsistent with Congressional intent.
The rules fail to justify why existing regulations are insufficient.
The rules fail to minimize paperwork burdens.
The rules reduce investor access to products and services.
The rules fail to properly consider unintended consequences.
The rules fail to utilize plain language drafting.
The rules reduce price discovery.
The rules fail to assess alternative regulatory approaches.
The rules lack safe harbors for compliance.
The rules are not properly coordinated with other regulators.
The rules lack a sufficient comment period.
The rules create inconsistencies with other regulations.
The rules lack sufficient transition periods.
The rules conflict with international standards.
The rules lack granularity and proportionality.
The rules were proposed without adequate notice.
The rules impose undue liability.
The rules fail to provide sufficient implementation time.
The rules fail to account for regional differences.
The rules impose undue litigation risk.
The rules fail to harmonize with industry best practices.
The rules lack sufficient flexibility in application.
The rules fail to undertake meaningful outreach efforts.
The rules fail to minimize regulatory burdens.
The rules violate cost-benefit analysis requirements.
The rules undermine regulatory transparency.
The rules fail to assess effects on competition.
The rules are not evidence-based.
The rules are reactive instead of proactive.
The rules reduce investor participation in markets.
The rules undermine due process in adoption.
The rules reduce availability of financial advice.
The rules lack adequate transition provisions.
The rules are inconsistent with industry best practices.
The rules undermine market stability.
The rules fail to define key terms and standards clearly.
The rules lack clarity and are difficult to interpret.
The rules fail to consider impacts on efficiency.
The rules lack phase-in or transition periods.
The rules impose excessive paperwork burdens.
The rules lack transparency in analysis and assumptions.
The rules reduce availability of capital for businesses.
The rules lack transition provisions to phase-in compliance.
The rules reduce market competition.
The SEC did not properly consider comments.
The rules lack a reasoned basis.
The rules fail to provide implementation guidance.
The rules fail to tailor requirements appropriately.
The rules impose excessive recordkeeping requirements.
The rules conflict with other rules.
The rules reduce investor choice and participation.
The rules will stifle innovation.
The rules are not needed or address a non-existent problem.
The rules lack technology-neutral standards.
The rules lack phase-in periods.
The rules conflict with industry best practices.
The rules violate cost-benefit principles.
The rules lack coordination with international standards.
The rules will reduce market liquidity.
The rules lack retrospective review requirements.
The rules fail to properly consider impacts on small entities.
The rules create moral hazard.
The rules lack grandfathering of existing practices.
The rules undermine accountability in markets.
The rules fail to define key terms.
The rules harm minorities.
The rules fail to provide proper implementation guidance.
The rules lack clarity on key definitions and terms.
The rules lack transition provisions.
The rules fail to assess all costs and benefits.
The rules exceed statutory authority of the SEC.
The rules lack clarity in requirements and compliance steps.
The rules lack a robust public comment process.
The rules fail to consider less burdensome alternatives.
The rules fail to provide clear implementation guidance.
The rules lack flexibility for dynamic environments.
The rules lack proportionality in application.
The rules are not tailored enough.
The rules are not clear enough.
The rules undermine reliance interests without transition.
The rules lack tailoring to minimize regulatory burdens.
The rules lack clear and consistent rulemaking processes.
The rules reduce access to information.
The rules fail to harmonize with existing regulations.
The rules fail to evaluate incremental approaches.
The rules reduce access to investment information.
The rules lack an adequate implementation plan.
The rules undermine confidence in markets.
The rules lack sufficient economic analysis.
The rules reduce access to advice and information.
The rules lack pilot programs to improve calibration.
The rules harm the environment.
The rules lack evaluation of unintended consequences.
The rules reduce market competition and efficiency.
The rules fail to articulate clear compliance obligations.
The rules lack sunsetting provisions based on performance.
The rules fail to employ regulatory science best practices.
The rules lack outcome-based metrics.
The rules lack data-driven justifications.
The rules lack coordination across agencies.
The rules fail to properly evaluate alternative regulatory approaches.
The rules lack retrospective analyses.
The rules lack peer review of methodology.
The rules lack performance-based requirements.
The rules fail to properly tailor requirements to minimize burdens.
The rules fail to properly calibrate requirements.
The rules lack mechanisms to address implementation obstacles.
The rules lack proportionality in scope.
The rules lack adequate cost-benefit analysis.
The rules lack a sufficient public notice and comment period.
The rules reward bad actors.
The rules lack robust economic projections and modeling.
The rules lack grandfathering provisions.
The rules lack coordination across regulatory bodies.
The rules create an unlevel playing field.
The rules fail to properly consider impacts on small businesses.
The rules fail to tailor requirements to minimize burdens.
The rules lack a robust notice and comment process.
The rules are duplicative of other regulations.
The rules fail to properly define regulatory authority.
The rules lack sufficient public notice and comment period.
The rules fail to consider regional impacts.
The rules fail to consider international competitiveness.
The rules lack granularity in requirements.
The rules lack cost-effectiveness analysis.
The rules fail to employ oversight mechanisms.
The rules lack a sufficient transition period.
The rules lack feedback mechanisms and reassessment.
The rules fail to consider impacts on capital formation.
The rules lack proper coordination with other regulatory bodies.
The rules fail to properly consider impacts on competition.
The rules lack proper coordination across regulatory agencies.
The rules fail to consider regional differences.
The rules create inconsistent regulatory requirements.
The rules lack effective interagency coordination.
The rules reduce investor access to information.
The rules lack proper economic analysis and justification.
The rules fail to properly define problems to be addressed.
The rules exceed the SEC's statutory authority.
The rules lack harmonization with best practices.
The rules fail to undertake adversarial peer review.
The rules fail to assess alternatives objectively.
The rules exceed international standards.
The rules impose excessive compliance costs.
The rules lack peer review.
The rules lack outcome-based performance metrics.
The rules lack a sufficient implementation period.
The rules stifle capital formation.
The rules fail to consider impacts on efficiency and capital
formation.
The rules harm small businesses.
The rules lack transparency in assumptions and analysis.
The rules lack a phase-in period.
The rules fail to consider the rules' effects on efficiency,
competition, and capital formation.
The rules duplicate existing regulatory requirements.
The rules conflict with state regulatory authority.
The rules lack sunset provisions.
The rules fail to utilize plain language in drafting.
The rules lack robust public notice and comment process.
The rules fail to consider impacts on jobs.
The rules fail to employ stakeholder input appropriately.
The rules impose excessive compliance burdens.
The rules fail to employ least burdensome approach.
The rules increase compliance uncertainties.
The rules lack simplicity and clarity in drafting.
The rules lack coordination with other regulatory bodies.
The rules fail to establish user-friendly compliance resources.
The rules fail to properly balance regulatory costs and benefits.
The rules fail to properly incorporate public input.
The rules lack robust economic analysis justifying their costs.
The rules fail to properly weigh impacts on investor protection.
The rules lack clarity in compliance obligations.
The rules fail to address systemic risk.
The rules undermine market efficiency.
The rules lack a robust cost-benefit analysis.
The rules lack economic justification.
The rules lack clarity in requirements.
The rules fail to weigh costs and benefits appropriately.
The rules ignore less burdensome alternatives.
The rules impose undue compliance burdens on small entities.
The rules lack sufficient economic justification.
The rules lack clear articulation of their legal basis.
The rules fail to properly balance costs and benefits.
The rules fail to analyze incremental approaches.
The rules are too complex.
The rules fail to define key terms and standards.
The rules lack coordination with industry standards.
The rules lack adequate transition periods.
The rules create inconsistencies with existing regulations.
The rules reduce market transparency.
The rules lack flexibility.
The rules fail to define key terms and metrics.
The rules fail to promote simplification.
The rules lack proportionality in requirements and penalties.
The implementation timeframe is too short.
The rules undermine market stability and integrity.
The rules lack sufficient implementation timeline.
The rules impose undue compliance burdens.
The rules are ambiguous.
The rules lack peer review and empirical support.
The rules impose extraterritorial requirements.
The rules fail to properly define regulatory scope.
The rules lack clarity on key definitions.
The rules fail to consider reliance interests.
The rules reduce access to financial products.
The rules reduce investor choice.
The rules lack proportionality.
The rules fail to properly define key terms and standards.
The rules undermine Congressional intent and legislative principles.
The rules reduce access to capital.
The rules fail to balance costs and benefits appropriately.
The rules reduce investor participation.
The rules undermine investor protection.
The rules create ambiguities in legal requirements.
The rules fail to consider impacts on market stability.
The rules impose undue recordkeeping requirements.
The rules lack flexibility for dynamic business environments.
The rules fail to properly weigh public input.
The compliance costs are too high.
The rules lack outcome-driven performance metrics.
The rules lack rigorous peer review.
The rules go beyond the SEC's authority.
The rules fail to consider impacts on competition.
The rules lack clarity and are difficult to understand.
The rules are not data-driven.
The rules are politically motivated.
The rules impose undue adverse impacts.
The rules lack coordination across regulatory agencies.
The rules fail to properly incorporate retrospective analysis.
The rules fail to minimize compliance burdens.
The rules reduce market integrity.
The rules harm capital formation.
The rules reduce access to legitimate financial advice.
The rules harm productivity and efficiency.
The rules create undue compliance uncertainty.
The rules harm seniors and retirees.
The rules lack a feedback mechanism.
The rules lack evidence-based policymaking.
The rules lack flexibility for innovations.
The rules reduce transparency in markets.
The rules lack a reasoned justification.
The rules have unintended consequences.
The rules lack sufficient flexibility.
The rules lack retrospective analysis requirements.
The rules reduce product availability.
The rules fail to adequately justify regulatory approach.
The rules lack alternative approaches to regulation.
The rules lack harmonization with industry best practices.
The rules reduce availability of legitimate financial products.
The rules fail to provide compliance guidance.
The rules lack transition periods and phase-ins.
The rules lack feedback mechanisms for adjustment.
The rules fail to provide for transparent periodic reviews.
The rules lack flexibility in application.
The rules fail to properly consider impacts on efficiency.
The rules fail to provide for measured phase-in periods.
The rules duplicate industry best practices unnecessarily.
The rules fail to minimize administrative burdens.
The rules lack public participation mechanisms.
The reporting requirements are too burdensome.
The rules fail to properly incorporate public comments.
The rules reduce investor access.
The rules undermine state authority.
The rules reduce access to financial advice.
The rules reduce access to products, services and information.
The rules fail to consider impacts on small businesses.
The rules lack effective cost-benefit analysis.
The rules fail to provide sufficient implementation timelines.
The rules fail to properly scope regulatory authority.
The rules fail to consider regional economic impacts.
The rules lack a compliance safe harbor.
The rules lack analysis of less burdensome alternatives.
The rules harm competition.
The rules lack empirical support for their effectiveness.
The rules reduce transparency in rulemaking processes.
The rules lack adequate grandfathering provisions.
The rules fail to define key standards.
The rules exceed the SEC's expertise.
The rules lack a robust economic analysis.
The rules create inconsistencies in the law.
The rules are not simplified enough.
The rules harm job creation.
The rules impose extraterritorial authority.
The rules fail to properly weigh costs and benefits.
The rules reduce investor choic.
The rules impose undue proprietary costs.
The rules lack mechanisms for retrospective analysis.
The rules harm women.
The rules lack tailoring to minimize burdens on small entities.
The rules reduce accountability.
The rules fail to employ robust economic analysis.
The rules lack an adequate cost-benefit analysis.
The rules impose undue compliance uncertainty.
The rules lack coordination with other regulators.
The rules lack tailoring to minimize burdens.
The rules lack sufficient cost-benefit justification.
The rules lack sunsetting based on retrospective findings.
The rules reduce access to products and services.
The rules lack a robust alternatives analysis.
The rules create inconsistencies across regulations.
The rules lack tailoring for minimal market disruption.
The rules lack empirical support.
The rules impose undue burdens on small businesses.
The rules fail to consider reliance interests and transition.
The rules conflict with Congressional intent.
The rules fail to utilize pilot programs.
The rules fail to employ regulatory science.
The rules reduce transparency.
The rules duplicate existing requirements.
The rules fail to employ pilot programs and experiments.
The rules fail to evaluate less burdensome alternatives.
The rules lack sufficient public notice and comment.
The rules harm investors.
The rules fail to weigh alternative solutions.
The rules lack retrospective review processes.
The rules fail to quantify costs and benefits.
The rules fail to employ least restrictive means.
The rules impose undue paperwork burdens.
The rules lack pilot testing to improve calibration.
The rules encourage risky behavior.
The rules lack retrospective review.
The cost-benefit analysis is flawed.
The rules fail to utilize feedback mechanisms.
The rules fail to establish meaningful compliance milestones.
The rules fail to properly tailor requirements.
The rules lack transparency in development.
The rules undermine regulatory coordination.
The rules lack public accountability measures.
The rules undermine market discipline.
The rules are not technology neutral.
Thank you for considering my comments on Safeguarding Advisory Client
Assets. I eagerly await your published responses.