Oct. 29, 2023
Dear Securities and Exchange Commission, I am submitting this public comment in response to the proposed rules put forth in Release No. IA-6191, File No. S7-04-22, "Safeguarding Client Assets". I appreciate the SEC's goal of enhancing cybersecurity protections for investment advisers and their clients. However, I have concerns that some provisions may impose excessive centralization and burdens harmful to cryptocurrency innovation. While reasoned security measures are prudent given cryptocurrencies' high-risk profile, prescriptive requirements could conflict with their decentralized ethos. Self-custody, user control, privacy, permissionless platforms, and open innovation are virtues worth preserving. I respectfully ask that the final rules integrate flexibility for decentralized systems. Consider principle-based compliance, size/risk-based exemptions, audits over disclosure mandates, and accommodating emerging decentralized technologies. Security should not necessitate central intermediaries when properly implemented cryptographic proofs and governance mechanisms exist. Please refine due diligence to focus on sound ethics and protocols rather than prescribing specific providers. With collaborative guidance and iterative refinement, strong security and decentralized promise can co-exist. But overbearing application of centralized paradigms could inadvertently stifle this progress. Please take a measured approach in partnership with the crypto community. I welcome continued discussion toward our shared goals of investor protection and responsible innovation. Thank you for your consideration. Sincerely, Christopher James Bowman Sent with Proton Mail secure email.