Oct. 29, 2023
Dear Securities and Exchange Commission, I am writing to express my concerns and raise several issues regarding the proposed rule titled "Safeguarding Advisory Client Assets." While it is commendable that the aim of the rule is to enhance investor protections and address gaps in the custody rule, I believe it is important to also consider the impact on vulnerable individuals and communities who rely on investment advisers for financial security. As we consider the proposed rule, it is crucial to prioritize the well-being and protection of all investors, including those who may be at a disadvantage due to socio-economic factors or lack of financial literacy. The rule should reflect a deep understanding of the diverse needs and circumstances of individuals and communities, ensuring that safeguards are in place to protect their assets and financial futures. One aspect that requires careful consideration is ensuring access to affordable and accessible investment advisory services for individuals with limited financial resources. For many low-income individuals and marginalized communities, investment advisers play a crucial role in helping them achieve financial stability and independence. It is important that the proposed rule does not create barriers or disproportionately burden those who rely on these services the most. Furthermore, as the world continues to grapple with the economic impacts of the COVID-19 pandemic, it is vital to address the potential vulnerabilities faced by investors during times of crisis. The proposed rule should include provisions for enhanced protections and support mechanisms that can help investors navigate challenging economic conditions and safeguard their assets. Additionally, it is essential to ensure transparency and clear communication between investment advisers and their clients. The proposed rule should require investment advisers to clearly disclose fees, risks, and any potential conflicts of interest to their clients. This will empower investors to make informed decisions and protect them from any potential harm arising from undisclosed practices. Lastly, I would like to emphasize the importance of education and awareness programs aimed at increasing financial literacy among the general public. By promoting access to educational resources and materials, the proposed rule can help individuals become more informed about their investment options, better equipped to make decisions, and less susceptible to fraudulent activities. In conclusion, I urge the Securities and Exchange Commission to approach the proposed rule from a humanitarian perspective, taking into account the needs of vulnerable individuals and communities who rely on investment advisers for financial stability. By incorporating provisions that prioritize accessibility, transparency, and investor education, we can ensure that the rule not only enhances protections but also serves the broader goal of promoting financial well-being for all. Thank you for considering my comments. Sincerely, Sabine Faldon