Oct. 29, 2023
Dear Securities and Exchange Commission, I am writing to express my concerns regarding the proposed "Safeguarding Advisory Client Assets" rule. While I appreciate the aim to enhance investor protections, I believe the rule places a disproportionate burden on small businesses and startups, hindering innovation and growth in the digital asset industry. The proposed reporting requirements will require small businesses and startups, who would not otherwise be required to track personally identifiable information, to implement such tracking. This will cause an additional expense and administrative burden for these entities. For smaller companies with limited resources, these costs can create a significant barrier to entry or expansion within the industry. Furthermore, these additional compliance costs will put these projects at a disadvantage and could potentially stifle innovation in the digital asset sector. Startups and small businesses are often the driving force behind technological advancements and economic growth. Placing undue burdens on these entities could limit their ability to compete with larger firms and restrict the development of new and innovative ideas. It is important to recognize that small businesses and startups play a vital role in fostering competition and driving economic growth. By imposing onerous reporting requirements, the proposed rule could inadvertently create a barrier to entry for these entities. This, in turn, may lead to a less diverse and competitive marketplace, ultimately diminishing investor choices and potentially harming consumers. I urge the SEC to consider the impact of this proposed rule on small businesses and startups. While it is important to enhance investor protections, the SEC should strive to strike a balance that does not unduly burden smaller entities. Alternative approaches, such as tailored requirements based on the size and resources of the adviser, should be considered to ensure that regulation promotes both investor protection and innovation. In conclusion, I believe that the burdensome reporting requirements of the proposed "Safeguarding Advisory Client Assets" rule could have unintended consequences for small businesses and startups in the digital asset industry. I encourage the SEC to take into account the potential impact on innovation, growth, and competition when finalizing the rule. Thank you for considering my comments. Sincerely Patrick J Booth Jr Founder of BOLTEVM