Oct. 29, 2023
Dear Securities and Exchange Commission, I am writing to submit my public comment on the proposed rule "Safeguarding Advisory Client Assets." As an individual concerned about investor protections and privacy, I have several concerns and issues that I would like to address in regards to the proposed rule. Firstly, I am concerned about the lack of clarity in the definition of digital assets. The proposal does not provide clear guidance on what constitutes a digital asset, which could lead to confusion and potential misinterpretation. With the growing popularity of cryptocurrencies and blockchain technology, it is crucial to have a clear understanding of what falls within the scope of digital assets. This lack of clarity may hinder the effective safeguarding of client assets and compromise investor protections. Additionally, I have concerns regarding privacy and the safety of sensitive financial data. The proposed rule would require investment advisers to provide detailed information about custodians and account numbers to clients. While I understand the need for transparency and accountability, this poses a significant risk for the privacy and security of client data. Allowing numerous third parties to access such sensitive information increases the potential for identity theft, fraud, and other cyber threats. It is essential to strike a balance between transparency and privacy in order to ensure the protection of investors' personal and financial information. Furthermore, I strongly believe that digital assets should remain decentralized. The proposal should take into consideration the unique characteristics of digital assets, such as cryptocurrencies, and should not discourage their decentralized nature. Decentralization fosters innovation, transparency, and accessibility for individuals across different economic backgrounds. Imposing excessive regulations and constraints on digital assets could stifle their growth and hinder the potential benefits they can provide to investors. In conclusion, I urge the Securities and Exchange Commission to address the concerns raised regarding the lack of clarity on the definition of digital assets and the potential privacy risks associated with the proposed rule. It is crucial to strike a balance between investor protection and maintaining privacy rights. Moreover, I strongly emphasize the importance of allowing digital assets to remain decentralized, ensuring their continued growth and benefit to investors. Thank you for considering my public comment. Sincerely, Nalena J Culver