Oct. 30, 2023
Dear Securities and Exchange Commission (SEC), I am writing to provide my public comment on the proposed rule "Safeguarding Advisory Client Assets" (File Number S7-14-20) as an concerned individual in the finance industry. While I acknowledge the SEC's intention to enhance investor protections and address gaps in the custody rule, I have significant concerns regarding the potential negative impact this rule may have on the competitiveness of US companies and the burden it places on small businesses. Firstly, the proposed rule has the potential to put US companies at a competitive disadvantage compared to their international counterparts. The increased reporting requirements and compliance costs may lead to capital flight and loss of market share. As we strive to encourage economic growth and maintain a favorable investment climate, it is essential to consider the potential unintended consequences of such regulatory measures. Striking a balance between investor protections and the competitiveness of US companies is crucial for the overall health of our economy. Furthermore, I am deeply concerned about the impact of this proposed rule on small businesses and start-ups. The reporting requirements introduced by the rule will force these companies, which would not otherwise be required to track personally identifiable information, to implement such tracking. This will undoubtedly create significant expenses for these businesses and could potentially stifle innovation. As we aim to foster an environment that supports entrepreneurship and engenders economic growth, it is vital to carefully assess the burden placed on small businesses by regulatory measures. By imposing these additional costs, the proposed rule risks placing small businesses and innovative start-ups at a disadvantage. This, in turn, could hinder their ability to compete in the market, limit their growth potential, and discourage investment in these vital sectors of the economy. It is crucial to strike a reasonable balance between safeguarding client assets and ensuring the ongoing success of small businesses that are vital to our economy. In conclusion, I urge the SEC to consider the potential negative impact on the competitiveness of US companies and the burden placed on small businesses by the proposed rule. It is essential to carefully assess these concerns while seeking viable alternatives that balance investor protections with a supportive environment for economic growth and innovation. I appreciate the opportunity to provide input on this important matter and hope that my comments will be taken into consideration. Sincerely, Matthew P.