Oct. 30, 2023
Public Comment on "Safeguarding Advisory Client Assets" Proposal Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 To Whom it Concerns, I am writing to express my concerns regarding the proposed rule on "Safeguarding Advisory Client Assets" which aims to address the safeguarding of client assets by investment advisers. While I appreciate the efforts to enhance investor protection, I believe that the proposed rule may exceed the regulatory authority of the Securities and Exchange Commission (SEC), potentially encroaching on areas that should be regulated by other agencies. One notable concern is related to privacy and the safety of sensitive financial data and personal information. The proposed rule requires advisers to provide detailed information, including custodian account numbers and other sensitive data, to clients and regulators. While transparency and accountability are important in the financial industry, the widespread dissemination of such sensitive information raises legitimate privacy concerns. It is important to strike a balance between protecting investor assets and safeguarding personal privacy. Furthermore, the proposed rule expands the scope of regulatory control beyond what is appropriate for the SEC. By delving into areas that should be regulated by other agencies with specific expertise, there is a risk of regulatory overlap and potential confusion for market participants. Proper coordination among regulatory bodies is key to avoid duplicative or conflicting rules that may hamper the efficiency of the market and burden advisers unnecessarily. Additionally, the economic analysis of the proposed rule should be assessed carefully to ensure that the benefits outweigh the costs. While investor protection is of utmost importance, it is crucial to consider the potential impact on advisory services, competition, and compliance costs for qualified custodians. Adhering to overly burdensome regulations may stifle innovation and market competition, ultimately harming investors in the long run. Considering these concerns, I urge the SEC to carefully reassess the proposed rule to ensure that it remains within the bounds of its regulatory authority and prioritizes investor protection while also respecting personal privacy. It is crucial to avoid undue regulatory overreach and work collaboratively with other relevant agencies to achieve comprehensive and effective regulations that promote both investor confidence and market efficiency. Thank you for considering my comments on this important matter. I believe it is crucial to strike a balance between safeguarding client assets and respecting personal privacy while adhering to appropriate regulatory standards. If there are any specific questions or additional areas of concern that you would like me to address, please do not hesitate to reach out. I am committed to actively participating in the public discussion and further refining these proposals to better serve the needs of investors and the industry as a whole. Sincerely, Brandon Storn