Oct. 30, 2023
Dear Securities and Exchange Commission, I am writing to express my concerns regarding the proposed rule on Safeguarding Advisory Client Assets. While I appreciate the SEC's efforts to enhance investor protections and address gaps in the custody rule, I believe there are certain areas that need further consideration. One major concern is the inadequate consideration of self-custody solutions. The proposed rule seems to focus predominantly on traditional custodians, without giving enough attention to user-controlled asset management. By not recognizing the potential benefits and security offered by self-custody solutions, the SEC may unintentionally hinder innovation and limit choice for investors. User-controlled asset management allows individuals to have direct control and oversight of their assets, ensuring greater privacy and security. However, the proposed rule fails to acknowledge the importance of this option, potentially preventing individuals from safeguarding their assets in a way that aligns with their preferences and risk tolerance. Furthermore, this lack of consideration raises concerns about privacy and the safety of sensitive financial data. Allowing numerous third parties access to sensitive information, such as social security numbers, significantly increases the risk of data breaches and identity theft. As an individual investor, safeguarding my privacy is of paramount importance, and the proposed rule does not adequately address this concern. I strongly encourage the SEC to reconsider its position on self-custody solutions and their relevance in the modern financial landscape. By recognizing the potential benefits and weighing the importance of user-controlled asset management, the SEC would foster innovation, empower investors, and ensure a more inclusive and secure environment. Thank you for taking the time to consider my concerns. I trust that, in reevaluating the proposed rule, the SEC will propose amendments that better reflect the evolving nature of investment advisory services and enable individuals to exercise greater control over their financial assets. Sincerely, Jason