Oct. 30, 2023
Dear Securities and Exchange Commission, I am writing to express my concerns regarding the proposed rule "Safeguarding Advisory Client Assets." While I believe that enhancing investor protections and addressing gaps in the custody rule is of utmost importance, I believe there are certain areas that require further consideration. Firstly, I would like to address the lack of sufficient consideration given to blockchain interoperability. In today's technological landscape, blockchain technology has the potential to revolutionize asset management. However, the proposal does not adequately consider the interoperability of different blockchain networks, hindering the potential benefits of cross-chain asset management. It is vital that the SEC takes into account the advancements in blockchain technology and provide guidance that promotes secure and efficient management of client assets across multiple chains. Furthermore, I have significant concerns regarding privacy and the safety of sensitive financial data. The proposed rule would require extensive sharing of client information with third parties, including custodians and accountants. While I understand the need for transparency and oversight, the potential risks associated with so many parties having access to my personal financial information and social security number are alarming. It is crucial that the SEC provides stringent regulations and assurances to safeguard the privacy and security of client data. Additionally, I would like to highlight the existence of undefined grey areas within the proposed rule. Although the rule aims to enhance investor protections, there are certain areas where further clarification and definition would be beneficial. Ambiguities surrounding the application of the rule to specific assets and exceptions for unique situations could lead to confusion and potential non-compliance. It is imperative that the SEC provides clear guidelines and definitions to minimize uncertainty and ensure consistent adherence to the rule. In conclusion, while I commend the SEC's efforts to enhance investor protections through the proposed rule, I urge the commission to consider the concerns raised regarding blockchain interoperability, privacy, and undefined grey areas. By addressing these issues, the SEC can strengthen the rule and achieve a more comprehensive safeguarding of advisory client assets. Thank you for considering my comments. I look forward to the SEC's continued efforts to protect investors and promote the integrity of the financial industry. Sincerely, Regula Wicki