Oct. 30, 2023
Dear Securities and Exchange Commission, I am writing to express my concerns and objections regarding the proposed rule "Safeguarding Advisory Client Assets." While I appreciate the SEC's intentions to enhance investor protections and address gaps in the custody rule, I believe that certain aspects of the proposed rule may have detrimental effects on the decentralized finance (DeFi) sector and small businesses. Additionally, the proposed rule could stifle innovation and hinder the United States' competitiveness in the global digital asset space. Firstly, I would like to address the potential negative impact on decentralized finance projects. The proposed rules, particularly the expanded coverage of investments held in a client's account, could limit innovation and hinder the growth of DeFi projects. By imposing custodial requirements, the rule may limit the flexibility and decentralized nature of these projects, ultimately undermining their potential to provide financial inclusion and empower individuals with alternative financial services. It is crucial to strike a balance between investor protection and supporting the growth of innovative technologies in the financial sector. Furthermore, the increased reporting requirements and compliance costs may disproportionately affect small businesses and start-up protocols in the digital asset space. These entities, which may not otherwise be required to track and maintain personal identifiable information, will now have to allocate resources to implement these tracking systems. Such additional costs can put these projects at a significant disadvantage, potentially stifling their ability to compete and innovate. It is important to consider the potential burden these requirements may place on small businesses and whether they align with the intention of fostering entrepreneurship and attracting investment. Moreover, I am concerned about the broader implications of these rules on the United States' position in the global digital asset industry. As the digital asset space continues to evolve rapidly, it is essential for the United States to remain competitive and supportive of innovation. However, the proposed rule may be perceived as an overreach that discourages innovation, potentially causing the US to fall behind other jurisdictions that embrace technological advancements. It is vital for the SEC to balance investor protection with the US's ability to foster an environment conducive to digital asset innovation and entrepreneurship. In conclusion, I urge the SEC to carefully consider the potential negative impact on decentralized finance projects and small businesses in the digital asset space. I believe that it is essential to strike a balance between investor protection and fostering innovation, as well as maintaining the United States' competitive edge. The digital asset industry offers vast opportunities for financial inclusion, economic growth, and capital formation, and it is crucial for regulations to support rather than inhibit these advantages. Thank you for considering my concerns and objections. I trust that the SEC will carefully evaluate the potential negative implications of the proposed rule. -- Sweet Regards, Christine Miller Foodie Amor, Inc "made the old fashioned way" www.foodieamor.com