Oct. 30, 2023
Dear Securities and Exchange Commission, I am writing to express my concerns regarding the proposed rule titled "Safeguarding Advisory Client Assets." While I understand the intention behind this rule, which aims to enhance investor protections and address gaps in the custody rule, I believe that certain aspects of the proposal may have a negative impact on investor access and raise privacy concerns. Firstly, the proposed rule expands the coverage to include a broader range of investments held in a client's account, including digital assets. While it is important to address the safeguarding of these assets, I am concerned that the restrictions imposed by the rule may limit investor access to this emerging asset class. Digital assets have demonstrated significant potential for growth and diversification, and restricting investor access to them may hinder their ability to participate in this evolving market. Additionally, I have privacy concerns related to the proposed rule. The rule requires investment advisers to provide detailed information about custodians and account numbers to clients. While transparency is crucial, providing this level of sensitive financial data to numerous third parties raises privacy and safety concerns. It increases the risk of unauthorized access, identity theft, and potential misuse of personal information. Striking a balance between transparency and protecting individuals' privacy is essential to ensure confidence in the financial system. In considering these concerns, I urge the Securities and Exchange Commission to carefully evaluate the potential negative impact on investor access to digital assets and address privacy concerns associated with sharing sensitive financial information. It is vital to strike a fair balance between investor protection and preserving individuals' privacy. Thank you for considering my comments on this proposal. I look forward to further discussions and dialogue on these important matters. Sincerely,