Oct. 31, 2023
Dear Securities and Exchange Commission, My name is Jibril Gabriel Sirois Daramy , and I am writing to express my concerns about the proposed rule "Safeguarding Advisory Client Assets." While I recognize the importance of enhancing investor protections and addressing gaps in the custody rule, I am deeply troubled by the lack of consideration given to privacy and security concerns associated with the custody of digital assets. In an increasingly digital world, the safeguarding of personal information and financial data is of paramount importance. However, the proposed rule fails to adequately address the privacy and security risks involved in the custody of digital assets. As more personal information is shared with custodians and accountants, the potential for data breaches and the unauthorized access to sensitive financial information becomes a real concern. Investors' assets and personal information could be at risk if adequate protection measures are not implemented. Furthermore, the current proposal does not outline specific guidelines or requirements for ensuring the privacy and security of digital assets. While it is important to address the challenges associated with the custody of digital assets, it is equally important to prioritize the safeguarding of investors' personal information. Without clear guidance and stringent measures, investors may hesitate to entrust their assets to custodians, undermining the very purpose of the proposed rule. Additionally, the proposal does not sufficiently address the potential privacy concerns associated with the disclosure of sensitive financial information. The proposed rule mandates the disclosure of custodian information and custodial account numbers to clients. While transparency is critical, it is unclear how this level of disclosure aligns with privacy best practices. Investors may be uncomfortable with such extensive disclosure, especially given the rising concerns about identity theft and fraud. In addressing these privacy and security concerns, it is imperative that the Securities and Exchange Commission takes into account existing laws and regulations. The proposal should align with established privacy laws, such as the Gramm-Leach-Bliley Act (GLBA), which requires financial institutions to protect personal information. By integrating GLBA requirements into the proposed rule, the SEC can ensure that investor privacy remains a top priority. In conclusion, the proposed rule "Safeguarding Advisory Client Assets" must address the significant privacy and security concerns associated with the custody of digital assets. Without explicit guidelines and robust framework for safeguarding personal information, investors' assets and privacy are at risk. I urge the Securities and Exchange Commission to thoroughly consider these concerns and ensure that the final rule reflects a comprehensive approach to privacy and security. Thank you for considering my comments on this important matter. Sincerely, Jibril Gabriel Sirois Daramy