Oct. 30, 2023
Dear SEC, In response to S7–04–23, I'd like to address the following concerns: • Complexity: The proposed regulations exhibit unnecessary complexity, making it challenging for businesses to understand and comply with the rules. • Vagueness and Lack of Clarity: The lack of clear definitions and ambiguous language throughout the proposal raises concerns about its enforceability and understanding. • Inconsistency and Ambiguity: There are inconsistencies and ambiguities that could lead to legal disputes and compliance costs for affected parties. • Unintended Consequences: The proposed changes may have unintended consequences, impacting various stakeholders unfairly. • Administrative Burdens: The extensive paperwork and inefficient procedures outlined in the proposal could impose significant administrative burdens on businesses. • Lack of Flexibility: The rigid requirements and unreasonable timelines may hinder businesses' ability to adapt to changing circumstances. • Insufficient Stakeholder Input: It's essential to include more opportunities for stakeholder input to ensure a fair and balanced regulatory framework. • Transparency and Communication: The proposal lacks transparency and effective communication channels for affected parties to express concerns and seek clarification. • Inadequate Justification: A more thorough rationale should be provided to justify the need for these regulations and their potential impact. • Regulatory Overreach: There are concerns about overreach and the imposition of disproportionate burdens on specific groups without adequate justification. • Ineffective Enforcement: The proposed regulations may not effectively address enforcement concerns, which could lead to unfair competition. • Limited Access to Information: Access to relevant information is limited, hindering businesses' ability to make informed decisions and comply with the rules. • Inadequate Protection for Vulnerable Groups: The needs of vulnerable populations should be given more consideration within the proposed regulations. Overall, while the SEC's efforts to protect an investor are acknowledged, it is my opinion the proposal requires substantial revisions to address these issues and ensure a fair, effective, and transparent regulatory framework. Also as this is a new asset class with little public understanding, more education would be beneficial so that investors can be accountable for their own decisions.