Jul. 28, 2023
Providing the comment regarding the point 6 in part 2 of proposal (II. DISCUSSION) : --- Is the requirement that an internet investment adviser must provide digital investment advisory services through its website on an ongoing basis to more than one client appropriate? Should we require that the internet investment adviser provide digital investment advisory services to “one or more clients” instead? Alternatively, should we require a de minimis number of clients or some other exact number of clients (e.g. “no fewer than 6 clients” to align with section 222 of the Advisers Act)? --- I think there should be clearer definition of the "ongoing basis". Some of the investment advice services are provided in form of "fill up the form, submit, get the result" If the client filled up the form with his personal information, submitted to the website and then algorithms provided the investment advice in response but client never came back to re-submit the form with updated information - is he still considered to be served on "ongoing basis" ? Basically the question is which clients can be considered as serviced on ongoing basis? Total accounts created? Accounts that were active for the last year (clients logged in)? Or any other ways to define the ongoing service. Thank you.