Subject: File No. S7-24-15
From: Andrew Kellam

March 2, 2020

This rule seems unnecessary at best and like cronyism at its worst. Rule #1 for any investor has always been and should always be buyer beware. A rule like this might prevent ordinary investors who are quite sophisticated from being able to participate in markets without an intermediary when that is unnecessary. Additionally, it could potentially require individuals to submit great personal and private information to a third party that - as weve seen in the past - is not entirely capable of safeguarding that information. Whether that inability stems from underinvestment in security to prevent breeches or simple greed (selling the data onward) is an unimportant designation - the outcome remains the same.

Simply put, this rule will harm more investors more than it helps.