Circle Internet Financial responded to the SEC's proposal to amend rules for safeguarding client assets by Registered Investment Advisers (RIAs), advocating for the inclusion of cryptoassets under its Safeguarding Rule. Circle, while not an RIA or qualified custodian, supports the proposal's aim to enhance investor confidence in the cryptoasset industry by broadening covered assets and ensuring custodial protections. Circle emphasizes the importance of a segregation requirement for cryptoasset custodians to protect users in case of bankruptcy and the need for collaboration with federal banking regulators to address impediments like Staff Accounting Bulletin No. 121. The company supports the SEC's approach of maintaining existing types of qualified custodians and highlights the role of state-chartered banking organizations as leaders in cryptoasset custody. Circle also encourages clarification on the use of public blockchains by RIAs, suggesting that atomic settlement through smart contract protocols should not result in custodians losing control of assets. Circle values engagement with regulators and looks forward to further constructive dialogue.