Electronic Filing Of Transfer Agent Forms - Securities And Exchange Commission Page 10

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exemption, we recommend that all transfer agents review the system requirements and EDGAR Filer
Manual and be prepared to submit the forms on EDGAR.
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The Commission received six comment letters on the proposal from five commenters.
One
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commenter strongly supports the proposal
and three of the commenters oppose the proposal on the
grounds that it requires computer software and systems as well as experience with EDGAR that the
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transfer agent or its staff may not have.
The fifth commenter requested changes that relate only to
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Form TA-2 which is discussed in Section III.D. of this release.
The commenters who object to the
proposal stated that the expense of meeting the new requirement competitively disadvantages small
transfer agents and that these transfer agents should not have to bear the expense of a proposal which
they believe serves primarily to benefit the Commission. One commenter stated that the public does
not have any need to access the information reported on the transfer agent forms because transfer
agents are not public companies and do not solicit investments and that a person interested in
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Kevin Kopaunik, Fidelity Transfer Company, dated August 31, 2006; Loren K. Hanson,
Director, Investor Relations, Otter Tail Corporation, dated August 31, 2006; Loren K.
Hanson, Assistant Secretary, Otter Tail Corporation, dated October 4, 2006; Angie Orr,
Senior Legal Assistant, American Century Services, LLC, dated October 19, 2006; Diane M.
Butler, Director of Transfer Agency & International Operations, Investment Company
Institute, dated October 26, 2006; and Christeena G. Naser, Senior Counsel for Regulatory
and Trust Affairs, American Banker Association, dated November 2, 2006.
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Diane M. Butler, Director of Transfer Agency & International Operations, Investment
Company Institute, dated October 26, 2006.
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Kevin Kopaunik, Fidelity Transfer Company, dated August 31, 2006; Loren K. Hanson,
Director, Investor Relations, Otter Tail Corporation, dated August 31, 2006; Loren K.
Hanson, Assistant Secretary, Otter Tail Corporation, dated October 4, 2006; and Christeena
G. Naser, Senior Counsel for Regulatory and Trust Affairs, American Banker Association,
dated November 2, 2006.
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Christeena G. Naser, Senior Counsel for Regulatory and Trust Affairs, American Banker
Association, dated November 2, 2006.
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