Electronic Filing Of Transfer Agent Forms - Securities And Exchange Commission Page 11
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10024
obtaining such information may acquire it directly from the transfer agent.
This filer also
suggested that electronic filing be optional and not mandatory. Two of the commenters also stated
that although they find electronic filing on EDGAR to be burdensome, a PDF attachment or an
25
internet based form that does not require special software would be feasible.
One commenter also
26
expressed concerns about necessary software upgrades and any associated costs.
The Commission is very sensitive to the cost concerns of small transfer agents. The
EDGARLite program was designed to keep the costs to filers low and, while electronic filing may
require EDGAR skills and computer systems that all transfer agents do not currently have, we
believe any costs transfer agents may be required to incur are reasonable. The amendments to
mandate electronic filing are necessary to ensure that the information reported by transfer agents is
complete, accurate, and stored in a single, centralized database and that the information is publicly
available in an easily searchable format. To achieve this goal, electronic submissions must be
formatted as XML data tags and submitted on EDGAR. Forms submitted as PDF attachments are
not usable for analytical tools such as data aggregation, statistical analysis, and report generation.
The Commission designed EDGARLite to utilize commercial software because it was the
most cost-efficient way to allow information reported on a relatively small number of forms
to be filed on EDGAR as tagged data in XML format. It would not be economically feasible
for the Commission to develop an EDGAR application for transfer agent forms without using
commercial software or for the Commission to develop more than one electronic filing
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Kevin Kopaunik, Fidelity Transfer Company, dated August 31, 2006.
25
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.
26
Christeena G. Naser, Senior Counsel for Regulatory and Trust Affairs, American Banker
Association, dated November 2, 2006.
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