Electronic Filing Of Transfer Agent Forms - Securities And Exchange Commission Page 12

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system for transfer agent forms. The Commission considered the costs of the commercial
software very carefully and chose software that we believed would best meet our needs for
the EDGARLite functionality, including ease of use and data validation, and that we believed
would be affordable for all filers. There may occasionally be upgrades to the software;
however, transfer agents would only have to purchase upgraded software if the Commission
makes changes to the EDGARLite application that use the features of the upgraded version
of the software. Transfer agents who have not filed on EDGAR before will have to train staff
to file the transfer agent forms on EDGAR; however, the EDGAR Filer Manual provides
detailed instructions for each step of the filing process. Transfer agents will also have the
option of applying for a continuing hardship exemption under Rule 202 of Regulation S-T to
file in paper format if they believe the electronic filing requirement would cause them undue
burden or expense.
For these reasons, we believe that any additional costs the electronic filing requirement may
impose on transfer agents are necessary and reasonable in order to improve and modernize the
Commission’s filing program for transfer agent forms. Furthermore, we believe that the proposal
benefits the investing public and transfer agents and not just to the Commission. Transfer agents act
as the agents of issuers of securities and oversee such functions as stock transfers and dividend
payments. With respect to the comment that the public does not need access to the information on
the forms, we note that the Commission frequently receives requests for transfer agent data from
issuers, who may be interested in hiring a transfer agent, and from investors, who may be seeking to
contact the transfer agent or who want assurance that the transfer agent is registered and is current in
all its filings with the Commission. Additionally, electronic filing will substantially improve the
Commission’s ability to monitor and regulate transfer agent activities. This benefit to the
Commission will benefit the investing public as a whole because it will help to ensure that transfer
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