Electronic Filing Of Transfer Agent Forms - Securities And Exchange Commission Page 25
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100and investors by improving the efficiency and quality of the information filed with the Commission,
which is available to the public. We also believe that the amendments will result in certain costs to
most transfer agents because they may need to purchase computer software and possibly hardware
and will need to train personnel to create forms in the EDGARLite™ application and to file the
forms on EDGAR. The Commission received three comment letters which discuss the costs and
47
benefits of the proposal.
These commenters believed the benefits of the proposal are mainly to the
Commission and that the costs of the proposal to small transfer agents are too high. One commenter
also stated that the information on the forms does not need to be disseminated on EDGAR because
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the public does not have use for the information reported on the forms.
A.
Benefits
An electronic filing system will improve the efficiency of the filing process for transfer
agents and would also improve the public dissemination of the information on the forms. The
electronic filing system will eliminate the burdens associated with the paper forms and the
possibility of the forms being lost or misdirected. By performing data validation checks, the
EDGARLite application will help to ensure that transfer agents fill the forms out completely and in
the appropriate format. It will also provide transfer agents with email notification that a form has
been accepted or suspended by the Commission.
The rule will benefit the public because it will make the information on transfer agent forms,
which is publicly available information, more easily accessible and available in a more timely
manner in EDGAR than it currently is through the Commission's public reference room. The new
system would also improve the Commission’s ability to maintain, review, and analyze transfer agent
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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; and Loren K.
Hanson, Assistant Secretary, Otter Tail Corporation, dated October 4, 2006.
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Kevin Kopaunik, Fidelity Transfer Company, dated August 31, 2006
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