Electronic Filing Of Transfer Agent Forms - Securities And Exchange Commission Page 26

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forms by collecting and storing all of the information on the forms in a single, centralized database.

The database will be updated immediately upon the receipt of new filings and will help the

Commission identify delinquent filers. It will also allow for analytic tools such as data aggregation,

statistical analysis, and report generation. Additionally, the information will be disseminated as

submitted by filers so there will be no risk of transcription error as there is with information that is

submitted in hardcopy and manually entered into the database.

The Commission received one comment letter that discusses the benefits of the proposal.

The commenter stated that it believes the proposal will not be beneficial to any entity other than the

Commission.

First, the commenter stated that much of the investing public does not have an

interest in transfer agent data and that the few people who would like the data can request it directly

from the transfer agents themselves. Second, the commenter stated that electronic filing will cause a

lot of expense and labor for the transfer agents but will only benefit the Commission. The

commenter recommended that electronic filing should therefore be optional and not mandatory.

While we appreciate the commenter’s concerns, we believe that the proposal does benefit the

investing public and transfer agents. Transfer agents act as the agents of issuers of securities and

oversee such functions as stock transfers and dividend payments. We frequently receive 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, although 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 they are registered and are operating in conformance with the requirements under

Section 17A of the Act.

Kevin Kopaunik, Fidelity Transfer Company, dated August 31, 2006.

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