Electronic Filing Of Transfer Agent Forms - Securities And Exchange Commission Page 28

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Commission electronically in EDGAR. These transfer agents have the necessary computer
system requirements and personnel to file the transfer agent forms in EDGAR, but many do
not have the MS InfoPath™ software necessary to construct forms in EDGARLite. Transfer
agents that have purchased Microsoft Office 2000 Professional Enterprise Edition™ have
MS InfoPath™ included as part of their operating system; however, most of these transfer
agents are not familiar with MS InfoPath™ and would have to train their personnel to use the
software. Of the transfer agents that do not currently file forms electronically in EDGAR,
most have the computer system requirements to file in EDGAR, but would need to purchase
MS InfoPath™, train personnel to construct forms using EDGARLite, and submit forms
electronically to EDGAR. In addition, some transfer agents may not have the necessary
system requirements to file in EDGAR and will need to purchase upgrades to their computer
systems as well as incur the costs related to purchasing the MS InfoPath™ software and
training personnel to file forms in EDGAR using EDGARLite.
From the above information, the Commission believes that the cost to transfer agents of the
electronic filing could range from only the cost of training personnel to create forms in EDGARLite
to the cost of upgrading systems, purchasing MS InfoPath™ and training personnel to use the
EDGAR system and EDGARLite. The EDGARLite application is designed to be easy to use and
the MS InfoPath™ software is a relatively low-cost software package that is readily available. The
EDGAR Filer Manual will provide instructions for installing MS InfoPath™ and for using
EDGARLite. Based on this, the Commission believes that any training for personnel with respect to
electronic filing will be two hours for each registered transfer agent. Additionally, the Commission
believes that transfer agents registered with the Commission will require an additional two hours to
refile the information on Form TA-1 as an amended Form TA-1. The Commission believes a cost of
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