Electronic Filing Of Transfer Agent Forms - Securities And Exchange Commission Page 29
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100$31.50 per hour and that the total labor cost to the transfer agent industry for complying with the
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proposed amendments will be $98,910.
Alternatively, transfer agents or a third party could prepare the forms without MS InfoPath™
by creating an XML tagged version of the filing as an ASCII document using technical
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specifications that will be available on the Commission’s public Web site.
The Commission will
integrate the XML tags with the form template to create a structured form that is identical to the
form created in EDGARLite for the purpose of viewing the form in EDGAR. This filing method
would require some technical expertise on the part of the filer, however. Transfer agents could also
hire a third party filer to prepare and submit the forms on their behalf using MS InfoPath.™ Third
parties generally charge separate fees for preparation and submission of EDGAR filings, and they
either charge a fee per page of a filing or, for some forms, offer a flat rate per form. Based on the
published cost structures of some of the larger third party filers, we estimate that the cost of hiring a
third party filer to fill out a single transfer agent form would be in the range of $150 to $200.
The Commission believes that transfer agents will incur a small amount of ongoing costs
with respect to the amendments, such as purchasing upgrades to MS InfoPath™ software and
maintaining access to the Internet. Additionally, transfer agents will have to have personnel that are
familiar with the EDGAR system to file Form TA-2 each year and amendments to Form TA-1
whenever the information on the form becomes inaccurate, misleading, or incomplete.
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The cost per hour is based on the estimated per hour salary of a senior computer operator
using the Securities Industry Association’s Office Salary Data for 2003, adjusted for
inflation.
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See note 10.
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