Electronic Filing Of Transfer Agent Forms - Securities And Exchange Commission Page 32
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100to the Commission. However, filers will not be required to use EDGARLite and could submit the
57
information reported on the forms to the Commission in ASCII text characters.
An electronic filing system will eliminate the burdens associated with the paper forms and
the possibility of the forms being lost or misdirected. The EDGARLite application will perform data
validation checks, which 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. Accordingly, the implementation of the electronic
filing system should promote efficiency. The electronic filing system should also promote accuracy
because the information reported on the forms will be submitted in electronic format by transfer
agents so there will be no risk of transcription error as there is with information that is submitted in
hardcopy and is manually entered into EDGAR or another Commission database. The amendments
will apply to all transfer agents and the EDGARLite application is intended to be a program that is
easy to use at a reasonable cost. Most transfer agents will be able to comply with an electronic filing
requirement without difficulty; however, the amendments will allow transfer agents to apply for a
continuing hardship exemption under Rule 202 of Regulation S-T if the electronic filing requirement
would cause undue burden or cost and the Commission determines that such exemption is
appropriate and consistent with the public interest and the protection of investors. As a result, the
amendments are not expected to adversely impact a transfer agent’s ability to file transfer agent
forms and, accordingly, likely will not have an adverse impact on competition. The amendments are
not expected to affect the operations of transfer agents and will not materially change the
information that is required to be reported to the Commission on the forms. The amendments will
57
See note 10.
32
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