August 31, 2006
We assert that requiring transfer agents to file forms electronically would not prove beneficial for any entity other than The Commission.
The Commission believes it would make the information provided by the transfer agents publicly more easily available. Although this point may be valid, it is our belief that the public is not interested in what a transfer agent files with The Commission. They would not have any reason to view this data as transfer agents are not public companies and are not soliciting investments as an exchange traded company may be. Perhaps, a prospective client of the transfer agent is interested in obtaining such information before they make a decision on whether to hire the transfer agent. This information would be available from the transfer agent to the prospective client if the transfer agent wished to provide that information.
Although we acknowledge the benefit to the Commission with electronic filing, we believe that it should be an option for each transfer agent and not mandated.
As mentioned in the proposal, electronic filing involves skill and software that isn't currently needed or required of transfer agents.
If this rule is approved, it would cause a lot of expense and labor for the transfer agents that, we believe would not prove to accomplish anything but ease the burden on The Commission.
We are excited to welcome the electronic age, but we do not believe it should be mandated to any private business to acquiesce to unreasonable government demands, especially when they cause additional time, expense, and resources to comply with. Certainly not when it isn't necessary for public safety or confidence and simply a bureaucratic change for convenience.
We appreciate the opportunity to comment on this proposal.
Fidelity Transfer Company