Securities Information Center
By Electronic Mail
October 30, 2003
Jonathan Katz, Secretary
Re: File no. S7-13-03
Securities Information Center (SIC) appreciates the opportunity to comment on the proposed amendments to Rule 17AD-7 concerning recordkeeping requirements. Our comments pertain to the possible destruction of securities certificates which are now held in hardcopy form.
SIC currently maintains the Lost & Stolen Program where all lost, stolen, missing and counterfeit certificates get reported. The primary purpose of the database is to remove illicit securities from the marketplace but the industry has been using SIC to report cancelled certificates to help reduce risk over the past few years.
SIC would respectfully suggest that any physical certificates earmarked to be destroyed should be reported to the SIC database so that the possibility of these certificates resurfacing and being traded would be minimized, thus reducing the risk of destroying the certificates. We believe SIC can help reduce any risk by citing an example from a Proposed Rule dated October 2, 2000 relating to the Processing Requirements of Cancelled Security Certificates (Release No. 34-43401; File No. S7-18-00):
We thank you for the opportunity to make these comments. Please contact me at (617) 856-2342 if you need any additional information, or have questions or comments regarding the above.
Very truly yours