Subject: File No. S7-35-04
From: James L. Nesfield, Mr.
Affiliation: Fisherman

October 19, 2004

The need to report to shareholders should not be voluntary, but the non-reporting companies seem to have made a peace by offering this olive branch. Many of these companies should be reporting via the number of shareholders they have for example Corp HQ a voluntary reporting company that has over the reporting limit of shareholders. This fact is considered public rumor. Perhaps rather than voluntary reporting the Commission should investigate with the Transfer
Agents if these non-reporting companies should be reporting to begin with. In addition since these issuers are non-reporting what is the purpose of a voluntary system does this mean that the fraud and lies told to investors can be compounded with a false sense of safety? The Commission by revoking the registration of reporting companies is creating more non-reporting shells. Basically all companies should be reporting in a real time fashion with an approved chart of accounts. Transfer Agents should be required by law to submit daily records of transfer by issuer even if the issuer is the transfer agent. The lack of accountability of issuers and their transfer agents has allowed firms like Corp HQ to avoid reporting. This is no mere oversight on the part of this issuer they have used this venue to add to the fraud. Corp HQ has raised money using a Gambino Call Center called Livingstone in fact some of their officiers have been involved with the likes of Hunter Adams. Since the CEO Council that represents non-reporting issuers has hoisted this voluntary idiots game upon the public let the non=reporting issuers prove they are entitled to be non-reporting and issue audited reports that account for their shareholder base which exceed the limit in many cases. Before we allow voluntary anything lets clean up the bad guys like Corp HQ and their PR front Investrends. Voluntary seems like softer kinder way of dealing with criminals and scammers.