Subject: File No. 4-725
From: Jason Carter
Affiliation: Colonial Stock Transfer

July 31, 2018

It's time to allow the issuers to have access to both their NOBOs and OBOs. The process for obtaining lists is antiquated, at least for one of the intermediary data providers. It takes around 2 weeks to obtain a CD with an encryption password being sent separately, which often gets thrown in the trash, leading to additional delays. Also, the current data provided is lacking modern communication methods such as phone numbers and emails. I would recommend that DTC facilitate the collection of this data through a secure portal to issuers or their designated agents. This will also create a more streamlined method for determining if the shareholder data provided matches DTC's balances for shareholder meetings.

Also, by having DTC manage the data collection, true competition in the proxy space can exist, which will drive costs of shareholder meetings down to save companies money.