Nov. 3, 2026
Re: File No. S7-2026-30; Docket SEC-2026-5516; Release No. 34-106246; RIN 3235-AL55; FR Doc. 2026-18190 (91 FR 56946 et seq., Sep. 4, 2026) Transfer Agent Rules To the Securities and Exchange Commission: I am a private citizen in California. I support the proposal with conditions. Transfer agents keep the official ownership record and help the clearance and settlement system work. Most of today's rules date to the late 1970s and early 1980s, when paper certificates dominated. Updating Forms TA-1 and TA-2, amending the processing and safeguarding rules, rescinding Rule 17ad-4's outdated exemptions, and adding Rule 17ad-30 (compliance policies) and Rule 17ad-31 (restrictive legends) is the right modernization. Accurate books, honest legends, and public machine-readable reporting protect investors and American markets. I offer these asks. America First Markets 1. Adopt Rule 17ad-31 so transfer agents maintain a current authorized-issuer contact list and have a reasonable basis—backed by the proposed non-exclusive safe harbor—before facilitating an unregistered transfer that would violate Securities Act section 5. 2. Keep the adopting release clear that legend removal is not a free pass on registration; anti-fraud and anti-manipulation authority stays intact. 3. When rescinding Rule 17ad-4, publish a short public table of which turnaround, processing, and recordkeeping duties now apply to formerly exempt limited-partnership, DRIP, open-end fund, and low-volume agents, so small agents and issuers can comply without guesswork. Accountability and Transparency 4. Finalize the Form TA-2 expansions (employees, activities, issues serviced, service providers, distribution amounts) in custom XML, and post aggregate industry statistics from those filings in a free public data feed at least annually. 5. Within two years of the compliance date for Rule 17ad-30, publish a short staff report on exam findings, common gaps, and any material ownership-record failures, so the Commission can refine the rule on evidence. 6. On Rule 17ad-17 (lost and inactive securityholders), state plain search steps and timelines that help reunite holders with property without creating a paperwork trap for ordinary investors. Digital-First Records 7. Affirm in the adopting release that electronic and other technology-neutral recordkeeping that meets the integrity, access, and retention standards of the amended rules satisfies the recordkeeping obligations—no mandate for paper certificates, and no lock-in to one ledger design. Thank you for modernizing these rules and for taking public comment. Reconciliation Items a. Footnote 345 (Manhattan Transfer Registrar Company settlement) opens two parentheticals and closes only one. b. The geographical discussion states 301 U.S. and 25 non-U.S. transfer agents out of 327; those counts sum to 326. Footnote 393 states one transfer agent did not report a country or state. c. Table 1 titles new Rule 17ad-30 "Compliance Program," while section IV.A is headed "Proposed Rule 17ad-30: Compliance." Respectfully, Alec Snelling California This comment was crafted with super intelligence (SI) support.