Sent: Thursday, March 18, 2004 6:18 PM
Subject: S7-13-04:


Dear Sir or Madam:

In response to the request for comments of the dematerialization
of physical stock certificates, we believe that  this would be a
grave mistake and that the removal of the physical stock
certificate would mean the putting out of business of many small
established independent transfer agents.  Further, that the costs
involved in a certificate-less system would be much more than is
currently in a certificated environment and less investor
confidence would follow.

Fidelity Transfer Company is celebrating its 50th year in
business this year.  We have been issuing physical stock
certificates for that entire time.

We believe that if The Commission changed the rule so that
physical stock certificates could not be issued any longer it
would substantially increase the costs to the issuer company's
and their shareholders.

One reason for this is transfer agencies make their living by
charging issuer company's fees and/ or by charging shareholders
and brokers for the transfer fees.  If book shares were the sole
type of proof evidencing the ownership of shares, the transfer
agents would have to charge the issuer companies a large amount
of money to be able to cover costs, since a large portion of
business is derived from the transfer of physical stock
certificates.  With this significant portion removed, the bulk of
the operating expenses would then be charged to the issuer
company's.

This in itself may or may not be a huge problem for large
corporations.  However, many corporations are small pink sheet,
OTC:BB, or NASDAQ SC, companies that could NOT afford to make up
the costs that would be lost without the issuance of physical
stock certificates.

These charges then would show on the bottom line and in the
financial statements of the issuer company's who in turn would
most likely have less shareholder value and reduced stock price.

Another way that the costs for the dematerialization of stock
certificates would cost more is that many small independent
transfer agents would have to invest significant amounts of money
to become compliant with a book entry only format.  These costs
would be passed on to the transfer agent's clients and ultimately
the shareholders.  Transfer agents have been doing it this way
for many, many years and this is what we are good at.  If the
system is not broken, don't fix it.

Further on economic matters, if the book entry only system were
put into place, it would put many people out of work because
there would be less people needed to do the job, but still cost
consumers more for the service. This could be a wide spread
problem.

Many shareholders like to have a physical stock certificate in
their possession or in a safety deposit box.  This helps them
have pride in the company, and indicates proof that they own the
stock.

There are many lost stock certificates this is true, however, the
number is so small compared to those that are kept safe that it
is insignificant.  We only deal with a small handful of lost
securities compared to the other items we process.  In any system
there is going to be problems.  Our job as a transfer agent and
securities industry is to minimize them.  I believe if a book
entry format only was initiated, the problems with that would be
insurmountable and ultimately cost more that they do now and lead
to more shares being lost due to electronic failure, back up
problems etc.

We don't believe that there can be much done to engender public
confidence in a certificate-less system because people like to
have a stock certificate.  Computers lose data, markets crash,
Broker Dealers go out of business, etc. etc.  People like to have
the assurance in their hand. Like cash or gold, a physical stock
certificate shows ownership.

Publicly traded companies should NOT be required to issue their
stock in book entry form.  They should be able to issue stock
certificates if that is how they choose to do it.  This is
America after all, isn't it?

Sincerely,

Kevin Kopaunik, President

Fidelity Transfer Company

1800 South West Temple Suite 301

Salt Lake City, UT  84115

801-484-7222 phone 801-466-4122 fax

www.fidelitytransfer.com