From: Madeleine Franco [MadFranco@aol.com] |
To Whom It May Concern: As the Commission thinks this through, please keep in mind that at the present time not all companies or individuals obligated to file have access to computers and the internet. Nor are all CEOs, company principals and insider shareholders computer literate to the point of filling out online forms, including electronic signatures. Since signatures are required, and filing agents and miscellaneous third parties, other than legal counsel, are no longer permitted to request ID numbers, the proposed rule would likely add to the complexity and expense of obtaining codes for such companies and individuals. While my own firm does not charge for obtaining codes for clients under the current system, I'm not sure that all filing agents and others would treat this as a courtesy service were electronic filing of Form IDs to become a requisite. Sincerely, Madeleine Franco |