American Funds Service Company P.O. Box 2205 Brea, CA 92821-2205 Telephone (213)486-9426 Fax (213) 486-9041 November 27, 1996 Jonathan G. Katz Secretary United States Securities & Exchange Commission 450 5th Street, N.W. Washington, D.C. 20549 Re: Proposed Rules 17AD-17 and 17a-24; File No. S7-21-96 Dear Mr. Katz: American Funds Service Company appreciates the opportunity to respond to the Commission s request for comments on the proposals discussed in Securities Exchange Act Release No. 37595 (Aug. 22, 1996). The Commission s proposed Rule 17AD-7 is designed to reduce the incidence of lost securityholders by requiring transfer agents to conduct multiple searches within specific time frames to locate lost securityholders, and Rule 17a-24 would allow the collection of certain information regarding lost securityholders with a view to public dissemination of some or all of that information. In general, American Funds Service Company supports the Commission's efforts in this area and concurs with the comments of the Investment Company Institute submitted in its response dated November 27, 1996. We respectfully request that the Commission implement those comments and, in addition, permit mutual fund transfer agents to make a lost securityholder designation after the first piece of mail is returned as undeliverable (rather than forcing a remailing of the returned correspondence). In addition, we agree with the Investment Company Institute s opposition to the proposal to build a database of lost securityholders social security numbers. We feel strongly that the potential for fraud far outweighs any benefit that could be associated with a database, and are concerned that such a database would require daily feeds (at significant cost) from transfer agents in order to keep the information current. American Funds Service Company ("AFS") is registered with the Securities and Exchange Commission under Section 17A of the Securities Exchange Act of 1934 as a transfer agent. It is the transfer agent and shareholder servicing agent for 39 investment companies including The American Funds Group of Mutual Funds and maintains approximately 8 million shareholder accounts. Again, American Funds Service Company appreciates the opportunity to comment on the proposed rules designed to address lost securityholders and respectfully requests consideration of the views expressed in the letter from the Investment Company Institute. If you have any questions, or would like to discuss these comments in more detail please feel free to call the undersigned at (213) 486-9253. Sincerely, Kenneth R. Gorvetzian Secretary