February 6, 2004
Mr. Paul Roye
Dear Mr. Roye:
As the provider of the USPS Electronic Postmark (USPS EPM) service under contract to the U.S. Postal Service, AuthentiDate has consulted with the SEC, several leading mutual funds trading firms and a leading clearinghouse. Based on our understanding of the needs of the SEC, and the desires of the firms to address these needs while avoiding early trading cutoffs that would be detrimental to investors, we have designed a possible solution to address late processing and market timing abuses with little of no detrimental impact on mutual funds investors.
The USPS has already submitted a white paper on Mutual Fund Reform and the USPS EPM, which outlines the reasons why the USPS EPM is well situated to be a non-repudiation provider and time stamp authority for the mutual fund industry, which should be considered as background material to this document. This document outlines one possible solution based on the USPS EPM. However many other solutions could be designed that also utilized the USPS EPM, and in fact the USPS EPM could serve as the time stamping and non-repudiation system behind many of the solutions others have proposed to the SEC during this comment process.