From: Samer.Bazerbashi@bisys.com
Sent: Monday, May 17, 2004 3:10 PM
To: rule-comments@sec.gov
Subject: File No. S7-27-03

Hello my name is Samer Bazerbashi and I work at  an outsourced transfer
agency Bisys.  I read over your proposed rule and did a presentation to
co-workers.  Obviously tackling late trading will take much effort and I
believe will include even hedge funds and 401k's in the future.  We
discussed that as a TA we wouldn't be able to know if a trade was a late
trade after 4:00pm or after the fund has priceed it's NAV.  Our fund
managers may call and ask us to accept a late submission of trades ususally
due to technical difficulties which is acceptable.  I believe that if the
SEC has a comission that is ready to research late trades and it required
immediate notice of late trades from the TA by law it will help identify
potential illegal activity much more quickly.  To make things even more
streamlined, if the SEC requires all funds to outsource their transfer
agencies to a different company it will reduce the conflict of interest
generated from having a TA that can be easily directed illegaly by a fund
manager.  Obviously this isn't a comprehensive plan, but since I work in a
TA I've noticed that we could help with notification of illegal activity.

Samer Bazerbashi


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