Subject: File No. S7-27-04
From: Mr. James L. Nesfield

July 1, 2004

Issuers and their officiers should have to report all changes in the ownership to a central repository where the regulatory time clock can determine if it is lawful for a transaction to occurr. By holding the significant shareholders and insiders as different than the general public this centralized repository can isolate violations in a more uniform manner. This manditory form of compliance could remove the cost from the issuer and protect the general shareholder. By using DTCC facilities and creating accounts for these special shareholders compliance could be centralized and automated. The filing with the Commission would be done automatically as a matter of procedure to create the account at DTCC.