Securities and Exchange Commission issued a concept release seeking comment on
potential changes to the existing transfer agent rules in late December 2015.
You can access a copy of the release on the SEC website
. We’re very pleased
that the SEC is taking a closer look at modernizing the transfer agent rules to
make sure transfer agents continue to securely and efficiently address issuer
and shareholder needs. To that end, we have submitted a comment letter
in response to the SEC’s request for information, which will be posted along
with other comment letters (including those from the Securities Transfer
Association (STA) and the Shareholder Services Association) to the SEC website here
Computershare participated in the STA’s working group that formulated the organization’s
response. We support the STA’s position on updating the current transfer agent
rules to better fit the modern processing environment as well as expanding the
rules to address important areas as safeguarding funds and securities,
developing and maintaining business continuity/disaster recovery plans as well
as requiring written agreements between issuers and agents.
In our comment letter we also endeavored to provide the SEC with helpful
information from the issuer, investor and agent perspective regarding potential
conflicts or complications with existing laws and costs. We recommended that
any proposed rules be principle-based rather than process-based as the
technology supporting the industry will continue to evolve.
Related to technology, our comment letter also addressed blockchain – a new way
to record and store data across a network that can potentially speed trading
and settlement of certain types of transactions. We have established a global
working group exploring the potential of using this ledger system as well as
the legal and regulatory implications of blockchain in the securities
Computershare clients should let their relationship managers know if they’d
like more information about blockchain, any of the items in the concept release
or our comment letter.