Institute Comment Letter on SEC Proposal to Require Electronic Filing of Transfer Agent Forms

©2006 Investment Company Institute. All rights reserved. Information may be abridged and therefore incomplete. Communications from the Institute do not constitute, and should not be considered a substitute for, legal advice. [20530] October 31, 2006 TO: OPERATIONS COMMITTEE No. 29-06 SEC RULES COMMITTEE No. 47-06 SMALL FUNDS COMMITTEE No. 28-06 TRANSFER AGENT ADVISORY COMMITTEE No. 73-06 RE: INSTITUTE COMMENT LETTER ON SEC PROPOSAL TO REQUIRE ELECTRONIC FILING OF TRANSFER AGENT FORMS On October 26, 2006 the Institute submitted a comment letter to the Securities and Exchange Commission on its proposal to amend the rules and forms under Section 17A of the Securities Exchange Act of 1934 to require that the forms filed with respect to transfer agent registration, annual reporting, and withdrawal from registration be filed with the Commission electronically.1 A copy of the Institute’s comment letter is attached. The letter states that the Institute strongly supports the goal of the Commission, which is to improve the Commission's ability to utilize the information reported on the forms in performing its oversight function of transfer agent operations and to publicly disseminate the information on the forms. Diane M. Butler Director – Transfer Agency & International Operations Attachment (in .pdf format) 1 See Electronic Filing of Transfer Agent Forms, SEC Release No. 34-54356; File No. S7-14-06. The Release is available on the SEC’s website at: http://www.sec.gov/rules/proposed/34-54356.pdf.