Subject: Administrative Proceeding File No. 3-16098
From: Mon Vilaga
Affiliation:

Jul. 16, 2020

Good Afternoon,

We have a client whose main concern is how the investors would be identified for eligibility in the Wilmington Trust Corporation (SEC). Could you kindly advise on the below comment? Thank you!

The proposed plan of distribution (attached) appears to be for individual shareholders. For investors such as our clients this doesn’t seem like a sophisticated distribution methodology. 
Since these are securities held in the US, the sale records could be facilitated via DTCC as depository. Making the distribution electronically. My thought is how can they assure they have the correct addressees if not? 

Thank you,

Mon Vilaga
Junior Analyst 
SCAS Operations