October 4, 2006
In reference to this proposal, I have concerns about the expense and addtional time it will take our company to process the TA1 or TA2 form. Currently, it takes us about 10-15 minutes to complete the TA-2 form and only takes a postage stamp and envelope to complete the submission of the data.
While we are in favor of eliminating paper where ever possible and using current technolgy were economically feasible, in this case we would be required to use an Edgar-related platform and purchase software that may or may not work on our computers.
Is there not another universal tool, such as sending a PDF file or a document that would be created in Word that could be sent electronically without having to buy special software and comply with Edgar formatting that requires special technical skills?
As a small transfer agent, this type of requirement only adds additional expense with no real benefit to our company or our shareholders. In fact, it is yet another requirement which makes small in-house transfer agent hard to justify and leads to outsourcing to large commerical agents that can justify the expense since they run it as a business and can pass the cost on to the issuers.
Our company has always maintained that we can service our shareholders needs better than large commercial transfer agents and yet, if we are faced with requirements like this, it becomes increasingly more difficult to defend that position.
Thank you for your time and consideration of these comments.