November 10, 2019
October 30, 2019
Securities and Exchange Commission
100 F St. NW
Washington, DC 20549-9303
Re: Fee Payment Modernization, Release Nos. 33-10720 34-7395 IC-33676
File S7-20-19
Dear SEC:
While the implementation of Automated House Clearing (ACH) payments allows for a most efficient means of payment for most companies filing with the SEC, it would be more beneficial to include the option to pay via debit or credit card. As mentioned in the SEC report, the use of ACH payments can be a burden for foreign affiliates if they do not have a U.S. bank account. By requiring payments via ACH, international affiliates will have a more difficult time trying to pay their filing fees, and errors that result in a payment being returned to the affiliate may create additional chargeback fees for the affiliates as well as increase the time before payment is properly received by the SEC. An alternative payment method that would help prevent these issues with international affiliates would be to allow payment via debit or credit cards. While these methods of payment typically incur additional charges to the payee, those fees could be pushed back to the payer by requiring a processing fee for any payment made with a debit or credit card. Despite being charged an extra fee, the convenience of making payments without the hassle of contacting ones bank to initiate payment, as suggested by the SEC, would have more beneficial value to an international affiliate than the added costs would be for the processing fee.
Sincerely,
Nash Larson