The Huntington National Bank
Huntington Center
Columbus, Ohio 43287

Direct Telephone Number
(614) 480-4628
                                        October 28, 1996



Jonathan G. Katz
Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549


     Re:   File No. S7-21-96


Dear Mr. Katz:

     This letter sets forth comments of The Huntington
National Bank ("Huntington") to the Securities and
Exchange Commission's proposals to address the problems
of lost securityholders as set forth in Release 34-
37595.  Huntington is a registered transfer agent
located in Columbus, Ohio, and performs transfer agent
services for 41 corporations having in the aggregate
over 100,000 security holders.

Proposed Rule 17Ad-17

A.  Definition of Lost Securityholder

     Based on our experience, we believe that the
proposed definition of a lost securityholder, based on
a three month period between mailing of two
correspondences,  is appropriate.  Our policy is to
resend a returned item immediately, as we have found
that a second attempt is frequently successfully
delivered.  Thus, two returned mailings is a better
test than one returned mailing.   Also, many
shareholders maintain two residences, and are away from
their primary residence for extended periods.  We
utilize seasonal addresses when available to ensure
delivery.




B.  Transfer Agent Search Requirements

      We anticipate that complying with search
requirements would be an expensive proposition.  Our
corporate clients collectively have over 100,000
shareholders who span all 50 states and ten foreign
countries.   An extensive data base would be required
to follow up with all lost shareholders.  The time
frames are not in themselves unreasonable, but for
agents who service numerous issuers the timing of
identifying lost holders can be daily.  Currently
systems  do not have fields specific to information
surrounding contact with lost holders, nor the date we
deem them to be lost.

     The multi level search will take additional time,
costing transfer agents, the issuer and ultimately, the
shareholders, and potentially interfering with meeting
turn-around requirements.

     Our feeling is any entity holding assets for
others should be included.

     We strongly support the setting of a de minimis
threshold of $250.00 cash
only.

     The testing of the effectiveness of locating lost
holders is an additional burden on agents. As all
individuals are charged with cost effectiveness any
review process causes a reduction in productivity. And
as these funds are paid to the states under the
unclaimed funds laws, the states are the most equipped
to locate lost holders considering their years of
experience.

C.  Definition of Information Database
     
     We concur with the definition.

D.  Verification of Shareholder Identity

     Currently these procedures are employed.

E.  Recordkeeping Requirements

     System programing required and file space secured.

Proposed Rule 17a-24

A.  Data bases currently exist within the Federal
Government with the IRS and Social Security
Administration.

     These would take no additional programming nor
development to utilize, only developing procedures to
access and use the data.

B.  Definition of Recordkeeper

     We concur with the definition.

C.  Recordkeeper Filing Requirements

     If the IRS data base was used the electronic
filing could take place when reporting tax information
for each calender year.

D. Method of filing

     If the IRS data was used EDGAR would be fine.

E. Dissemination of Information
     We concur.

F. Proposed Recordkeeping Requirements

     Some program changes will be necessary.

G.  Commission Supported Database

     This would only take the combining of all 50
states unclaimed funds records.

                              Yours very truly,



                              Jolene Hickman
                              Vice President