SEC Proposes Extension of Stock Record Mismatch Reporting Rule
Published Date: 2/28/2025
Notice
Summary
The SEC is asking to keep Rule 17Ad-11 going, which makes transfer agents report certain mismatches in stock records and delays in updating files. This rule mainly affects transfer agents who handle stock records, but it won’t cost them much extra time or money. The rule helps keep stock info accurate and requires reports to be kept for three years.
Analyzed Economic Effects
2 provisions identified: 0 benefits, 2 costs, 0 mixed.
Transfer agents must report record mismatches
If you are a registered recordkeeping transfer agent, you must report to issuers and the appropriate regulatory agency when an "aged record difference" (one that has existed more than 30 calendar days) causes the aggregate market value to exceed certain thresholds. You must also report buy-ins and report when you fail to post certificate detail to the master securityholder file within five business days as required by Rule 17Ad-10. Keep a copy of any Rule 17Ad-11 report for at least three years after the report date, with the first year in an easily accessible place.
Estimated minimal time and dollar burden
The Commission estimates about 8 respondents will file a total of approximately 1 Rule 17Ad-11 report annually, with each report taking about 30 minutes. Using an average hourly rate of $78, the Commission estimates an average internal compliance cost of $39 per report and a total annual internal cost for the industry of approximately $39, with a total annual time burden of about 0.5 hours.
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