SEC Extends Comment Period With Respect to Proposed Revisions to Transfer Agent Rules

February 23, 2016

In a February 10, 2016 notice to clients we described the Securities and Exchange Commission (the “SEC”) Exchange Act Release No. 34-76743, which contains an Advance Notice of Proposed Rulemaking providing public notice that the SEC is considering new and amended rules governing transfer agents and a Concept Release addressing other aspects of transfer agent regulation (the “Transfer Agent Release”).

On February 18, 2016, the SEC issued Exchange Act Release No. 34-77172 (the “Extension”), which extends the comment period for the Transfer Agent Release. The SEC is extending the public comment period for 45 days, from February 29 to April 14, 2016. The SEC believes this extension is appropriate in order to provide the public additional time to consider and comment on the issues addressed in the Transfer Agent Release.

As described in our notice to clients, the Transfer Agent Release proposes transfer agent rules and rule amendments in various areas, including registration and reporting requirements, safeguarding of funds and securities, standards for restrictive legends, and cybersecurity. The Transfer Agent Release seeks comments on these topics and in addition comments on issues that may be relevant to the regulation of transfer agents but as to which the SEC is not currently planning to propose rules or rule amendments.

Comments may be submitted via electronic or paper methods as described in the Extension.

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If you have any questions regarding the Transfer Agent Release or the Extension, please contact any of the attorneys listed below.