Obligations To Search for Lost Securityholders

SIFMA provides comments to the Securities and Exchange Commission (SEC) on the SEC’s proposed amendments to Rule 17Ad–17 under the Securities Exchange Act of 1934 including: 1) Transfer Agents’, Brokers’, and Dealers’ Obligation To Search for Lost Securityholders; and 2) Paying Agents’ Obligation to Search for Missing Securityholders; File No. S7-11-11; Release No. 34-649099.  The proposed amendments are in accordance with Section 925W of  the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).  The amendments would impose certain obligations on broker-dealers to search for lost securityholders and would also require that paying agents provide a single written notification within a designated timeframe to each missing securityholder that the missing securityholder has been sent a check that has not yet been negotiated. While SIFMA strongly supports the rights and interests of shareholders who would be deemed lost or missing under the proposed amendments, SIFMA believes that certain aspects of the proposed amendments to Rule 17Ad-17 should be reconsidered or clarified.