Capital updating

I have also updated the analysis by including the five years of additional data that have become available since the original study was completed.

The new estimates, presented in the current note, continue to indicate that social security substantially depresses private saving.

These safeguards could include transfer agent due diligence obligations prior to the removal of restrictions (or legends) on stock certificates that otherwise would restrict their transfer.[17] As noted, transfer agents function as gatekeepers, and persuading them to remove the restrictions on unregistered stock certificates is an essential step in perpetrating a fraudulent offering of unregistered securities.In fact, various JOBS Act provisions may result in an exponential increase in the number of companies whose shares are traded in the secondary market without the benefits of registration, making the transfer agents’ “gatekeeper” function even more critical.[13] 5) There appears to be momentum toward early-stage rulemaking for transfer agents as the Commission staff is considering recommending that the Commission propose a concept release.[14] But concept releases often take years to develop into rules.What would you like to see happen in the way of rulemaking?However, in circumstances where the Commission has developed experience and information as to known problems, the Commission should be willing to move forward to address those issues through the normal rulemaking process.The Commission has been studying the transfer agent issues for some time.In determining what steps may be necessary, we should be guided by the need for investor protection and market efficiency.8) Transfer agents have no cybersecurity rules, and no disaster and business continuity requirements. What would happen if a hacking or natural disaster struck these firms?In fact, in October 2011, the Commission hosted a public Roundtable on the Execution, Clearance, and Settlement of Microcap Securities, which identified a number of issues related to the transfer agents' roles in the issuance and transfer of these microcap securities.[10] Among other issues, the Roundtable highlighted the lack of Commission rules addressing appropriate levels of due diligence by transfer agents, the lack of guidance for removing restrictions from securities, and the need for more disclosure to the market of certain information that would inform investors about the appropriateness of transacting in microcap securities.[11] 4) There can be no doubt that transfer agents are gatekeepers.After all, they keep track of the ownership of corporate securities.[12] As I mentioned earlier, transfer agents have a key role in removing restrictions (or legends) that would otherwise restrict the transfer or sale of securities.[1] Transfer agents play an important role in our capital markets.They act as registrars and keep track of changes in the record ownership of a company’s securities.[2] They ensure that companies’ interest, dividends, and other distributions get paid to the right holders of stocks and bonds.[3] Transfer agents also monitor the restrictive legends and “stop transfer” orders that distinguish restricted securities from freely-tradable securities.[4] This responsibility puts transfer agents in a unique position to identify and potentially prevent unregistered securities from being unlawfully distributed.

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