In a letter following up on a recent meeting between ABA and the Securities and Exchange Commission, ABA called for greater clarity on Rule 17Ad-16, which relates to expectations for notice of assumption responsibilities of indenture trustees, in order to reduce unnecessary operational burden.
Specifically, ABA asked the SEC to clarify that the rule only requires a notice with the Depository Trust and Clearing Corporation when the filing transfer agent ceases to perform transfer agent services to an issuer, the filing transfer agent is the successor to a previous transfer agent or there is a change of a transfer agent’s name or address.