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"A key component of corporate action access and communication is improved transparency of investors, including shareholder identification. Although the identification of investors is not addressed in the current proposal, it is a subject of various non-U.S. regulatory initiatives. For instance, developments in Europe and Canada address rules regulating the transparency of beneficial owners in light of the process mechanics by which an issuer solicits votes, and an owner receives and returns proxy materials. This is likely to continue to be a strong imperative world-wide, and we would encourage exploration of these broader issues at this time or in the near future." Verdun Edgtton, Bank of New York, SEC Comment Letter, February 13, 2006, SEC File No. S7-10-05.

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