In summary, DTC is a monopoly engaged in predatory, anti-competitive conduct with respect to its direct competitors. The effects of this anti-competitive behavior are far-reaching as to price and mandated services; and it may result in scores of small transfer agent competitors being forcibly evicted from the marketplace. Finally, in filing these proposed Rules, DTC is usurping the SEC’s exclusive jurisdiction to regulate transfer agents.

Read the full letter: 20080320 dtc200616-32