The Securities Transfer Association (STA) has commented on the broker fee increase proposal submitted by the NYSE PFAC committee and has disagreed on several points. With an 18-month effort by NYSE PFAC to review and update the broker proxy fee schedule, the STA has recommended that the fee proposal should be disapproved for several reasons:
The NYSE rule filing does not include an independent review of proxy costs, as recommended by the NYSE Proxy Working Group in 2006;
The NYSE rule filing does not include a thorough analysis of the costs and benefits of the proposed proxy fee changes, using the same degree of rigor as the SEC applies to its own rules;
The proposed NYSE processing and intermediary unit fees do not allocate fees equitably between large and small issuers;
The NYSE proxy fee proposals favor the interests of broker-dealers and discriminate against issuers;
The structure and level of the proposed NYSE proxy fees place a burden on competition; and
Paper and Postage Elimination Fees were intended to cover the printing of a Voting Instruction Form (“VIF”) and enclosing it with an annual report, proxy statement, and return envelope in a poly wrapped package. If these basic processing functions are not performed, then these fees should not be charged for a suppressed account. Additionally, and for the same reasons, Broadridge should not be permitted to charge a Notice and Access fee for suppressed accounts.
In response, Colonial Stock Transfer created a managed proxy service to help reduce the costs associated with a Proxy by 40-65%, which includes:
A dedicated Proxy Manager;
NOBO/OBO Oversight and Management;
Online Voting, Management and Tabulation; and
Printing & Delivering Materials.
Colonial Stock Transfer has performed hundreds of managed proxies with the average customer experiencing a significant savings. Call 877-285-8605 to speak with a representative about Colonial’s Shareholder Meeting Services.