CyberKey Solutions fka CKYS

[jking1999]

Apparently National Trust has not met the SEC requirements to act as a Transfer Agent for any publicly traded company since 2004. So why is Jim using them in that capacity?

I asked the SEC two questions: Where they registered with the SEC, and could a company that wasn't registered with the SEC act as a TA.

I just got this response (I deleted my day phone and email address as it is for my work). I checked the exemptions under securities act of 1935 and they don't apply: They are not an investment company (Section 12(g)(2)(B)) or insurance company (Section 12(g)(2)(G)).

_________________________________________________________________

Dear Mr. King,

Thank you for contacting the SEC.

National Stock Transfer Inc., has not registered with the SEC as a tranfer agenct since March 31, 2004.

Under 17A(c) any person acting as a transfer agent with respect to a security registered under Section 12 or which would be required to be registered except for the exemption provided in Sections 12(g)(2)(B) or 12(g)(2)(G) must register as a transfer agent. The transfer agent either registers with us or, if it is a bank, with its appropriate bank regulatory authority. All registered transfer agents, including bank transfer agents, are required to file the annual Form TA-2 with the Commission.

For more information about tranfer agents and a link to the relevant laws, please review the following link:

http://www.sec.gov/divisions/marketreg/mrtransfer.shtml

I hope you find this information helpful.

Sincerely,

RINELL RANDOLPH JR
Attorney
U.S. Securities and Exchange Commission
100 F St, NE
Washington, DC 20549-0213



---------------------------------------------------------
QUESTION
---------------------------------------------------------
Submitted: 2007-02-01

INVESTOR INFORMATION
Name: Mr. Joseph W King
Day Phone:
Email:


QUESTION

I'm trying to find out if a company's transfer agent is properly registered with the SEC. The transfer agent is National Stock Transfer, Inc.

Also, does a company need to be registered with the SEC in order to act as a transfer agent for a publicly traded stock?

Thank you in advance for your help in answering these questions.

Joseph W. King