I am still awaiting an explanation from one brokerage firm, but a CSR from another firm called me and said she does not believe they have a transfer agent. That all the trades are carried out between the buying and the selling firms and that this can be done because all the shares are in street name and not held as individual certs. I don't know if I agree with this or not but that is what they told me. I do know that firms do hold most shares in street name to allow them to loan them out for short sales. it is a lucrative part of the brokerage business. I just cannot say for sure that it eliminates the need for a tranfer agent especially if you are not sending out dividends or annual statements
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