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Re: None

Friday, 04/29/2011 9:27:51 PM

Friday, April 29, 2011 9:27:51 PM

Post# of 346917

Approaches to reform of the current OBO/NOBO framework range from minor incremental changes to a comprehensive overhaul. Any reform must advance the goal of operational reliability — or at least not appear to further impair the reliability of the current framework. One important question of course is the degree of reliability of the current framework, which is the subject of some debate. There is no systematically gathered information regarding reliability. Broadridge and intermediaries express the view that reliability is high. There is some anecdotal evidence of breakdowns in reliability, including NYSE examination results and the 2008 under-reporting by Broadridge of withheld votes for certain directors of Yahoo.



http://www.sec.gov/comments/s7-14-10/s71410-22.pdf


Accuracy of data is important. NOBO/OBO does not necessarily care about absolute accuracy and relies on broker responses.

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