📚 Map 17Ad-7(c) continuing agency records to active issuer and restriction records

[JFWooten4]

17 CFR § 240.17Ad-7(c) requires the listed 17Ad-6 record categories to be kept in an easily accessible place during the continuance of the transfer agency and for one year after termination of the transfer agency.

This issue tracks the continuing records that define the transfer agency relationship itself, active restrictions, transfer and registrar journals, and authorized/outstanding issuer records.

Covered content

17 CFR § 240.17Ad-6(a)(8)

Any document, resolution, contract, appointment or other writing, any supporting document, concerning the appointment and the termination of such appointment of such registered transfer agent to act in any capacity for any issue on behalf of the issuer, on behalf of itself as the issuer or on behalf of any person who was engaged by the issuer to act on behalf of the issuer;

17 CFR § 240.17Ad-6(a)(9)

Any record of an active (i.e., unreleased) stop order, notice of adverse claim or any other restriction on transfer;

17 CFR § 240.17Ad-6(a)(10)

A copy of any transfer journal and registrar journal prepared by such registered transfer agent; and

17 CFR § 240.17Ad-6(b)

Every registered transfer agent which, under the terms of its agency, maintains securityholder records for an issue or which acts as a registrar for an issue shall, with respect to such issue, obtain from the issuer or its transfer agent and retain documentation setting forth the total number of shares or principal amount of debt securities or total number of units if relating to any other kind of security authorized and the total issued and outstanding pursuant to issuer authorization.

Implementation notes

This is the long-running operating-record bucket. These records are not just historical processing logs. They define whether we are acting, for whom we are acting, what issue is covered, what restrictions are live, and what the authorized and outstanding security position is supposed to be.

This should be tied closely to issuer onboarding, agency appointment records, restriction handling, transfer journals, registrar journals, and any authoritative source for authorized and outstanding amounts.

Task list

• Map 17Ad-6(a)(8) to issuer appointment and termination records.
• Map 17Ad-6(a)(9) to active stop orders, adverse claims, and transfer restrictions.
• Map 17Ad-6(a)(10) to transfer and registrar journals.
• Map 17Ad-6(b) to authorized and outstanding issuer documentation.
• Identify where these records live while the agency relationship continues.
• Define the one-year post-termination retention path.
• Confirm how this interacts with successor agent or backup custodian workflows.