SEC Division of Trading and Markets no-action letter: Equiniti Trust Company

July 29, 2021
David Becker, General Counsel
Equiniti Trust Company
275 Madison Avenue, 34th Floor
New York, NY 10016
Re: Request for No Action Relief from Section 17A of the Securities Exchange Act of 1934 and Rules 17f-1 and 17Ad-19 thereunder Dear Mr. Becker:
In your letter dated July 19, 2021, you request that the staff of the Division of Trading and Markets (“Staff”) of the U.S. Securities and Exchange Commission (“Commission”) grant no-action relief from Section 17A of the Securities Exchange Act of 1934, as amended (“Exchange Act”) and the Rule 17f-1 Requirements for Reporting and Inquiry with Respect to Missing, Lost, Counterfeit or Stolen Securities and Rule 17Ad-19 Requirements for Cancellation, Processing, Storage, Transportation, and Destruction, or Other Disposition of Securities Certificates, in connection with the administration by Equiniti Trust Company (“EQ”), a registered transfer agent, and General Electric Corporation, a publicly traded issuer client of EQ (“GE”), of certain exchanges of shares related to the reverse stock split of GE described in your letter (“GE Reverse Split”). Response:
On the basis of the facts and representations contained in your letter, the Staff will not recommend enforcement action to the Commission under Exchange Act Section 17A, including under Rules 17f-1 and 17Ad-19 thereunder, against EQ or GE if EQ and GE conduct the exchanges of shares in connection with the GE Reverse Split in the manner and subject to the conditions and procedures described in your letter. The position of the Staff is based strictly on the facts, circumstances, and conditions discussed in your letter, and any different facts, circumstances, and conditions might require a different response. This response expresses the Staff’s position on enforcement action only and does not purport to express any legal conclusions on the questions presented. The Staff expresses no view with respect to any other questions that