Depository Trust Clearing Corp., commonly referred to as DTC has quietly implemented a change to the DTC Eligibility Application process. They have implemented a new email requirement on DTC Eligibility applications. This simple change brought about with no official announcement is slowing down the application review process. It deserves our bringing to issuer’s attention in the interest of having their DTC Eligibility applications approved in a timely manner.
What is the Email Requirement on a DTC Eligibility Application ?
Depository Trust Clearing Corp. is now requesting that the securities counsel listed on a DTC Eligibility application have an email address other than a GMAIL, AOL, HOTMAIL, Yahoo, or any other form of generic, non-professional email address. Starting sometime around May or June of this year, DTC started requesting that security counsels listed on DTC Eligibility applications provide email addresses tied to firm domains. Shortly thereafter, we received email correspondence concerning an application, where DTC simply stated it would no longer send requests for legal opinions to generic, non-professional types of email addresses.
Why the Change ?
DTC has not provided any explanation or statement for this change in the email requirement on a DTC Eligibility application. Based upon our experience, we believe the change is an effort to improve the process surrounding the legal opinions and who is able to submit them for review. DTC is effectively stating that it is only willing to accept legal opinions from law firms that have an actual website. We believe this to be part of their efforts to obtain appropriate background information on the attorneys who submit opinions for review.
How to Respond to the Change
Depository Trust Clearing Corp. has been very straight forward regarding their new email requirement on a DTC Eligibility application. If your attorney only has an email address from one of these mail email providers, and does not have an email address tied to a professional domain, then the issuer will need to find a new securities counsel to write the requested legal opinion letter. It is as simple as that. The issuer’s securities counsel must have a public website, or their opinions will not be accepted.
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