“Securities held pursuant to […] share plans (dividend reinvestment, direct stock purchase, etc.) should be registered such that they could not be considered property of the transfer agent. (https://www.sec.gov/comments/s7-27-15/s72715-40.pdf, p.12)

“DTCC shares the Commission’s concerns that securities and funds held by transfer agents are subject to a risk of loss from fraud, theft or other misappropriation or disruption and supports the Commission’s proposals to strengthen the practices and procedures involving the safeguarding of funds and securities by transfer agents.” (https://www.sec.gov/comments/s7-27-15/s72715-32.pdf, p. 8)

“[…] Plan Administrators maintain custody of purchased shares on the participants’ behalf, with the purchased shares typically being registered in the name of the transfer agent’s nominee.” (https://public-inspection.federalregister.gov/2015-32755.pdf, p. 194)