July 12, 2023 SEC Investor Bulletin: Holding Your Securities. When the SEC publicly states exactly what to do with stock purchase plan shares to make them DRS
Considerations for holding securities through direct registration include:
Purchases made through the issuer (or its transfer agent) of securities you intend to hold in DRS are usually executed under the guidelines of an issuer’s stock purchase plan, which uses a broker-dealer to execute the orders. Thus, to hold in DRS once the securities are acquired, you would need to instruct the transfer agent to move the securities from the issuer plan to DRS.
When normal, retail investors have to educate the head of the SEC about DRS... I dunno, Gary feigning ignorance about DRS months back in that one interview...