1. When you bought shares on Havelock, you bought passthrough shares. Every right that you assumed when you bought those shares remains. There was never an implication of converting, migrating, or managing your shares in any way unmentioned in the prospectus.
There was a lot of talk like "we will be creating our exchange or move to colored coins". True no one said it would be free, but neither that it would have a cost, and it seemed reasonable to assume the first.
Also, it's the first time I hear talking about passthrough shares; IIRC it was mentioned here in the past that Havelock and Bitfunder shares were not passthroughs, but "as real as you could get"
2. There is cost, time, and liability involved with facilitating the management of your shares. There are monthly fees to even exist on Havelock at all.
How has that anything to do with transfer fees? That would be an argument to justify having a percentage of dividends cut out, but not for transfering OUT of Havelock, thus if anything reducing those costs you mention for you.
3. Havelock shareholder records are backed up to multiple parties twice daily. No shareholder "needs" to move to direct shares. It is an optional service, and therefore, one with a fee.
I'm in for the long term, I don't care so much about liquidity and I don't want the counter party risk involved with Havelock. Of course I don't "need" direct shares but they would be very appreciated, since I thought that was what I bought.
5. The fees also serve as "friction" to prevent people from abusing the service and to curb overwhelming customer service needs. People should only really be moving shares when they want to sell them, or if they feel safer storing them with Neo.
Then do as I suggested: first time it's free, then there's a fee. So you have the friction AND you show appreciation to your early investors.
EDIT: my bad, I saw now that btct.co and havelock shares were allways mentioned as passthroughs, and bitfunder were the direct ones. What about people who bought IPVO (not traded) shares in the period when there was only Havelock? How were they supposed to buy direct shares?