[17582]
May 25, 2004
TO: CLOSED-END INVESTMENT COMPANY MEMBERS No. 37-04
SEC RULES MEMBERS No. 79-04
SMALL FUNDS MEMBERS No. 60-04
VARIABLE INSURANCE PRODUCTS ADVISORY COMMITTEE No. 5-04
RE: INSTITUTE COMMENT LETTER ON SEC EDGAR PROPOSAL
The Institute has filed a comment letter with the Securities and Exchange Commission
regarding proposed amendments to electronic filing on the EDGAR system. The proposed
amendments would require open-end investment companies and insurance company separate
accounts to obtain identifiers for each of their series or classes (or contracts, in the case of
separate accounts) and include the identifiers in electronic filings.1 The proposed amendments
would also require litigation materials and fidelity bonds to be filed electronically over the
EDGAR system. A copy of the Institute’s comment letter is attached and summarized below.
The Institute’s letter supports the proposal to require series, classes and contract
identifiers in electronic filings, noting that it will enable investors and others using the EDGAR
system to easily search for and identify filings relating to a particular series, class or contract.2
The letter makes several recommendations intended to ensure that electronic filings are not
delayed or disrupted due to identifier-related problems.
1 See Memorandum to Closed-End Investment Company Members No. 20-04; SEC Rules Members No. 45-04; Small
Funds Members No. 36-04 [17319], dated March 30, 2004.
2 Effective April 26, 2004, the EDGAR Filer Manual has been updated to support series, class and contract identifiers
in anticipation that the Commission’s rule proposal will be approved. Additional information is available on the
Commission’s website at http://www.sec.gov/info/edgar/edmanuals87.htm.
2
The Institute’s letter urges the Commission to permit, but not require litigation materials
to be filed electronically. The letter indicates that litigation materials are typically received in
paper form and that it will be difficult to convert them into electronic form and file them within
the mandated ten-day time period.
Gregory M. Smith
Director - Operations/
Compliance & Fund Accounting
Attachment (in .pdf format)
Note: Not all recipients receive the attachment. To obtain a copy of the attachment, please visit our members website
(http://members.ici.org) and search for memo 17582, or call the ICI Library at (202) 326-8304 and request the
attachment for memo 17582.