May 15, 1992
TO: EDGAR PILOT PARTICIPANTS
ACCOUNTING/TREASURERS COMMITTEE NO. 23-92
OPERATIONS COMMITTEE NO. 15-92
SEC RULES COMMITTEE NO. 34-92
RE: ADOPTION OF AMENDMENTS TO TEMPORARY RULES FOR THE EDGAR
SYSTEM
__________________________________________________________
Enclosed are amendments to temporary rules that will permit
Pilot filers to submit their official SEC filings on the
Operational System rather than the Pilot System. The rules will
also be applicable to investment companies and institutional
investment managers who currently file reports on Form N-SAR or
Form 13F via the EDGAR Pilot System and who wish to continue
filing these reports electronically on the Operational System.
The amended temporary rules will supersede the temporary rules
adopted for the EDGAR Pilot.
The EDGAR Pilot System will be closed on July 14, 1992 and
these amended temporary rules will become effective July 15,
1992. Note that there are two sets of amended temporary EDGAR
rules enclosed. One relates specifically to investment companies
and institutional investment managers whose filings are subject
to review by the Division of Investment Management; the other
relates to corporate filers whose filings are subject to review
by the Division of Corporation Finance, but also discusses
provisions that are generally applicable to all electronic
submissions.
We are also enclosing a copy of the latest SEC EDGAR
newsletter, which contains questions and answers from a recent
EDGAR filers conference and a brief discussion of the SEC’s
implementation plans for Operational EDGAR. As the SEC has
suggested in the enclosed newsletter, investment company Pilot
filers are encouraged to test Release 2.0 of the Operational
System, implemented in January 1992, in preparation for
conversion to the Operational System on July 15, 1992. Pilot
filers should also be alert for a letter from the SEC announcing
implementation of Release 2.1 of EDGAR in July so they can submit
test filings on Release 2.1 in advance of making any live filings
on or after July 15.
2The SEC expects to publish for comments later this year,
rules governing mandatory electronic filing on the Operational
EDGAR System. The proposing release for those rules is expected
to include a phase-in schedule which will list investment
companies (grouped by complex) and other SEC filers along with
the dates when they must begin filing their SEC documents
electronically via EDGAR. It is expected that larger complexes
(measured by assets under management) will be phased in first.
Mandatory electronic filing is currently expected to begin
approximately mid-1993 and be completed by the end of 1995.
During the phase-in period, approximately 700 - 800 investment
companies are expected to be brought onto the EDGAR System every
six months.
The Institute intends to sponsor an EDGAR workshop for ICI
members, beginning several months prior to the implementation of
mandatory electronic filing, with the assistance and
participation of investment company EDGAR Pilot participants and
SEC EDGAR staff. The workshop will be presented in different
locations around the country and will be offered at nominal cost
to permit ICI members to easily send more than one attendee. The
workshop will be an excellent opportunity for ICI members to
obtain practical guidance and advice from other ICI members with
EDGAR experience and from SEC staff responsible for managing the
EDGAR System. The workshop will address all aspects of becoming
an EDGAR filer and composing and transmitting an EDGAR filing.
We will keep you informed of further developments.
Donald J. Boteler
Assistant Vice President -
Operations
Enclosures