June 21, 1994
TO: ACCOUNTING/TREASURERS COMMITTEE NO. 33-94
SEC RULES COMMITTEE NO. 67-94
RE: SEC REQUEST FOR COMMENT ON THE EDGAR SYSTEM
__________________________________________________________
The Securities and Exchange Commission is requesting public
comment on the Electronic Data Gathering, Analysis, and Retrieval
(EDGAR) system. Responses will be used to evaluate EDGAR's
readiness to accept electronic filing for all SEC registered
companies, including investment companies.
Currently, fifteen investment company complexes and fourteen
unit investment trust sponsors file all federal securities
registration materials electronically on the EDGAR system. These
filers are part of a "significant test group" which Congress has
stated must file successfully for at least six months before the
Commission can adopt final mandatory filing rules. The significant
test group, which also includes industrial companies filing with
the SEC's Division of Corporation Finance, is approaching the
conclusion of the six month test period.
As of March, 1994, approximately 55,000 live filings had been
accepted by the operational EDGAR system. Based on the experience
of the significant test group, the Commission is now proposing to
expand EDGAR to include all SEC registered companies. Respondents
are asked to comment on EDGAR performance in the following areas:
integrity, reliability, responsiveness, stability, security,
capacity and usability. In addition, respondents are also asked to
identify any reason why the Commission should not proceed with
mandated electronic filing by all SEC registered companies.
Comments should be received by the SEC on or before July 11, 1994.
On April 12 the Institute submitted a letter to the Commission
detailing several problems its member firms have encountered in
connection with submitting filings on the EDGAR system (See
Memorandum to Accounting/Treasurers Committee No. 17-94, SEC Rules
Committee No. 46-94). These problems related to: a) file
transmission speed, b) identification codes and c) timeliness of
acceptance/suspension notices.
The Institute's letter responding to the Commission's request
for public comment will reiterate the concerns raised in our
earlier letter and will express general support for mandated
electronic filing by all SEC registered companies. If you have any
additional comments please call the undersigned no later than July
5 at 202/326-5851.
Gregory M. Smith
Director - Operations/
Compliance & Fund Accounting
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