July 14, 1994
TO: ACCOUNTING/TREASURERS COMMITTEE NO. 37-94
SEC RULES COMMITTEE NO. 77-94
RE: INSTITUTE COMMENT LETTER ON THE OPERATIONAL EDGAR SYSTEM
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The Institute's comment letter on the operational EDGAR system is attached. The Securities
and Exchange Commission requested comment on the operational EDGAR system in order to evaluate
EDGAR's readiness to accept electronic filings 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.
The Institute's comment letter expresses support for the Commission's EDGAR program and
urges the SEC to proceed with rulemaking that would mandate electronic filing for all SEC registered
companies, including investment companies. Further, the Institute's comment letter addresses several
technical problems member firms have encountered when making filings on the EDGAR system.
These problems relate to: a) slow file transmission speeds, b) the inability of EDGAR to accept
graphics, c) the need for increased electronic filer support staff at the Commission, and d)
EDGARLink, the SEC's file transmission software.
If final mandatory filing rules are adopted as planned, all remaining investment companies will
be phased-in to EDGAR between August 1994 and November 1995. We will keep you informed of
developments.
Gregory M. Smith
Director - Operations/
Compliance & Fund Accounting
Attachment