1 See Memorandum to SEC Rules Committee No. 7-96, dated January 25, 1996; Memorandum to Accounting/Treasurers Committee No. 5-96, dated January 26, 1996.
March 11, 1996
TO: ACCOUNTING/TREASURERS COMMITTEE No. 12-96
SEC RULES COMMITTEE No. 18-96
TECHNOLOGY ADVISORS ROUNDTABLE
RE: INSTITUTE COMMENT LETTER ON EDGAR FILING SYSTEM
______________________________________________________________________________
As we previously informed you, the Securities and Exchange Commission recently
published a Request for Information ("RFI") that sought comment on how to improve the
EDGAR filing process.1 The RFI described four different models for the architecture of EDGAR
that are presently under consideration by the SEC.
The Institute filed the attached comment letter on the RFI. The letter recommends that
the Commission evolve the current EDGAR filing system so that it can accept documents
formatted in ASCII, HTML, PDF or one of the commonly used word-processing software
programs. The letter opposes the SECs proposed models that involve the use of a filing
depository, arguing that the interpositioning of a depository between the filer and the SEC
would neither simplify the EDGAR filing process nor benefit filers such as mutual funds.
The Institute also suggested several other changes to EDGAR that will better assist
registrants in meeting their filing obligations. These include: (1) a suggestion that, whenever
the SEC adopts a new filing form for registrants, it also adopt a new template for use with the
EDGAR system, (2) a recommendation that the SEC develop an automated balance inquiry
system for EDGAR and (3) a recommendation that the SEC allow registrants the option of filing
documents by using electronic mail on the Internet.
Alexander C. Gavis
Assistant Counsel
Attachment