* See Memorandum to Accounting/Treasurers Committee No. 18-97, Investment Advisers Committee No. 22-97 and
SEC Rules Committee No. 66-97, dated July 8, 1997.
[9131]
August 6, 1997
TO: ACCOUNTING/TREASURERS COMMITTEE No. 23-97
INVESTMENT ADVISERS COMMITTEE No. 26-97
SEC RULES COMMITTEE No. 75-97
RE: INSTITUTE COMMENT LETTER ON PROPOSED MANDATORY ELECTRONIC
FILING OF FORM 13F
______________________________________________________________________________
As previously indicated, the Securities and Exchange Commission recently proposed to
require electronic filing on the EDGAR system of Form 13F, the report that institutional
investment managers exercising investment discretion over accounts holding at least $100
million in reportable equity securities must file quarterly with the SEC.* The Institute has filed
a comment letter with the SEC concerning the proposal. A copy of the letter is attached and it
is summarized below.
The comment letter states that although the Institute has no objection to the SECs
proposal, the SEC should consider deferring its consideration of the proposal until anticipated
efforts to further modernize the EDGAR system have been implemented. In this way, filers
(including those that do not currently make any filings on the EDGAR system) could avoid the
possibility of having to convert their Form 13F filings to the current EDGAR format now, and to
a different format shortly thereafter. The letter recommends that if the SEC is not inclined to
delay the electronic filing requirement until the EDGAR system is updated, it should provide a
phase-in period of at least one year.
The letter also recommends that the SEC make its official list of Section 13(f) securities
available on, and downloadable from, its Internet web site, thus enabling 13F filers to design
computer programs that would compare the list against their investment databases and
generate the required information.
Frances M. Stadler
Associate Counsel
Attachment (in .pdf format)