Notice to EDGAR Filers:
Use of Graphics in Filings
Rule 304 of Regulation S-T specifies when graphics may appear in EDGAR submissions. Paragraph (e) of the rule notes that "…filers may not present in a graphic or image file information such as text or tables that users must be able to search and/or download …". This rule is designed, in part, to make it easier for the public to locate and analyze required information in Commission filings.
A number of recent Form 8-K filings or submissions have included PowerPoint presentations that contain graphics with tabular or textual information that has not been converted to text files. As a result, these very large submissions (some as large as 100 megabytes) are either not viewable on many investors' computer systems or they take an inordinate amount of time to download. Even if the investor is able to see the filing, because required material information in the filing has been submitted as a graphic, it is not word searchable or downloadable.
Since these documents are not in compliance with Regulation S-T, they must be amended promptly to provide the information in a proper format. To avoid this problem in the future, we are reminding companies and filing agents that PowerPoint and similar graphic presentations must be converted to text in an ASCII submission or to text or an HTML table in an HTML submission. Most presentation software products have the capability of automatically saving information into a text file. Doing this will reduce the size of the submissions and make it easier for the public and the staff to view and use the information.