James W. Burns
100 Business Park Drive
Princeton, NJ 08542-0888
Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609
Re: Proposed EDGAR Amendments (File No. S7-05-00)
Dear Mr. Katz:
As a current subscriber to the EDGAR dissemination feed provided by the Securities and Exchange Commission ("SEC") via TRW, we write to provide the SEC with our comments in connection with EDGAR 7.0 and the proposed changes therein pursuant to File No. S7-05-00. Notably, we believe that these comments will serve to benefit all disseminators of EDGAR 7.0, the SEC and the general public.
By way of background, proposed data specification changes were first made available to disseminators on March 13, 2000; portions of this data specification, as well as the proposed changes in File No. S7-05-00, were discussed at a SEC/disseminator conference held on March 15, 2000. At that conference, SEC representatives deferred answering several questions until after the public comment period had concluded and further requested that these questions be submitted as comments for the rulemaking commission to review.
As a disseminator, serious concerns exist not only with the proposed changes in File No. S7-05-00, but also with the accompanying data specification changes. Accordingly, BLOOMBERG L.P. respectfully requests that the SEC review and consider the following comments for the purpose of better disseminating information through EDGAR 7.0:
- At the SEC/disseminator conference, SEC representatives indicated that (i) the planned release date for EDGAR 7.0 is May 30, 2000, and (ii) disseminators cannot expect a finalized specification until after the public comment period and the completion of a subsequent review. As a result, disseminators are controlled by a May 30, 2000 release date without a firm specification until some unknown date after April 3, 2000. This schedule places an extremely short, and possibly impossible, time limitation on disseminators to release production software.
- The SEC and TRW have not made any plans, commitments or arrangements for testing with the disseminators. At best, verbal comments at the SEC/disseminator conference indicated potential testing in May. This means disseminators will lack the time and quality opportunity to reliably test. Disseminators are, therefore, being forced to release software, which could potentially be unreliable, unstable and destructive for direct use by their clients.
- The SEC proposes to allow external links in documents to www.sec.gov. The SEC, through the www.sec.gov site, however, can make no long-term commitment as to the length of time that documents will be stored. BLOOMBERG L. P. would, therefore, seek SEC comment on our proposal to be able to modify these external links from www.sec.gov to links/connections within the BLOOMBERG L. P. system.
- Also, the specification allows for internal links within a filing. For instance, an Annual Report on Form 10-K can have multiple "files" within it and one such "file" could be an exhibit. The proposal does not clearly indicate, however, if an external link should be able to directly link to the internal link in a previous document (i.e., whether an external link will allow a user to link only to a Form 10-K, or to include a direct link to any exhibits therein, as well).
- HREFs to external documents should only be permitted for official documents. This is so because HREFs to unofficial documents could be confusing and misleading. Therefore, it is suggested that since PDF documents are unofficial, HREFs should not be permitted to PDF documents.
We certainly hope that these comments prove helpful by highlighting certain issues that need to be addressed as soon as possible. If there is an additional information that we can supply to the SEC, or if you have any questions for us concerning our comments, please feel free to contact me.
We thank you, in advance, for your consideration.