March 21, 2000
Mr. Jonathan Katz
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609
Subject: Comments regarding File No. S7-05-00, Rulemaking for EDGAR System
Financial Insight Systems, Inc (FIS) appreciates the opportunity to provide the Securities and Exchange Commission with comments on its proposed amendments to the rules for the EDGAR System.
FIS fully and completely supports the proposed elimination of the Financial Data Schedules (FDS), the inclusion of graphic and image files within HTML file submissions, and the ability to use hyperlinks within HTML file submissions.
Financial Data Schedules (FDS)
FIS supports the proposed elimination of Financial Data Schedules (FDS). Our experience with the Financial Data Schedules is extensive and as a result, we have determined that there is an extremely high error rate with the use of the Element Tags and, more significantly, with the associated values contained with the FDS.
Typical tagging errors include:
The use of unsupported Element Tags is extensive. FIS has documented the existence of over 700 Element Tags that are not supported or specified in the official Filer Manual. To give you an idea of how extensive this problem is, the number of unsupported and/or unofficial Element Tags in use today in the Financial Data Schedules (over 700) is greater than the total universe of valid tags.
More significant than the use of unsupported and/or unofficial Element Tags is the actual numeric discrepancies that exist between the tagged values that appear in the Financial Data Schedule and the actual values that appear in the official Financial Statements. In many cases, the Tagged Values are wrong and/or inaccurate. Individuals and Institutional investors who rely on the Financial Data Schedules for analysis are unknowingly making decisions based on incorrect information.
Fact is, the investing public is not being well served by the existence of the Financial Data Schedules and the elimination of these schedules is perhaps the single most significant step the SEC could take to improving the accuracy of Company fundamental data.
Graphic and Image Material Within HTML Submissions
FIS supports the requirement of graphics in HTML documents whenever SEC rules or forms require information to be in graphic form.
Limitation of Hyperlinks
FIS supports the proposal to allow hypertext links to other documents within the same filing (i.e. exhibits) and the proposal to allow hypertext links to previously filed documents. FIS supports the ability of a company to include hyperlinks to the documents of affiliated companies only.
Again, thank you for the opportunity to comment.
Albert E. Girod