Subject: File No. S7-05-00; Rulemaking for EDGAR System Date: 03/20/2000 10:58 AM March 16, 2000 Jonathan G. Katz, Secretary Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Re: File No. S7-05-00; Rulemaking for EDGAR System Global Securities Information urges the Commission to allow at least 90 days between the final rulemaking on S7-05-00 and the actual implementation. In addition, Global Securities Information urges the Commission to consider a permanent policy of requiring at least 90 days between final rulemaking and implementation with changes to the EDGAR system that affect feed recipients. Currently, EDGAR 7.0 is proposed to go into effect on May 30. Indications from the Commission have been that final rulemaking on S7-05-00 will not be complete until the end of April, which will give feed recipients about 20 business days to react to the changes. Global Securities Information urges the Commission to consider the following factors: ** Feed subscribers must adapt to changes in the EDGAR system. While the new filing formats are optional for EDGAR filers, recipients must prepare for filings in the new formats, regardless of whether they are actually adopted by filers. If subscribers are unable to make changes by the implementation date, their customers will receive incomplete, erroneous or delayed information. ** Until the rulemaking is final feed subscribers do not know for sure what changes they will have to make. ** The less time subscribers have to make those changes, the greater the chance of erroneous, incomplete or delayed information being disseminated to investors, and the greater the cost to subscribers. ** Twenty business days is not a sufficient amount of time for a feed subscriber with many customers and products to make changes to its internal systems and products, and test those changes, to guarantee that all customers will have an uninterrupted flow of EDGAR data. ** Delaying the implementation of EDGAR 7.0 will not have an impact on the community of EDGAR filers and users. HTML and PDF filing is not popular with the filing community, and it is not popular with the research community. By our count, since HTML filing was enabled in 1999 there have been 592,234 documents filed through EDGAR. Of those, 5,194 (0.8%) have used the HTML option, and 559 (.09%) have used the PDF option. Among the experienced securities researchers who use our product, LIVEDGAR, we have found that when presented with the same document in plain text and HTML versions, 7 times out of 8 users will choose the plain text version. Global Securities Information would like to remind the Commission that all of these issues were factors a year ago when EDGAR Version 6.0 was released, and that at that time the Commission decided to delay the implementation to allow feed recipients time to make the necessary adjustments. We encourage the Commission to make the same decision this year, and to put in place a permanent policy so that the issue does not recur with every enhancment to the EDGAR system. Global Securities Information urges the Commission to weigh these factors in light of the mandate of the Commission to provide timely, accurate, and comprehensive disclosure to the investment community. Sincerely, Nicholas B. Keenan Chief Technology Officer Global Securities Information, Inc.