Global Securities Information
419-7^th Street NW
Washington, DC 20004

 
April 17, 2000
 
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450-5^th Street NW
Washington, D.C. 20549-0609
 
RE: File No. S7-10-00
Electronic Filing by Investment Advisers; Proposed Amendments to Form ADV
 
Dear Mr. Katz:
 
Global Securities Information appreciates the opportunity to comment on proposed amendments to rules regarding Form ADV filings by Investment Advisers.  We urge the Commission to consider disseminating the information gathered through the Investment Adviser Registration Depository (IARD) via the EDGAR feed. Please consider the following:

The Commission's EDGAR system is an existing, proven dissemination tool, which efficiently provides information to the investment community.  We strongly urge the Commission to add the Forms ADV to the EDGAR dissemination stream.  This will allow the markets to distribute the information with many value added features while allowing the general public free access to the data.

Currently the Form BD information is difficult to obtain through the Commission.  In the past the SEC has given over the CRD material to NASDR and much of the data was lost.

The ability of the NASDR to disseminate the Form ADV information in a satisfactory manner is in doubt. Will NASDR allow bulk purchasing of the information as the SEC does with EDGAR? Will they allow the markets to distribute the information with many value added features? They do not currently allow this with Forms BD.

Why build a second dissemination system to distribute related information to the investing public when a workable system is already in place? This ostensible waste of taxpayer dollars does not make sense.

Thank you for the opportunity to comment on the proposed rule. Please do not hesitate to contact me at 202 628 1155 if you have any questions or would like to discuss the above comments.
 
Sincerely,
 
Debra F Strahan
Global Securities Information