Financial Executives International

January 14, 2002

Mr. Jonathan G. Katz
U.S. Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609

RE: File No. S7-18-01 Mandated Edgar Filing for Foreign Issuers

Dear Mr. Katz:

The Committee on Corporate Reporting (CCR) of Financial Executives International (FEI) appreciates the opportunity to comment on this proposal to mandate electronic filings for foreign private issuers and foreign governments of their securities documents, including registration statements, reports and other documents under the Securities Acts of 1933 and 1934. We agree with the proposal and believe its adoption would contribute to accomplishing the long-standing goals of the Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system, that being to facilitate the rapid dissemination of financial and business information while making the delivery and processing of the Commission's filings more efficient. Currently, foreign private issuers and foreign governments are encouraged, but not required, to file electronically while domestic issuers have been required to file electronically since 1993. Although it may not have been the case in 1993, we believe that current foreign issuers now possess the technology necessary to file electronically without incurring excessive cost or experiencing undue hardship.

CCR has long held the belief that rules applicable to domestic filers in the U.S. should also apply to non-U.S. filers wherever possible. In this case, we do not hold the opinion that requiring foreign filers to electronically file would represent a significant burden beyond that experienced by U.S. filers. We therefore believe that in an effort to present a level playing field for domestic and foreign issuers, both groups should be required to file under the EDGAR rules.

CCR believes, consideration must be given to extending the EDGAR filing hours to a 24 hour period or to some other extended interval beyond the current 8:00 AM to 10:00 PM Eastern Standard Time (EST) to accommodate the needs of international filers. We recognize the Commission's need to maintain and periodically upgrade the EDGAR system, and that extended hours may interfere with this, but we believe the Commission can work to find a way to deal with both sets of needs. The current hours place an undue burden on those foreign companies operating in different time zones and as investors needs for real-time information continues to increase, we believe the Commission must adjust electronic filing hours to accommodate non-U.S filers.

As the number of non-U.S. corporations listed on exchanges regulated by the SEC continues to grow, it becomes increasingly important that investors be afforded the ability to rapidly retrieve, analyze and disseminate information on those companies to make more efficient and timely investment decisions. We therefore believe that mandatory EDGAR filing should be required for all foreign issuers.

We appreciate the opportunity to comment on this proposal and if you would like to further discuss these comments, please contact Christine DiFabio at 973.898.4671 or David Sidwell at 212.270.1892.

Sincerely yours,

Philip D. Ameen
Chair, Committee on Corporate Reporting
Financial Executives International