James W. Burns
100 Business Park Drive
Princeton, NJ 08542-088
Jonathan G. Katz
Secretary, Securities and Exchange Commission
450 Fifth Street, NW
Washington, D.C. 20549-0609
Dear Mr. Katz
The following comments are with respect to File no. S7-9-99. BLOOMBERG L.P. is a subscriber to the EDGAR feed provided by the SEC via TRW. BLOOMBERG L. P. has gone to great lengths and considerable effort in preparing these comments. However, BLOOMBERG L.P. feels that the commentary period has been too short and will not reasonably represent the viewpoints of the disseminators. With the exception of preliminary documents, specifications on the changes to the EDGAR feed for EDGAR release 6.5 were not made available until April 9, 1999. As such disseminators, have not been provided a substantial commentary period.
- The SEC has not made any arrangement for/with TRW for testing with the disseminators. Disseminators at this point and time are in effect being told that they will need to go live with systems that have been developed in an extremely short period of time. This means the disseminators will lack the time and opportunity to test. Disseminators are being forced to release untested code, which could be potentially unreliable, unstable and destructive for direct use, by their clients.
- The SEC via TRW and at a significant cost provides EDGAR documents in real-time to several major disseminators. These disseminators in turn provide the EDGAR documents to thousands of end-users. These disseminators have spent large sums of money and time on providing their end-users with reliable systems that enable quick access, enhanced search capabilities, and other added value tools. Changing the EDGAR format to an HTML based system will not necessarily enhance the way the end-user is able to view EDGAR documents. As of April 8, 1999, disseminators had not been provided any formal specifications or formal test documentation. Without such information disseminators can not make changes to their systems to reflect the new document format.
- We question the addition of PDF documents as official or unofficial filings. The Bond Market Association formed a task force on Electronic Information Delivery and reported its finding in a report released in February of 1998. The report is available at http://www.bondmarkets.com/market/roe2.shtml. This report validly brings up the following points: PDF is not readily convertible into other formats or software; PDF as a format is wholly based and dependant on software controlled by a private entity (Adobe), and extraction from PDF is labor intensive. We agree with the issues that the Bond Market Association presents in the report and feel that the issues outweigh any benefit that the addition of PDF documents may provide.
- Additionally, since we can not expect comments from the SEC until after April 15, 1999, disseminators must view any documentation that they receive prior to April 15, 1999 as suspect. Assuming the SEC provides all of its comments back on April 15, 1999, disseminators would then have only 27 standard business days to implement there changes.
- Documentation received on 4/9/1999 from TRW indicates that extended character sets within HTML documents are to be allowed. Not all disseminators are Web based, in some cases disseminators are using proprietary hardware/software systems, such hardware/systems may be unable to accommodate the extended character set. Given the small window of time between April 15, 1999 and May 24, 1999 it is unreasonable to expect all disseminators to be able to accommodate extended character sets.
- Disseminators will be asked to handle a potentially massive increase in file sizes. HTML documents are expected to be 170-180% times the size of the standard "Legacy" ASCII documents. PDF documents are expected to be 100-300% times the size of the standard "Legacy" ASCII documents. These assumptions where provided by TRW. Disseminators will need to resize their hardware systems to account for this vast increase in size. For example, if a document contained a Legacy ASCII filing, HTML filing and unofficial PDF filing the document would be anticipated to be between 370-580% times the size of the Legacy ASCII document.
Until the above issues are resolved and disseminators can be provided the proper amount of time to reasonably prepare systems for their end-users, the May 24, 1999 date should be extended and the EDGAR release 6.5 should be pushed back.