October 13, 2017
It is proposed in the FAST Act release that the requirement would apply to forms used by investment companies, such as registration statements on Form S-6, Form N-1A, Form N-2, Form N-3, Form N-4, Form N-5, Form N-6, and Form N-14 and to reports on Form N-CSR. Page 112 of the proposal states that under the proposed requirements, these registration statements would be required to be filed in HTML format. The proposal does not address the fact that html does not support Type 1 Modules, that are used by Annuity filers on Form N-4 or Life filers on Form N-6. Type 1 Modules can only filed in Ascii, with registration statement filings that reference the modules, filing in Ascii as well. Requiring N-4 and N-6 filers to file their registration statements in HTML would require one of two primary changes: (1) the EDGAR system be updated to support Type 1 Modules to be filed in HTML to allow for the linking of the module to the corresponding registration statements, or (2) no longer allow filers to use Type 1 Modules, which would considerably impact the workflow for these filers and increase their costs, by having to include the content of these modules in each of their registration statements. Please address how these issues will be handled and/or the Commission's plan to modernize EDGAR to support Type 1 Modules.