Subject: File No. S7-19-16
From: Jacob Vollmer
Affiliation: MBA, SEC Reporting Consultant

September 7, 2016

The SEC's justification is, "The proposed changes should make it significantly easier to locate documents attached to company filings."

I personally don't understand how the exhibits from the same SEC filing package are difficult to find in the first place. Most people who actually go to the SEC site to view filings know that exhibits are specifically listed under the main filing document that the reader would already have accessed if viewing an exhibit list.

All the reader has to do is click back on the browser and then click the necessary exhibit which already has a label. Does requiring just ONE extra click make it significantly easier...? Doubtful.

The incorporate by reference exhibits would take a bit more research since they are not readily available without knowing which filing they were previously submitted with. This is where I could see the most (and only) significant benefit from the proposed rule.

This hyperlinking requirement would also be impossible to comply to without knowing the specific accession number for each filing before they are filed with the SEC.

While we know parts of the hyperlink, (e.g. Hyperlink base, company CIK, Filing Agent CIK, Exhibit number and version), it would be next to impossible to determine the number after the Filing Agent CIK before the actual filing goes through. The only way to know for certain would be if they are requiring links ONLY for files incorporated by reference.



ACCEPTED FORM TYPE 10-Q (0001564590-16-024242) The 024242 number being the impossible number to know.

Exhibit 31.1 hyperlink: