Subject: File No. S7-20-19
From: Brittany Jones

November 4, 2019

Dear Commissioners,

I am writing regarding File Number S7-20-19.

I am genuinely surprised to discover that the federal entity charged with regulating and enforcing securities law is relying on paper checks, money orders, and manual record-keeping in the year 2019. This does indeed sound inefficient and rife for error. I believe modernizing the fee reporting and collecting system with the use of iXBRL and ACH will improve efficiency, accuracy, and disclosure.

Utilizing EDGAR to read iXBRL and process the fee information should improve efficiency. Given that filers are already required (or soon will be, depending on their filing type) in iXBRL, it follows that the SEC should expand that requirement to the fee forms. This will allow filers to test file and to clear errors. It will also ensure a clean record of the fees.

Employing ACH to process the fees themselves seems like something that should have happened long ago. ACH is more secure than money orders and checks and has been standard practice elsewhere for decades. It certainly isnt new or particularly innovated technology. I support the Commissioners move to bring the SEC (and all its filers) into the twentieth century.

Thank you for your time,
Brittany Jones